6 Things you need to know about Meaningful Use and EHR Certification in 2014

Steven Posnack, Director Federal Policy Division, ONC

With the 2014 EHR reporting period for meaningful use right around the corner, here are 6 key pieces of information you need to know:

#1. Does meaningful use (MU) Stage 1 change in 2014?

Yes, the 2014 reporting period marks the beginning of a restructured meaningful use Stage 1.

Certain “core” and “menu” objectives have been removed/combined and eligible professionals (EPs), eligible hospitals (EHs), and critical access hospitals (CAHs) can no longer count measure exclusions toward meeting menu objectives. Equally important is that all Stage 1 EPs, EHs, and CAHs now need to provide more than 50% of unique patients with the ability to access their health information online (to meet the new Stage 1 core measure as part of the “View, Download, Transmit to 3rd Party” objective).

#2. Do all EPs, EHs, and CAHs need to upgrade to 2014 Edition certified EHR technology in 2014?

Yes, starting with the 2014 meaningful use reporting period all EPs, EHs, and CAHs need to upgrade to 2014 Edition EHR technology only – regardless of the meaningful use stage they need to meet.

The 2014 Edition EHR certification criteria support both revised MU Stage 1 and new Stage 2 requirements. They also include important updates that set new baselines for better interoperability, electronic health information exchange, and patient engagement. EHR technology certified to the 2011 Edition will no longer be acceptable for the purposes of meeting the “Certified EHR Technology” definition and from a regulatory perspective 2011 Edition certifications will “expire” come the 2014 MU reporting period.

#3. What is the meaningful use reporting period length in 2014?

2014 has a special MU reporting period length for all non-first time EPs, EHs, and CAHs.

As a result, no EP, EH, or CAH (that previously demonstrated MU before 2014) has to start MU at the beginning of the Federal Fiscal Year (FY) [October 1, 2013] or Calendar Year (CY) [January 1, 2014].

The 2014 MU reporting period for both Stage 1 and Stage 2 performance is set to one calendar quarter during a Medicare EP, EH, and CAH’s reporting year (e.g., April 1, 2014 through June 30, 2014 would be a Medicare EP’s 2nd quarter and an EH/CAH’s 3rd quarter). All Medicaid EPs, EHs, and CAHs (as determined by their state) will have an “any continuous 90-day” or 3-month reporting period during 2014. Last, all new EPs, EHs, and CAHs continue to have an “any continuous 90-day” reporting period.

#4. What happens if a Medicare EP, EH, or CAH skips meaningful use in 2014 or applies for a hardship exception in 2014 (to avoid the 2016 payment adjustment)?

Once a Medicare EP, EH, or CAH starts meaningful use, it is required to continue to meet highermeaningful use stages according to the regulatory schedule set by the Centers for Medicare & Medicaid Services.

This policy applies even if the Medicare EP, EH, or CAH is granted a “hardship exception” for a given reporting year, it skips, or it fails. For example, regardless of whether an EP “passes,” “hardships,” “skips,” or “fails” their “Stage 1, Year 2” performance during 2014 they will be required to move up to “Stage 2, Year 1” in 2015 (with a full year reporting period) and will not get to repeat Stage 1 for a third year.

Medicaid EHR Incentive Program policy is different in two respects. First, the Medicaid program does not have payment adjustments, so hardship exceptions are unnecessary. Second, Medicaid providers are not required to participate in consecutive years of the Medicaid EHR Incentive Program (see Medicaid FAQ). Thus, unlike Medicare providers, Medicaid providers who skip years of participation will resume their meaningful use progression where they left off.  For example, if a Medicaid EP skips 2014 (which would otherwise be their “Stage 1, Year 2”) and also skips 2015 but comes back to the Medicaid program in 2016, they would be required to demonstrate “Stage 1, Year 2” in 2016 as if they never left the Medicaid program for those two years.

#5. When is the last year Medicare EPs can start meaningful use to get incentive payments?

2014 is the last year in which an EP can begin to get incentive payments.

As stated in the Health Information Technology for Economic and Clinical Health (HITECH) Act, no incentives can be paid to Medicare EPs that begin MU after 2014.  EPs that start MU in 2014 could still earn as much as $24,000 in incentives if they demonstrate MU from 2014 through 2016.

#6. How does 2014 meaningful use performance relate to Medicare payment adjustments?

2014 meaningful use performance is the basis for 2016 Medicare payment adjustments.

For EPs this potentially means a -2% reduction to the Medicare physician fee schedule (PFS) amount for covered professional services furnished by the EP during 2016 (EP tip sheet). The payment adjustment calculation for EHs and CAHs is a little more complicated and different for each. Here’s a link to CMS’ EH/CAH tip sheet.

This article was originally published on the ONC’s Health IT Buzz blog and is used here with permission.