Happy Labor Day and Back-to-School Week! September is here, which means hospitals and EPs participating in Meaningful Use are rapidly approaching deadlines for their respective 2014 reporting periods. Hospitals are in the closing stretch and have until September 30th when their reporting period closes for the 2014 FY. For EPs, October 1 is the last date to begin their reporting period for the 2014 calendar year.
As a holiday weekend present to us all, CMS finalized regulations this past Friday granting flexibility to certain EPs and hospitals participating in Meaningful Use. Too little, too late, the final rule comes as hospitals have already finished or are in the last month of their 2014 reporting period, and only a month before the last possible date for EPs to begin their reporting period for the year.
The final rule permits EPs and hospitals having difficulty implementing 2014 Edition CEHRT to demonstrate Stage 1 or Stage 2 of Meaningful Use using 2011 Edition CEHRT, 2014 Edition CEHRT, or a combination thereof, for their 2014 reporting periods. You can review your participation options in the CMS “Quick Guide“. Although the flexibility is welcomed by many, the final rule is still not a get-out-of-jail-free card, as providers need to be able to demonstrate that they were unable to fully implement 2014 Edition CEHRT in order to take advantage of the extension.
Although this flexibility may buy EPs a few more months to finish working through all the technical and workflow difficulties with implementing the new versions of their 2014 Edition CEHRT, a hospital must be up and running on 2014 Edition CEHRT and begin its 2015 reporting period on October 1, less than thirty days from now. Citing delays to the progress of health IT infrastructure and misalignment with other quality programs, CMS declined to change the requirement that all EPs and hospitals demonstrate Meaningful Use using 2014 Edition CEHRT in 2015, nor the full-year reporting period requirement for Stage 2 in 2015.
The final rule is scheduled for publication tomorrow, September 4, 2014. A copy of the full rule is available online at the Federal Register website.