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.

Having just experienced the attestation process firsthand as I watched an SRS client successfully attest to meaningful use, I am happy to report that this part of demonstrating meaningful use is relatively easy—a bit tedious if you are attesting for multiple providers, but not at all difficult. CMS has created a user-friendly, web-based attestation system. Assuming that your EHR provides the information you need in a useful format, you have successfully met all the required measures, and you come prepared, there should be no reason to have an unsuccessful attestation.

Here are some tips that will ensure your success:

• Register in advance: Even though you can register as late as at the time of attestation, the combined task would be overwhelming—particularly if you are attesting “on behalf of” a provider. Registering in advance ensures that everything is up-to-date in NPPES and PECOS and that you have all the necessary information.
• Make sure that all measures have been met: If your EHR does not show the percentages for measures that have thresholds, do the math yourself to verify your success on each one. CMS offers a worksheet that you might find helpful for this purpose. Verify that you have also met all other (non-numerical) measures. If you fail to satisfy even one measure, do not attest now—go back and try another reporting period.
• Have documentation for each provider:
  - Registration confirmation page with registration ID#

  - Password

  - EHR certification number

  - Reporting period dates (make sure it covers at least 90 days)

  - Printout of all meaningful use measures: numerators and denominators, exclusions and reasons

    (when there is more than one possible reason)

  - Clinical Quality Measure report: numerators, denominators, exclusions

• Do not hit “Submit” until you have reviewed the “Attestation Summary” page: Double check your data. Make sure that you have said “yes” to all yes/no measures and that your numbers are entered accurately. The summary page does not display percentages, so you have to do the math yourself to be sure that you meet the thresholds.
• Submit attestation and print the “Submission Receipt” as confirmation: If you have done everything correctly it will state that “all measures are accepted and meet MU minimum standards.”

While not necessary, I highly recommend having a second person help you attest. A second set of eyes will shorten the time the process takes and will reduce the potential for errors in posting your data.

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.

Meaningful Use Monday posts have delved into the nitty-gritty details of meaningful use, but I know that there are many providers and practice administrators who are still trying to wrap their arms around the basics of the EHR Incentives Program. CMS has just condensed the enormous amount of information available on its website into one handy, presentation-style document that explains the program.

Called “An Introduction to the Medicare EHR Incentive Program for Eligible Professionals” (PDF), its URL identifies it as a “Beginners Guide”. (They could just as easily have named it “Meaningful Use for Dummies”, trademark infringement issues notwithstanding.) Although it is 85 slides long, the presentation is succinct, easy-to-navigate, and covers a full range of topics—including eligibility, program options, meaningful use measures, registration, attestation, other resources, etc.

Check it out! …And for more information, I invite you to browse through the comprehensive Meaningful Use Resource Center on the Government Affairs section of our company’s website (www.srssoft.com).

Wishing everyone Happy Holidays and a “Meaningful” New Year!
Lynn

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.

HHS recently announced the postponement of Stage 2 Meaningful Use to 2014. The only providers who are in a position to act on this “opportunity” are those who have not yet, but still could, attest to meaningful use in 2011—but, a word of caution before you rush to attest in 2011. 

The HHS announcement “encourages any providers who have been waiting until 2012 to attest to Stage 1 meaningful use now. ….Those providers who first attest in 2011 can get three payment years for meeting the Stage 1 expectations, while those first attesting in 2012 can only get two payment years under Stage 1 criteria.” 

True. However, you must carefully weigh the benefit, (earning the $8,000 third incentive payment under the rules of Stage 1 instead of those of Stage 2), against the cost, (the permanent loss of your 2011 Medicare ePrescribing bonus money). Remember, you cannot receive incentive payments under both programs during the same year, so you maximize your total reimbursement by collecting the 1% ePrescribing bonus this year and waiting just 3 months to begin earning the $44,000 in EHR incentives over the next 5 years. There is no universally right or wrong strategy—just do the math and analyze the trade-off before making a decision.

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.

Meaningful Use penalties—or to use the politically correct word, “adjustments”—are scheduled to begin in 2015 for providers who are not meaningful users of certified EHR technology by 2014. There’s something about the prospect of incurring a revenue reduction that seems to evoke a visceral response among providers—even among those who do not find the potential incentive money motivating.

Here’s what you need to know about the penalties:

1) Penalties apply to Medicare only.
- Adjustments will be applied as a percent of Medicare Part B Professional Fee Schedule Charges.
- They are scheduled to begin in 2015, and continue as follows:
2015: 1%
2016: 2%
2017: 3%
2018 and 2019: may increase 1%/year, at the discretion of the Secretary of HHS.

2) There has been speculation by some industry pundits that the penalties will be delayed or not implemented at all, but to rely upon that as a given would be a mistake.

3) There are no penalties associated with the Medicaid program—adjustments do not apply to Medicaid revenue. Pursuing the EHR incentives as a Medicaid provider, however, does not totally insulate a physician from the penalties. If a Medicaid provider does not become a meaningful user by 2014, the revenue he/she generates under Medicare would be subject to the adjustments above.

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).

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.

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 3^rd, 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.

Lynn is out partying in New York (otherwise known as the SRSsoft user group meeting), and so I’m going to try and fill in for her today in our continuing series of Meaningful Use Monday posts.

The great thing is that I was recently sent a meaningful use tool that was developed by Stacey Chapman, a consultant at PTS Consulting Group. Here’s a little background on Stacey:

Stacey Marie Chapman is a Principal Consultant with PTS Consulting, having previously worked as an Implementation Consultant, as well as, for eClinicalWorks. Stacey recently worked on curriculum development and instructional content for the ONC sponsored Community College Consortia to Educate Health Information Technology Professionals in Health Care Program through Bronx Community College.

PTS provides customized Electronic Health Record Project Management solutions for engagements of all size and specialty; effectively aligning IT applications with client’s process models, to achieve maximum operational efficiency and overall usability.

So, this Meaningful Use tool is built in excel and goes over all the various meaningful use requirements.(Note: Since it’s an excel file, I suggest you click the download link below since excel files don’t display very well in an embed)

You can see the full screen version of the meaningful use tool here.

Also, we’d love to get more questions you’d like answered on Meaningful Use Monday. If you have any questions or think there’s a topic we haven’t covered on Meaningful Use Monday, let us know in the comments or on our Contact Us page.

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.

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.