I’d previously gotten some bad information on when meaningful use stage 1 would be applied and when meaningful use stage 2 would go into affect. In fact, I put it out there as a reason why providers should show meaningful use of a certified EHR in 2011 and not wait until 2012. Turns out I was wrong about this.
The meaningful final rule actually does allow you to show 2 years at the meaningful use stage 1 level for 2 years even if you wait to implement and meaningfully use your EMR in 2012 (or even 2013). Here’s an image of the chart provided in the meaningful use final rule on page 44323:
Yes, that means that whether you show meaningful use in 2011 or 2012 you get essentially the same benefits. Although, I guess if you wait to show meaningful use in 2012, then you’ll benefit from all the learning that those that showed meaningful use in 2011 experienced. Now that I think about it, I’m not sure exactly why you’d show meaningful use in 2011. Maybe some readers of EMR and HIPAA have ideas.
Of course, let’s separate implementing an EMR and meaningful use. Would I suggest implementing an EMR in 2011? Absolutely!
You don’t need to rush the implementation. You can make sure you:
1. Choose the right EMR software
2. Implement the EMR software in the most effective way possible
However, every EMR implementation I’ve seen goes in phases. I’d implement an EMR system now so that you can phase in all the meaningful use requirements over time. It makes a lot more sense than rushing to do meaningful use all at once. Not that you can’t do much of the meaningful use during the initial EMR implementation, but sometimes it’s ok and even beneficial to phase things in over time.
Thanks to Lynn at SRSsoft for pointing this out to me along with the location in the meaningful use final rule.
[…] This post was actually off base a bit. I posted a meaningful use stage one correction post that clarifies […]
Remember that an EP must only “attest” to MU in the first year of participation. This means one can purchase & attest in 2011 and receive incentive for 2011. In the second year, one must demonstrate MU by showing 90 consecutive days of data. So, in this example, the EP has all of 2012 up until Q4 to get up to speed in capturing CQM’s for the required % of encounters – in order to be prepared to successfully report Q4 of 2012 in order to receive incentive for year 2 of participation. Additionally, an EP is allowed to skip a year, too. So, if the EP were unable to attain the required CQM goals to show the 90 consecutive days of data in 2012 (using our example here), he or she could “drop out” for 2012, and re-enter in 2013 as year 2 of participation.
Legend: EP = Eligible Professional; MU = Meaningful Use; CQM = Clinical Quality Measure; Q4 = 4th Quarter
The 2010 in my post above s/b 2012 – apparently there is not an option to correct a post like there is on LinkedIn.
Wes,
You certainly have to attest in 2011. Although, my understanding was that you would have to attest that you were a meaningful user for 90 days in 2011. Are you saying that’s not the case? The 90 days only starts in 2012? That would be odd, but it is government work.
The idea of skipping a year is interesting. The real question though is will CMS give them the notice that they’ve failed to meet the 90 days so that they can then drop out and wait for the next year? Or once CMS has ruled on your 90 days not qualifying for meaningful use, are you then stuck with a lost year?
In fact, there’s a lot of unknowns about what happens when someone doesn’t quite meet the meaningful use requirements. Can they reapply the same year? Will they be allowed to make corrections? etc etc etc.
Yes, you’re right that there’s not a way to edit your comments, unless you get a login for the site and that’s really not usually worth the effort.
There is an additional benefit to electing 2012, instead of 2011, as an EP’s first EHR incentive payment year (an unintended consequence of the legislation, no doubt!) In that case an EP can still collect the ePrescribing (1%) bonus for 2011, while potentially qualifying for the maximum ($44K) in EHR incentives. An EP cannot collect under both MIPPA (ePrescribing) and ARRA (EHR incentives) during the same reporting period.
In response to Wes Kemp’s comment about the 90-day reporting period and the consequences of skipping years, note that the rules differ under Medicare and Medicaid. Under Medicare, 90 days is sufficient for an EPs FIRST PAYMENT YEAR, regardless of what calendar year that is. For all subsequent payment years, the EP must report on the full year. After the first payment is received by the EP, every year is considered a payment year, whether or not an incentive is earned. So, while an EP can skip a year, he/she forfits the money for that year. Payment amounts are governed by the year in which they are received, not by what year it is for the EP. (p. 44319 of Final Rule.)
Yes, requirements are more relaxed under Medicaid, than Medicare for MU incentives. My posts relate to MediCAID, since that is my current client’s need. So, with that in mind:
Yes, John, under MediCAID, an EP can attest and then apply for the funds the very next day – no reporting period / requirements in first year. 90 consecutive days reporting in year 2 is required, and full-year reporting for all subsequent participation years.
For subsequent years, the targets are clear enough that EPs will be aware of whether or not they have complied just by reading the data before submitting it. The measures are listed, from which a certain number are selected to report. The denominator / numerator are clearly defined…as are the % targets for each measure. So an EP is able to monitor and strive to achieve the required % of encounters counseled about smoking, for example.
Indeed there are items still to be defined. Optometrists are not specifically included as EPs under the MediCAID MU rules – however, I have been told more than once by ONC that for FQHCs they will be, this is not yet written anywhere that I am aware of. Also, for larger clinics, tracking all the MU measures by EP will require significant effort; especially if EPs come & go during the reporting year.
[…] EHR Incentive Numbers Down – We’ve all heard the $36 billion in EHR incentive money. Of course, this is just the projection of how much EHR incentive money they’ll have to give out. I expect that when we get the total amount of EHR incentive money paid out in 2011 that it will be much lower than the projected targeted. Especially if many of them sit out 2011 and wait for 2012. […]
First question: In trying to decide whether to attest in 2011 and then have to report stage 1 yet again for the full calendar year in 2012 – I am considering attesting in 2012 but am I just delaying the inevitable? Is it conceivable I will still have to keep reporting stage 1 for a full calendar year ie: 2013 until CMS is ready for stage 2 which could be late 2013 or not until 2014? Second question: I read that there is one small difference between starting Stage 1 in 2012 vs 2011. I thought CMS wants the CQM data submitted electronically in 2012 either using a local Health Information Exchange or one that CMS has. I also understand that if CMS isn’t ready to recieve CQM data electronically then you can continue to “attest” to the CQM data in 2012 just like in 2011. Can you give me accurate information on this?
Jolene,
I think that’s a good thing if you don’t have to report on MU stage 2 until later. Delay that inevitable as long as possible. Might or might not be the best thing for healthcare and the spending of the incentive money, but is definitely the best thing for a clinic.
I’d heard something about your second point about submitting electronically. I think that’s what’s talked about in the comments on this thread: https://www.healthcareittoday.com/2011/09/12/how-critical-is-the-october-1-2011-deadline-%e2%80%93-meaningful-use-monday/ I’m not exactly sure. I’ll ask Lynn and some other people I know what they’ve heard about this.