The following is a guest post by Barry Haitoff, CEO of Medical Management Corporation of America.
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.
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.
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:
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.