As I’ve written in previous posts, MU 2 is truly a work of art and the stakeholder response to it has been very positive. There are a few persistent questions about the MU program that are worth sharing with the community.
1. What is the timing of each stage for early adopters – those who wish to attest as early as possible?
2012 – use stage 1 criteria
Eligible Professional (EP) reporting period is January 1, 2012-December 31, 2012 with attestation in Jan/Feb 2013
Hospital reporting period is October 1,2011-Sept 30, 2012 with attestation in Oct/Nov 2012
2013 – use stage 1 criteria with optional refinements
EP reporting period is January 1, 2013-December 31, 2013 with attestation in Jan/Feb 2014
Hospital reporting period is October 1,2012-Sept 30, 2013 with attestation in Oct/Nov 2013
2014 – use stage 2 criteria (NOTE the 90 day reporting period to enable adoption of new MU Stage 2 certified products)
EP reporting period is January 1, 2014-March 31, 2014 with attestation in April/May 2014
Hospital reporting period is October 1, 2013-December 31, 2013 with attestation in Jan/Feb 2014
I’m guessing that stage 3 will return to the year long reporting period pattern.
2015 – use stage 3 criteria
EP reporting period is January 1, 2015-December 31, 2015 with attestation in Jan/Feb 2016
Hospital reporting period October 1,2014-Sept 30, 2015 with attestation in Oct/Nov 2015
I’ve also been asked by pathologists, anesthesiologists and especially radiologists about penalties for non-attestation. These hospital-based specialists may file for the hardship exemption. See the MU Stage 2 final rule page 446 for more detail.
Finally, the stage 2 tip sheets provide valuable educational material for EPs and hospitals. In the past, I’ve created educational materials on my blog, but these are so good, you can use materials directly from CMS!