How Critical is the October 1, 2011 Deadline? – Meaningful Use Monday

Written by:

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money. Check out Lynn’s previous Meaningful Use Monday posts.

As October approaches, providers who want to apply for the 2011 EHR incentive—and their vendors—are scrambling to implement in time to allow for the 90-day reporting period. An EMR and HIPAA reader submitted the following question: 

Under the EHR Incentive program, in order to receive payment for 2011, the 90- day reporting period must begin no later than 1 October 2011 [Technical point: October 3 is the actual deadline]. Does this mean that the ONC Certified EHR must be in place and operational at that time or can it be installed after 1 October 2011 as long as the pertinent patient data is entered into the EHR once it is installed?

 The EHR must be in use during the entire 90-day period. Data must be reported for the entire 90 days; some measures require something to “be enabled” for the entire period, (e.g., a clinical decision support rule, drug formulary); and other measures have time frames attached, (e.g. provide a clinical summary within 3 business days), which would not be possible to accomplish retroactively. 

My suggestion is that you take the pressure off by postponing meaningful use—and the receipt of your incentive—by just 3 months. If you begin reporting on January 1 instead, you will still have the opportunity to earn the full $44,000 over the 2012-2016 period. You can attest at the end of March and expect your incentive by May. This schedule has the additional advantage of allowing you to earn a 1% ePrescribing bonus for 2011, which you would forego if you earn an EHR incentive since you cannot collect both in the same reporting period. Focus your energy this year on ePrescribing for 25 Medicare encounters and on successfully implementing your new EHR in 2012.