CMS has issued a proposed rule which would allow providers to continue using electronic health records certified for 2011 Edition CEHRT or a combination of 2011 Edition and 2014 Edition CEHRT for meaningful use reporting in 2014.

Will CMS extend meaningful use deadlines?

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Q: Will CMS extend meaningful use deadlines?

A: The Centers for Medicare and Medicaid Services (CMS) has issued a proposed rule that would allow providers to continue using electronic health records (EHR) certified for 2011 Edition certified EHR technology (CEHRT) or a combination of 2011 Edition and 2014 Edition CEHRT for Medicare meaningful use reporting in 2014. If finalized, this change would only affect reporting in 2014, as providers would be required to use EHRs with 2014 Edition CEHRT starting in 2015.

Providers have three options to report for meaningful use in 2014 based on the certification criteria of their EHR:

  • Option #1 – If the provider’s EHR is currently certified to 2011 CEHRT standards, they can report Stage 1 meaningful use measures that were used in 2013 for the 2014 reporting period regardless of the stage they are currently in. Additionally, providers would report the clinical quality measures (CQMs) that were outlined in Stage 1 of meaningful use. For example, if a provider began reporting for meaningful use in 2011, they would have had to begin reporting for Stage 2 in 2014; however, this proposed rule allows providers to continue reporting Stage 1 measures with their 2011 CEHRT EHR for 2014.
  • Option #2 – If the provider’s EHR is currently certified to a combination of 2011 and 2014 CEHRT standards, they can choose to either report Stage 1 meaningful use measures that were used in 2013 or Stage 2 meaningful use measures for the 2014 reporting period regardless of the stage the provider is currently in. Additionally, they would report the CQMs that were outlined in Stage 1 of meaningful use.
  • Option #3 – If the provider’s EHR is currently certified to 2014 CEHRT but is unable to fully implement all of the criteria from this upgrade, the provider can choose to report Stage 1 meaningful use measures that were used in 2014 for the 2014 reporting period regardless of the stage they are currently in. Additionally, they would report the CQMs that were outlined in Stage 2 of meaningful use.

Regardless of the option they choose, if this proposal is finalized, providers must attest on the CMS website that their EHR was not implemented to the Stage 2 standard because of issues related to the certification process. Additionally, CMS has proposed a delay for Stage 3 so it would not begin until 2017 for those providers who started meaningful use in 2011 or 2012. Learn more about meaningful use on the Academy's HIT and EHR resources Web page. For more information, contact Rachna Chaudhari at hit@aad.org.