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Where Are We At With Meaningful Use?

Posted on December 11, 2013 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.

The following is a guest post by Barry Haitoff, CEO of Medical Management Corporation of America.
Barry Haitoff
It seems like meaningful use is in a constant state of flux with moving deadlines and multiple stages that apply to each organization differently. With meaningful use stage 2 just around the corner for many providers it is worth taking a quick look at where we are on the journey to meaningful use.

Meaningful Use Timelines
The most important thing many organizations need to remember is the various timelines for each meaningful use stage. This can be pretty complex because it changes based on when you first attest to meaningful use. Plus, last Friday CMS announced an extension to meaningful use stage 2 and a delay of meaningful use stage 3 for one year.

Before this recent change, CMS put out the following chart which clearly illustrates how much EHR incentive money a provider will get for showing meaningful use of a certified EHR. Plus, it shows which meaningful use stages you will have to comply with based on the year you started attesting to meaningful use. After the aforementioned announcement, the only change to this chart would be that both meaningful use stage 3’s would become meaningful use stage 2.

Meaningful Use Medicare Incentive Timelines and Stages

The above chart is just for EHR incentive money under Medicare. The chart for Medicaid is much simpler and hasn’t changed much since the EHR incentives were first announced.

Meaningful Use Medicaid Incentive Timelines and Stages

EHR Penalties
While the incentive money for EHR is important for many, it seems like doctors are motivated as much or more by the Medicare adjustments that will be enforced if they aren’t meaningful users of a certified EHR system. Here’s the timeline for the EHR payment adjustments:

Meaningful Use Penalty Schedule

There are a number of hardship exemptions that a provider can claim to avoid the penalties. If you plan to pursue one of these hardship exemptions, you have to apply for one by July 1, 2014. CMS has put out a nice tipsheet covering payment adjustments and hardship exemptions. As you can see, the exemptions are pretty narrow. Although, maybe they’ll create more exemptions over time like they did with the eRX penalties.

Other Notable Meaningful Use Updates
Regardless of what stage of meaningful use you are at or any prior years reporting, all eligible professionals will only have to attest to 90 days of meaningful use in 2014. This change was made to give organizations plenty of time to upgrade to the 2014 certified EHR technology. However, many EHR vendors have taken this extra time into account and are still not 2014 certified because they know eligible providers only have to attest to 90 days in 2014. Anyone attesting to meaningful use regardless of meaningful use stage will have to be on a 2014 certified EHR. The 2011 EHR certification will be expired and not accepted.

It is also worth noting that those who have not begun participation in the Medicare EHR incentive program will need to attest to meaningful use in 2014 if they want to be eligible for any EHR incentive money.

Meaningful Use Audits
If you’ve already attested to meaningful use stage 1, then you better make sure your documentation is in order. Meaningful Use audits have already begun and a number of organizations are getting caught without the proper documentation. This is worth also noting for those planning to attest to meaningful use for the first time. Make sure that you keep all your meaningful use attestation documentation in case you’re ever audited.

The most common audit issue organizations have is with core measure 15 which requires an organization to conduct a security risk analysis. Many organizations checked off this box without actually doing a security risk analysis. That’s a very risky proposition. This is one meaningful use requirement where you can’t rely on your EHR vendor to do it for you. This is not a hard task and many organizations will be happy to come and do one for you. Just make sure you’ve actually done it before you attest.

Medical Management Corporation of America, a leading provider of medical billing services, is a proud sponsor of EMR and HIPAA.

Meaningful Use Stage 2 Extension, MU Stage 3 Delay and New 2015 EHR Edition Certification Proposed

Posted on December 6, 2013 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.

The big news of the week just came out of CMS at 4 PM EST on a Friday. Feels like they’re trying to bury the news story, but maybe it was just the way the timing worked out. Either way, there’s no way anyone who lives in the EHR and meaningful use would miss the announcement (not to mention I’ve already seen it posted on every major health IT news site). CMS is proposing an extension of meaningful use stage 2 another year through 2016 and so that means a delay in meaningful use stage 3 until 2017.

Here’s how Robert Tagalicod, Director, Office of E-Health Standards and Services, CMS and Jacob Reider, MD, Acting National Coordinator for Health Information Technology, ONC described the change in meaningful use timeline:

Under the revised timeline, Stage 2 will be extended through 2016 and Stage 3 will begin in 2017 for those providers that have completed at least two years in Stage 2. The goal of this change is two-fold: first, to allow CMS and ONC to focus efforts on the successful implementation of the enhanced patient engagement, interoperability and health information exchange requirements in Stage 2; and second, to utilize data from Stage 2 participation to inform policy decisions for Stage 3.

The phased approach to program participation helps providers move from creating information in Stage 1, to exchanging health information in Stage 2, to focusing on improved outcomes in Stage 3. This approach has allowed us to support an aggressive yet smart transition for providers.

Meaningful Use Stage 2 and 3
This shouldn’t come as a surprise to many. In fact, we’d been discussing the possible meaningful use stage 2 extension in the comments of my post: ICD-10 will be delayed. We thought meaningful use delay was possible, and now it’s happened.

I do like that this delay gives CMS and ONC more breathing room to know what to include in meaningful use stage 3. Plus, maybe they’ll get the MU Stage 3 certification requirements out in plenty of time for EHR vendors to be able to update their software.

One thing that is really interesting about this delay is that meaningful use stage 3 won’t go into effect until after the Medicare EHR incentive money is over. The Medicare EHR incentive money is only scheduled to be paid through 2016. Medicaid wasn’t implementing MU stage 3 until year 6, so I expect there’s no change there. While you won’t have to show MU stage 3 for Medicare EHR incentive money, you will have to attest to meaningful use stage 3 in 2017 if you want to avoid the EHR penalties (Payment Adjustments if you prefer CMS’ terminology). In 2017, those EHR penalties will be at 3%.

Many have called for a delay to meaningful use stage 2 as well, but that didn’t happen today.

2015 Edition EHR Certification
The other part of the CMS announcement is the 2015 Edition EHR certification. They propose having an additional 2015 EHR certification that sounds like it would amount to an update to the 2014 edition. The 2015 edition would fix any issues with the 2014 edition and update any changes to interoperability standards. Sounds like an EHR certification patch.

The catch is that EHR vendors that are 2014 Edition EHR certified wouldn’t have to do 2015 Edition. This is good since we don’t need software vendors having to certify again (as much as certifying bodies would love the new revenue). Although, I won’t be surprised if most EHR vendors take the new standards in the 2015 edition and update their software to those standards. Let’s just hope that if they choose to do so, it doesn’t kill their 2014 Edition EHR certification. We should all be using the latest and greatest standards. Even more important, we need to all be on the same standard.

What do you think of the announcement? I look forward to hearing your thoughts in the comments.

See Also:
HIMSS Response – HIMSS Supports Stage 2 Extension
CHIME Response – Meaningful Use Timeline Shift Does Not Afford Flexibility in 2014

Meaningful Use Stage 3 Timeline – Meaningful Use Monday

Posted on November 19, 2012 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.

The big meaningful use news this week was the release of the meaningful use stage 3 recommendations (PDF) that the meaningful use workgroup released to the public. Some on Twitter thought that this was the meaningful use stage 3 rule that could be commented on. This is not open for public comment yet, but should be soon.

In fact, Healthcare IT News listed the following timeline for meaningful use stage 3:

  • Dec. 21, 2012 – RFC deadline
  • January 2013 – ONC to synthesize the RFC comments for HIT Policy committee workgroups to review
  • February 2013 – The workgroups will reconcile RFC comments
  • March 2013 – The workgroups will present a revised draft of Stage 3 requirements to ONC
  • April 2013 – ONC is expected to approve final Stage 3 recommendations
  • May 2013 – ONC will transmit final Stage 3 recommendations to HHS

That’s a pretty aggressive timeline to have meaningful use stage 3 published by May 2013. If my dates are right, meaningful use stage 3 won’t be effective until 2016. I like that ONC wants to get the MU stage 3 out soon so that no one can use not having the meaningful use details as an excuse for not complying. However, I also don’t think ONC should rush the process either. We have to live with meaningful use, good and bad, for a long time to come.

I’d love to hear what you notice in the meaningful use stage 3 proposal (PDF). We’ll be sure to cover it a lot more in the future.

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

Posted on October 8, 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.

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.