Question: When does my second year of Meaningful Use begin?
Answer: On January 1st following completion of your initial MU reporting period.
To be clear, this means for example that you could complete your initial 90-day MU period on March 31st, 2012 and have no obligation to continue meaningfully using your EHRs until January 1, 2013.
Why was this a surprise? The dates are not the surprise, rather the permissibility to start, stop and re-start as much as 9 months later. Since the intent of the HITECH Act is to drive continuous and permanent change through the use of certified EHRs, it is surprising to see a start-stop-restart design in the process.
It is our strong recommendation that you do not stop meaningfully using your EHRs. While permissible by the letter of the law, we believe there is no advantage - indeed a disadvantage - in stopping the good habits you've developed. Beginning in year 2, Meaningful Use will indeed become a continuous and permanent expectation.
Alistair Jackson, M.Ed.
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