2014 has had a few twists thrown into the mix when it comes to Meaningful Use attestation and subsequent goals. And we are only in the second quarter.
I’m sure like our staff, many of you are wondering after the latest announcement from CMS and ONC about their proposal for CEHRT flexibility and a Stage 2 extension, what this means in terms of meeting your timeline for the EHR Incentive Program. What course do we take now and how do we stay on track to avoid penalties or to ensure our milestones are being met?
That’s where our team is here to help. We have been reading the proposal and talking to our contacts at ONC and CMS, and here is a breakdown of how to look at this proposal.
First and foremost, this isn’t an official rule change… yet. We believe that this proposed rule will move forward in some form. However, it must go through the proper channels, including a 60-day comment period, before the final ruling. The soonest official announcement would be in August.
Second, these proposed changes apply ONLY in 2014, so it’s imperative to keep working toward a 2014 CEHRT upgrade or attestation will be an issue in 2015. In the proposed rule, 2015 remains a 365-day reporting period requiring 2014 CEHRT beginning January 1, 2015 for Eligible Professionals (EPs). For Medicaid EPs, a 2014 CEHRT product is required for Adopt, Implement or Upgrade (AIU) attestations.
Proposed Rule Change by Stage
Essentially, if the 2014 certified version of your EHR is not available in time for a 3-month/90-day attestation period, then under this rule you would be allowed to use 2011 certified technology for 2014 only. However, if your 2014 certified version is available, that is the technology and measures reporting you should be following.
Stage 2 Extension
As documented in the official announcement, the proposed alternatives are for providers that could not fully implement 2014 Edition CEHRT to meet meaningful use for the duration of an EHR reporting period in 2014 due to delays in 2014 Edition CEHRT availability. Providers will have to attest to this fact, if the rule passes and becomes available.
So, how do you move forward from here? Our recommendation is to stay on the course you intended and are capable of meeting, including your upgrade plans to a 2014 CEHRT if this is available to you, as it will only be easier moving into 2015 for your practice. The proposed rule is not final and won’t be for a few months. Though it appears there will be flexibility (if passed) for those that aren’t able to meet the original timeline allotted because of vendor delays in meeting 2014 CEHRT criteria.
Click here to read the full proposal from CMS and ONC. If you have any questions or need assistance, we are here to help. Contact us.