Stage 2 Meaningful Use Requires Three Month Reporting Period
2014 Meaningful Use: A Gift to Providers and Vendors
The rules and regulations regarding Stage 2 Meaningful Use for both Eligible Hospitals (EHs) and Eligible Professionals (EPs) include some much needed breathing room. This is true not only for those receiving the incentives but also their vendors. At EMRAdvocate, where we have worked with over 175 vendors on their certification projects, this is a welcome relief. Stage 2 Meaningful Use is the gift that keeps on giving.
The text from CMS is simple enough: “For 2014 only: all providers regardless of their stage of meaningful use are only required to demonstrate meaningful use for a three-month EHR reporting period….CMS is permitting this one-time three-month reporting period in 2014 only so that all providers who must upgrade to 2014 Certified EHR Technology will have adequate time to implement their new Certified EHR systems.”
What does mean for providers and vendors?
Providers: EHs and EPs in 2014 only have to meet Meaningful Use for a three month reporting period with Stage 2 (now called 2014 Edition) software. It doesn’t matter if they attested and received incentives in 2011, 2012, and 2013 or if they are required to meet Stage 1 or Stage 2 Meaningful Use based on where they are in the process. All they need is three months of Meaningful Use of 2014 Edition software in 2014. It was only a few short months ago that we were on a timeline that required EHs (deadline – July 2013) and EPs (deadline – January 2014) to be on 2014 Edition software. That is no longer the case. The deadline has now moved and EHs have until July 1, 2014 and EPs have until October 1, 2014 to begin their three month reporting period with 2014 Edition software. Of course some of the providers will be in a position to achieve in the first quarter, rather than the last, and obtain incentives much earlier.
Vendors: They are being gifted with an opportunity to achieve Edition 2014 certification and rollout to customers on a much less compressed timeline. ONC authorized testing and certification for 2014 Edition software is expect to begin in early January 2013. The Office of the National Coordinator for Health Information Technology (ONC) has been posting waves of the 2014 Edition test procedures online and each wave is followed by a two week opportunity to submit public comment. Currently this process is ongoing and not until the test procedures are finalized will vendors have clarity on what specific functionality they will need to demonstrate during certification testing. Vendors were under the intense pressure of having to wait until the final test procedures were released, complete development, go through the certification process, and then roll out their applications to customers who would need training. EH vendors were facing having to do all this for all their customers seeking incentives by October 1, 2013. EP vendors had until January 1, 2014 to make this all happen. Thankfully, the timeline based on the “2014 Rule”, is now doable. Not easy, but manageable.
Jim Tate is founder of EMR Advocate and a nationally recognized expert on the CMS EHR Incentive Program, certified technology and meaningful use.