Implementing Stages of Meaningful Use

With the release of the final Stage 2 Meaningful Use regulations, CMS issued a CMS Press Release on Stage 2 that, among other things, attempted to clarify when practices that implement an EHR will need to comply with which stage of the regulations.  In the beginning of the incentive program, there was some concern that practices that delayed EHR adoption might have to jump right to a later stage of meaningful use to obtain any incentive money.  The following chart describes the current phased-in approach based on when a practice first adopts an EHR as compared to when that practice has to demonstrate which stage of meaningful use.

As you can see, for practices that decide to adopt an EHR in 2013, the individual eligible providers will be able to demonstrate compliance with the Stage 1 criteria in both 2013 and 2014, delaying the Stage 2 criteria to 2015.  Readers should note that Medicare eligible providers that delay implementing an EHR until 2015 will not be eligible for any incentive dollars; instead they will just be staving off the proposed Medicare reimbursement cuts of 1% per year (up to 5%) by adopting EHR.  See § 495.211.  For those Medicaid eligible providers, the last year one might adopt an EHR is 2017 to be able to receive any incentive payments (though such a provider would not have to meet the Stage 2 criterion until 2019).  See § 495.310.

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Maryland technology attorney and college professor.

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