I receive many questions about the 90-day reporting period and skepticism about whether the provision applies to years beyond 2011. To clarify: The reporting period is 90 days as long as it is the first payment year for that particular provider—whether that year is 2011, 2012, 2013, or even 2014.

People frequently ask me for documentation of the above, so I am providing it here.

The following citations are from the Final Rule in the Federal Register:

• “We are finalizing the 90-day reporting period for the first payment year based on meaningful use as proposed for Medicare EPs, eligible hospitals and CAHs and full year EHR reporting periods for subsequent payment years.” – page 44320.
• “The first payment year for EPs is any calendar year (CY) beginning with CY 2011 and for eligible hospitals and CAHs is any fiscal year (FY) beginning with 2011.” – page 44318.

The ARRA legislation also defines the first payment year and relates it to the specific provider: “the first year for which an incentive payment is made with respect to professional services furnished by an eligible professional. The terms ‘second payment year’, ‘third payment year’, etc. refer to each successive year immediately following the first payment year for such professional.” – Section 4101(a)(o)(1)(E) – page 355.

Lynn Scheps is Vice President, Government Affairs at EMR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money.