The Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs provide financial incentives for the “meaningful use” of certified EHR technology (CEHRT) to improve patient care. To receive an EHR incentive payment for meeting meaningful use, providers have to show that they are “meaningful users” of certified EHR technology by meeting thresholds for specified objectives. (The Medicaid EHR Incentive Program allows first-year participants to earn an incentive payment by demonstrating that they have adopted, implemented, or upgraded EHR technology; in subsequent years, the Medicaid program requires demonstration of meaningful use.) The Centers for Medicare & Medicaid Services (CMS) has established the objectives for “meaningful use” that eligible professionals (EPs), eligible hospitals, and critical access hospitals must meet every year to receive an incentive payment and avoid a downward adjustment to Medicare payments.^[1]

ONC published the 2014 Edition Standards & Certification Criteria final rule (2014 Edition final rule), which defines CEHRT for specific calendar and fiscal years. It also establishes the standards and certification criteria (2014 Edition) for the certification of EHR technology.^[2] The 2014 Edition supports the capabilities that EPs, eligible hospitals, and critical access hospitals need to attempt to meet not only Stage 1 but also Stage 2.

Certified EHR Technology (CEHRT)

The fiscal year and calendar year 2014 CEHRT definition is as follows:

EHR technology certified under the ONC Health Information Technology (HIT) Certification Program to the 2014 Edition EHR certification criteria that has:

(i) The capabilities required to meet the base EHR definition^[3]; and

(ii) All other capabilities that are necessary to meet the objectives and associated measures under 42 CFR 495.6 and successfully report the clinical quality measures selected by CMS in the form and manner specified by CMS (or the states, as applicable) for the stage of meaningful use that an EP, eligible hospital, or critical access hospital seeks to achieve. Resources may be found on the ONC website.

The capabilities to meet the base EHR definition include, but are not limited to:

1. Patient demographic data and clinical health information, such as medical history and problem list.
2. Has the capacity to provide clinical decision support.
3. Has the capacity to support physician order entry.
4. Has the capacity to capture and query information relevant to health care quality.
5. Has the capacity to exchange electronic health information with and integrate such information from other sources.
6. Has the capacity to protect the confidentiality, integrity, and availability of health information stored and exchanged.

A complete list of Certified Health IT products can be found on the ONC website, covering products certified for the 2011 and 2014 editions of certification, as well as for the combination 2011 to 2014 edition changes.

Technology and Meaningful Use

Stage 1 of meaningful use established a core and menu structure for objectives that all providers must achieve to demonstrate meaningful use. Under 2014 Stage 1 criteria, EPs have to meet 13 core objectives and 5 menu objectives that they selected from a total list of 9.^[4] Exclusions are included for several objectives such that providers may achieve meaningful use without meeting the objectives falling outside of their normal scope of clinical practice.

Stage 2 retains this core and menu structure for meaningful use objectives, and the majority of Stage 1 objectives are now core objectives under the Stage 2 criteria.^[4] New objectives were also introduced for Stage 2 and, like Stage 1, many of the Stage 2 objectives include exclusions to account for scenarios where an objective may not apply to an EP’s normal scope of clinical practice. To demonstrate meaningful use under Stage 2, EPs must meet 17 core objectives and 3 menu objectives that they select from a total list of 6, for a total of 20 objectives.^[4]

EPs must achieve meaningful use under Stage 1 before moving to Stage 2, whether they are new or established program participants.^[5] 2014 Edition EHR certification criteria support an EP’s attempt to achieve either meaningful use Stage 1 or Stage 2.^[2] EPs who were early demonstrators of meaningful use in 2011 were in Stage 1 for 3 consecutive years before advancing to Stage 2 in 2014.^[6]

Regardless of provider stage of meaningful use, CMS has established a 3-month quarter EHR reporting period for meaningful use in 2014 for any provider beyond their first year of demonstrating meaningful use. Those in their first year may use any consecutive 90-day reporting period to demonstrate meaningful use.^[6] On May 23, 2014, the US Department of Health and Human Services published a proposed rule from CMS and the ONC that would allow providers who were unable to fully implement the 2014 Edition CEHRT for a full reporting period in 2014 due to delays in 2014 Edition CEHRT availability to use the 2011 Edition CEHRT or a combination of 2011 and 2014 Edition CEHRT for the EHR reporting period in 2014 for the EHR Incentive Programs.^[7] Under this proposed rule, providers would still be required to use the 2014 Edition CEHRT beginning in 2015. ^[7]

Resources and Information

EPs in all phases of EHR implementation can request assistance from an ONC Regional Extension Center (REC) in their area. RECs focus on providing on-the-ground technical assistance for individual and small provider practices, providing support for:^[8]

• EHR implementation and project management
• Health IT education and training
• Vendor selection and financial consultation
• Practice/workflow redesign
• Privacy and security
• Partnering with state and national health information exchanges
• Ongoing technical assistance