Meaningful Use Stage 2 Delayed Until 2015 (Unless You Don’t Want to Wait)

Posted on May 20, 2014 I Written By

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Big news coming out of HHS today, CMS issued a proposed rule that changes the EHR certification requirements, firms up the meaningful use stage 3 delay that was announced previously, and most importantly delays the meaningful use stage 2 requirement until 2015. I guess one could argue that it’s not a delay since you can still attest to MU stage 2 in 2014 if you’d like (some already have), but for practical purposes this is a delay in the enforcement of meaningful use stage 2 for many organizations.

It looks like CMS and ONC was listening to the backlash against meaningful use stage 2 and the potential fallout. This isn’t quite blowing up meaningful use, but it’s a step in that direction. Here’s the chart that ONC put out that shows the new timelines:
New Meaningful Use and EHR Certification Timelines - Meaningful Use Stage 2 Delay

It’s worth noting that this is just a proposed rule, but there were usually very few drastic changes between proposed rules and final rules in the past. Sure, there could be a few tweaks, but I bet this goes into place essentially as it stands.

This will be a relief to hundreds of EHR vendors that are behind on becoming 2014 Certified. I expect most will continue with their 2014 Certified plans, but many of their users will likely opt to stick with the simpler meaningful use stage 1 objectives and measures. What’s not clear to me is if the attestation process will stay the same (ie. self attestation in MU stage 1) or not. I’ve asked HHS and will update the post (see update at the bottom of the post) once I hear from them.

What do you think of these changes? What impact will this have on you and your organization?

Here’s another email that CMS sent out:

CMS and ONC Release NPRM Allowing CEHRT Flexibility and Extending Stage 2

Today, CMS and ONC released a notice of proposed rulemaking (NPRM) that would allow providers participating in the EHR Incentive Programs to use the 2011 Edition of certified electronic health record technology (CEHRT) for calendar and fiscal year 2014.

The NPRM will grant flexibility to providers who are experiencing difficulties fully implementing 2014 Edition CEHRT to attest this year. The proposed rule would allow providers to use EHRs that have been certified under the 2011 Edition, a combination of the 2011 and 2014 Editions, or the 2014 Edition.

Beginning in 2015, all eligible providers would be required to report using 2014 Edition CEHRT.

2014 Participation Options
Under this proposal, valid only for the 2014 reporting year, providers would be able to use 2011 Edition CEHRT for either Stage 1 or Stage 2, would have the option to attest to the 2013 definition of meaningful use core and menu objectives, and use the 2013 definition CQMs.

Providers currently working on Stage 1 in 2014 would be able to demonstrate:

  • Stage 1 (2013 Definition) using 2011 Edition CEHRT, or using a combination of 2011 and 2014 Edition CEHRT; or
  • Stage 1 (2014+ Definition) using 2014 Edition CEHRT.

Providers currently working on Stage 2 in 2014 would be able to demonstrate:

  • Stage 1 (2013 Definition) using 2011 Edition CEHRT, or using a combination of 2011 and 2014 Edition CEHRT;
  • Stage 1 (2014+ Definition) using 2014 Edition CEHRT; or
  • Stage 2 (2014+ Definition) using 2014 Edition CEHRT.

UPDATE: Here’s the response I got from CMS about the reporting periods:

Reporting periods are not changing.

For 2014 Only
Because all providers must upgrade or adopt newly certified EHRs in 2014, all providers regardless of their stage of meaningful use are only required to demonstrate meaningful use for a three-month (or 90-day) EHR reporting period in 2014:

Medicare eligible professionals beyond their first year of meaningful use must select a three-month reporting period fixed to the quarter of the calendar year for eligible professionals. Providers must attest to these reporting periods no later than February 28, 2015 at 12 am ET.

Medicare eligible professionals in their first year of meaningful use may select any 90 day reporting period.

Medicaid eligible professionals can select any 90-day reporting period that falls within the 2014 calendar year.