ScreenHunter_30 Nov. 20 11.24

Stage 2 Changes? Don’t Hold Your Breath

We’re getting close to the January 1, 2014 Stage 2 MU start – and so far, not a word from CMS or ONC about any changes to MU 2 despite major concerns expressed by several organizations (see post from October 11th). There are several major issues with the Medicare EHR Incentive Program:

  1. With less than 6 weeks left in the year, many EHR vendors have not gotten certified for 2014 and once they do, it will still take months to upgrade practices to 2014 standards;
  2. Even if the EHRs are upgraded to 2014 standards by September 2014, this would leave EPs who need to report meet Stage 2 requirements little time to implement new workflows and processes;
  3. Once upgraded to 2014 specifications, practices will need to train clinicians and staff to use the new features/functions, educate/engage patients on the view/download/transmit and secure email metrics, and implement/ refine portal functionality to meet these (and other) objectives;
  4. Many EPs who intend to achieve Stage 2 MU will likely have to wait until the 4th quarter (October 1, 2014) to have CEHRT in place and workflows ironed out. This is the last 90-day reporting period for 2014. EPs must complete the attestation process by February 28, 2015 (See CMS Stage 2 guide, page 10). If anything goes wrong, not only would the practice lose the incentive payment for 2014, but they would incur penalties in 2015 and 2016;
  5. According to the Stage 2 MU toolkit, page 54 from CMS, “EPs who first demonstrate meaningful use in 2014 must demonstrate meaningful use for a 90-day reporting period in 2014 to avoid payment adjustments in 2015. This reporting period must occur in the first 9 months of calendar year 2014, and EPs must attest to meaningful use no later than October 1, 2014, in order to avoid the payment adjustments.” [Emphasis added]. So, new MU attesters (Stage 1 using a 2014 Certified EHR) have an even tighter time line to implement and attest to Stage 1 MU in order to avoid payment adjustments in 2015 and 2016.

Given these challenges, why doesn’t CMS extend the reporting period for MU Stage 2 and delay the penalties? It is not realistic to expect any practice to upgrade to 2014 CEHRT, purchase new functions/features (i.e., portals, secure email messaging), implement, train staff, educate patients…and be ready to attest by October 1 (for previously participating EPs) or July 1 (for EPs attesting for the first time).

Here’s the question: Who thinks that CMS will modify the 2014 requirements?

This post is the personal opinion of the author and does not necessarily reflect the official policy or position of the American College of Physicians (ACP).

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