Do you find that you are forced to use the last calendar quarter of 2014 as your meaningful use reporting period due to installation delays? Are you finding that the certified EHR technology you need to support you in meeting the Stage 2 objectives is just not available or has not been implemented yet? Are you experiencing training nightmares as a result of these delays? If you answered yes to one or more of the questions above, you may experience significant relief from the Flexibility Rule published by CMS on 9/4/2014. Here are some key points:
1. Providers may use any calendar quarter in 2014 to capture data for attestation, they are not limited to the last quarter of the year.
2. There is a special provision for providers that are unable to meet the Summary of Care, measure 2, due to the inability to identify recipients of an electronic transmission. In other words, if none of your referral providers have direct addresses for you to send your referral documentation (Summary of Care consolidated-CDA), this would apply to you.
3. Providers may be able to attest to the 2014 Stage 1 objectives and measures and in some special circumstances the 2013 Stage 1 measures thanks to the flexibility rule.
4. Providers will have to prove that they were not able to fully implement the 2014 edition of CEHRT. This could be due to availability and timing of software installation (clinical decision support, direct messaging, and clinical quality measure availability, for example) and ties into the ability to implement any new workflows and/or processes necessary to meet the objectives. This is a bit of subjective area so documentation is key in justifying your choice.
Once you make the decision as to whether or not you are eligible for a flexibility option in 2014, the CMS (Table 2) below, does a good job of giving you available options.
