May 21, 2014
Many providers have struggled to properly implement and attest to Meaningful Use / MIPS in 2014. A senior CMS official reported recently that only four hospitals have attested to Stage 2 Meaningful Use / MIPS so far this fiscal year.
Many EHR vendors have communicated to CMS that the amount of time available after the publication of the Stage 2 final rule was too short to make the required coding changes to enable their products to be certified to the 2014 Edition of EHR certification criteria. This has resulted in many EHR products being certified later than anticipated, and has seriously impacted the time available to providers—especially hospitals—to effectively deploy 2014 Edition CEHRT.
The CMS rule, released in pre-publication form on May 20, 2014, allows providers to continue to use 2011 Edition CEHRT or a combination of 2011 Edition and 2014 Edition CEHRT for the EHR reporting periods in CY 2014 (physicians) and FY 2014 (hospitals). Furthermore, the rule recognizes that hospitals who haven’t fully deployed 2014 Edition CEHRT may not be able to certify to the 2014 Stage 1 standards.
As a result, CMS has proposed some flexibility in the objectives and measures providers must attest to. The objectives and measures providers are required to attest to in 2014 depend on which stage of Meaningful Use / MIPS they were originally required to attest to in 2014, and whether they have completely or partially installed a 2014 edition compliant EHR.
The table below summarizes the options:
Able to attest to Meaningful Use / MIPS in 2014 | |||
If scheduled to demonstrate in 2014: | Using 2011 CEHRT | Using a Combination of 2011 and 2014 CEHRT | Using 2014 CEHRT |
Stage 1 | 2013 Stage 1 objectives and measures | 2013 Stage 1 objectives and measures OR 2014 Stage 1 objectives and measures |
2014 Stage 1 objectives and measures |
Stage 2 | 2013 Stage 1 objectives and measures | 2013 Stage 1 objectives and measures OR 2014 Stage 1 objectives and measures OR Stage 2 objectives and measures |
2014 Stage 1 objectives and measures OR Stage 2 objectives and measures |
The original requirement for all providers to meet the new standards for reporting electronic quality measures is also relaxed. The methods now required for quality measure reporting in FY14 depends on the measure providers choose to certify for Meaningful Use / MIPS in the same timeframe.
Certify Meaningful Use / MIPS in 2014 using: | Must report Quality Measures: |
2013 stage 1 measures | CQMs by attestation as in 2013 |
2014 Stage 1 objectives and measures or the Stage 2 objectives and measures | eCQMs as outlined in the Stage 2 rule |
Overall, this proposed revision makes October 1, 2014 (hospitals) and January 1, 2015 (eligible professionals) the required start dates for exclusive use of 2014 Edition certified Complete EHRs and EHR modules to meet the CEHRT definition.
Since the latest date for exclusive use of 2014 Edition was previously the start of the final quarter of this year, the change in rules gives providers an extra 90 days to fully deploy 2014 Edition EHRs.
What To Do Now
Most providers who haven’t fully deployed 2014 Edition software will choose to use 2013 standards for reporting this year — this represents significant relief. However, the extra 90 days to complete the installation of 2014 edition software is not a significant amount of extra time. Providers should not use this relief as an excuse to wait 90 days on their installation, training, and workflow efforts for the 2014 edition. For most providers, the extra 90 days makes the difference between having to make a heroic effort and a more reasonable one.
Phoenix Health Systems consultants are working every day with hospitals to meet the requirements for Meaningful Use / MIPS. If you’d like to speak with one of our consultants about the impact of this rule change on your facility or even about more general assistance in meeting the Meaningful Use / MIPS requirements, contact us here.