Proposal Extends Stage 2 MU Requirements

ONC and CMS announced a proposal on May 20 to extend Stage 2 and postpone the requirement for eligible providers to begin using 2014 Edition certified EHRs due to delays in 2014 Edition CEHRT availability. (See: http://www.ofr.gov/OFRUpload/OFRData/2014-11944_PI.pdf)

At a high level overview, this proposal states that:

  1. 2011 Edition certified EHRs are basically still valid for providers to use in Meaningful Use (MU) attestation during the current Fiscal Year/Calendar Year 2014 and
  2. Eligible providers who were on schedule to start Stage 2 in FY/CY 2014 may elect to use Stage 1 measures instead of the MU attestation.

In a nutshell, it basically means we are repeating FY/CY 2013 all over again in terms of 2011 Edition and 2014 Edition certified EHRs being permissible for MU attestation. Thus, those 2011 Edition certifications would no longer be considered effectively "expired," but are now still "valid" for MU attestation in FY/CY 2014.

NOTE: This is a high level summary. Please read the entire document to fully understand additional details and clarifications. The Medicaid program of MU has some specific qualifications for using 2014 Edition certified EHRs this year. 

Of course, this is a still an NPRM, which means it is not technically official. It will have a 60-day comment period and then would have to be published as a Final Rule. This means it would not be effective until August, or most likely later this year. However, it seems very unlikely ONC and CMS would release this unless they had the full intention of finalizing it.

If this is approved, the impact is significant. Eligible providers that have not yet upgraded their EHRs to 2014 Edition certified systems may keep their 2011 Edition certified system and still attest to MU this year. Organizations that have already upgraded can elect to use the "easier" Stage 1 measures for MU attestation. Vendors who are only certified to 2011 Edition can still promote their EHRs are viable for MU attestation. Vendors with 2014 Edition certified EHRs, or currently in plans for 2014 Edition certification, may either relax their rollout dates or adjust their customer support as necessary. Vendors who have not yet started the process of 2014 Edition certification have a little more time.

However, it should be noted that this is really only a 3-month extension to the current "deadline" to implement 2014 Edition CEHRT. The current rules still state that eligible providers will need to begin using 2014 Edition certified EHRs by the start of FY/CY 2015, and nothing in this NPRM changes that. Thus, ambulatory vendors should still plan to have their customers upgraded to, and prepared to use, 2014 Edition certified EHR technology by Jan. 1, 2015, and inpatient vendors must be ready by Oct. 1, 2014, which is the start of the CMS fiscal year.

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