On September 4, 2012, the Department of Health and Human Services, Centers for Medicare and Medicaid Services (“CMS”), published final regulations for Stage 2 criteria for the Medicare and Medicaid Electronic Health Record Incentive Program (the “EHR Incentive Program”). Under the EHR Incentive Program, eligible professionals (EPs), eligible hospitals, and critical access hospitals (“CAHs”) (referred to collectively in this Alert as “providers”) that adopt and meaningfully use certified electronic health record technology (“CEHRT”) are eligible for incentive payments. CMS is implementing the program in stages.
Stage 1, in which some providers began participating as early as 2011, established 15 required core objectives for EPs and 14 core objectives for eligible hospitals and CAHs. In addition, Stage 1 required providers to meet five additional objectives from a list of 10 menu set objectives. Collectively, the objectives were designed to establish certain basic functionalities for EHR usage, including recording certain information electronically, providing patients with electronic copies of their information, and reporting on specified quality measures.
Stage 2 builds upon Stage 1 by increasing the requirements for providers to exchange information electronically. Stage 2 also encourages patients to access their health information online and to generally become more involved in their own care and health. For the most part CMS adopted the Stage 2 proposed rule as final. However, and as explained in more detail below, CMS modified the timeframe for certifying Stage 2 meaningful use because providers expressed concern that the proposed implementation schedule was too aggressive.
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