Unintended Consequences of the Flexibility Rule

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Posted By: Roberta Mullin September 22, 2014

flexibilityPay Attention to State Level Registries for Medicaid EHR Attestations

By Joy Rios, Managing Partner at Practice Transformation
Twitter: @askjoyrios

As we wrap up National Health IT Week, there’s just one more topic I’d like to bring to light.

While the new Final Rule is adding flexibility for many providers, there are some unintended consequences related to its passing.

Through facilitating several Medicaid EHR attestations, I have had the pleasure of getting to know the different state level registries – the folks responsible for accepting, reviewing, and approving state-level MU submissions.

When the final rule passed, I heard rumors that some states had already upgraded their attestation systems to meet the 2014 certification criteria — meaning they have already removed technical specifications that match 2011 Edition CEHRT in order to put 2014 Edition specifications in their place.

Makes sense to me – they were actually planning ahead and preparing for what was to come.

However, now that the flexibility rule was passed, the state level registries are expected to accept providers’ submissions from two very different sets of criteria. This means they have some developing / programming to do!

This week I received confirmation from the California SLR that they are still researching their options, but “hope to take applications from providers using the new Flexibility rule sometime next year. Currently, the SLR is only able to accept 2014 submissions from providers doing AIU or reporting MU with 2014 standards.”

In a worst case scenario, if they are not capable of accepting submissions until, say June 2015, that would push back when providers receive incentive money for 2014.

If you or someone you know is participating in the Medicaid EHR Incentive Program, I highly recommend checking in with the state agency to find out what their attestation system is capable of accepting. Among other things, this will help you get clarity on MU submission timing and your organization’s 2015 budget.

Related: I asked the folks in last Thursday’s Kareo chat about other unintended consequences of the Flexibility Rule and I thought this answer was relevant: