On May 20, HHS published a new proposed rule that would provide eligible professionals (EPs) more flexibility in how they use certified electronic health record technology (CEHRT) to meet meaningful use. Recognizing that many software vendors are having a difficult time making the necessary changes to get their EHR products certified and then getting their customers upgraded to the 2014 Edition CEHRT under the current timetable given in the 2014 Edition final rules, the newly proposed rule, from CMS and the Office of the National Coordinator for Health Information Technology (ONC), would let providers use their prior 2011 Edition CEHRT or a combination of 2011 and 2014 Edition CEHRT for the EHR reporting periods in 2014. Beginning in January 2015, all EPs would still be required to report using only a 2014 Edition CEHRT for the entire year. The proposed rule also includes a provision that would formalize CMS and ONC’s previously stated intention to extend Stage 2 through 2016 and begin Stage 3 in 2017.
These proposed modifications to the Incentive Program have not gone into effect. While there is the possibility that such changes could be enforced, we do not advise that DCs participating in the Incentive Program to change course based on possible rule modifications. The ACA will be submitting comments in support of the extension stated in the proposed changes and once the final rule is issued, on or after August 1, we will be sure to inform the membership of CMS’ final decisions.
It should also be noted that this proposed rule will not affect the calendar quarter reporting periods for 2014 (beginning July 1 or October 1) for EP’s who have already begun participation in the EHR Incentive Program, nor does it affect the payment reductions that will go into effect on January 1, 2015. Therefore, the ACA encourages all DC’s to continue to participate in the EHR Incentive Program and new participating EP’s must be aware that in order to avoid the 2015 payment reductions, they must begin MU no later than July 1, 2014 and attest no later than October 1, 2014. Additionally, the absolute last date for any new participating DC to enter into the EHR Incentive Program to be eligible for the up to $24,000 incentive payments is October 3, 2014.
Decisions to participate must be made soon if any DC wishes to receive any federal incentives, with up to $12,000 per provider for 90 days of participation in 2014 for successfully attesting to Meaningful Use. If an EP has not begun Meaningful Use before October 3, 2014, they will not be eligible to receive any future incentive payments; but they will be subject to payment reductions starting January 1, 2015. Payment reductions will increase each subsequent year for not participating.CMS Issues Proposed Rule – Potential MU Timeline Modifications
On May 20, HHS published a new proposed rule that would provide eligible professionals (EPs) more flexibility in how they use certified electronic health record technology (CEHRT) to meet meaningful use. Recognizing that many software vendors are having a difficult time making the necessary changes to get their EHR products certified and then getting their customers upgraded to the 2014 Edition CEHRT under the current timetable given in the 2014 Edition final rules, the newly proposed rule, from CMS and the Office of the National Coordinator for Health Information Technology (ONC), would let providers use their prior 2011 Edition CEHRT or a combination of 2011 and 2014 Edition CEHRT for the EHR reporting periods in 2014. Beginning in January 2015, all EPs would still be required to report using only a 2014 Edition CEHRT for the entire year. The proposed rule also includes a provision that would formalize CMS and ONC’s previously stated intention to extend Stage 2 through 2016 and begin Stage 3 in 2017.
These proposed modifications to the Incentive Program have not gone into effect. While there is the possibility that such changes could be enforced, we do not advise that DCs participating in the Incentive Program to change course based on possible rule modifications. The ACA will be submitting comments in support of the extension stated in the proposed changes and once the final rule is issued, on or after August 1, we will be sure to inform the membership of CMS’ final decisions.
It should also be noted that this proposed rule will not affect the calendar quarter reporting periods for 2014 (beginning July 1 or October 1) for EP’s who have already begun participation in the EHR Incentive Program, nor does it affect the payment reductions that will go into effect on January 1, 2015. Therefore, the ACA encourages all DC’s to continue to participate in the EHR Incentive Program and new participating EP’s must be aware that in order to avoid the 2015 payment reductions, they must begin MU no later than July 1, 2014 and attest no later than October 1, 2014. Additionally, the absolute last date for any new participating DC to enter into the EHR Incentive Program to be eligible for the up to $24,000 incentive payments is October 3, 2014.
Decisions to participate must be made soon if any DC wishes to receive any federal incentives, with up to $12,000 per provider for 90 days of participation in 2014 for successfully attesting to Meaningful Use. If an EP has not begun Meaningful Use before October 3, 2014, they will not be eligible to receive any future incentive payments; but they will be subject to payment reductions starting January 1, 2015. Payment reductions will increase each subsequent year for not participating.
