Electronic Health Records

Adoption & Implementation News

Breaking Down the Final Rule for Meaningful Use in 2014

By Kyle Murphy, PhD

- The rule with the purpose of providing flexibility to eligible professionals and hospitals is now final, much to the chagrin of many commenters who sought to effect many more changes through their feedback.

Back in May, the Centers for Medicare & Medicaid Services (CMS) revealed its plan for addressing many of the difficulties that eligible providers were facing in meaningful use for the 2014 reporting year, most of which hinged on a lack of available certified EHR technology (CEHRT) without which demonstrating meaningful use is not possible.

Following the public comment period and a review of stakeholder feedback, CMS has now finalized elements of the proposed rule without any significant changes.

Here’s the quick and dirty of it (via CMS):

2014 Participation Options

READ MORE: HIMSS Seeks Delay in Use of 2015 Edition Certified Technology

Under the rule, providers are able to use 2011 Edition CEHRT, and have the option to attest to the 2013 Stage 1 meaningful use objectives and the 2013 definition CQMs.

2011 CEHRT
Providers scheduled to meet Stage 1 or Stage 2:

• 2013 Stage 1 objectives and 2013 CQMs

Combination of 2011 & 2014 CEHRT
Providers scheduled to meet Stage 1:

• 2013 Stage 1 objectives and 2013 CQMs; or
• 2014 Stage 1 objectives and 2014 CQMs

READ MORE: CMS Finalizes Changes to Hospital Meaningful Use Requirements

Providers scheduled to meet Stage 2:

• 2013 Stage 1 objectives and 2013 CQMs; or
• 2014 Stage 1 objectives and 2014 CQMs; or
• 2014 Stage 2 objectives and 2014 CQMs

2014 CEHRT
Providers scheduled to meet Stage 1:

• 2014 Stage 1 objectives and 2014 CQMs

Providers scheduled to meet Stage 2:

READ MORE: CMS Finalizes 2018 Meaningful Use Requirement Flexibilities

• 2014 Stage 1 objectives and 2014 CQMs; or
• 2014 Stage 2 objectives and 2014 CQMs

CEHRT Flexibility Resources

To help the public understand the final rule’s changes to 2014 participation, CMS has developed the following resources:

•  CEHRT Interactive Decision Tool – providers answer a few questions about their current stage of meaningful use and Edition of EHR certification, and the tool displays the corresponding 2014 options.

• 2014 CEHRT Flexibility Chart – chart provides a visual overview of CEHRT participation options for 2014.

• 2014 CEHRT Rule Quick Guide – guide provides corresponding resources based on the option a provider chooses to participate in the EHR Incentive Programs in 2014.

Extending Stage 2

The rule also finalizes CMS and ONC’s recommended timeline to extend Stage 2 through 2016. The earliest a provider can participate in Stage 3 of meaningful use is now 2017.

Not surprisingly, the final rule is not sitting well for some. The College of Healthcare Information Management Executives (CHIME) was one such group. The association’s head Russell Branzell, FCHIME, CHCIO, voiced his disappointment with the finalized requirement of a 365-day reporting period in 2015.

“This single provision has severely muted the positive impacts of this final rule. Further, it has all but ensured that industry struggles will continue well beyond 2014,” he wrote late last week. “Roughly 50% of EHs and CAHs were scheduled to meet Stage 2 requirements this year and nearly 85% of EHs and CAHs will be required to meet Stage 2 requirements in 2015. Most hospitals who take advantage of new pathways made possible through this final rule will not be in a position to meet Stage 2 requirements beginning October 1, 2014.”

The lack of a change has CHIME and likely others questioning whether the EHR Incentive Programs has a future.

“This sensible recommendation, if taken,” Branzell continued, “would have assuaged industry concerns over the pace and trajectory of rulemaking; it would have pushed providers to meet a higher bar, without pushing them off the cliff; and it would have ensured the long-term vitality of the program itself. Now, the very future of Meaningful Use is in question.”

In the final rule, CMS addressed this request for reporting changes in 2015 and provided the rationale behind its decision to ignore them:

We are not considering changes to the EHR reporting periods for 2015 or subsequent years in this final rule for the same reasons we are not considering changing the edition of CEHRT required for 2015 or subsequent years. Changes to the EHR reporting period would put the forward progress of the program at risk, and cause further delay in implementing effective health IT infrastructure. In addition, further changes to the reporting period would create further misalignment with the CMS quality reporting programs like PQRS and IQR, which would increase the reporting burden on providers and negatively impact quality reporting data integrity.

Apparently, the pursuit of quality program alignment — indicated with the mention of both the Physician Quality Reporting System (PQRS) and Inpatient Quality Reporting (IQR) programs — and progress as a whole via health IT implementation and adoption has the federal agency unwilling to further relent.

Stay tuned for more updates on the implications of the final rule on providers.

 

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