Extension Would Impact 2014 Meaningful Use Timeline

Attributed by David Holtzman, VP Compliance

CMS Action: Proposed Rule

When: 60 day comment period ends July 22, 2014

Possible Outcome: Extension could be adopted as a final rule in the 4th quarter of 2014

Who: Hospitals and physicians that couldn’t fully implement a Certified EHR Technology in 2014 and continued to use a 2011 CEHRT or a combination of 2011 & 2014 CEHRT for the 2014 MU reporting period. They would then be allowed to use the 2014 criteria in 2015. This proposed option would be available only for providers who can attest that they were unable to fully implement a Certified EHR Technology in 2014 because of delays caused by the availability of the 2014 certified version of their EHR by their vendors.

The provider would attest to the stage of Meaningful Use based on the edition of the CEHRT they have implemented. For example, a hospital that was not able to implement 2014 edition CEHRT in its 2014 reporting year would not have the capability to attest to stage 2 Meaningful Use objectives and measures. Therefore, in 2014 this hospital would be permitted to continue attestation to MU stage 1 measures and objectives.

Note: The options proposed by CMS are only for providers who can attest that they were unable to fully implement 2014 CEHRT caused by delays in system availability that was the fault of the vendor.

The modifications for the continued use of 2011 CEHRT to attest for meaningful use in 2014 is only a proposal.  There is no guarantee that CMS will adopt these provisions as a final rule, when they would be adopted, or if they would apply retroactively.