CMS Releases Stage 2 Requirements For Use of Electronic Health Records
|October 19, 2012|
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The Centers for Medicare and Medicaid Services (CMS) has released its final rule on the Stage 2 requirements for the electronic health record (EHR) incentive program.
Under the EHR program, providers can qualify for Medicare and Medicaid incentive payments under the Health Information Technology for Economic and Clinical Health (HITECH) Act if they meaningfully use certified EHR technology, as outlined in the Stage 1 and Stage 2 final rules.
The final rule for Stage 1 was released in July 2010. It established the basic EHR functionalities and set out a group of mandatory "core" requirements and optional "menu" requirements.
The 672-page Stage 2 final rule, released in August, deals with five general topics: timeline, clinical quality measures, meaningful use objectives, payment adjustments, and modifications to Medicaid patient encounters.
Most notably, Stage 2 delays the compliance date with the final rule to 2014 at the earliest. CMS had previously established in the Stage 1 regulations that providers demonstrating meaningful use in 2011 must satisfy Stage 2 criteria in 2013. However, the final rule delays that timeline by one year.
The Stage 2 final rule also sets the rate of payment adjustment for those providers that are not meaningful users of EHR. CMS will apply the adjustment differently to each provider type, but all will receive some form of penalty for not satisfying meaningful use criteria.
The text of the final rule can be read at:
The views expressed in this document are solely the views of the author and not Martindale-Hubbell. This document is intended for informational purposes only and is not legal advice or a substitute for consultation with a licensed legal professional in a particular case or circumstance.
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