Blog Post

How to understand CMS's new proposal on Meaningful Use

May 21, 2014

    Robin Raiford, Health Care IT Advisor

    CMS on Tuesday released an inspection document of a Notice of Proposed Rule Making (NPRM) that suggests new options for providers unable to upgrade in time to attest to meaningful use (MU) this year. The proposal is welcome news for providers—specifically those who planned to submit a hardship exception application because they could not fully implement all of the functionality of 2014 Edition certified EHR technology (CEHRT), including development of new processes and workflows, testing, and end-user training.

    But this is not a blanket policy for all providers. These proposals only apply to those who can demonstrate that they are unable to fully implement 2014 Edition CEHRT.   
    Here's a bit more context: 

    • CMS and ONC propose to effectively roll back the mandatory CEHRT upgrade requirement for Federal Fiscal Year (FY)/Calendar Year (CY) 2014, only.
    • The proposal would allow providers, who attest that they are unable to fully implement 2014 Edition CEHRT because of issues related to CEHRT availability delays, to meet one of three CEHRT options.
    • Because CEHRT was designed for use at varying years and Stages of MU, dependent upon the CEHRT option selected, the provider would have a greater range of MU measures to report on. For example, CMS allows these providers who are in Stage 2 in 2014 to demonstrate meaningful use by meeting the original Stage 1 objectives and measures if they are still using the 2011 Edition CEHRT.

    This table from the NPRM describes the different CEHRT options and associated MU measures available to report in 2014.

    You'll note that Stage 1 objectives and measures are referenced two ways in this table: 2013 and 2014. The 2013 designation references the original Stage 1 objectives and measures, and the 2014 reflects those changes CMS finalized in the Stage 2 Final Rule, effective this year.

    In this NPRM, CMS also includes other proposals.

    Adopt, Implement, and Upgrade (AIU)

    CMS proposes to amend the definition of Adopt, Implement, and Upgrade (AIU) for the Medicaid EHR Incentive Program. Here's what that would mean: Providers may only use 2014 Edition CEHRT to attest to AIU this year.

    CQM Reporting Options

    CQM reporting depends on the CEHRT option providers will use to demonstrate meaningful use. CMS proposes to revert the CQM reporting requirements for those providers attesting with 2011 Edition CEHRT. Meaning, EHs would report 15 CQMs finalized in the Stage 1 Final Rule, and EPs report on 6 selected CQMs as they did in previous years regardless of Stage. Providers with 2014 Edition CEHRT still report on the requirements finalized in the Stage 2 Final Rule (i.e., 16 of the finalized 29 for EHs and 9 for EPs). Providers using a combination of 2011 and 2014 Edition CEHRTs will need to meet the CQM requirements depending upon their Stage of MU. 

    Delay of Stage 3

    As previously discussed on the CMS blog, CMS includes the official proposal to delay Stage 3 to begin on October 1, 2016 for EHs and January 1, 2017 for EPs.

    Get more perspective

    See more analysis from the Health Care IT Advisor team: Our take on Stage 1 changes and the Stage 3 delay. And access our Meaningful Use Navigator to get peace of mind before you attest.

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