stage 1 measures and avoid having to meet
the hefty stage 2 measures. Noticeably
missing in the Federal Register discussion
is a clear indication what those practices
in their first year of meaningful use (stage
1) that have 2014-certified software must
do. These practices have a shorter period of
time to reach meaningful use in 2014 than
any other group — they must start their
reporting periods by July 1. At first blush it
appears these practices, which need relief
most, will not receive any.
The biggest problem created by the
announcement of the flexibility rule is the
timing of knowing whether it will be con-
firmed later in the year. As a result, practices
may not be able to properly direct their
resources. Regardless of which set of rules
are in play, weeks of planning, workflow
changes and other efforts are required to
achieve the meaningful use goal. With no
clear direction, many practices may spend
their time going down the wrong road.
The best way to keep out of trouble
is to stay the course, if at all possible, as
though the flexibility rule were never
announced. Another wise move might
be to apply for the recently announced
hardship exemption. This will mitigate
the danger of incurring the Medicare
reimbursement penalty for not meeting
meaningful use slated to begin in January
2015. This exemption would eliminate
the penalty if a practice can reasonably
make a case that it was unable to reach
meaningful use this year because of delays
in getting its 2014-certified software.
You are not locked into the hardship
exemption and can therefore still try
achieving meaningful use. The hardship
exemption applications must be submitted
by July 1, 2014, and can be found at the
CMS website.
John Netti is President of the EHR Advisory
Group, www.ehradvisorygroup.com (formerly
Netti Consulting Services), which provides
an array of EHR as well as HIPAA privacy
and security services. For more informa-
tion, go to www.ehradvisorygroup.com or
call 315-437-4377. ■
M D N E W S . CO M ■ MD NEWS Central New York
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