Timing of Stage 2 CMS EHR Incentive Program

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Posted By: Roberta Mullin August 28, 2012

Dissecting Stage 2 of EHR Adoption

In the 2011 final rule for the CMS EHR Incentive Program, the rule established a timeline for the then 3 stages of meaningful use of certified technology. The Medicare eligible participants beginning in 2011 would report and attest for 2 years meeting the meaningful use criteria required in stage 1. The first year reporting period of 90 days and the second year reporting of a full year. The participants would then move on to Stage 2 in the third year of reporting, 2013.

In the 2012 final rule for the CMS EHR Incentive Program, the rule has delayed starting stage 2 criteria for another year. The earliest any participant can report and attest to stage 2 meaningful use criteria will be 2014 fiscal year for hospitals and 2014 calendar year for EPs. For those who were the early adopters in 2011, they will report and attest to three years of stage 1 criteria. All participants will report and attest to stage 1 requirements for the first 2 years of their participation regardless of the calendar year they begin. They will only begin stage 2 in their third year of participation. Participants will then report and attest to 2 years of Stage 2 criteria before moving on to stage 3.

In the CMS Medicaid EHR Incentive Programs, 2011 final rule did not require initial participants to achieve meaningful use. Their first year of participation consists of adopt/implement/upgrade. Once the Medicaid participant does begin reporting and attesting to meaningful use, it will be a progression of 2 years in each stage, reporting 90 days in that starting year.

And finally the 2012 final rule outlines reporting in 2014. For 2014 only, all participants regardless of the stage they are reporting will only be required to report and attest to 90 days of meaningful use. CMS feels the 90 day reporting period will allow participants the time to upgrade and implement to 2014 Certified EHR Technology.

  • For Medicare participants, eligible hospitals will report the 90 days in fiscal year 2014 while eligible professionals will report in the calendar year 2014. The reporting period will be the same quarter reporting existing CMS quality measurement programs such as the Physician Quality Reporting System (PQRS) and Hospital Inpatient Quality Reporting (IQR).
  • For Medicaid participants only eligible to receive Medicaid EHR incentives, the 90 day reporting quarter is not fixed to any other reporting programs.