The following is a guest post by Barry Haitoff, CEO of Medical Management Corporation of America.
We’re deep in the heart of meaningful use. Every organization has likely evaluated their participation in meaningful use and knows their path forward. While the meaningful use program is quite mature, the regulations are still shifting as various organization push forward their agendas. It’s important to keep an eye on these shifts so you can plan appropriately for your organization. Here are three meaningful use items you should keep an eye on since they could have a significant impact on your clinic:
Flex-IT Act – For those not familiar with this act, it would change the attestation period for meaningful use stage 2 from 365 days to only 90 days. This act is being backed by some very strong healthcare organizations including a call from the AMA, CHIME, HIMSS, and MGMA to make this change. As is noted by these organizations, very few hospitals have attested to meaningful use stage 2 and only 2 percent of eligible providers have attested to meaningful use stage 2 so far (they do have until the end of February).
If the meaningful use stage 2 numbers continue on this trend, CMS will need to do something or risk having the program be labeled a failure. It’s hard to predict what will happen (or not happen) in Washington, but the pressure to change the meaningful use stage 2 reporting periods to 90 days is growing. Poor meaningful use stage 2 attestation numbers could very well push this issue over the edge.
EHR Penalty Hardship Exemption – In case you missed it, CMS reopened the meaningful use hardship exception period. Originally you had to file for a meaningful use hardship exception by July 1, 2014, but you now have until November 30, 2014 to apply for an exception. This is a big deal for those who likely didn’t know they’d need an exception for meaningful use.
While this exception is related to the EHR certification flexibility (ie. your EHR vendor software isn’t ready for you to implement and attest), many have wondered if we won’t see more ways for organizations to avoid the coming meaningful use penalties. These prognosticators suggest that if meaningful use stage 2 numbers continue to be as awful as what’s described above, it’s possible that the government will provide some relief from the meaningful use penalties. As of now, the meaningful use penalties are coming, so you better be prepared.
AMA’s Meaningful Use Letter – The AMA has a strong political voice in Washington and they’ve recently decided to tackle meaningful use head on. They’ve put their efforts into a Meaningful Use Blueprint that calls for more flexibility in the meaningful use program. Without going into all the line by line details, the AMA is asking CMS to:
- Adopt a More Flexible Approach to Meaningful Use and move away from the current All or Nothing approach to Meaningful Use
- Align the quality measures, reporting burden and overlapping penalties that exist across programs (Meaningful Use, PQRS, Value Based Reimbursement, etc)
- Focus Meaningful Use and EHR certification on key areas like Interoperability
None of these issues have been put into action by CMS or ONC yet, but I believe this blueprint provides the framework for the AMA’s lobbying efforts. Therefore, it’s a strong indicator of where the meaningful use program might be going. I expect the majority of these suggestions would be welcome by doctors unless they’ve already gone off the meaningful use deep end and given up on meaningful use altogether. However, you don’t want to be caught flat footed if and when changes to the meaningful use program occur.
Security Risk Assessment
This is not really a change to meaningful use, but a reminder that many organizations have not paid appropriate attention to the HIPAA security risk assessment which is required as part of meaningful use. Far too many organizations check this check box during their meaningful use attestation without actually doing a proper security risk assessment. This is coming back to haunt many organizations during their meaningful use audit.
In case you missed it, you might want to start with the Security Risk Analysis Myths and Facts that EMR and HIPAA posted previously. It covers such topics as security risk analysis’ being optional (they’re not) and your installed certified EHR takes care of your risk analysis (more is required). This CMS FAQ offers more details on what needs to be done to meet this meaningful use requirement. For example, you need to do a security risk analysis ever year you attest to meaningful use. Make sure you take the time to do an appropriate risk assessment of your organization.
What other meaningful use trends and changes do you see on the horizon? What other things should we be considering as we plan our meaningful use future?
Medical Management Corporation of America, a leading provider of medical billing services, is a proud sponsor of EMR and HIPAA.