On May 20, 2014, CMS released a Notice of Proposed Rulemaking (NPRM) which would grant flexibility to Eligible Hospitals (EH) and Eligible Providers (EP) unable to fully implement 2014 Edition CEHRT for the full 2014 EHR reporting period. At first glance, this NPRM might have appeared to offer quick and easy relief, yet significant questions remain. Below are four key unanswered questions.
- What is meant by “not able to fully implement 2014 Edition CEHRT for a full EHR reporting period?”
Since the NPRM only applies to an EH or EP who falls into this category, we suddenly need greater clarity around the definition and the documentation required to support this categorization if audited. For example, would the NPRM apply to an EH or EP who is able to “implement,” yet a receiving provider/care setting they rely on for meeting the Summary of Care measure is not?