CMS Issues Final Rule for 2014 EHR Incentive Program Participation

CMS just released a final rule regarding provider EHR incentive program participation for the 2014 program year.

It has been a long haul for those trying to implement and use an EHR program to complete the government’s incentive program.  Especially this year, as the transition from stage 1 to stage 2 meaningful use is supposed to be occurring.  Nothing is ever easy. Even for those providers who started their EHR journeys a couple of years ago, there was change that needed to occur.  Most had hoped that the EHRs they’d invested in would progress and roll with the government changes.  Many found out that this was not going to happen without additional work, frustration, pain, and money from them, so many have dropped out. 



One of the problems with the changeover from stage 1 to stage 2 was having a properly “certified” EHR program.  As a developer, programmer, and support provider for our own 2014 (stage 2) certified EHR we can tell you that it is not an easy or cheap thing to develop and acquire.  Many EHRs that had achieved stage 1 (2011 certification) meaningful use, simply couldn’t afford, the within the short period of time given, to re-create or update their software and go through the certification testing process again.  Unfortunately it left many providers hanging out in the clouds trying to figure out what to do and how to scramble to get into another EHR that was 2014 certified and start over again.

Then there are the late adopters who really didn’t care about the meaningful use dollars from the ARRA “stimulus” program, but are now feeling the sting of possibly losing money next year and each additional year, for a while for NOT meaningfully using a certified EHR.  This has caused additional problems as these providers started to sort through what was left of the EHRs and see how CMS and the government was going to handle the problems of moving from stage 1 to stage 2 this year.

So, after listening to all of the comments and weighing the options here is the new FINAL Rule regarding the 2014 program year (all 90 pages of it).


Here is the shorter, cut to the bones information on it.


It also includes how things are going to proceed for 2015 and a bit about how they are going to use what they’ve learned from this latest upgrade fiasco.  When they publish the proposed 2015 edition of certification criteria, they are proposing to leave the 2014 certified EHR editions as a baseline, from which things can be upgraded, added to over time, and modified. 

“We expect to propose that the 2015 Edition would be voluntary in the sense that providers participating in the EHR Incentive Programs would NOT have to upgrade to 2015 Edition EHR technology and NO EHR technology developer who has certified its EHR technology to the 2014 Edition would need to recertify its products. Our intention would be for the 2014 Edition to remain the baseline certification criteria edition for meeting the Certified EHR Technology definition.”

On the upside – CMS does have a VERY comprehensive page to help you determine what you need to be doing and what you need to know to get it done. (I believe it contains all the links I am listing, plus MUCH more.)


However, last but not least, the two most helpful tools for you, the provider, are these:
CEHRT Rule Tool (to help guide you through the rules options)

And, the HITECH 2014 CEHRT Flexibility chart