Meaningful Use Final Rule Summary for Eligible Providers

Date: September 17th, 2014Category: CORHIO e-NewsletterTopics: EHRs, Meaningful Use

Starting October 1st, the modifications to the Medicare and Medicaid EHR Incentive Program for 2014 are in effect. Here’s what you need to know.

On August 29th, The Department of Health and Human Services published modifications to the EHR Incentive Programs and the timing of Stage 2. The final rule acknowledged that some providers are having a difficult time attesting due to EHR 2014 product delays and shortcomings and provides a new timeline and options to help providers with this issue. It’s important to note that this new rule is not a delay to stage 2. All providers and hospitals that can attest to 2014 Stage 1 or Stage 2 must do so or run the risk of forfeiting their incentive payment.

Attestation Options Available for 2014

The final rule provided an updated Meaningful Use timeline with 2011 and 2014 certified EHR edition options as follows:

 

You would be able to attest for Meaningful Use:

Scheduled to demonstrate:

Using 2011 Edition CEHRT

Using 2011 & 2014 Edition CEHRT Combination

Using 2014 Edition CEHRT

Stage 1 in 2014

2013 Stage 1 objectives and measures*

2013 Stage 1 objectives and measures* OR

2014 Stage 1 objectives and measures*

2014 Stage 1 objectives and measures

Stage 2 in 2014

2013 Stage 1 objectives and measures*

2013 Stage 1 objectives and measures* OR

2014 Stage 1 objectives and measures* OR

Stage 2 objectives and measures

2014 Stage 1 objectives and measures* OR

Stage 2 objectives and measures

*Only providers that could not fully implement 2014 Edition CEHRT for the EHR reporting period in 2014 due to delays in 2014 Edition CEHRT availability.

Additional Modifications

  • Definition of delay in 2014 Edition CEHRT availability – The final rule acknowledges that some providers are experiencing difficulties in attesting to 2014 Stage 1 or 2 due EHR product-related issues, such as product availability, product installation timelines and the product’s ability to retrieve data. A provider may only choose one of the options above if they are unable to attest due to one of the specified product issues listed in the final rule. The option for all providers to use a 90-day reporting period is for 2014 only and all providers (with the exception of first-time attestations to Meaningful Use) will be required to report with a full-year reporting period in 2015. A 2014 Edition CEHRT will be required for all providers in 2015.
  • Stage 2 Summary of Care – Providers can exercise one of the options above if unable to meet the 10% threshold because the recipients of the transitions or referrals were impacted by issues related to 2014 Edition CEHRT delays.
  • Stage 1 Immunization Registry – Providers do not need to send another test message to their local public health agency if the test message was sent prior to 2014. A provider that sent a test message prior to 2014 and is attesting to the 2013 Stage 1 objective can submit the same documentation submitted in previous attestations, including exclusions.
  • EPs Practicing in More than One Location – If over 50% of the EP’s patient encounters during the EHR reporting period occur at a location with a fully implemented 2014 Edition CEHRT, the options above will not be available.
  • Clinical Quality Measures – If a provider is attesting to 2013 Stage 1, the CQMs will be the same as the Stage 1 final rule. If a provider is attesting to 2014 Stage 1 or Stage 2, the CQMs will be those outlined in the Stage 2 final rule (EPs = 9 measures in 3 domains, EHs = 16 measures in 4 domains).
  • Stage 3 Delay – The final rule makes the delay to Stage 3 official. For providers that first attested to Stage 1 in 2011 or 2012, Stage 3 will begin on January 1, 2017 for EPs and October 1, 2016 for EHs.

For More Information

To provide you with more information on these modifications, CORHIO has recorded a helpful webinar, which is available on our Events page. Or you can download the new Quick Guide from CMS on the EHR Incentive Programs 2014 CEHRT Rule.