CMS has approved a rule that conditionally allows providers to delay implementing 2014 Edition meaningful use changes. Eligible providers (EPs) are granted flexibility in their meaningful use demonstration if:
- Their EHR vendor did not have the software available in time;
- They did not have enough time to install the new software; or
- They didn’t have sufficient time to train themselves and their staff.
Under this new rule, you could attest to three months of Stage 1 under the 2013 Edition requirements in 2014—even if you were supposed to start Stage 2. You could even use 2011 Edition certified software like OfficeMate/ExamWRITER v10 to complete Stage 1 in 2014.
Should you take advantage of the delay?
Let the Provider Beware
On the surface, the reprieve sounds like a pretty sweet deal. You get a free ticket to postpone the headache of adopting the onerous 2014 Edition standards. Simply continue Stage 1 as you have in previous years, and collect an incentive payment. You may have personal or professional reasons for taking advantage of this delay, such as a high turnover in staff or recovering from a natural disaster that may have prevented you from installing 2014 Edition certified software. Evaluate your reason for choosing to delay, and weigh the benefits vs. challenges.
But What’s the Catch?
CMS will require you to verify that certified software was unavailable and prevented you from meeting meaningful use deadlines. You must have a defensible position, and CMS will require you to provide documentation.
For example, how would you explain not upgrading to OfficeMate/ExamWRITER v11.1 between May and July 1 or October 1? Do you have documentation to back up your explanation? The extent or nature of the documentation CMS requires is ambiguous.
“Good” May Not Always Be Good for YOU
The reprieve is short lived. Beginning January 1, 2015, you will be required to report and attest to 2014 Edition criteria. If you didn’t upgrade your software and train your staff by October 1st, you will be juggling that complexity with the holidays and the end-of-year rush. Are you prepared to address meaningful use Stage 2 during the busiest time of the year? When you’re weighing your options to take the delay or not, consider if the delay is good for your business.
For more information:
- 2014 Rule: Quick Guide
- 2014 Rule Decision Tool
- Final Rule
- Press Release: CMS rule to help providers make use of certified EHR technology
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