FAQ 3. How long is Stage 1?
Year 1 of MU is a minimum of 2 years, depending on when the provider started. Most providers will report Stage 1 for 2 years. For example, if you began reporting for MU in 2013, you will report Stage 1 in 2013 and 2014, then move into Stage 2 in 2015.
In some instances you may have to report Stage 1 for 3 years. If you started reporting for MU in 2011, you will report for 3 years before starting Stage 2. These time frames do not account for the flexibility rule that allows providers to submit Stage 1 based on the vendor 2014 certification process.
FAQ 4. How do I account for the 90-day reporting period?
Regardless of the year when you are starting MU, the Stage 1 process begins with a 90-day reporting period for the first year and full year reporting period in Stage 1, year 2. Your practice needs to report the 90-day period only once, irrespective of whether you successfully met MU requirements or were eligible for a hardship. However, you must successfully demonstrate MU in Stage 1 before you can move on to Stage 2.
Medicare has not updated the 90-day criteria between 2014 and 2015, so if you are starting MU in 2015, you will be reporting a 90-day period using 2014 criteria. If you reported a 90-day period in 2014, you will be moving into a full year of reporting for 2015.
FAQ 5. How many times must I attest during Stage 1?
You need to submit an attestation only once for any reporting year. If you reported Stage 1 using July – September, 2014 data, you would not need to report again at the end of 2014. If you reported for the first time in 2014, you would report Stage 1 again, but this time for all of 2015. If 2014 was your second year of Stage 1, and hence full year of reporting, you would report a full year of Stage 2 in 2015.
If you are in Stage 1, year 2 (ie, will be attesting for all of 2015), you will still need to attest only once during the period defined by Medicare. Any provider who attested before 2015 will be reporting for all of 2015 between January 1, 2016 and February 28, 2016.