Saturday, September 6, 2014

CMS’ Final Rule for Meaningful Use in 2014 Offers Providers Flexibility

By Kathy McCoy

CMS approved the proposed rule to ease the Meaningful Use obstacles faced by many providers on August 29, giving providers assurance that they can use EHRs that have been certified under the 2011 Edition, a combination of the 2011 and 2014 Editions, or the 2014 Edition of certified electronic health record technology (CEHRT) for 2014.

Overview of the September 2014 Meaningful Use Final Rule

  1. Stage 2 of the Meaningful Use incentive program will be extended through 2016
  2. Stage 3 will begin in 2017 for providers who first became meaningful users of electronic health records in 2011, 2012 or 2013
  3. Maintains the 3 month (quarterly for Medicare) reporting period
  4. Allows eligible providers to use any of the following options to meet Meaningful Use in 2014:
    1.  2011 edition certified electronic health record technology (CEHRT),
    2. a combination of 2011 and 2014 edition CEHRT
    3. 2014 CEHRT to report Stage 1 objectives
    4. 2014 CEHRT to report Stage 2 objectives
  5. Eligible professionals (EPs) must use the 2014 edition CEHRT in 2015
  6. The 2015 reporting period for EPs is the full calendar year
None of the flexibility rules above have changed when comparing the May 2014 proposed rule to the September 2014 final rule, but CMS has clarified several issues that caused concern for many in the medical community.

Among the issues that were unclear in the proposed rule were:

1.     When CMS said that the alternatives were available only for those providers that “could not fully implement” 2014 certified EHRs, what does “fully implement” mean?
In the Final Rule, CMS provided this definition: “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.”

2.     What about that “transitions of care” objective that was not feasible for most providers due to a lack of ability on the part of other providers?
CMS has also clarified their position on the “transitions of care” objective in the final rule: “…the sending provider may experience significant difficulty meeting the 10 percent threshold, despite the referring provider’s ability to send the electronic document, if the intermediary or the recipient of the transition or referral is experiencing delays in the ability to fully implement 2014 Edition CEHRT. 

We acknowledge referring providers may not be able to meet the summary of care measure in 2014, if receiving providers they frequently work with have not upgraded to 2014 Edition CEHRT.”

CMS reinforces that providers not able to meet the transition / summary of care measure may attest to Stage 1 and they remind the provider to retain documentation that they were unable to meet the measure’s 10% threshold.

2014 Participation Options
A useful chart provided by the industry publication EHR Intelligence, based on information from CMS, outlines the options for eligible providers.

CEHRT Flexibility Resources
To help the public understand the final rule’s changes to 2014 participation, CMS has developed the following resources:
•  CEHRT Interactive Decision Tool – providers answer a few questions about their current stage of meaningful use and Edition of EHR certification, and the tool displays the corresponding 2014 options.
• 2014 CEHRT Flexibility Chart – chart provides a visual overview of CEHRT participation options for 2014.
• 2014 CEHRT Rule Quick Guide – guide provides corresponding resources based on the option a provider chooses to participate in the EHR Incentive Programs in 2014.

No changes to proposed rule, despite requests

Although many public comments signaled that a significant number of stakeholders would have preferred additional changes, CMS approved the proposed rule without any significant changes. One of the items at issue for many providers was the requirement to report for 12 months in 2015; a number of industry groups proposed changing the reporting period to the 90 days required in 2014.

“CHIME is deeply disappointed in the decision made by CMS and ONC to require 365 days of EHR reporting in 2015,” said Russell Branzell, President and CEO of The College of Healthcare Information Management Executives (CHIME) in a press release. “This single provision has severely muted the positive impacts of this final rule. Further, it has all but ensured that industry struggles will continue well beyond 2014.”

Another requirement to remember for 2015 is that a 2014 certified EHR will be required to attest next year. If you are looking for an EHR, it’s best to select one that is already 2014 certified to insure that you will be able to attest in 2015.

For more information on Meaningful Use, see:

Kathy McCoy, MBA, is Director, Content Marketing, for HealthFusion’s MediTouch® EHR & Practice Management Software. She can be reached at

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