The Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) jointly released a proposed rule, published in the Federal Register on May 23rd, which changes the Meaningful Use timeline and the definition of Certified Electronic Health Record Technology (CEHRT).
Under the modified attestation schedule, eligible professionals, eligible hospitals, and critical access hospitals are allowed to use the 2011 Edition CEHRT, 2014 Edition CEHRT, or a combination of the two editions for Stage 1 or Stage 2 in 2014. They can attest using the 2013 definition of MU core and menu items and use the 2013 definition of clinical quality measures. The rule states: “We are proposing this change for 2014 only. We will maintain the existing policy that all providers must use [the] 2014 Edition CEHRT for the EHR reporting periods in 2015, and in subsequent years, or until new certification requirements are adopted in subsequent rulemaking.” Also incorporated in the proposed rule is a provision to extend Stage 2 through 2016 and start Stage 3 in 2017.
Call for More Flexibility Answered
This change came about as a result of numerous healthcare organizations contacting CMS and ONC to ask for more flexibility in the MU program. Calls increased after CMS announced that only four hospitals and 50 eligible professionals had attested for Stage 2 during the first half of 2014, expressing concerns about vendor readiness and delays in the delivery of the 2014 CEHRT.
CMS and ONC acknowledged that vendors have not had sufficient time to make the required coding changes to move to the 2014 edition and that EHR certification bodies have a backlog in certifying upgraded products. “Increasing the adoption of EHRs is key to improving the nation’s healthcare system and the steps we are taking today will give new options to those who, through no fault of their own, have been unable to get the new 2014 Edition technology, including those at high risk, such as smaller providers and rural hospitals,” explained Karen DeSalvo, MD, National Coordinator for HIT.
Conflict of Dates
Although providers have been asking for more flexibility, a change this late in the attestation period leaves room for concern. The public comment period on the proposed rule is 60 days, and the final MU reporting period for 2014 begins July 1st. This means that healthcare leaders have to make decisions about attestation before they definitively know the end result of the proposed rule.
For hospital leaders planning to move up to Stage 2, their payment year began on October 1st, 2013. Because the current rule allows them to begin their 90-day attestation periods for Stage 2 only on the first day of the fiscal quarters, that gives hospitals only one period to react to the rule change. This includes hundreds of hospitals scheduled to meet Stage 2 requirements for the first time this year.
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Kim Futrell, MT (ASCP)
Products Marketing Manager
Orchard Software Corporation