A Twist in the Newly Proposed Stage 2 and Stage 3 EHR Incentive Timelines
Facing the Facts
I was driving through the mountains last Friday at sunset when my phone started ringing. Now I don’t like to talk on phone when I’m driving, especially at dusk in the mountains, so I didn’t answer. The calls kept coming and by the time I pulled over 15 minutes later I had 9 voice mails. Every message was from a different person and essentially said the same thing: “Stage 2 Meaningful Use has been delayed”. I could almost hear the champagne corks popping. It was like an early holiday present. All the fear and dread of what has been called the “perfect storm of 2014” (ICD-10, Stage 2, 2014 Edition EHRs, Affordable Care Act) suddenly starting looking a whole lot better.
Funny how facts turn into rumors and spread like a wildfire. Many of the headlines and Tweets coming from reputable sources proved to be wrong. Too bad we have to sometimes face the facts. Here they are, just the facts, and nothing more.
CMS and ONC have proposed a timeline that will extend Stage 2 for one more year and Stage 3 will begin in 2017. The actual delay will be in the onset of Stage 3. This action is similar to earlier adjustment that extended Stage 1 and delayed Stage 2 by one year. The Final Rule for Stage 3 is expected in the first half of 2015.
For 2014 there are no changes. All providers will need 2014 Edition Certified Electronic Health Record Technology (CEHRT) to achieve meaningful use (MU). If you were scheduled for Stage 2 in 2014, you still are. Put that cork back in the bottle and save it for another day.
One twist in this announcement was the proposal for a 2015 Edition of certification criteria. It appears to be “voluntary” in the sense that the 2015 Edition of CEHRT will not be required by providers to achieve MU for Stage 1 or Stage 2. In addition there is no requirement for vendors to test against the 2015 criteria. So why would vendors pursue the “voluntary” certification? One word, “competition”. If you could boast of a 2015 Edition certification when your competitor only flies the 2014 Edition flag you have an advantage.
Jim Tate is known as the most experienced authority on the CMS Meaningful Use (MU) audit and appeal process. His unique combination of skills has brought successful outcomes to hospitals at risk of having their CMS EHR incentives recouped. He led the first appeal challenge in the nation for a client hospital that had received a negative audit determination. That appeal was decided in favor of the hospital. He has also been successful in leading the effort to reverse a failed appeal, even after the hospital had received notification of the failure with the statement, “This decision is final and not subject to further appeal”. That “final” decision was reversed in less than a week. If you are a hospital with questions or concerns about the meaningful use audit process, contact him at: firstname.lastname@example.org.