The American Recovery and Reinvestment Act of 2009, also referred to as the stimulus package, included provisions referred to as the Health Information Technology for Economic and Clinical Health Act. Among these provisions were funds for an incentive program for physicians who “meaningfully use” electronic health records (EHRs) beginning in 2011.

The Centers for Medicare and Medicaid Services (CMS) has determined that the federal EHR Incentive Program will be implemented in stages.

Current timeline for EHR Incentive Program Implementation:

  • January 2011: Federal EHR Incentive Program begins
  • September 2013: Stage 2 of the Federal EHR Incentive Program begins for eligible hospitals who began participating in fiscal year (FY) 2011 or FY2012.
  • January 2014: Stage 2 of Federal EHR Incentive Program begins for eligible professionals who began participating in either calendar year (CY) 2011 or CY2012.
  • April 2014: Last opportunity for eligible hospitals to begin participation and avoid 2015 payment penalties.
  • July 2014: Last opportunity for eligible professionals to begin participation and avoid 2015 payment penalties
  • September 2014: CMS and the Office of the National Coordinator for Health IT (ONC) announce delay of Stage 2 implementation for eligible professionals or eligible hospitals unable to fully implement EHRs upgraded to 2014 Edition of EHR Standards and Certification Criteria.
  • October 2014: Penalties phase of EHR program begins for eligible hospitals; Stage 2 begins for eligible hospitals granted hardship exception because of delays in EHR upgrades.
  • January 2015: Penalties phase of EHR program begin for eligible professionals; Stage 2 begins for eligible professionals granted hardship exception because of delays in EHR upgrades.
  • January 2018: As it is currently proposed, Stage 3 of the EHR Incentive Program for all program participants would begin. Program participants could chose to voluntarily participate at the Stage 3 level in 2017.

Timeline for major regulatory releases/announcements (does not include changes made as part of Medicare physician fee schedule or minor corrections):

  • January 2010: Stage 1 proposed regulation released, along with proposed regulation for 2011 EHR initial standards and certification criteria.
  • July 2010: Stage 1 regulation and 2011 Edition of EHR Standards and Certification Criteria released.
  • Oct. 2010: Revisions released to 2011 Edition of EHR Standards and Certification Criteria.
  • March 2012: Stage 2 proposed regulation released, along with proposed 2014 Edition of EHR Standards and Certification Criteria. The Stage 2 proposed rule also included a proposal to delay implementation of Stage 2 from 2013 to 2014. (ACC comments available here)
  • September 2012: Stage 2 regulation and 2014 Edition of EHR Standards and Certification Criteria released.
  • May 2014: Release of proposed regulation to allow delay in Stage 2 implementation through a hardship exception for eligible professionals and eligible hospitals experiencing delays/difficulties upgrading EHRs to 2014 Edition of EHR Standards and Certification Criteria.
  • September 2014: Final regulation released delaying Stage 2 implementation through a hardship exception for eligible professionals and eligible hospitals experiencing delays/difficulties upgrading EHRs to 2014 Edition of EHR Standards and Certification Criteria.
  • March 2015: Proposed Stage 3 regulation released along with proposed 2015 Edition of EHR Standards and Certification Criteria.
  • April 2015: Release of proposed regulation to adjust 2015-2017 Meaningful Use reporting years. The proposal includes aligning all program participants to reporting on the calendar year, providing for a 90-day reporting period in 2015, and reducing program complexities. 

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