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The Final Rule on Stage 2 MU is Finally Out

On Friday afternoon, while many physicians and practice executives were headed out for the extended Labor Day weekend, the Centers for Medicare & Medicaid Services (CMS) issued its highly anticipated Final Rule on Stage 2 of the Electronic Health Record (EHR) Incentive Program. On the heels of the Proposed Rule issued in May, CMS officially delayed Stage 3 until 2017 but, most importantly, provided official confirmation that physicians can indeed use technology certified to 2011 standards to meet Stage 2 requirements. Of course, the only physicians who need to be concerned about Stage 2 now are those who began the government’s program in 2011 or 2012.

With many vendors failing to deliver a fully functional 2014 certified edition – or for those physicians who could not make the required workflow changes, this August 29 Final Rule was the last hope for successful reporting in 2014. According to CMS, the viable options for Stage 2 reporting now include attesting to:
• 2013 Stage 1 criteria and 2013 clinical quality measures (CQMs) using the 2011 Edition of certified EHR technology (CEHRT);
• 2013 or 2014 Stage 1, or 2014 Stage 2 criteria and 2013 or 2014 CQMs using a combination of 2011 and 2014 Editions of CEHRT; or
• 2014 Stage 1 or 2 criteria and 2014 CQMs using the 2014 Edition of CEHRT.

For physicians poised to attest to Stage 1, whether they be in their second year of the program or just beginning, the CMS announcement provides them the flexibility to use the 2013 or 2014 criteria and CQMs with the same options provided to the Stage 2 subscribers.

Given the complexity of the new options, CMS released a series of “Flexibility Resources” to assist physicians and other eligible professionals. While this guide may not eliminate all of the confusion, you can get started by clicking here to access CMS’ new resources.

In the press release that accompanied the issue of the Final Rule, CMS administrator Marilyn Tavenner revealed: “We listened to stakeholder feedback and provided flexibility for 2014 to help ensure providers can continue to participate in the EHR Incentive Programs.”

While the announcement was welcomed, most felt it was necessary. CMS had received successful attestations for Stage 2 from just 104 eligible professionals as of the end of June, in contrast to the nearly 300,000 who reported Stage 1.

CMS’ delay, however, is limited to 2014. Eligible professionals, as well as the vendors supplying them the technology required to attest for the government’s program, must ready themselves for the coming year. Industry requests to limit reporting to 90 days in 2015 were ignored, with CMS’ Final Rule revealing that a full, 365-day reporting year will be required for 2015, and that the 2014 Edition of CEHRT is mandated.

Woodcock & Associates: Changing the Way You Work