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Expanded Time Periods Not Often Used By Providers; When Used They Meet Meaningful Use

Your CEHRT is likely not setup to include these allowed actions that occurred outside your chosen 90-day reporting period in your MU objectives. We suggest contacting your CEHRT vendor, providing them with this email and discussing it with them!


The MU (Meaningful Use) EHR reporting period remains as an EP selected 90-day period for Program Years 2017 (accepting attestations until 6/30/18) and 2018 (not yet available).

ModifiedStage2 has certain objectives which allow you to include actions that can occur outside the 90-day MU reporting period. This means you choose your 90-day CEHRT meaningful use data reporting period but calculation options for challenging objectives (secure messaging and patient use of a portal etc.) allow you to count patient actions that happen outside that 90-day period in the numerators while keeping the denominator data the same!  We feel many providers are not aware of this and when used, may allow them to meet the threshold percentages! Below, we identify important considerations (for example: you can count patients that opt-out of electronic access in the numerator) when making your calculations. If you have difficulty with meeting a measure, choose a different 90-day period and review your patient actions for the entire year. You may need to consult with your vendor or documentation to establish this.

 How to calculate for the objectives below:

  •  Numerator (top number): You should include the total number of actions in the numerator for the entire calendar year 2017 (for PY17); or for Objective 6, from January 1, 2017 through the date of attestation submission. These actions must relate to the unique patients represented in the Denominator. For Obj. 6 - you can add actions from 1/1/17 all the way through 6/30/18 if you submit on 6/30/18, which is the deadline)! This will increase your percentages (if it isn’t, you are likely calculating it incorrectly – contact HIT)!
  •  Denominator (bottom number): Number of unique patients(or for Obj. 5 the number of transitions of care or referrals…) seen by the EP during their selected 90-day reporting period ONLY. A unique patient is counted only once in the Denominator, regardless of how many actions/ visits/ etc. relate to them in the numerator (you may count each action in the numerator for the same unique patient).

The following Objectives for Modified Stage 2inProgram Years 2017and2018allow actions to be counted for the entire year (or for Objectives 1 and 6, until you submit your attestation). Eachobjective’sspecification sheet lists the information under the‘AdditionalInformation’ section for reference (click the link):

 Objective1-ProtectPatientHealth Information

Itisacceptable forthe annual review of the security risk analysisto be conducted outside the 90-day MUreporting period;however,the analysismust be uniqueforeachprogram yearand must be conducted prior to submission of the attestation.

Objective5-Health InformationExchange

This exchangemayoccur before, during, orafter the90-day MUreporting period. However, itmust occur within thecalendaryear inwhich theEHR MUreporting period occursto count inthe numerator.


This exchangemayoccur before, during, orafter the90-day MUreporting period. However, itmust occur no earlier than the start of the same calendar year as the EHR reporting period and no later than the date of attestation to count in the numerator. IF YOU ARE HAVING TROUBLE MEETING OBJECTIVE SIX, YOU STILL HAVE TIME TO PROVIDE MATERIALS TO PATIENTS SEEN DURING THE EHR REPORTING PERIOD UP UNTIL YOU SUBMIT YOUR ATTESTATION! THESE ACTIONS WILL COUNT IN THE NUMERATOR even though they happened later.

 Objective8– PatientElectronicAccess

ForMeasure2, the patient action may occur before, during, or after the90-dayMUreporting period.However, itmust occur within the calendar year inwhich theMUreportingperiod occurs to count inthe numerator.

Also, be aware regarding Patient Electronic Access

  • If a patient elects to "opt out" of participation, that patient must still be included in the denominator.
  • If a patient elects to "opt out” of participation, the provider may count that patient in the numerator if the patient is provided all the necessary information to subsequently access their information, obtain access through a patient-authorized representative, or otherwise opt-back-in without further follow up action required by the provider.


Thepatient action may occur before,during, or after the90-dayMUreporting period. However, itmust occurwithinthe calendaryear inwhich the MUreporting period occursto count inthe numerator.

Also, be aware regarding Secure Electronic Messaging

  • Provider initiated action and interactions with a patient-authorized representative, are acceptable for the measure and are included in the numerator.
  • A patient-initiated message would only count toward the numerator if the provider responds to the patient.

IMPORTANT NOTE: Attesting to optional Stage3criteria isnot required inProgramYears2017 and2018 (you can attest to Modified Stage 2). If you wish to attest to Stage 3, please contact us and we will provide the allowances and guidance for Stage 3.

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