The following is a guest post by Beth Houck, Vice President of Client Services at SA Ignite.
As we near the last quarter of 2013, many providers will have earned over half of their Meaningful Use (MU) incentive dollars and will be adept at following the workflows required to meet the Stage 1 measures. With two years (or more) of following MU under their belts, it’s really just old hat, right? Maybe, but not so fast.
For small practices with no turnover and no upgrades to their EHR, practice managers can follow many of the same checklists that got them through the first year: verification that all non-percentage based measures have been met (e.g., a completed security risk audit, evidence of enabled features in the EHR such as Clinical Decision Support and Formulary Checks, completion of an immunization test) and a secure copy of the report that was generated from the EHR that supports percentage-based measure compliance and CQM submission. Practice managers may find themselves nudging providers to stay on track, but a small, stable practice has far less moving parts from year-to-year.
This is in significant contrast to large practices and Federally Qualified Health Centers (FQHCs) that experience significant turnover. It’s September 2013 and a new provider started with your organization. Do you know what payment year he is in? Are you allowed to attest for him or did his previous practice lay claim on these dollars? It’s July 2013, and a new provider brings her report from the certified EHR she was using in the first part of the year. What do you do with this information? How does this impact this provider’s attestation?
As larger provider organizations advance beyond the earliest stages of MU reporting, they realize that a once manageable process quickly becomes complicated, and the risk that incentive dollars will be lost drastically increases. Ensuring compliance means knowing what rules apply to these providers. Through our work monitoring more than 5,000 providers, we’ve worked to automate the attestation process. Here’s our list of four key best practices to ensure you’re on track to MU compliance.
- The first step is to determine the provider’s Payment Year and under which program(s) they’ve received incentive dollars. You can look this up using the same login to attest for providers.
- Then if they are in payment year 2 for Medicare, never having switched from Medicaid, they will need to meet MU for the entire 365 days. This means that MU data from any previous practices’ EHRs will need to be added to their current MU data. CMS has published a list of frequently asked questions on how to calculate these numbers. On a positive note, you will not be required to have your Clinical Quality Measures (CQMs) align with the previous practice’s EHR. If they don’t match, you can just use the CQMs from the system where you had more visits.
- The next step is to determine which of the non-percentage based measures need to be repeated for this provider. For example, if you don’t have any record of an immunization test being completed at the previous practice, one will need to be completed.
- Finally don’t forget that the EHR Certification ID that you used when you originally attested for your providers won’t necessarily apply to subsequently hired providers. If the new hire is bringing data from their old practice that needs to be merged with their new practice, you will need to obtain a new Certification ID from the Certified Health IT Product list. Following the sites instructions, you will need to add both the provider’s previous EHR and your EHR to the “basket” to obtain a new, unique Certification ID produced for this combination of EHRs.
It’s clear that there is so much more to MU compliance than double checking if you printed Visit Summaries for more than 50 percent of your patients. As we move into 2014, there are multiple payment years, programs and stages to track, so you will need to be certain that you have a system in place to ensure that you can manage the cases mentioned above to maximize the EHR incentive dollars for your organization.