Meaningful Use Final Rule in Pictures

CMS and the Office of the National Coordinator (ONC) recently announced modifications to the meaningful use attestation requirements for 2014.  Following significant lobbying from EHR vendors, eligible professionals (EPs), and hospitals, CMS issued a brief reprieve to meeting Stage 2 meaningful use in 2014 – for some lucky participants.  Recognizing that EPs and hospitals may still be using 2011 certified EHR technology (CEHRT) or a mixture of 2011 and 2014 CEHRT, CMS created a chart of decision points meant to enable flexibility for EPs and hospitals alike.  These options also accommodate EPs and hospitals that have upgraded to the 2014 CEHRT but are still unable to meet the Stage 2 requirements within the mandatory timetables.

However, this flexibility comes with a caveat:  EPs and hospitals must explain that their failure to meet Stage 2 in 2014 as scheduled is because they could not “fully implement 2014 Edition CEHRT for the EHR reporting period in 2014 due to delays in 2014 Edition CEHRT availability.”  So who is allowed to claim this exception?  Though CMS does not provide an exhaustive list of examples, its published comments in the final rule provide some insights and helpful explanations.

Below is a map of decision points and examples of acceptable and unacceptable justifications for not meeting an EP’s scheduled meaningful use stage in 2014, whether it be the 2014 Stage 1 or Stage 2 objectives and measures.  Any EPs or hospitals that attest for a different stage than what they were scheduled for must be prepared to defend this decision in an audit, understanding that each case will be evaluated individually; this defense should therefore be very well documented.

MU_GRAPHIC_FIRST OR SECOND YEAR-FINALMU_GRAPHIC_THIRD OR FOURTH YEAR_FINAL

Elana Zana, attorney with Ogden Murphy Wallace, co-authored this post.

This entry was posted in EHR, Meaningful Use and tagged , , , , , , by Michelle Holmes. Bookmark the permalink.

About Michelle Holmes

Michelle is a leading industry expert on the application of IT strategies in physician practices and ambulatory care settings. As a leader of ECG’s Healthcare IT practice, she directs the development of IT plans and other key services. Michelle’s deep background with implementation and management allows her to craft strategies that prioritize actions with the greatest short- and long-term impact on patients, staff, physicians, and leadership, rather than tasks that may be the quickest and easiest. She is known for leading focused engagements that create value for her clients, apply innovation to complex tasks, and ensure clarity at the task level so that action plans are successfully executed. With expertise in many major IT platforms, including NextGen, eClinicalWorks, Epic, and MEDITECH, Michelle frequently shares her insights in articles and educational presentations for national audiences. Healthcare executives, IT vendors, professional associations, and industry publications, such as The Wall Street Journal’s MarketWatch, rely upon her insights for using IT to enhance and streamline patient care delivery and ensure that IT investments deliver their expected returns and benefits. Michelle has master’s degrees in business administration and health services administration from the University of Washington, a bachelor of arts degree in health services administration from Eastern Washington University, and a bachelor of science degree in business management from The University of Utah.

One thought on “Meaningful Use Final Rule in Pictures

  1. Pingback: Shaping Emergency Department Utilization Through Predictive Analytics | ECG Management Consultants, Inc.

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