Do EPs meet Stage 1 Meaningful Use if they start in 2014?

Stage 1 Meaningful Use and Stage 2?

I thought as we moved deeper into Stage 1 Meaningful Use (MU) the questions would get easier. This is not always the case. A topic came up this week that drove me all the way back to the Final Rule. That’s right, I had to get a step ladder, pull the Rule down from the top shelf, and dust it off. I felt like Harry Potter in the Hogwarts Library. All roads lead to the Final Rule and this was no exception. The question on its surface was simple: “If a Medicare Eligible Professional’s initial year in the CMS EHR Incentive Program is 2014 what Stage of MU Criteria must they meet to be eligible for the incentives? The answer, surprisingly, is “Stage 1”.

You don’t have to believe me. Go to Table 1 on page 11 of the Final Rule and look for yourself. Table 1 documents that going forward we will have EPs (as well as EHs and CAHs) at different Stages in the same year. Now, of course Stage 2 has been delayed one year since this table was created, but the effect is the same.

Based on current rules we are set to have some Medicare EPs at Stage 1 and some at Stage 2 in 2014. It all depends on their initial year in the CMS EHR Incentive Program. Some medical practices will have providers at different Stages of MU, but all will be receiving incentives. At some point down the road every EP will have to be at the same Stage, but we simply don’t know what year that synchronization of Stages will be required. The Final Rule states: “However, due to the many comments on alignment starting in 2015 and our plan to engage in additional more rounds of rulemaking, we are removing discussion of actual alignment between the first payment year of an EP, eligible hospital, or CAH and the Stage of meaningful use they will be expected to meet for all years after 2014. Our policies for 2015 and subsequent years will be determined through future rulemaking.”

I ran across one other interesting fact about the MU timeline while poring over the fine print in the Final Rule: “Please note that nothing in this discussion restricts us from requiring additional stages of meaningful use (beyond stage 3) through future rulemaking.” Did I hear someone say Stage 4?

Jim Tate is a nationally recognized expert on the CMS EHR Incentive Program, certified technology and meaningful use and author of The Incentive Roadmap® The Meaningful Use of Certified Technology: Stage 1.