Practice Makes Perfect: Final rule expands meaningful-use reporting options for 2014

In June, the Medical Group Management Association released the results of a questionnaire that ranked members’ most pressing practice management challenges. In this edition of “Practice Makes Perfect,” we’ll tackle No. 8 on that list: participating in the CMS’ meaningful-use program for electronic health records.

The final rule expanding options for eligible professionals (EPs) to report under the meaningful-use EHR Incentive Program was published on Sept. 4. The rule, issued by the CMS, was in response to the drop-off in the number of EPs who have successfully met the program requirements. Where several hundred thousand EPs received incentive payment for using 2011 Certified EHR Technology (CEHRT), as of mid-September, fewer than 4,000 have attested using 2014 CEHRT.

While supportive of the additional 2014 reporting flexibility contained in the final rule, MGMA remains concerned about the ability of EPs to meet the more rigorous Stage 2 requirements and update software in time to meet the full-year reporting mandate in 2015. Many medical practices are struggling with these inflexible programs and shortened reporting period. In the final rule, the CMS outlined three options for EPs in 2014 in an effort to grant more flexibility to those who experienced 2014 Edition CEHRT product availability issues and saw it affect their ability to fully implement 2014 Edition CEHRT to meet meaningful use. It is important to note, however, that the CMS did not make these options available for the 2015 reporting year. Here are options for EPs:

Option 1: Using 2011 Edition CEHRT only

EPs use only 2011 Edition CEHRT for their EHR reporting period in 2014 and must meet the meaningful-use objectives and associated measures for Stage 1 that applied for the 2013 payment year, regardless of their current stage of meaningful use. EPs who choose this option must attest that they are unable to fully implement 2014 Edition CEHRT because of issues related to 2014 Edition CEHRT availability delays when they attest to the meaningful-use objectives and measures.

Option 2: Using a combination of 2011 and 2014 Edition CEHRT

EPs attest in 2014 using a combination of 2011 and 2014 Edition CEHRT, and for their EHR reporting period in 2014 may choose to meet the 2013 Stage 1 or 2014 Stage 1 objectives and measures, or if they are scheduled to begin Stage 2 in 2014, they may choose to meet the Stage 2 objectives and associated measures. EPs who choose this option must attest that they are unable to fully implement 2014 Edition CEHRT because of issues related to 2014 Edition CEHRT availability delays when they attest to the meaningful-use objectives and measures.

Option 3: Using 2014 Edition CEHRT for 2014 Stage 1 objectives and measures in 2014 for EPs scheduled to begin Stage 2

EPs use 2014 Edition CEHRT to attest to the 2014 Stage 1 objectives and measures for the 2014 EHR reporting period. This applies to EPs scheduled to begin Stage 2 for the EHR reporting period in 2014 who cannot fully implement all the functions of their 2014 Edition CEHRT required for Stage 2 because of issues related to 2014 Edition CEHRT availability delays.

EPs who choose this option must attest (and retain supporting documentation) that they are unable to fully implement 2014 Edition CEHRT because of issues related to 2014 Edition CEHRT availability delays when they attest to the meaningful-use objectives and measures.

The CMS EHR meaningful-use program continues to be challenging for medical practice executives. While MGMA continues to recommend that the CMS add additional flexibility to the program, it’s important for practice staff to understand the rule to begin or continue their participation.

Robert Tennant is senior policy adviser at MGMA.