CMS Proposed Rule: Meaningful Use Stage 2 Extension

On Tuesday May 20th CMS released a proposed rule to help providers make use of Certified EHR Technology (CEHRT) through increased flexibility in the attestation parameters in 2014 and extending Stage 2 through 2016. Upon cursory review of the press release: CMS rule to help providers make use of Certified EHR Technology organizations and providers may think this is the relief they have been looking for from the pressure to install a 2014 version of their CEHRT before the MU reporting periods run out.

WAIT! It is extremely important to take pause, read the actual proposed rule and consider the following questions:

1. Does this apply to you?

• Have you already converted to a 2014 CEHRT? If YES, this may not apply.
• Do you fit into the suggested 3 ways to take advantage of the proposed rule? If NO, this may not apply.
• Do you have users attesting to both Stage 1 and Stage 2? If YES, this may not apply due to your CEHRT.

2. What can you do to take advantage of this change?

• Delay your upgrade? Check with your vendor!
• Adjust your upgrade timeline? Check with your vendor!

3. Can you wait 60 days to decide?

• The rule comment period is 60 days, this may drastically impact your process, limiting your ability to take advantage of the new rule.

This potential change does extend the reporting time for Stage 2, which will greatly help vendors prepare for the requirements of Stage 3; it is not wise to think that you are ‘in the clear’ for MU attestation and reporting because of this rule. Carefully review the proposed rule, consider all options and get the correct information before making any course changes!