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ePrescribing in 2012: Keep On G-Coding – Meaningful Use Monday

Posted on January 23, 2012 I 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.

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.

Many physicians will be pursuing EHR incentives in 2012. Because meaningful use is not dependent upon G-codes, providers have been asking whether they need to continue putting “G-8553” on Medicare claims. The answer is YES—keep on G-Coding! 

Even though physicians who receive a Medicare EHR incentive are ineligible for an ePrescribing (MIPPA) incentive, they are still subject to future ePrescribing penalties. These penalties can be avoided by ePrescribing in 2012:

  • Prevent the 2013 (1.5%) penalty – CMS is giving providers a second chance. If you failed to ePrescribe on the minimum 25 Medicare encounters in 2011, (which would have already protected you from the 2013 penalty), report G-8553 10 times between January 1 and June 30, 2012 on any Medicare claims. These claims don’t even have to be for the specified CPT “denominator” codes.
  • Prevent the 2014 (2%) penalty – Report the G-code 25 times between January 1 and December 31, 2012. These claims must be associated with the specified CPT codes (typically E&M visits). 

If you are not pursuing meaningful use in 2012—or if you are, but for some reason fail to earn the incentive this year—you can still earn a 1% ePrescribing bonus under MIPPA if you report the G-Code on claims with the specified CPT codes 25 times between January and December . 

Like last year, there will be a process for requesting an exemption from the 2013 penalties, but surprisingly, the Proposed Rule did not include earning an EHR incentive as one of the justifications.

Switching Between Medicare and Medicaid Incentive Programs – Meaningful Use Monday

Posted on November 14, 2011 I 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.

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.

EPs cannot receive EHR incentives from both Medicare and Medicaid in the same year—they must choose between the two, even if they are eligible under both programs. As discussed in a prior Meaningful Use Monday post, Medicaid is typically the EHR incentive program of choice for EPs who have a sufficiently large Medicaid volume. 

But providers must re-qualify annually, so what happens if the participating provider’s Medicaid volume drops below the 30% (or 20% peds.) threshold in a future year, making him/her no longer eligible for that program? What about an EP who initially participates as a Medicare provider, but subsequently becomes eligible for the more generous Medicaid program? As the first EHR Incentive Program participants approach year 2, they need to understand their options in this regard. 

The rule is as follows:  An EP may switch from one program to another, but only one time after receiving his/her first EHR incentive payment, and only for a payment year before 2015.  

Note: In case you are doing the math and calculating how you could game the system to increase your potential revenue, the rule goes on to say that under no circumstances can an EP’s total incentives exceed the total available under Medicaid, (i.e., $63,750).

Can 2-State Medicaid Providers Collect 2 EHR Incentives? – Meaningful Use Monday

Posted on October 31, 2011 I 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.

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.

A Meaningful Use Monday reader asked whether a provider who practices near the border of two states and treats patients under the two distinct Medicaid programs can participate in both EHR incentive programs. A similar question has been asked by physicians who have practice locations in two neighboring states. The answer is “No”, even if the EP meets or exceeds the 30% patient volume threshold in both states. 

EPs can receive only one incentive each year, and they must choose the state from which they wish to receive the payment. They can, however, change states on an annual basis when they re-attest—flexibility which is valuable in the event that their Medicaid volume falls below the required level in the first state and they lose eligibility for that program. 

CMS created a single registration system for both incentive programs to enable the States to check for—and make them responsible for preventing—duplicate payments, whether from two states or from Medicaid and Medicare simultaneously. My next Meaningful Use Monday post will discuss the rules for switching between the Medicaid and Medicare EHR incentive programs.

Are You Ready for 2012? – Meaningful Use Monday

Posted on October 17, 2011 I 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.

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.

Year 1 of the EHR Incentives program is almost history. Do you have a plan for 2012? What you do next year depends on what you did this year. 

If you did not pursue meaningful use in 2011—and many Medicare providers did not, either because they were not ready yet or because they opted to earn the ePrescribing incentive under MIPPA instead—it is now time to focus on meaningful use. You can choose any 90-day reporting period in 2012 starting as late as October 3rd, but it would be wise not to leave it to the last minute.

If you successfully attested to meaningful use in 2011, your reporting period for the second year’s incentive is a full calendar year. Regardless of which 90-day period you chose to report on for 2011, in 2012 you will report from January 1 to December 31. Incentives are tied to calendar years, so even if you completed your 2011 reporting period in September, your next period does not begin until January. Take a break from reporting, but do not abandon your meaningful use workflow.

For EPs who participate under the Medicare program, the 5 years of incentive payments must be continuous in order to earn the full $44,000 in incentives. Once you receive your first payment, skipping a subsequent year, (i.e., failing to demonstrate meaningful use), while permissible, will mean that you forfeit the payment associated with that calendar year. 

For EPs who receive a 2011 Medicaid incentive for “Adoption, Implementation, or Upgrade,” 2012 will require the demonstration of meaningful use. Since it will be your first year of meaningful use, you will only be expected to report on a 90-day period, and that period can occur any time during the year. Medicaid participants are eligible for 6 incentive payments—as opposed to 5 for Medicare providers—and unlike Medicare, the years do not have to be consecutive, as long as they are all completed by 2021. 

It’s time to start thinking about 2012.

The Meaningful Use Decision – Meaningful Use Monday

Posted on October 10, 2011 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

What else could be written about meaningful use that hasn’t already been said? Really. I’ve been thinking this over since I think we’ve been writing about the EHR incentive money and meaningful use for almost two years now.

I still remember the first time I read about the government planning to give out incentive money for those who adopt an EMR. Some thought that they’d just give out the money to doctors who adopt an EHR kind of like they did for those who purchased a home. I guess the government assumes that when you purchase a home you’re going to use it, but when you purchase an EHR that’s not always the case. So, meaningful use was born.

One of my biggest problems with meaningful use has always been its conflict with certified EHR. I’ll never understand why the government wants to certify EHR software (ie. more expense) when they could have just built the requirements of meaningful use so that the only way for a user to meet the requirements is by using an EHR software that performed the functions required. I guess I can partially see some security checks that could be done in an EHR certification that wouldn’t show in meaningful use, but does anyone really think that EHR software is much more secure thanks to EHR certification?

Of course, much of this is water under a bridge. We have meaningful use and certified EHR and there’s no going back now.

At this point, I wonder how many doctors are still undecided on meaningful use and EHR software. Considering all the discussion and chatter, I feel like most doctors have made the decision on the subject. They’re either going to use an EHR or not. I guess there might b e a few doctors that want to use an EHR, but are waiting for the right one. Certainly there are many doctors that know that EHR is the future, but they just haven’t committed the time to evaluating the various EHR software and deciding which one is best for their office.

My gut feeling tells me that the EHR incentive money wasn’t enough for many of them to finally get down to the business of selecting and implementing an EHR. I imagine many of them are waiting and hoping for a clear EHR market leader to emerge. I’m sorry to inform them that I don’t think that’s going to happen for another 2-3 years at least. Plus, I still think we might have market leaders in each medical specialty.

I’ve heard some argue that it’s the future meaningful use stages that have people scared to implement an EHR. Basically, they believe that meaningful use stage 1 is reasonable, but they think that meaningful use stage 2 & 3 will be much harder and not worth the effort. Kind of reminds me of the arguments that businesses have made about the uncertainty of economic policy causing them not to “move” on more investments. I think many doctors are uncertain about the EHR stimulus money, future stages of meaningful use, and how private insurance companies may react in the future. This uncertainty does cause issues for their ability to plan.

One thing I think the EHR industry could do to provide more comfort to doctors is to provide doctors that adopt your EHR a pathway to leave your EHR if you don’t meet their expectations. Why vendors try to lock someone into their EHR that hates it is beyond me. Ok, I get the short term gain and why you hate losing customers. However, by locking them into a product they don’t like you’re creating an eternal enemy to your product and believe me when I say that doctors talk. Plus, if you have doctors that want to leave because your product doesn’t meet their expectations, then you have a bigger issue on your hands. Sure one or two that have work flows that don’t match your product, fine. A mass exodus from your product because you chose to make it easy for them to leave means you should probably fold up shop anyway or fix the reasons why they want to leave.

Unfortunately, the large EHR vendors won’t really care at all. They’re all about lock in whether you like it or not. I hope doctors start to kick against this and support EHR vendors that provide pathways out of their product. I’d still be happy to support a movement to “liberate” EHR data. Any EHR vendors want to join?

This brings us back to meaningful use. It’s too bad the meaningful use didn’t require practical elements that would make a lot of sense for government to institute. For example…
-Require EHR vendors to create an easy export of all patient data
-Require EHR vendors to communicate with other EHR vendors
-Require EHR vendors to send public health data (they’ve kind of done this)

I’m sure there are more, but that’s a good start.

Now the most interesting thing is going to be how this first wave of meaningful use doctors react to the EHR software they’ve chosen. Unfortunately, I’ve really only seen meaningful use doctors who’ve had an EHR software well before the term meaningful use was coined. If you are a doctor who recently implemented an EHR post meaningful use, I’d love to hear from you so we can tell your story.

Exemption from 2012 eRx penalties: The Process is Now in Place – Meaningful Use Monday

Posted on September 19, 2011 I 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.

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.

The Final Rule on ePrescribing was published in the Federal Register on September 6. This is the rule that adds new categories under which some providers can request a hardship exemption from the 2012 (1%) ePrescribing penalties, and it eliminates some of the discrepancies between the Medicare ePrescribing rule and ARRA. (See Meaningful Use Monday June 6.)The only change from the Proposed Rule is the deadline for filing a request—it has been extended to November 1, 2011 (from October 1). Providers should file as early as possible, however, to minimize the number of claims that have to be reprocessed. 

Requests will be reviewed on a case-by-case basis. To submit a request for exemption:

  • Access the exemption request form on CMS’ QualityNet website www.qualitynet.org/pqrs
  • In the “Related Links” box on the upper left, click on “Communication Support Page”, which will display the online form
  • Provide identifying info (TIN, NPI, name, address, etc.)
  • Indicate which hardship category applies
  • Submit a justification statement explaining how ePrescribing represents a significant hardship
  • Attest to the accuracy of the information submitted. 

Craft your argument thoughtfully. There is no appeal process—the decision of CMS is final.

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

Posted on September 12, 2011 I 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.

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.

EHR Growth, HIT and EHR Standards, Hospital EMR User Tracking Bill, and MGMA Conference in Las Vegas

Posted on September 4, 2011 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Time for my roundup of interesting topics seen throughout the interwebs and related to EHR and healthcare IT.

@Allscripts
Astounding growth in use of EHRs – 5x in 2.5 yrs – Dr. Mostashari at #ACE2011 (via Skype) – does your doc use an EHR?

I’d like to see where Dr. Mostashari got those numbers. I think there’s little doubt that EHR use is up. If we say that 2.5 years ago it was at about 15%, then that would mean that using his growth number we’re now at 75%. That seems way too high for me.

@shelleypetersen – Michelle Petersen
US are starting to standardise vendor requirements for #healthit and language used in #EHR regions, important move

Is this a misread of what’s being done with meaningful use and EHR certification? I haven’t seen standards really emerge for most of this. I guess it does say “starting.”

Hospital EMR User Tracking Bill
Don’t ask me why, but this post about a CA Bill Requiring Hospital EMR Software to Track Users came across my tweet stream as well even though it was posted back in June. I guess that’s one thing I love about Twitter. It can bring back interesting content that you wouldn’t have seen otherwise.

After reading the post, I wondered if the CA bill passed or not. I’m guessing not. Although, I’m still shocked by the article’s comments that even an expensive Epic install at Kaiser can’t meet the requirements of reporting on what data for a patient in an EHR has been deleted and who’s accessed that patient data.

MGMA Conference in Las Vegas
I’ll admit that I’ve wanted to go to the MGMA conference for a couple years now. This year I’m lucky that it’s hosted in the beautiful Las Vegas. So, I’ll definitely be there enjoying the event. I’ve been thinking about doing a New Media Meetup at MGMA like I do at HIMSS. Are any readers interested if I put it together? If there’s only a few of you, we could just do a dinner or something. Let me know in the comments or on my contact us page.

More on Stage 2: Clinical Quality Measure Reporting – Meaningful Use Monday

Posted on August 22, 2011 I 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.

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.

In addition to the Meaningful Use Stage 2 recommendations discussed in last week’s Meaningful Use Monday, the HIT Policy Committee proposed a new framework for the reporting of clinical quality measures that was designed by its specifically-tasked Quality Measure Workgroup. The recommended concept is depicted in the graphic below—the intention is to broaden the scope of reporting to address a wider spectrum of factors affecting care and to accommodate all types of physicians.

Providers would report on some number of the core measures, (between 5 and all 8 or 9 is the recommendation), and at least one measure from each of the 6 menu “domains”. The core quality measure set would include all of the core and alternate core measures from Stage 1 and an additional 2 measures related to care coordination. Interestingly, there was no mention of establishing required thresholds to be met on any of the quality measures.

The intention is that all physicians (including specialists) will find measures relevant to their specialty in the core set as well as in each of the domains. This seems like a tall order from a practical perspective, given the primary-care focus of the Stage 1 quality measures, (particularly true of the core, but also the additional measures.) To accomplish this, the workgroup submitted quite a lengthy “library” of measures to CMS for its consideration—some measures are carried forward from Stage 1, others are recently retooled, and many are still “to be developed”.

We’ll be watching intently to see what CMS does with clinical quality measures, since this is such a fundamental part of meaningful use.

What’s in Store for Meaningful Use Stage 2? – Meaningful Use Monday

Posted on August 15, 2011 I 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.

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.

A few weeks ago, the HIT Policy Committee forwarded its Stage 2 meaningful use recommendations to CMS. CMS is expected to issue a Proposed Rule in early 2012 and the Final Rule in mid-2012. 

The first recommendation—intensely debated, but overwhelmingly supported in the end—is to delay the start of Stage 2 until 2014, recognizing the unrealistic time pressure that vendors and providers would face if required to upgrade, implement, and train for the new set of requirements by 2013. 

Most of the proposed changes to the measures themselves are not dramatic in scope. Some measures did not change at all, (e.g., problem list, medication list, etc.) Others, (e.g., ePrescribing, smoking status), would have higher thresholds to meet—not a major obstacle if the higher-than-required performance trend reported among early attesters continues—and some would have a slightly broader scope, (e.g., CPOE would include radiology). 

All menu measures would become core measures, which means that they would be required of all providers. If CMS adopts this recommendation, it will be important to identify exclusion criteria to accommodate physicians for whom particular measures may not be relevant, as they did for specific core measures in Stage 1. 

The changes that are more controversial are those that hold physicians responsible for factors beyond their control, such as requiring that a given percent of patients actually view their electronic health information (Stage 1 only requires that the information be made available), or requiring that a given number of patients send a secure message to the physician/practice. Also interesting is that some of the new measures recommended for Stage 2 are measures that were specifically removed by CMS during the Stage 1 rule-making process, such as advance directives and progress notes.

If you are interested in the specifics associated with the recommendations summarized above, Computer Sciences Corporation’s Update on Stage 2 (PDF) presents a nice review.