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Meaningful Use Update: CMS Announces Revised Timeline

on Monday, 27 January 2014 in Health Law Alert: Erin E. Busch, Editor

Over the past several years, the health care industry has seen rapid adoption of electronic health record (EHR) technology by health care providers and facilities. Recent adoption of EHR technology was spurred by the Centers for Medicare and Medicaid Services (CMS) EHR Incentive Program (also known as Meaningful Use). Under the Meaningful Use program, eligible providers and hospitals are required to adopt and use EHR technology or face penalties, including reductions in Medicare reimbursement. The Meaningful Use program provides for stages of adoption. Each stage has different goals and criteria. For example, Stage 2 is focused on patient engagement and exchange of health information. Many industry experts believed that CMS’ initial timeline for implementation of Meaningful Use was too aggressive, and would force providers to focus efforts and resources on constant technology upgrades rather than patient care and provider adoption and awareness of EHR technology.

 

CMS previously revised the implementation timeline for Meaningful Use Stages 1 and 2. On December 6, 2013, CMS announced another revised timeline. Stage 2 is now extended through 2016. Stage 3 will now begin in 2017 for providers who have completed two years in Stage 2. The revised timelines will affect providers differently, based on when the provider started in the Meaningful Use program. CMS provided the following explanation of the revised timeline:

 

Providers Who Began the Medicare EHR Incentive Program in 2011 or 2012:

  • Must demonstrate Stage 2 Meaningful Use in 2014 (3-month reporting period)
  • Must demonstrate Stage 2 Meaningful Use in 2015 and 2016 (full year reporting period)
  • Begin Stage 3 in 2017

 

Providers Who Began the Medicare EHR Incentive Program in 2013:

  • Must demonstrate Stage 1, Year 2 Meaningful Use in 2014 (3-month reporting period)
  • Must demonstrate Stage 2 Meaningful Use in 2015 and 2016 (full year reporting period)
  • Begin Stage 3 in 2017

 

The revised timeline provides for an easier transition through the stages of Meaningful Use and allows providers to focus on implementation of the requirements for each stage. Adoption of EHR technology requires a variety of resources from different perspectives including clinical, information technology, financial and compliance. Providers and organizational leaders should continue to plan carefully and well in advance for transition through each of the Meaningful Use stages.

Michael W. Chase

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