Guest post by Christina Caraballo, MBA, Get Real Health.
Hospitals and eligible professionals that have yet to meet their meaningful use requirements are facing a good news/bad news scenario. First the bad news: The clock is ticking, as major deadlines loom. The good news: It’s not too late to hop aboard the MU train, although some running might be required. If you’re among those seeking MU attestation this year, here are key points you need to know.
Before you take one more step, make sure your technology vendor is 2014 certified. Regardless of whether you are attesting to meaningful use Stage 1 or Stage 2, all eligible professionals (EPs) and eligible hospitals (EHs)/Critical Access Hospitals (CAHs) are now required to use an ONC 2014 Edition Certified technology to successfully attest to both MU1 and MU2.
You might have been under the impression that Stage 1 corresponds with the 2011 Edition and Stage 2 corresponds to the 2014 Edition. This is not the case, but your confusion is understandable.
What happened? When meaningful use was first introduced, the Centers for Medicare and Medicaid Services (CMS) published MU Stage 1 and the Office of the National Coordinator for Health Information Technology (ONC) published the 2011 Edition Certification; then MU Stage 2 and the 2014 Edition Certification Criteria were released within days of one another.
Here’s a quick break-down of the new timetable:
- Now through 2016: 2014 Edition Certified EHR Technology is required to successfully attest to Stage 1 and Stage 2 meaningful use. (ONC extended Stage 2 timelines through 2016 to give hospitals and EPs more time to successfully implement meaningful technology that promotes patient engagement, data exchange and interoperability.)
- Don’t worry about 2015: Hospitals and EPs will not be required to use 2015 Certified EHR Technology. The 2015 Edition certification is voluntary for EPs and EHs/CAHs. Its real purpose: give technology vendors more time to adapt to changes and become 2017 certified. Rather than forcing companies to comply in one big leap, regulators have made it a stepping-stone process. In turn, this should give EPs and EHs/CAHs confidence that vendors will get with the program, so to speak, in time for 2017.
- Starting in 2017: As it stands now, hospitals and EPs will be required to use the 2017 Edition for attesting to any MU stage. For providers that have completed at least two years of Stage 2, Stage 3 will begin in 2017—probably January 2017 for EPs and October 2016 for EHs/CAHs.
Any technology vendor that falls short not only puts its customers at risk of noncompliance, it also invites legal challenges. One example: a medical center in Montana sued its technology vendor in federal court after the company failed to provide the medical center with a certified EHR system.
Online Access for Patients
Patients really benefit from the new 2014 MU requirements. Now, EPs and EHs/CAHs must give patients timely access to their health information online. That requirement replaces the earlier MU1 objectives to provide electronic copies of health information or discharge instructions in a timely manner.
That means patients will have the ability to view, download and transmit their health information via human readable and machine readable Consolidated Clinical Document Architecture (C-CDA). The use of the C-CDA is important to patients, because it ensures that MU-compliant organizations and technologies can accept the data in their health record.
Patients are the “meaning” in meaningful use. That’s worth remembering as you race to catch the MU train. The regulatory changes aim to ultimately serve the larger purpose of ushering in a new era of connected healthcare, which helps patients and providers alike. Attesting to Meaningful Use is the best way for providers to say, “Great…we’re on board!”
Christina Caraballo, MBA, is a healthcare strategist at Get Real Health in Rockville, Maryland.