CMS published a proposed rule on April 15, 2015 that would modify the Medicare and Medicaid Electronic Health Record (EHR) Incentive program to reduce complexity, simplify reporting requirements, and align Stage 1 and Stage 2 objectives and measures with Stage 3. Notably, CMS proposes to change the Medicare and Medicaid EHR Incentive Program reporting period in 2015 for all eligible professionals, eligible hospitals, and critical access hospitals (regardless of prior participation) to a 90-day period aligned with the calendar year. According to CMS, this 90-day EHR reporting period for 2015 would give providers more time to address any remaining issues with implementation of technology certified to the 2014 Edition and to accommodate the changes to the objectives and measures of meaningful use included in the proposed rule. CMS also proposes that EPs, eligible hospitals, and CAHs demonstrating meaningful use for the first time may use a 90-day EHR reporting period during calendar year 2016, but returning participants would use an EHR reporting period of the full calendar year 2016. In 2017, all providers would use an EHR reporting period of one full calendar year (with a limited exception for Medicaid providers demonstrating meaningful use for the first time).

In addition, CMS proposes that beginning with an EHR reporting period in 2015, providers would no longer be required to attest to certain objectives and measures that are redundant or "topped out." CMS also proposes various changes to individual objectives and measures for Stage 2 of meaningful use, beginning with the EHR reporting period in 2015. CMS will accept comments on the rule until June 15, 2015.