Meaningful Use Attestation

Meaningful Use Stage 3 Retires Measures that Doctors Don’t Do

The other day I was spending some time going through the proposed meaningful use stage 3 measures. It’s quite an experience if you haven’t done this already.

As I was going through each of the measures I realized something that could be a little troubling. In a number of cases, they are proposing that certain measures should be retired from the meaningful use attestation process because essentially those measures have reached a percentage in meaningful use stage 2 that they’re fully adopted. I think this is generally a good idea. We don’t need clinics and hospitals reporting information just to report information.

Although, I did find a surprising trend when it came to the measures that were being retired in meaningful use stage 3. Almost all of the measures (possibly all, but I didn’t dig that deep) were measures that were done by someone other than the doctor. A few examples were vitals, smoking status, and demographics. I guess in some cases the doctor might enter these, but you can see how the vitals were likely entered by a nurse or MA and not the doctor.

On the one hand this is a really great thing. That means that in the previous meaningful use stages, the biggest burden was placed on someone other than the doctor while the doctor was only required to have a much smaller percentage. Unfortunately this means that the higher percentages required in meaningful use stage 3 put the burden largely on the backs of physicians.

Important Dates in the Life of a Meaningful EHR User – Meaningful Use Monday

Written by: Lynn

Here’s a look at some of the important dates to know for those looking to attest for Meaningful Use:

October 3, 2012: Last date to start the 90-day reporting period to earn an $18,000 EHR incentive payment for 2012, and to be eligible for the maximum total of $44,000. (The potential total drops to $39,000 in 2013.) Physicians do not have to be registered by this date—they can register at any time before they attest.

January 1, 2013: First day of the 365-day, 2013 reporting period for any provider who earned his/her first incentive payment in 2011 or 2012.

February 28, 2013: Last date to register and to attest for the 2012 EHR incentive. (Happily, no one has to spend New Year’s Eve attesting!) But remember, the entire reporting period has to have occurred within 2012.

October 3, 2013: For EPs whose first EHR payment year will be 2013, last day to start the 90-day reporting period and earn a $15,000 2013 incentive.

2013: EPs who successfully demonstrate meaningful use in 2013 will not be subject to the 2015 payment adjustment.

October 1, 2014: For EPs whose first incentive year is 2014, this is the last date to submit a successful meaningful use attestation and avoid the 2015 payment adjustment.

How Should Locum Tenens Attest to Meaningful Use for the Medicaid EHR Incentive Program? – Meaningful Use Monday

Written by: John Lynn

Jessica Shenfeld, Esq. is the founding partner at The Law Office of Jessica Shenfeld, a boutique law firm that caters to physicians’ legal needs. She is also CEO of EHR Incentive Help, Inc., which helps physicians satisfy the Meaningful Use criteria and apply for the Medicare/Medicaid EHR Incentive Program benefits. For more information, visit http://jessicashenfeld.com/healthcare-legal-services/ehr-incentive/.

A reader asked about the best way for a locum tenens to attest to Meaningful Use for the Medicaid EHR Incentive Program. As you may know, the phrase “locum tenens” is Latin for “place holder” or “substitute.” Locum tenentes physicians – like substitute teachers – may receive assignments that vary in length from a couple weeks to many months. As such, a locum tenens physician can work in multiple clinic/office locations over any given ninety-day period. This issue addressed below applies not only to locum tenens, but also to any doctor that works in multiple practice locations and wants to apply for the EHR Incentive Program as an individual eligible professional (EP). The reader’s question breaks down into two separate questions:
1. What location should the doctor use to demonstrate Meaningful Use?
2. What patient data should the doctor use to calculate the patient volume threshold – that at least 30% of the patients the EP treated were Medicaid patients?

The important point to remember is that doctors that work at more than one clinical practice site are NOT required to use data from all sites to support their demonstration of meaningful use and the patient volume threshold.

1. Meaningful Use: Under the Medicaid EHR Incentive Program, an EP must have at least 50% of their of their patient encounters during the EHR reporting period at a practice/location or practices/locations equipped with certified EHR technology capable of meeting all of the meaningful use objectives. In lay terms, that means that in order to receive the Medicaid EHR incentive, a doctor must have had a certified EHR system installed (either adopted, implemented, or upgraded) in at least half locations where they practiced over any 90-day period in the prior calendar year.

2. Patient Volume: In order to be eligible for the Medicaid EHR Incentive Program, at least 30% of an EP’s patients over that same 90-day reporting period must have been Medicaid patients. This calculation is called the “patient volume” calculation, and it may be calculated differently in each state. The answer that applies in New York is that EPs may choose one (or more) clinical practice sites in order to calculate their patient volume. While the calculation does not need to include all practice sites, at least one of the sites from which patient data is drawn must have certified EHR technology. In other words, if an EP practices in two locations, one with certified EHR technology and one without, the EP must include the patient volume from the site that includes the certified EHR technology. In this example, the EP has the choice as to whether he wants to include the patient volume from the site without certified EHR technology to calculate patient volume calculation.

Although the reader asked about the Medicaid EHR Incentive Program, a locum tenens can apply for the Medicare EHR Incentive Program using the framework outlined above with one exception: to establish Meaningful Use, at least half the practice sites where the locum tenens worked over a 90-day period in that same calendar year must have had a certified EHR system capable of meeting the Meaningful Use requirements. The patient volume analysis above applies to both Medicaid and Medicare.

MU Attestation Audits – Meaningful Use Monday

Written by: Lynn

By definition, attestation is based on the honor system—that is, at least until you find yourself the subject of an audit. CMS has launched its anticipated program, and some physicians who have received an EHR incentive payment recently received a letter from the designated auditing firm, Figloiozzi and Company.

Although there is no way to predict which physicians will be audited, providing the information requested should not be too onerous a task for those “lucky” ones who are tapped. Providers are being asked to show proof that they possess a certified EHR and to substantiate the data they reported for the core and menu measures—specifically, via “a report from their EHR system that ties to their attestation.” Since all certified EHRs generate an automated measure calculation report and a clinical quality measure report, that documentation should be readily accessible. It would not surprise me if they are also asked to provide documentation of the security and risk analysis that the practice conducted to ensure HIPAA compliance. For suggestions regarding the type of data to retain to support your attestation, see the Meaningful Use Monday post, MU Attestation: Save Your Documentation.

Based on material published by the auditors and by CMS on its EHR Incentives website, it does not seem that the audits will be so detailed as to require site visits or reviews at the patient chart-level. My sense is that CMS is looking to identify failures to comply with the major requirements—adopting and using a certified EHR to meet the meaningful use measures and reporting accurately on the data generated by that EHR.

(If you have been audited and would like to share your experience, please post a comment.)

Medicaid EHR Incentive Attestation with Multiple Practices – Meaningful Use Monday

Written by: John Lynn

Jessica Shenfeld, Esq. is the founding partner at The Law Office of Jessica Shenfeld, a boutique law firm that caters to physicians’ legal needs. She is also CEO of EHR Incentive Help, Inc., which helps physicians satisfy the Meaningful Use criteria and apply for the Medicare/Medicaid EHR Incentive benefits. For more information, visit www.jessicashenfeld.com.

A reader of this blog, a physician who worked throughout 2011 in one practice, dissolved her practice in November 2011, and immediately opened a new practice with a new Group NPI (National Provider Identifier) number the same month, November 2011. She now wants to qualify for the Medicaid EHR Incentive in 2012, but was told that she cannot do so using data from 2011 because the new practice only has two qualifying months in 2011 (November and December) and the first practice’s data is mute because it was dissolved. The issues boil down to two questions:
1) Can a closed practice’s data be used during Attestation or is the date mute?
2) Can an individual physician use patients from two different practices to satisfy the Medicaid Patient Volume requirement?

The technical answer to the first question is not straightforward – it depends on what your state says. While Medicaid is a federal program, each state is responsible for administering it and each state makes its own rules for eligibility that vary slightly. The threshold issue here is whether the applicant qualifies an Eligible Professional (“EP). Once the applicant is accepted as an EP, the state has vetted his/her eligibility and that EP’s patient data from the last calendar year can be used during Attestation. In New York, the provider described above would qualify as an Eligible Professional since continues to accept Medicaid patients. However, the final decision as to whether an individual qualifies as an EP is up to each state to decide. EP Eligibility is determined when Registration for the EHR Incentive is submitted. I recommend e-mailing your individual state representative for that answer, or just submitting the Registration and seeing whether it is accepted. Upon Registration, the physician is notified whether he or she was deemed an EP.

The answer to the second question – whether an individual physician can use patients from two different practices to satisfy the Medicaid Patient Volume requirement – is no. A provider cannot attest using two group NPI numbers. The Medicaid Patient Volume requirement imposes a threshold of 30%, calculated using a ratio where the numerator is the total number of Medicaid patient encounters over a continuous 90-day period in the most recent calendar year and the denominator is all the patient encounters over that same 90-day period. Luckily, all is not lost. Although in this case the provider cannot attest using the group’s aggregate patient volume, she has the option of attesting using her individual provider’s patient volume. When reporting on her individual data, the 90-day period can consist of 90 days from the first practice, or 90 days that span across both practices if there was no break in time between the two practices.

One final point – even if a provider applying for the Medicaid EHR Incentive is not deemed an EP in 2012, that provider can delay Registration to as late as 2016 without incurring any reduction in the incentive payment. Conversely, applicants for the Medicare EHR Incentive payment must attest by 2013 using data from a 90-day period in 2012 in order to receive the full benefit.

MU Attestation: Save Your Documentation – Meaningful Use Monday

Written by: Lynn

The end of March will likely bring a host of meaningful use attestations as the first 90-day period in 2012 draws to a close. Before you sit back and wait for your check, make sure that you assemble all the documentation that supports the information you provide to CMS. There will be provider audits, and EPs who cannot back up their attestation could forfeit their incentive payments. Documentation can be in paper or electronic format, and should be retained for 6 years.

CMS does not specify all the necessary documentation, so the following are some suggestions:

Your EHR’s Automated Measure Calculation report – showing the numerators and denominators for each of the meaningful use measures that are numerically based
Clinical quality measures report – clinical quality measures must be reported “exactly as generated as output from the certified EHR technology.”
Clinical decision support rule – perhaps a dated screen shot to show that a CDS rule was implemented for the reporting period
Evidence of your data exchange test – whether the test was successful or not
Documentation of the security risk analysis you conducted – what you did, deficiencies you identified, corrective actions you took
Your test of the ability to submit immunization data and/or syndromic surveillance data – either proof that you conducted the test or documentation that the registry/public health agency cannot electronically accept the data (if you claim that exclusion)
The actual Patient List you generated (if you selected this menu measure)

For more information, see the CMS website.

Predicting a 6 Month Rush to EHR Starting August 2012

Written by: John Lynn

As I look forward to EHR in the year 2012, it was suggested to me at HIMSS that we’re going to see an EHR adoption rush starting in August 2012. If you think about the timeline and all the other EHR happenings, I think this very much will be the case.

I saw a tweet (which I can’t find now) which said something to the effect of meaningful use attestation in January of 2012 was as big as all of 2011. I also have read about the mass of meaningful use attestation that happened at the end of 2011. With only having to attest for 90 days it makes sense why so many people waited until the end of 2011 to attest to meaningful use.

I expect we’re going to see the same rush to meaningful use attesation in 2012 as well. However, you don’t just implement and EHR and then start your meaningful use attestation the week after you implement an EHR. In most cases, you need at least a couple months (more in the hospital case) after implementing an EHR to “get your feet under you” and be ready to concern yourself with the meaningful use requirements.

With this in mind, I expect these next 3 months will be critical for EHR vendors that want to fill their Fall EHR sales pipeline. EHR adoption will slow down a bit during summer when doctors head out on vacations. Then, Fall 2012 will start the rush of EHR adoption in order to meet meaningful use requirements in 2012.

Of course, it’s also likely that many doctors will procrastinate their EHR selection process. They’ll wait until Fall and then rush through EHR selection. I think this would be a real tragedy for EHR since selecting the right EHR is the mot important part of the EHR implementation.

More Meaningful Use Stage 1 Numbers from 2011

Written by: John Lynn

In a previous Meaningful Use Monday we wrote about a bunch of the Meaningful Use 2011 statistics that were put out by ONC and CMS. I know that my readers love statistics and information about Meaningful Use. Carl Bergman sent me a PDF file that contained some really interesting data on Meaningful Use stage 1 in 2011. The first pages we basically covered in the previous post, but starting on about page 10 or so there are some more detailed numbers.

Take a look at let us know which numbers you find interesting and/or unique.

Meaningful Use Numbers from 2011 and Looking Towards 2012 – Meaningful Use Monday

Written by: John Lynn

HITECH Answers recently posted a great post that gives a run down of the EHR Incentive program’s progress in 2011. Here’s their list with my own analysis and commentary of each point.

123,921 Eligible Professionals have registered for EHR Incentives, 15,255 have successfully attested to meaningful use in the Medicare program.
This seems like such a HUGE difference in numbers. That’s just over 12% of Eligible Professionals that registered attested to meaningful use. Does this mean that we’re going to see a tidal wave of meaningful use attestation in 2012? Possibly.

I believe that we’ll see more eligible professionals attesting to meaningful use in 2012. However, the question is how many of those other 108,666 will attest to meaningful use in 2012 and how many are like the Happy EMR Doctor who just registered to see the MU process. I wonder how many first hand meaningful use experiences by doctors will scare doctors away from MU attestation.

3.077 Eligible Hospitals have registered EHR Incentives and 604 of those have successfully attested to meaningful use.
This is almost 20% of hospitals that have registered that have attested to meaningful use. It’s not surprising that this number is a lot higher than eligible professionals. I still believe that the wave of meaningful use attestation will come from these other 2473 hospitals and probably many more that still haven’t registered. I haven’t seen a good number of how many hospitals are in the US. Does anyone know that number? The EHR incentive money that goes to hospitals will dwarf those of eligible professionals.

$2,533,689,145 has been paid out in Medicare and Medicaid Incentives.
$2.5 billion sent out in 2011. I just went back to the first time I tagged meaningful use on this site on April 3, 2009 (coincidentally I have 19 pages of 10 posts each tagged with Meaningful Use). Amazing to think that it’s taken basically 3 years to spend $2.5 billion on EHR.

277 hospitals have received payments under both Medicare and Medicaid and of those 12 were CAHs.
That’s about half of the hospitals that have attested to meaningful use under Medicare are also getting the Medicaid EHR incentive money as well.

22% of eligible professionals that have been paid EHR incentives are Family Practitioners and 20% are Internal Medicine.
I must admit that I would have thought that the percentage of family doctors that got paid EHR incentive money would have been a lot higher. I guess when you have so many other specialty areas I shouldn’t be that surprised. I also wonder why the internal medicine number is so high. These numbers actually make me believe that a lot of family practice doctors are sitting out when it comes to meaningful use.

41 States Medicaid programs were open for registration. Two additional States launched in January of 2012.
I wonder what’s holding back the other 7 states. From what I’ve seen all the states will eventually get there.

More than 1500 EHR products have been certified by ONC-ATCBs.
That’s a lot of EHR software. I still put the EHR company list at about 300 EHR vendors. 1500 includes multiple versions of the same software, partial EHR certification for products like data warehouses, ePrescribing, etc. The best thing that’s come from the ONC-ATCB program is that it has made EHR certification basically irrelevant in the EHR selection process. Every EHR vendor is certified now. This is much better than the false assurances that EHR certification provided before. I still dislike what EHR certification has done to the industry, but at least it’s not misleading doctors the same way it was before.

Tips for Successful MU Attestation – Meaningful Use Monday

Written by: Lynn

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.

Meaningful Use Stage 3 Retires Measures that Doctors Don’t Do

Important Dates in the Life of a Meaningful EHR User – Meaningful Use Monday

How Should Locum Tenens Attest to Meaningful Use for the Medicaid EHR Incentive Program? – Meaningful Use Monday

MU Attestation Audits – Meaningful Use Monday

Medicaid EHR Incentive Attestation with Multiple Practices – Meaningful Use Monday

MU Attestation: Save Your Documentation – Meaningful Use Monday

Predicting a 6 Month Rush to EHR Starting August 2012

More Meaningful Use Stage 1 Numbers from 2011

Meaningful Use Numbers from 2011 and Looking Towards 2012 – Meaningful Use Monday

Tips for Successful MU Attestation – Meaningful Use Monday

Top EMR & HIPAA Posts

Calendar

Recent Posts

EMR & HIPAA Resources

Recent Comments

Categories

May 2013
M	T	W	T	F	S	S
« Apr
		1	2	3	4	5
6	7	8	9	10	11	12
13	14	15	16	17	18	19
20	21	22	23	24	25	26
27	28	29	30	31