CMS Permitting a One-Time 3-Month Reporting Period in 2014
In order to allow for adequate time for providers to upgrade to 2014 Certified EHR technology, CMS is permitting this one-time three-month reporting period in 2014 for eligible hospitals and eligible providers. Eligible Hopsitals have until July 1, 2014 and Eligible Providers have until October 1, 2014 to begin their three month reporting period with 2014 Edition software. Therefore, some providers will be able to achieve Meaningful Use in the first quarter, rather than the last, and receive incentives earlier.
The table below illustrates the progression of meaningful use stages from when a Medicare provider begins participation in the program.
Note that providers who were early demonstrators of meaningful use in 2011 will meet three consecutive years of meaningful use under the Stage 1 criteria before advancing to the Stage 2 criteria in 2014. All other providers would meet two years of meaningful use under the Stage 1 criteria before advancing to the Stage 2 criteria in their third year.
In the first year of participation, providers must demonstrate meaningful use for a 90-day EHR reporting period; in subsequent years, providers will demonstrate meaningful use for a full year EHR reporting period (an entire fiscal year for hospitals or an entire calendar year for EPs) except in 2014, which is described below. Providers who participate in the Medicaid EHR Incentive Programs are not required to demonstrate meaningful use in consecutive years as described by the table above, but their progression through the stages of meaningful use would follow the same overall structure of two years meeting the criteria of each stage, with the first year of meaningful use participation consisting of a 90-day EHR reporting period.
For 2014 only, all providers regardless of their stage of meaningful use are only required to demonstrate meaningful use for a 3-month EHR reporting period. For Medicare providers, this 3-month reporting period is fixed to the quarter of either the fiscal (for eligible hospitals and CAHs) or calendar (for EPs) year in order to align with existing CMS quality measurement programs, such as the Physician Quality Reporting System (PQRS) and Hospital Inpatient Quality Reporting (IQR). The 3-month reporting period is not fixed for Medicaid EPs and hospitals that are only eligible to receive Medicaid EHR incentives, where providers do not have the same alignment needs. CMS is permitting this one-time 3-month reporting period in 2014 only so that all providers who must upgrade to 2014 Certified EHR Technology will have adequate time to implement their new Certified EHR systems.
CMS is also providing an interactive participation timeline on their website. The timeline will help EPs determine which year to demonstrate each stage of Meaningful Use and also the required length of time for each stage.