Modifications to the Medicare and Medicaid EHR Incentive Program for 2014 effective October 1, 2014

The Centers for Medicare & Medicaid Services (CMS) has issued a Final Rule enacting modifications to the Electronic Health Record (EHR) Incentive Program. The regulations are effective October 1, 2014.

The Final Rule gives eligible providers the flexibility to use previous editions of Certified EHR Technology (CEHRT) to meet 2014 reporting requirements, and modifies reporting requirements for Clinical Quality Measures (CQMs) to align with the various choices providers have depending on the version of CEHRT used during the reporting period (see Provider Choices below).  Other issues in the Final Rule include: extending Stage 2 for a full year until 2016, which means that Stage 3 will not commence until 2017 (or October 2016 for eligible hospitals). 

Please note that this Final Rule makes no changes to the 2015 reporting requirements for Stage 2.  In other words, providers are will still be required to report over a period of 365 days, which in turn means that providers scheduled to demonstrate Stage 2 in 2015 must obtain and fully implement 2014 Edition CEHRT in order to start their reporting period on January 1, 2015 (or October 1, 2014 for eligible hospitals)

Provider Choices

In order to use previous editions of CEHRT, providers will be required to attest that they could not fully implement 2014 Edition CEHRT for the EHR reporting period in 2014 due to delays in 2014 Edition CEHRT availability. The preamble of the proposed rule states:  “A provider’s ability to fully implement all of the functionality of 2014 Edition CEHRT may be limited by the availability and timing of product installation, deployment of new processes and workflows, and employee training.”

If EP/EH is scheduled to demonstrate:

Then EP/EH would be able to attest for Meaningful Use:

 

Using Only 2011 Edition CEHRT to do:

Using 2011 & 2014 Edition CEHRT to do:

Using Only 2014 Edition CEHRT to do:

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

 

Resources

The CMS Final Rule can be accessed on the Federal Register by clicking the following link:

https://www.federalregister.gov/articles/2014/09/04/2014-21021/medicare-and-medicaid-programs-modifications-to-the-medicare-and-medicaid-electronic-health-record

The Office of the National Coordinator for Health Information Technology (ONC) has modified the definition of CEHRT to support the Final Rule's changes to 2014 reporting requirements. To view information from ONC regarding certification changes please click on the following link:

http://www.healthit.gov/policy-researchers-implementers/standards-and-certification-regulations