CMS has published the final rule on 2014 flexibility for the EHR incentives program. The flexibility options are outlined below.
A few highlights from the ruling are:
- Some providers can attest using 2011 Edition certified EHR technology for 2014, if they have been unable to implement to 2014 edition CEHRT. See chart below.
- Providers may get flexibility in the Stage they can attest to in 2014, if they were unable to “fully implement a 2014 Edition CEHRT for the HER reporting period in 2014 due to delays in 2014 Edition CEHRT availability”. The final rule further clarifies that “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.”
- All Eligible Providers will be required to use 2014 EHR Edition certified EHR technology for 2015
- All Eligible Providers will be required to report a 365 day reporting period in 2015 (either fiscal or calendar year, for hospitals and professionals respectively)
- Stage 3 of Meaningful Use is pushed back a year. Early adopters of Meaningful Use will not need to meet S3MU until 2017 at the earliest.
While gMed cannot make a recommendation for you, we encourage you to read the ruling, and spend some time reviewing the resources provided below. Then you can select the reporting option that works best for your practice. If you choose to attest to a different Stage from what you were originally scheduled to, be sure to thoroughly document why you think the extension applies to you and save this information for the future. This will come in handy in case you are audited down the road. Keep in mind that choosing to report on a different stage will mean having to meet a different set of core and menu measures, so you need to make the assessment early in the reporting period to ensure you will be able to meet the measures.
*If you are a gMed HITECH Advisor client, this will be reviewed on a case by case basis with your gAdvisor.
Additional links to EHR incentive program articles: