Are you struggling with figuring out how you are going to meet some of the more challenging measures in Stage 2? Are you finding that the technology you need to support you in meeting the objectives is just not available or has not been implemented yet? Do you find that you are having to wait until the last calendar quarter of 2014 in order to achieve implementation of the necessary functionality to attest to the 2014 Stage 2 measures?
If you answered yes to one or more of the questions above, you may experience significant relief from this final rule. There were a couple of key points I noted as I read through the final rule which is due to be published on 9/4/2014.
- Providers may use any calendar quarter in 2014 to capture data for attestation, they are not limited to the last quarter of the year. (page 36)
- 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, clinical quality measure data) and ties into the ability to implement any new processes in order to meet the objectives. This is a bit of subjective area so documentation will need to be available to justify. I am happy to go into more detailed discussions in the Q/A session on Sept 5th (see the Education page). There are simply too many scenarios to discuss here.
- 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. That too requires distinct documentation.
Once you make the decision as to whether or not you are eligible for a flexibility option in 2014, the CMS table (Table 2) in the above link, does a good job of giving you available options. The CQM options get a little tricky if you are using the 2011/2014 combination since you are allowed to use an alternate reporting period for the CQMs.