New Time Table Proposed for Meaningful Use Stage 2 Certification
Eligible Providers (EP) and hospitals must meet the criteria of three stages of Meaningful Use (MU) over time, in order to continue to receive reimbursements from Medicaid or Medicare (EP’s can receive incentive money from both though not at the same time). At this time, covered entities who have met criteria and attested to compliance for MU Stage I (Data Collection and Sharing), should take necessary steps to meet the HIPAA objectives and demonstrate and attest to compliance with the goals for MU Stage 2 (Advanced Clinical Processes). The 2014 version of HIPAA rules and regulations requires a covered entity to demonstrate compliance for a 90 day period.
Due to the large number of EP’s and hospitals that have adopted EHR’s, a new time table has been proposed by the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC), for determining eligibility for incentive funds for Stage 2 MU compliance. The schedule would require those who have already qualified and been certified for MU Stage I to demonstrate compliance with MU Stage 2 by the end of the reporting period for 2016.
Though not yet confirmed, it is expected that this new schedule for certification will be approved soon with an announcement to follow. However, it is important to note that the 2014 deadline for submitting confirmation and attestation documents are still in place. The new timetable was proposed to allow those without the required compliance data necessary to certify in 2014, to still be able to complete two years in MU Stage 2 and earn continued funding through certification in 2016.
Those seeking certification for any MU Stage must demonstrate compliance with the stage specific criteria for two years. This means those who have been certified for Stage 1 should begin working towards certification for Stage 2 and after completing two years that can be used to demonstrate compliance with Stage 2 objectives should start implementing changes to meet requirements for Stage 3. Covered entities who receive certification for MU Stage 2 are expected to demonstrate compliance with objectives for MU Stage 3 (Improved Clinical Outcomes) at the end of two years. Stage 3 will begin in 2017.
Despite the extended deadline, some eligible professionals have found it difficult to keep to such a rigorous schedule, fearing the loss if incentive funds due to lost time waiting for the review and certification process. The best approach to obtaining timely certification is to work towards implementing the next stage in the cycle once the application for the previous stage has been submitted. It is not necessary to wait for confirmation of certification for a completed stage unless you are concerned you have not fully met criteria and will need to make changes to current policies and procedures based on feedback from OMS. The key is to seek certification only when you know you can demonstrate compliance with MU criteria. Frequent risk assessments and internal audits will help improve the ability to determine whether an organization is ready to attest to MU compliance for a specific stage.
Whether or not you are looking to receive incentive funds it is important to keep up to date with all HIPAA Rules and Regulations. Now that the initial flurry of audits have been completed and covered entities have a clearer picture of what is required of them, ONC will be turning attention to regularly updating deadlines and requirements for HIPAA compliance. Although major changes in HIPAA rules and regulations are not expected at this point, changes that help clarify goals or stage specific criteria for MU compliance may be altered or expanded. It is crucial that all covered entities and eligible professionals keep abreast of all announcements from CMS and ONC to prevent loss of incentive funds or being fined for non-compliance due to failure to demonstrate compliance with updated HIPAA rules or MU criteria.