The Centers for Medicare and Medicaid Services has issued a proposed rule to align the Electronic Health Record (EHR) Incentive Program's 90-day reporting period with the calendar year for 2015 and 2016. Specifically, this proposal would change the EHR reporting period for eligible hospitals from a period based on the fiscal year to one based on the calendar year beginning in 2015—a move that the agency's stage 3 proposed rule mandates for all providers in 2017 (see the March 25, 2015 HRC Alerts). If finalized, the proposed rule would also streamline the program by removing reporting requirements on measures that have become redundant, duplicative, or topped out through advancements in EHR function and provider performance and modify the patient action measures in the stage 2 objectives related to patient engagement. Other proposed changes to the individual objectives and measures for stage 2 of meaningful use include changing the threshold in the second measure from the objective for patient electronic access from "5 percent" to "equal to or greater than 1," changing the threshold from the objective related to secure electronic messaging from being a percentage-based measure to a yes-no measure stating that the functionality is fully enabled, consolidating all public health reporting objectives into one objective with measure options following the structure of the stage 3 public health reporting objective, and changing the eligible hospital electronic prescribing objective from a "menu" objective to a mandatory objective with an exclusion available for certain eligible hospitals. The proposed rule was published in the April 15, 2015, Federal Register; comments are due June 15, 2015.

HRC Recommends: Risk managers should discuss CMS's proposed rule and meaningful use criteria with organization leadership and with relevant staff members so that the organization may provide comments to the agency, accordingly.