Home Forums Discussions Meaningful Use A little breathing room for providers and vendors?

Press Release from CMS

CMS rule to help providers make use of Certified EHR Technology

We are from the government and are here to help; it's so good we will impose a penalty so that you are encouraged to enjoy the benefits; the beatings will continue until the moral improves.
There I feel slightly better.

If I read it right we could use the Stage 1 measures to get Stage 2 certification in 2014. That would be a great help.

CMS is scared that no one cares about Stage 2 MU. IMHO, $8k isn't worth the new hoops they want us to jump through. Screw 'em.

I'm out for sure.
Not meaningful at all.
And the potential for HIPAA violations and inadvertent disclosure of PHI is just positively frightening.

I'm not sure I follow what the CMS press release is saying. As I understand it the key change is that CMS will allow EMRs to continue to use the 2011 CEHRT rather than the 2014 version of the standards. I know AC is still waiting to get its 2014 CEHRT as are a lot of other EMRs.
The other change as I understand it is that the move from MU2 to MU3 is delayed from 2016 to 2017. But it still looks like MU2 will be required for those of us who started the process in 2011 or 2012.
So as I understand it, which is now doubt incompletely and perhaps incorrectly, this will take a little pressure off AC but not take any pressure of those of us who want to continue with the MU process.

The whole press release is rife with errors and contradictions:
-- "let providers use the 2011 Edition CEHRT or a combination of 2011 and 2014 Edition CEHRT for the EHR reporting period in 2014": This would imply that Stage 1 will be acceptable for a third year, as some have reported (see graphic here), HOWEVER...
-- the top table in the news release ("Proposed changes to meaningful use timeline") still requires Stage 2 in 2014 if a provider has already attested to Stage 1 for 2 previous years. But the table below that ("You would be able to attest for MU:") allows either 2013 or 2014 Stage 1 objective, or Stage 2 objectives. Huh?
-- ?Increasing the adoption of EHRs is key to improving the nation?s health care system": This has not been proven for either hospitals or outpatient settings, despite the enormous outlays paid out to date under the HITECH program.

Just more shoddy work from our gubbermint minions.

Another question would be if Stage I is now acceptable for 2014, do we have to attest to a full year or just 90 days for 2014?

For the record, I attested (in Feb) for 2013 using stage 1 criteria -- my third year -- and the CMS website accepted it and now says "locked for payment."
The check is in the mail, however.

Yes, Tom, so did I--we did finally get our check. It's 2014 that's the question. Will we still all be using stage 1 criteria or stage 2?

@John Howland --

The way I read it, we attest for stage 2 using 90 days out of the year 2014.

I won't be doing that.
The requirements are too onerous, the payoff too small and the penalty also too small.

Keep in mind that the press release referenced above is for a PROPOSAL. These changes have not gone into effect yet.

The questions to be answered is whether to apply for an exemption as A C is not certified for 2014 till today
Will 2011 certified version,( if the proposed law is passed) be able to fulfil meaningful use 2?

According to Cms table if you started attestation for meaningful use in 2012 you have to attest for stage 2 in 2014

As usual CMS lays out a maze that providers need to figure out.

As anyone in the forum applied for an exception and got it successfully based on non availability of 2014 software?

KenP,

I submitted your question to CMS and this is their response:

If a provider uses 2011 certified EHR technology to meet 2014 attestation requirements are they required to report for the 90 day timeframe or the full year for 2014? Yes, they will still have the same 90-day reporting period.


CMS also provided a 28 page pdf file of their official statement regarding the proposed changes which I can email to you if you'd like.

Can you please email me a copy to sunillallamd@gmail.com
Thanks

Is it possible to determine from their response whether they are referring to qualifying for Stage 1 for the first year (which always has been 3 months), or have they surprised us and require the third year attestation to be only 3 months?

The attestation period for MU objectives for 2014 is 90 days for both stage 1 and stage 2.

Clear as mud. I have seen the questioned asked, but unclear of response. Can I still use Stage 1 attestation in 2014, after having done three years of Stage 1? It seems like that is the suggestion until I upgrade to AC Stage 2 version. If yes, do I attest for the entire year in 2015 like I have done in the past, or is it for a three month segment of 2014 in 2014.

All attestations for 2014, regardless of how many years a provider has participated in MU or whether they are at stage 1 or stage 2, is for a 90 reporting period. Providers that have successfully attested in the past must report their 90 day period based on calendar quarters. First time attesters can report their 90 day period based on any continuous dates but must do so by October 1, 2014 to earn the incentive.

The proposed changes for the Modifications to the Medicare and Medicaid Electronic Health Record Incentive Programs for 2014 and Health Information Technology (ie, allowing providers to use 2011, 2014 CEHRT or a combination of both) have yet to be finalized therefore until they are, providers should proceed attaining MU under the current requirements.

Based on your scenario, that would mean your providers should attest to Stage 2 for 90 days in 2014 using 2014 CEHRT.

As Amazing charts has officially announced that they have attained Stage 2 certification there are no vendor limitations.
If you're still unclear on the requirements, CMS has a handy widget that provides a visual of your particpation timeline. http://cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Participation-Timeline.html

So the question remains, can an EP who has already attested to Stage 1 for two or three years still use the 2011 criteria to attest in 2014 for a third or fourth year? Stage 2 is looking pretty impossible for me. I am quite rural and to get interface for lab or X-ray and meet the %age criteria is probably pretty impossible. It seems awful expensive to try to get interfaces for all of the different facilities used by my patients who reside in 71 different communities in 21 different states. Is the final rule yet available? I understand that if I attested for last year, I could do nothing and not be penalized. Why is this so complicated....like why race and ethnicity? Someone please help me understand how that nuance is useful? I'm just a country bumpkin doctor trying to take care of patients and stay afloat.
Nancy