There's something about October 1. It's the historic compliance deadline for ICD-10 – pushed back multiple times – and the last possible day for eligible providers to start a 2015 90-day meaningful use reporting period.

One perhaps telling problem: The federal government still has not delivered requisite guidance on exactly what criteria healthcare organizations must meet to qualify for EHR incentives. 

There may be little choice at this point other than to tweak 2015 timelines. Indeed, on Sept. 30 U.S. Senators John Thune (R-SD) and Lamar Alexander (R-TN) urged CMS to adopt the Stage 2 modifications immediately and Lamar followed that up on Oct 1. by publicly circulating five reasons to postpone making the final Stage 3 rule.

"There is no reason not to take time to do it right," Alexander said in a prepared statement, "and there are plenty of reasons to do this."

The American Medical Association, curiously quiet on ICD-10, issued a statement calling on CMS to create "an automatic hardship exemption" for doctors and physicians unable to complete the reporting period.

"It's now Oct. 1 and CMS has left physicians without any guidance or assurances that they will be capable of meeting program requirements before the end of the year," AMA President Steven J. Stack, MD noted. "The AMA has regularly stressed that CMS must finalize Meaningful Use modifications well ahead of Oct. 1 to provide the time that physicians need to plan for and accommodate these changes, yet CMS has continued to delay finalizing this rule."

Stack added that such a hardship exemption should be designed not to penalize providers due to circumstances outside their control. 

Many in the industry would invariably welcome such an exemption or extension to the reporting period, if only because the EHR makers have not even received the guidance either.

With no more open days on the calendar, something has to change.

Will CMS be pragmatic and extend or delay the 2015 90-day reporting period and a final Stage 3 rule while it's at it? And does this signify a failure of the meaningful use program? 

[Clarification: This article previously stated that hospitals had to start a 90-day reporting period by October 1. The above now reflects that eligible providers are the ones who have to start by that date.]