6 Things you need to know about Meaningful Use and EHR Certification in 2014

With the 2014 EHR reporting period for meaningful use right around the corner, here are 6 key pieces of information you need to know:

#1. Does meaningful use (MU) Stage 1 change in 2014?

Yes, the 2014 reporting period marks the beginning of a restructured meaningful use Stage 1.

Certain “core” and “menu” objectives have been removed/combined and eligible professionals (EPs), eligible hospitals (EHs), and critical access hospitals (CAHs) can no longer count measure exclusions toward meeting menu objectives. Equally important is that all Stage 1 EPs, EHs, and CAHs now need to provide more than 50% of unique patients with the ability to access their health information online (to meet the new Stage 1 core measure as part of the “View, Download, Transmit to 3rd Party” objective).

Graph 1


#2. Do all EPs, EHs, and CAHs need to upgrade to 2014 Edition certified EHR technology in 2014?

Yes, starting with the 2014 meaningful use reporting period all EPs, EHs, and CAHs need to upgrade to 2014 Edition EHR technology only – regardless of the meaningful use stage they need to meet.

The 2014 Edition EHR certification criteria support both revised MU Stage 1 and new Stage 2 requirements. They also include important updates that set new baselines for better interoperability, electronic health information exchange, and patient engagement. EHR technology certified to the 2011 Edition will no longer be acceptable for the purposes of meeting the “Certified EHR Technology” definition and from a regulatory perspective 2011 Edition certifications will “expire” come the 2014 MU reporting period.


#3. What is the meaningful use reporting period length in 2014?

2014 has a special MU reporting period length for all non-first time EPs, EHs, and CAHs.

As a result, no EP, EH, or CAH (that previously demonstrated MU before 2014) has to start MU at the beginning of the Federal Fiscal Year (FY) [October 1, 2013] or Calendar Year (CY) [January 1, 2014].

The 2014 MU reporting period for both Stage 1 and Stage 2 performance is set to one calendar quarter during a Medicare EP, EH, and CAH’s reporting year (e.g., April 1, 2014 through June 30, 2014 would be a Medicare EP’s 2nd quarter and an EH/CAH’s 3rd quarter). All Medicaid EPs, EHs, and CAHs (as determined by their state) will have an “any continuous 90-day” or 3-month reporting period during 2014. Last, all new EPs, EHs, and CAHs continue to have an “any continuous 90-day” reporting period.


#4. What happens if a Medicare EP, EH, or CAH skips meaningful use in 2014 or applies for a hardship exception in 2014 (to avoid the 2016 payment adjustment)?

Once a Medicare EP, EH, or CAH starts meaningful use, it is required to continue to meet higher meaningful use stages according to the regulatory schedule set by the Centers for Medicare & Medicaid Services.

This policy applies even if the Medicare EP, EH, or CAH is granted a “hardship exception” for a given reporting year, it skips, or it fails. For example, regardless of whether an EP “passes,” “hardships,” “skips,” or “fails” their “Stage 1, Year 2” performance during 2014 they will be required to move up to “Stage 2, Year 1” in 2015 (with a full year reporting period) and will not get to repeat Stage 1 for a third year.

Medicaid EHR Incentive Program policy is different in two respects. First, the Medicaid program does not have payment adjustments, so hardship exceptions are unnecessary. Second, Medicaid providers are not required to participate in consecutive years of the Medicaid EHR Incentive Program (see Medicaid FAQ). Thus, unlike Medicare providers, Medicaid providers who skip years of participation will resume their meaningful use progression where they left off.  For example, if a Medicaid EP skips 2014 (which would otherwise be their “Stage 1, Year 2”) and also skips 2015 but comes back to the Medicaid program in 2016, they would be required to demonstrate “Stage 1, Year 2” in 2016 as if they never left the Medicaid program for those two years.


#5. When is the last year Medicare EPs can start meaningful use to get incentive payments?

2014 is the last year in which an EP can begin to get incentive payments.

As stated in the Health Information Technology for Economic and Clinical Health (HITECH) Act, no incentives can be paid to Medicare EPs that begin MU after 2014.  EPs that start MU in 2014 could still earn as much as $24,000 in incentives if they demonstrate MU from 2014 through 2016.


#6. How does 2014 meaningful use performance relate to Medicare payment adjustments?

2014 meaningful use performance is the basis for 2016 Medicare payment adjustments.

For EPs this potentially means a -2% reduction to the Medicare physician fee schedule (PFS) amount for covered professional services furnished by the EP during 2016 (EP tip sheet). The payment adjustment calculation for EHs and CAHs is a little more complicated and different for each. Here’s a link to CMS’ EH/CAH tip sheet.



  1. Jeff Newlin says:

    Interesting information. I work for an company with an 2011 certification and we are feverishly working on completing the stage 2 requirements. I doubt we will be ready by Jan 1 2014. It sounds like if we achieve our certification by April 1 2014 that our current users can then start their 3 month reporting period for Stage 2 using our then-certified product?

    Thank you

    • Steven Posnack says:

      As the blog post notes, 2014 has a special reporting period. Assuming you are thinking about eligible professionals (EPs) (given your mention of January 1, 2014), yes, it would be possible for you to achieve certification for your product in early 2014 and then provide it to customers in time for them to demonstrate a 3-month/1 calendar quarter reporting period.

  2. Karen Perry says:

    I am planning to attest to the 2nd year of Stage 1 meaningful use during 2014. My EHR is not yet certified for 2014, but is hoping to achieve certification in early 2014. The 2011 Certification expired as of 12/31/13. I understand that until they have their 2014 Edition certification, I will no longer have a product that will allow me to attest to not only Stage 2, but for Stage 1 as well. Can you tell me what will be my reporting period? Will I have to report for the entire calendar year or one quarter period? Will I still be able to report for 2014? Thank you.

    • Sarah Barwick says:

      As long as your EHR is certified 2014 by October 1st of 2014 you will have at least 1 quarter to attest to. Your reporting period will be a calendar quarter, which one will depend upon when your EHR is certified.

    • Jessica Buffkin says:

      If your vendor isn’t 2014 certified yet, it is my understanding that you can take advantage of the flexibility rule.

      • Duckett says:

        As it relates to Transitions of Care, I understand the flex rule can be used if your trading partners are not on a 2014 CEHR. However, I am curious to know how others are responding to situations where the trading partners have 2014 CEHRT, but have not turned on direct messaging functionality.

  3. Mike Ostler says:

    Do system certifications for the 2014 Edition have a planned expiration date?
    If not, will an expiration date be announced when stage 3 is firmed up?

  4. Ken Kirchner says:

    Thank you for this article – it provides the best answers to my questions that I have seen thus far. I just listened to a CMS webinar that stated that we could still attest to Stage 1 EP in 2014 since we did our 1st attestation in 2013, but neglected to mention that there are different 2014 requirements. Alas, our vendor will not be Stage 1 2014 certified for the EP system so per your information, we will not be able to attest. If you respond to questions, can you tell me if the physicians could get a hardship exemption since the system they use will only have the hospital side 2014 certified?

    • Brett Coughlin says:

      Here is a recent listserve message we sent out that may be of some help.

      Eligible Professionals: Hardship Exception Applications due July 1, 2014
      Are you a Medicare provider who was unable to successfully demonstrate meaningful use for 2013 due to circumstances beyond your control? CMS is accepting applications for hardship exceptions to avoid the upcoming Medicare payment adjustment for the 2013 reporting year.

      Payment adjustments for the Medicare EHR Incentive Program will begin on January 1, 2015 for eligible professionals.

      However, you can avoid the adjustment by completing a hardship exception application and providing supporting documentation that proves demonstrating meaningful use would be a significant hardship for you. CMS will review applications to determine whether or not you are granted a hardship exception.

      CMS has posted hardship exception applications on the EHR website for:
      • Eligible professionals
      • Eligible professionals submitting multiple National Provider Identifiers (NPIs)
      Applications for the 2015 payment adjustments are due July 1, 2014 for eligible professionals. If approved, the exception is valid for one year.
      New Hardship Exception Tipsheets
      You can also avoid payment adjustments by successfully demonstrating meaningful use prior to the payment adjustment. Tipsheets are available on the CMS website that outline when eligible professionals must demonstrate meaningful use in order to avoid the payment adjustments.
      Want more information about the EHR Incentive Programs?
      Make sure to visit the Medicare and Medicaid EHR Incentive Programs website for the latest news and updates on the EHR Incentive Programs.

  5. Sheryl says:

    OMG…………I do not know how anyone can possibly keep up with this ridiculous government of ours! We attested to our first 90d MU Stage 1 in 2012…….and got paid! We did not attest last year to our first full year of MU1 as we got caught up in the Medical Assistant loop hole! This year I am fully ready to attest to my 90d MU 1…….even have SOME Stage 2 in place……..GOOD thing! Now, I find out that there is no skipping years! Ha…….My EHR is certified for MU2 THANK GOODNESS……..now just have to figure out how to get 9,000 patients signed up with a non-functioning patient portal by the end of August…………….can anyone say WALMART………………UGH!

    • BHOLT says:

      I would imagine this is give the capability for 50% patients to access. The Government cannot force patients to participate and penalize Providers for not forcing the Patients to go to a Portal. The wording is provide the capability to, Would love some other points on this matter.

      • Sarah Barwick says:

        Actually measure 15 does require that 5% of unique patients access their portal record, and measure 17 requires the same percentage of unique patients to message through the portal. The CMS wording is very clear on this. It is up to the physician to encourage patients to use portal.

    • Geneva Foster says:


      Indeed, this program is confusing. I think you have figured out most of what you need to from this point… As of January 1, 2014 you need to be on 2014 Certified EHR Technology, check. EHR reporting periods in 2014 are one of the 4 quarters of the Calendar year, check. Now all you need to do is verify that you are achieving the 2014 modified Stage 1 Objectives. I advise all not to forget the new 2014 Clinical Quality Measures that must be transmitted electronically, separate from attestation. And for large medical group practices, learn about “Batch Attestations” and assure the documentation (xml or csv files) are structured to map with the Attestation portal.

      Geneva A. Foster, M.Ed., CHTS-TR | Meaningful Use Specialist
      Summa Physicians Inc. | Akron, Ohio 44310

  6. Kristen Townley says:

    I want to begin my 2014 Stage one meaningful use in July but my organization does not think the patient portal will be ready by then. Can I use Oct-Dec 2014 as my 90 days and still me criteria?

  7. Geneva Foster says:

    Earlier this week I learned from an Information Agent with the EHR information Center, that a Meaningful User failing to achieve Meaningful Use during a particular program year incurs the Medicare Payment Adjustment for that program year in perpetuity if she or he goes on to demonstrate Meaningful Use in subsequent years. In other words, miss attesting to Meaningful Use in any one year and you incur that Medicare Payment Adjustment two year hence and every year for the rest of your career. So, if one attested to Meaningful Use in 2011 and/or 2012 but missed attesting in 2013, one will incur -1% Medicare Payment Adjustment in 2015. And even if that Provider resumes Meaningful Use Attestation in 2014 and beyond, she or he will continue to incur the -1% Medicare Payment Adjustment in 2016 and every year after. I was told that the silver lining is that the -1% Medicare Payment Adjustment is locked in, so long as the Provider doesn’t miss attesting to Meaningful Use in another.

    I consider myself well read on the EHR Incentive Program Final Rules and I have never read or interpreted the Final Rules on Payment Adjustments in this way. Also, I have not heard from anyone in the Provider community who understands that, that is how Medicare Payment Adjustment will be applied. In the days since I received this information (for grins and giggles) I reviewed the EHR Incentive Program Final Rules and have yet to find any language that explicitly or implicitly indicates that a Meaningful User failing to achieve Meaningful Use during a particular program year, incurs the Medicare Payment Adjustment for that program year in perpetuity, if the EP goes on to achieve and maintains Meaningful Use in subsequent years.

    So I’m reaching out to anyone and everyone I can think of at the CMS to clarify the matter. I believe this is a good blog to reply to for a definitive answer. If it’s true, I wonder why there is no “buzz” about it. If it is not true, the EHR Information Center Agents need immediate in-service training and the CMS needs to reach out to all members of the Provider community who received this information and are now panicked to provide CPR. Because, in my opinion, at best this is a PR nightmare in the making and at worst an unethical revenue cycle practice, which will have Providers who support the ACA, in opposition to the Federal Government.


    Geneva A. Foster, M.Ed., CHTS-TR | Meaningful Use Specialist
    Summa Phsicians Inc. | Akron, Ohio 44310

    • Brett Coughlin says:

      The information you received is erroneous. CMS explains that there is a 1% cut associated with Medicare reimbursement in 2015 if you miss Meaningful Use in 2013. If you meet Meaningful Use in 2014 they avoid the 2016 offset and so on.

      • Geneva Foster says:

        Brett, Thank you. That’s what I told the Information Agent. But he said he confirmed the information with his supervisor after she reviewed the Program Final Rules. I subitted a request, through the FAQ section of the EHR Incentive Program website, to verify which interpretation of the Final Rules was correct. I my interpretation was the the correct one, I also requested in-service training with the Information Agent and his supervisor (I included the reference number of my call). I received verification that my interpretation was correct. But no indication that EHR Information Center Agents would receive appropriate training on this matter.

  8. Catherine says:

    Does anyone know if a practice applies for a hardship exception based on unforeseen and/or uncontrollable circumstances (2014 EHR Vendor Certification Issues and Delays) and later the vendor releases a certified version (mid third quarter) could the practice still attest for Meaningful Use in Q4? Since the hardship form is due July 1 I would like to complete the form as a back-up in case our vendor does not release a certified version. However, if we are granted a hardship exception can we still attest?

  9. Meaningfuluse12 says:

    Can someone explain this for me? I was under the impression that EP’s will need to meet 2 years of attestation in Stage 1, but I read this and it is quite confusing.

    If an EP attests to Meaningful Use for the first time under Stage 1 criteria in 2012, but does not attest in 2013, if they attest in 2014, they will need to meet the Stage 2 criteria.

  10. Carrie says:

    If a provider is in Stage 1, Year 1 and does not meet the October 1st deadline to avoid the 2015 penalty, but they are still able to complete Stage 1 attestation by the end of 2014. Will they still qualify for the incentive?

    I have tried to find this documentation in writing and have been unable.

    • Brett Coughlin says:

      Our friends at CMS say: “Yes. A provider can still get the incentive payment if they meet MU even if it is past the early attestation deadline. The provider can also apply for the hardship exception (if they qualify) and then still go on and meet MU later in the year and still get the incentive payment.”

      • Geneva Foster says:

        Carrie, Brett – The October 1, 2014 Attestation Deadline is specific to Eligible Professionals participating in the EHR Incentive Program for the first time in 2014 (i.e. 2014 Stage 1, Year 1 Meaningful Users). It’s not an early attestation deadline. It’s an extension, as 2013 is the reference year for Medicare Payment Adjustments. For Meaningful Users beyond the first year of program participation, the February 28, 2015 attestation deadline for 2014 EHR reporting periods stand. All Eligible Professionals who attest by their deadline for their respective EHR reporting periods will receive the incentive payment (less 2% for sequestration) for the Program Year they are in. In theory, those who first attested in 2011 are in Program Year 4, those who first attested in 2012 are in Program Year 3 and those who first attested in 2013 are in Program year 2. FYI, Those who become Meaningful Users for the first time in 2015, will receive no incentive payments whatsoever. But they will avoid Medicare Payment Adjustments in 2017.

      • Paula says:

        Hi Brett,
        Thanks for this answer. Assuming this is still true, could you please post the source or link for this information? I was planning to apply for hardships for all of my providers (105) as a safety measure but still want to attest for all that I believe can demostrate MU for 2015. I need to confirm this is an acceptable practice and be able to back that confirmation up if audited down the road.


  11. Vicki says:

    We successfully attested for Stage 1 MU in CY 2013 for reporting period 10.1.2012 – 12.31.2012. However, we missed the March 31, 2014 deadline to attest for the full year of Stage 1 2013. Can I still attest for 2013 Stage 1? Will we still receive the full incentive and avoid a payment adjustment?

    We also qualify for the Hardship exception (we are all Diagnostic Radiology), but if I take that and stop attesting for the next 5 years, will we essentially be giving up the incentive payments and still need to become meaningful users (having to meet all 3 stages) after the 5 year hardship exception period is up?

    I have been trying to figure out how we can meet the Stage 2 requirements, but it is very difficult for Radiology, especially since so many of the objectives are based on the definition of an “Office Visit” – does any one have any suggestions on what objectives Radiology can be excluded from while still successfully attesting to Stage 2?

    Thanks in advance!

  12. Kay Weaver says:

    I am waiting for the final rule on the Stage 2 delay. CMS has sent out a press release concerning this and there is an interactive tool for providers to use to determine whether they will be able to attest to Stage 1 or Stage 2 Meaningful Use in 2014 dependent upon whether they have upgraded to 2014 Edition certified software. What if a provider delays upgrading to 2014 Edition in anticipation of the delay being finalized but the vendor has the upgrade available. Will the provider be able to attest using 2011 software and attest to Stage 1 criteria instead of his scheduled Stage 2?

  13. Nancy Girard, D.O. says:

    If an EP has already attested for Stage 1 year 1 and 2, can they do a year 3 stage 1 with a 2014 certified EMR? It will be impossible for me to meet the granular lab and radiology benchmarks. I am very rural.

  14. Joy says:

    If you completed stage 1, year 1 in 2011 and got paid but skipped 2012 & 2013. Then try to attest in 2014, what stage/year would I be attesting in? I tried attesting and keep getting the stage 2 criteria. It says on the CMS website that they will be doing maintenance Oct 4 to Oct 6 to allow more flexibility for providers. Do I need to wait till after the update to see if I can select stage 1 objectives since this will technically be stage 1 year 2 for me?

  15. Chrissy Parente says:

    I cannot understand the fact that MU requires that 50% of patients must use the Web portal..we have a predominantly elderly patient base and they DO NOT use a computer. What are supposed to do aside from personally give each and every one their own email address to comply? Anyone? We are stumped..and that is the one and only reason we didn’t meet the criteria for attestation.

  16. Molly says:

    I am just wanting to clarify a couple of points.
    1) I am scheduled to attest to Stage 2 this year. I will be unable to meet the measures that relate to the patient portal and transitions of care via secure messaging. My EMR vendor informed me that we would qualify to attest to Stage 1 again. However, I have heard through the rumor mill that reattesting to Stage 1 would flag us for an audit. Do you have any information/verification of that.
    2) If I opt out of meaningful use altogether, do the reimbursement penalties continue forever, or just for three years? Many of the independent clinics in my county are giving up completely. They are going to continue to use their EMRs but are not planning on attempting attestation again.

    Thank you for your help.

  17. Mauricio Figueroa, MD says:

    I want to know how the HITECH act is even constitutional. I’ve heard that a commerce clause loophole is being used but seriously – the patient portal is just a blatant violation of our rights. I’ve polled my patients and none of them want to communicate with me that way (I have an elderly population that enjoys being able to interact with human beings). Now, if I pay out of my pocket to get this setup and then I do not FORCE my patients to use it, I get penalized as if I never bought the thing anyway, right? So the government FORCES on me a bad idea and then, when I prove it was a bad idea, I am the one penalized. Is that how it works? Please explain to me how this is still the land of the “free.”

  18. Karen Powell says:

    Can an EP still attest for Meaningful Use Stage 1 for the first time in 2015 to avoid the 1% per year reduction in Medicare reimbursements? I realize there is no more incentive reimbursements beyond 2014.

    • Hoan Valdez says:

      Are you able to attest for MU1 for 2015 if this is your first time attesting for MU, despite of my approval of EHR hadship for 2014? I appreciate your guidance.

  19. Uma says:

    We plan to register by February 2015 for Medicaid MU1. If the EHR verion we currently use has 2014 modular certification for MU2, does that imply that the version has 2014 complete certification for MU1? Is there a separate certification number for MU1 and MU2?

  20. J W says:

    I’m curious, does this only apply to medicare/medicaid patients? Or do you have to report to CMS non Medicare/Medicaid patients?

  21. lameta says:

    we had a delay in getting our EMR certified, had an upgrade in june 2014 that didn’t go so well, just got my MU dashboard turned back on in December 2014, report all my immunizations to the state online but not on the registry yet, now being told I can’t attest for this reason – so frustrated! any advice out there?

  22. julia says:

    The deadline to begin participation in the Medicare EHR incentive program has passed. With that in mind, can an EP register for the CMS EHR incentive program simply to avoid the future reductions in the physician fee schedule by demonstrating MU via attestation, knowing they would not be eligible for any incentive payments?

    • Brett Coughlin says:

      Julia, our friends at CMS were able to respond to your question. Here it is!

      “Yes, you can absolutely still register and attest to demonstrate meaningful use to avoid the Medicare payment adjustment. If you did have a certified EHR in place for 2014 and can meet the measures and thresholds for a 90 day period any time in 2014 you could also still come in and attest for 2014 and earn an incentive payment for the year as well. But even if you were not able to do a reporting period in 2014, you can attest for your first year in 2015 to start your participation and if you continue to participate each year you will no longer be subject to a payment adjustment beginning in 2016.”

  23. G. Zullo says:

    As an EP:
    in 2013 I attested but failed stage 1 MU for 2012 reporting.
    In 2014 I subsequently passed stage 1 MU for 2013 reporting.

    With this in mind –>
    for 2014 reporting am I now in stage 2 of MU
    year 2 of stage 1 of MU because of the initial “fail” ?

    In other words, did I already complete my 2 years of stage 1 even if the first attempt was a fail?
    I do not wish to attempt a 3rd year of stage 1.

    thank you.

  24. Andrew says:

    We started with the Medicare Meaningful Use in 2011 and this is our final year for the program in which the payment will have been paid. What I am unable to find is information that tells us that we are all done once this year is finalized. Does Medicare require us to attest every year after the final payment has been received? What would happen if we did not attest for future years once we met the initial requirements? I am reading that they are researching a Stage 3. Also is it too late for a Provider to start the Medicare Meaningful Use program in 2015? I am aware that there is no money, but would attesting this year help them avoid the penalty? Thank you in advance.

  25. Valere Beeck says:

    I started attesting in 2012 for 2011 Stage 1. I did the same of 2012 and 2013. In 2014 I attested for 2013 when my EHR had not met Stage 2 requirements, but was told that was ok to do. I was paid for my 2013 data. Now, I understand that many offices are being contacted for repayment of their 2013 payments do to the lack of stage 2 approval. Yet I answered all questions and was approved. On what basis is CMS doing this?

  26. J Spencer says:

    Do not have an EHR and thus have done nothing with this. Where does that leave us? So far, the penalty is against Medicare payments. We see few Medicare patients anyway so we haven’t been concerned. We have not wanted to be forced into purchasing something just to comply. Are we wrong?

  27. Judy says:

    I am confused totally with all of this. We attested in 2012 for the 1st time 90 days. In 2013 unable to attest due to CMS error. They worked on error all year. Dec 2014 called me and said error fixed try to attest– tried to attest and it was expired. at this point no attest for 2013 and 2014. sent in for hardship and received letter today approved only for 2016 payment adjustment year. I’m thinking this is for 2014? Should we be already receiving adjustments by now since we didn’t meet 2013? This is August 2015 and we have not had any adjustments yet. We are working hard to get 2015 attest in this year so we have no adjustments. Any help understanding would be great….

  28. David Dues says:

    My question mimics Andrew’s. We also started in 2011, and have received all payments..
    are we required to attest. If we don’t what is the penalty?
    We also have a provider who began the program in 2014. Would they attest to Stage 1 2nd year.. for full year? What are the dates for the attestation period?

    Thank you

  29. Sharon Palotas says:

    Is meaningful use submitted every year? Even after the first 3 years? WE submitted 2014, 2013 and 2012- are we done or do we still have to attest? I know we have to do pqrs every year, but thought we were done with MU

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