The following timeline, taken from the HIMSS website, illustrates some positive changes for those of you in the midst of your Meaningful Use compliance efforts (which, I hope by now, is most, if not all of you reading this). For those who attested as early adopters in 2011, you have another year of Stage 1 compliance before you must attest for Stage 2 (effectively delaying Stage 2 compliance from FY13 to FY14 for hospitals). This timeline also continues for a much longer time frame than previous rules in order to provide clarity on Stage 2 and 3 compliance dates. Finally, the 2014 adjustment allows a one time, 3 month attestation opportunity to allow time to implement the new certified technology.
All good adjustments, but the clock is still ticking, so consider this your daylight savings time adjustment but don’t expect significant changes going forward. Even though the slight change in the timeline is a welcome change, if you aren’t well on your way to Stage 1 attestation now, it may be time you call in some reinforcements to get this ball moving more quickly.
Stage 2 Timeline
The earliest that the Stage 2 criteria will be effective is in fiscal year 2014 for eligible hospitals and CAHs or calendar year 2014 for EPs. The table below illustrates the progression of meaningful use stages from when a Medicare provider begins participation in the program.
|1st Year||Stage of Meaningful Use|
Note that providers who were early demonstrators of meaningful use in 2011 will meet three consecutive years of meaningful use under the Stage 1 criteria before advancing to the Stage 2 criteria in 2014. All other providers would meet two years of meaningful use under the Stage 1 criteria before advancing to the Stage 2 criteria in their third year.
In the first year of participation, providers must demonstrate meaningful use for a 90-day EHR reporting period; in subsequent years, providers will demonstrate meaningful use for a full year EHR reporting period (an entire fiscal year for hospitals or an entire calendar year for EPs) except in 2014, which is described below. Providers who participate in the Medicaid EHR Incentive Programs are not required to demonstrate meaningful use in consecutive years as described by the table above, but their progression through the stages of meaningful use would follow the same overall structure of two years meeting the criteria of each stage, with the first year of meaningful use participation consisting of a 90-day EHR reporting period.
For 2014 only, all providers regardless of their stage of meaningful use are only required to demonstrate meaningful use for a 3-month EHR reporting period. For Medicare providers, this 3-month reporting period is fixed to the quarter of either the fiscal (for eligible hospitals and CAHs) or calendar (for EPs) year in order to align with existing CMS quality measurement programs, such as the Physician Quality Reporting System (PQRS) and Hospital Inpatient Quality Reporting (IQR). The 3-month reporting period is not fixed for Medicaid EPs and hospitals that are only eligible to receive Medicaid EHR incentives, where providers do not have the same alignment needs. CMS is permitting this one-time 3-month reporting period in 2014 only so that all providers who must upgrade to 2014 Certified EHR Technology will have adequate time to implement their new Certified EHR systems.