CMS | EMR Thoughts

EHR Incentive Sequestration and Guidance on Meaningful Use Attestation

The CMS website has a great resource with answers to a number of FAQs. For example, here’s two questions that related to sequestration’s impact on EHR incentive and meaningful use attestation.

Question: Will incentive payments earned in the Medicare and Medicaid Electronic Health Records Incentive programs be affected by sequestration?

Answer: Incentive payments made through the Medicare EHR Incentive Program are subject to the mandatory reductions in federal spending known as sequestration, required by the Budget Control Act of 2011. The American Taxpayer Relief Act of 2012 postponed sequestration for 2 months. As required by law, President Obama issued a sequestration order on March 1, 2013. Under these mandatory reductions, Medicare EHR incentive payments made to eligible professionals and eligible hospitals will be reduced by 2%. This 2% reduction will be applied to any Medicare EHR incentive payment for a reporting period that ends on or after April 1, 2013. If the final day of the reporting period occurs before April 1, 2013, those incentive payments will not be subject to the reduction.

Please note that this reduction does not apply to Medicaid EHR incentive payments, which are exempt from the mandatory reductions.

Question: For the Medicare and Medicaid EHR Incentive Programs, how should an EP, eligible hospital, or critical access hospital (CAH) attest if the certified EHR vendor being used is switched to another certified EHR vendor in the middle of the program year?

Answer: If an EP, eligible hospital or CAH switches from one certified EHR vendor to another during the program year, the data collected for the selected menu objectives and quality measures should be combined from both of the EHR systems for attestation. The count of unique patients does not need to be reconciled when combining from the two EHR systems.

If the menu objectives and/or clinical quality measures used are also being changed when switching vendors, the menu objectives and/or quality measures collected from the EHR system that was used for the majority of the program year should be reported.

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April 25, 2013 I Written By John

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit.

Tags:CMS CMS FAQ EHR Incentives EHR Stimulus HITECH Sequestration

EHR Incentive Money and Sequestration Update

At HIMSS, the news was tweeted out about the impact of Sequestration on Meaningful Use and EHR incentive money. I’d seen little other details about the impact of sequestration on the EHR incentive money until now. CMS just sent out the following update on the mandated sequestration.

Mandated Sequestration Payment Reductions Beginning for Medicare EHR Incentive Program

Incentive payments made through the Medicare Electronic Health Record (EHR) Incentive Program are subject to the mandatory reductions in federal spending known as sequestration, required by the Budget Control Act of 2011.

Incentive Payment Reduction
The American Taxpayer Relief Act of 2012 postponed sequestration for two months. As required by law, President Obama issued a sequestration order on March 1, 2013. Under these mandatory reductions, Medicare EHR incentive payments made to eligible professionals and eligible hospitals will be reduced by 2%.

Reduction Timing
This 2% reduction will be applied to any Medicare EHR incentive payment for a reporting period that ends on or after April 1, 2013. If the final day of the reporting period occurs before April 1, 2013, those incentive payments will not be subject to the reduction.

Please note: This reduction does not apply to Medicaid EHR incentive payments, which are exempt from the mandatory reductions.

The 2% will be a little annoying for a doctor’s office, but the 2% off the multi-million dollar EHR incentive a hospital receives is going to add up to a pretty penny. At least the information is out there so that hospitals can plan. Although, it’s not like you can stop the EHR implementation at this point in the cycle.

HHS announces 2013 Healthcare IT Agenda

Centers for Medicare & Medicaid Services (CMS) Acting Administrator Marilyn Tavenner and the National Coordinator for Health Information Technology Farzad Mostashari, M.D., today announced HHS’s plan to accelerate health information exchange (HIE) and build a seamless and secure flow of information essential to transforming the health care system.

“Thanks to the Affordable Care Act, we are improving the way care is delivered while lowering costs,” said Acting Administrator Tavenner. “We are already seeing benefits, such as a reduction in hospital readmissions due to these reforms. Health IT and the secure exchange of information across providers are crucial to reforming the system, and must be a routine part of care delivery.”

This year, HHS will:

Set aggressive goals for 2013: HHS is setting the goal of 50 percent of physician offices using electronic health records (EHR) and 80 percent of eligible hospitals receiving meaningful use incentive payments by the end of 2013.
Increase the emphasis on interoperability: HHS will increase its emphasis on ensuring electronic exchange across providers. It will start that effort by issuing a request for information (RFI) seeking public input about a variety of policies that will strengthen the business case for electronic exchange across providers to ensure patients’ health information will follow them seamlessly and securely wherever they access care.
Enhance the effective use of electronic health records through initiatives like the Blue Button initiative. Medicare beneficiaries can access their full Medicare records online today. HHS is working with the Veterans Administration and more than 450 different organizations to make health care information available to patients and health plan members. HHS is also encouraging Medicare Advantage plans to expand the use of Blue Button to provide beneficiaries with one-click secure access to their health information.
Implement Meaningful Use Stage 2: HHS is implementing rules that define what data must be able to be exchanged between Health IT systems, including how data will be structured and coded so that providers will have one uniform way to format and securely send data.
Underscore program integrity: HHS is taking new steps to ensure the integrity of the program is sound and technology is not being used to game the system. For example, it is conducting extensive medical reviews and issuing Comparative Billing reports that identify providers.

The goals build on the significant progress HHS and its partners have already made on expanding health information technology use. EHR adoption has tripled since 2010, increasing to 44 percent in 2012 and computerized physician order entry has more than doubled (increased 168 percent) since 2008.

“The 2014 standards for electronic health records create the technical capacity for providers to be able to share information with each and with the patient,” said Dr. Mostashari. “Through the RFI, we are interested in hearing about policies that could provide an even greater business case for such information sharing.”

In addition to seeking public input, the RFI also discusses several potential new policies and ideas to accelerate interoperability and exchange of a patient’s health information across care settings so that they can deliver better and more affordable care to their patients.

The RFI can be found at http://www.ofr.gov/OFRUpload/OFRData/2013-05266_PI.pdf. Deadline for comments is April 21, 2013.

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March 8, 2013 I Written By John

Filed Under: Healthcare Healthcare IT

Tags:CMS Farzad Mostashari Government Health IT Healthcare Interoperability Healthcare IT Plans HHS HHS Agenda Marilyn Tavenner ONC

Meaningful Use Attestation Deadline for 2012 and MU Stage 2 Testing Ready

Eligible professionals (EPs) who participated in the Medicare Electronic Health Record (EHR) Incentive Program in 2012 must complete attestation for the 2012 program year by February 28, 2013. In order to be eligible to attest you must have completed your 2012 reporting period by December 31, 2012.

CMS encourages Medicare EPs to register and attest as soon as possible to resolve any potential issues that may delay their payment.

Medicaid EPs should check with their State for their attestation deadline.

Resources from CMS
CMS has several resources located on the EHR Incentive Programs website to help EPs properly meet meaningful use and attest, including:

A Registration & Attestation page that includes information on registration and attestation, and links to additional resources.
The Meaningful Use Attestation Calculator, which allows EPs and eligible hospitals to determine if they have met the Stage 1 meaningful use guidelines before they attest in the system.
The Attestation User Guide for Medicare Eligible Professionals, providing step-by-step guidance for EPs participating in the Medicare EHR Incentive Program on navigating the attestation system.
The Attestation Worksheet for Eligible Professionals, allowing users to enter their meaningful use measure values, creating a quick reference tool to use while attesting.

Also, for EHR vendors, ICSA just announced that they are now set to begin testing EHR software for meaningful use stage 2. That’s right. Meaningful Use stage 2 is just around the corner.

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January 16, 2013 I Written By John

Filed Under: EHR Electronic Health Record Electronic Medical Record EMR Healthcare IT HITECH Meaningful Use

Tags:CMS EHR Certification ICSA Meaningful Use Deadlines Meaningful Use Stage 2 Meaningful Use Timeline

MU Stage 3 Comment Period and Hospital EHR Attestation Deadline Approaching

HIT Policy Committee sent out an email with a request for comments on meaningful use stage 3. Here’s the email that was sent out:

Speak up now to help ONC’s Health Information Technology Policy Committee (HITPC) develop Stage 3 meaningful use recommendations that will target a collaborative model of care with shared responsibility and accountability, building upon previous meaningful use objectives through the Request for Comment.

The comment period is now open. Each item that the HITPC is requesting comment on has been given an identification number in order to streamline the accumulation of comments. Please use this ID number when submitting comments. Submit a comment online.

The deadline for comments is 11:59p.m. ET on January 14, 2013.

Following the analysis of the comments received throughout the comment period, the HITPC intends to revisit these recommendations in its public meetings in the first quarter of 2013.

Also, for those Eligible Hospitals and Critical Access Hospitals (CAHs), the last day for you to register and submit attestation in fiscal year 2012 for the Medicare EHR program is November 30, 2012. For eligible hospitals and CAHs, this means that they must successfully attest to meeting meaningful use to be eligible to receive an incentive payment for FY 2012.

CMS has also put together this PDF of the meaningful use and EHR incentive timeline. Be careful so you don’t miss any deadlines.

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November 27, 2012 I Written By John

Filed Under: EHR EHR Incentive Electronic Health Record Electronic Medical Record EMR Healthcare IT HITECH Meaningful Use

Tags:CAHs CMS Eligible Hospitals HIT Policy Committee Meaningful Use Deadlines Meaningful Use Stage 3 Meaningful Use Timelines ONC

October 3 is the Last Day for EPs to Begin the Medicare EHR Incentive Program in 2012

Wednesday, October 3rd marks two important deadlines for the Medicare EHR Incentive Program:

The last day for eligible professionals (EPs) to begin their 90-day reporting period for calendar year (CY) 2012 for the Medicare EHR Incentive Program. For EPs, this means that they must begin their consecutive 90-day reporting period by October 3rd in order to attest to meeting meaningful use and be eligible to receive an incentive payment for CY 2012.
The last day Medicare EPs can start participating and receive their maximum possible Medicare incentive payment. This is the last year that EPs can begin participation in the EHR Incentive Program and get the full Medicare incentives of $44,000 per EP. If first-year Medicare EPs have not started their 90-day reporting period by October 3rd, they will not be eligible for a CY 2012 payment, and can only receive $39,000 in Medicare incentives if they successfully participate in 2013.

For more information on how incentive payments are distributed, take a look at the EHR Basics page of the newly updated EHR website. For EPs who have already completed their reporting period, CMS has a number of tools available to help prepare for attestation, including the Meaningful Use Attestation Calculatorand Attestation User Guide for Eligible Professionals.

Looking Ahead
Take a look at all of the other EHR Incentive Program important dates that are coming up by going to our Health Information Technology Timeline.

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September 25, 2012 I Written By John

Filed Under: EHR EHR Incentive Electronic Health Record Electronic Medical Record EMR Healthcare IT HITECH Meaningful Use

Tags:CMS EHR Incentive Timeline EHR Stimulus Eligible Providers Medicare EHR Incentive Program

Meaningful Use Stage 2 Final Rule Published

UPDATE: For those not wanting to go through all 672 pages of the meaningful use stage 2 final rule, ONC has put out this summary PDF.

Today, CMS publishes the meaningful use Stage 2 Final rule in the Federal Register. The MU stage 2 final rule is 672 pages long.

The HHS press release announcing the EHR incentive money stage 2 final rule also offered these important points to note:

Make clear that stage two of the program will begin as early as 2014. No providers will be required to follow the Stage 2 requirements outlined today before 2014.
Outline the certification criteria for the certification of EHR technology, so eligible professionals and hospitals may be assured that the systems they use will work, help them meaningfully use health information technology, and qualify for incentive payments.
Modify the certification program to cut red tape and make the certification process more efficient.
Allow current “2011 Edition Certified EHR Technology” to be used until 2014.

The second point annoys me a little after hearing about some of the EHR certification fraud and issues it could cause providers that attest to meaningful use.

The press release also offered the following EHR incentive participation numbers:
-120,000 Eligible Health Professionals have participated
-3,300 Hospitals have participated
-More than half of all eligible hospitals and critical access hospitals and 1 out of every 5 eligible health care professionals

Watch for more detailed coverage of the meaningful use stage 2 final rule in our ongoing Meaningful Use Monday series.

Meaningful Use Stage 2 Comment Period Ends May 7th

ONC and CMS sent out the following email about the meaningful use stage 2 comment period. It closes very soon and so I encourage everyone to submit their comments on meaningful use stage 2. I’m a real proponent of the benefits of crowd sourcing and if enough people comment on meaningful use stage 2, I think we’ll receive the benefits of the crowd participating in the discussion and improving MU stage 2. I encourage doctors in particular to share their comments on the meaningful use stage 2 NPRM.

Please note that the comment period closes on Monday, May 7 for the notices of proposed rule-making (NPRMs) for Stage 2 of meaningful use and updated certification criteria.

The Office of the National Coordinator for Health IT (ONC) rule proposes the capabilities and related standards and implementation specifications that Certified EHR Technology will need to include to, at a minimum, support the achievement of “meaningful use” by eligible health care professionals beginning with the EHR reporting periods in FY/CY 2014. The rule also proposes revisions to the permanent certification program for health information technology, which include changing the name of the program to the “ONC HIT Certification Program.”

ONC’s rule complements the newly released Centers for Medicare & Medicaid Services (CMS) proposed rule for Stage 2 of the EHR Incentive Programs, clarifying the specifications necessary to meet the criteria for these programs.

Comments Can Be Submitted in 4 Ways

Both ONC and CMS rules identify that comments can be officially submitted in 4 ways:

Electronically through www.regulations.gov – this is the preferred method

Regular mail

Express mail or overnight mail

Hand-delivered/courier

Faxes are not accepted.

To enhance the public comment experience, ONC and CMS have made a copy of the rule available in Microsoft Word to make it easier those who comment to access and copy portions of their proposed rule for use in their individual comments. Visit http://www.healthit.gov/providers-professionals/meaningful-use-stage-2 for more information.

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May 4, 2012 I Written By John

Filed Under: EHR EHR Incentive Electronic Health Record Electronic Medical Record EMR Healthcare IT HITECH Meaningful Use

Tags:CMS EHR Certification EHR Stimulus Meaningful Use Stage 2 Meaningful Use Stage 2 NPRM MU Stage 2 ONC ONC HIT Certification Program

5010 Enforcement Delayed by CMS

The Twitterverse is alive with people tweeting about the news that Modern Healthcare broke about CMS deciding to delay enforcement of 5010 until June 2012. Here’s a quote from the article:

The CMS will not begin enforcing the mandated move to Version 5010 transaction standards for an additional three months, until after June 30.

In some ways this is just delaying the inevitable and giving payers a reason to delay their 5010 implementation even more. However, there were likely so many practices that wouldn’t get paid under 5010 and many payers who would be paying using the non-compliant 4010 that this was probably a smart move to delay. For those not that familiar with some of the issues, here’s a good post about how practices should deal with the move from 4010 to 5010. The post highlights the challenge to a practice when some payers are on 5010 and others aren’t yet ready for it.

I’d been hearing a lot of rumblings about the challenges of 5010, so this isn’t that big of a surprise. Although, you can be sure that CMS didn’t want to delay 5010. Particularly since CMS had recently delayed ICD-10 implementation as well. Although, I think fewer people will complain about this 5010 delay compared with those still arguing against the ICD-10 delay.

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March 15, 2012 I Written By John

Filed Under: 5010 Healthcare ICD-10

Tags:4010 5010 5010 Delay CMS ICD-10 ICD-10 Delay Modern Healthcare

Farzad Mostashari’s Post on Meaningful Use Stage 2 NPRM

I love that Farzad Mostashari and other people at HHS and ONC have been blogging about these exciting times in healthcare IT. Farzad recently did a post about the meaningful use stage 2 NPRM (see this Meaningful Use Monday post on Meaningful Use Stage 2). He starts off the post with some interesting numbers:

to date, more than 43,000 providers have received $3.1 billion to help make the transition to EHRs; the number of hospitals using EHRs has more than doubled in the last two years from 16 to 35 percent between 2009 and 2011; and 85 percent of hospitals now report that by 2015 they intend to take advantage of the incentive payments.

I’ve always found the ONC/CMS/HHS numbers to be a bit higher than reality. Although, I bet their hospital numbers aren’t too far off. There’s little doubt that hospitals are interested in EHR.

Farzad also offered the most succinct view of the 3 stages of meaningful use that I’ve seen. Here’s basically his vision for meaningful use:

Stage 1 (which began in 2011 and remains the starting point for all providers): “meaningful use” consists of transferring data to EHRs and being able to share information, including electronic copies and visit summaries for patients.
Stage 2 (to be implemented in 2014 under the proposed rule): “meaningful use” includes standards such as online access for patients to their health information and electronic health information exchange between providers.
Stage 3 (expected to be implemented in 2016): “meaningful use” includes demonstrating that the quality of health care has been improved.

I posted a comment on the blog post which is still waiting to be approved:

Some very interesting numbers and I appreciate the overall vision of what each stage will do. The first part of this post reminds me of what I heard at HIMSS, that ONC has become more of a marketing organization. I found that interesting since you could easily see why ONC is considered an EHR marketing organization.

These first year numbers are interest, but the second year numbers will matter even more. The first year numbers were likely those who already adopted EHR versus those that implemented EHR post-stimulus. Let’s hope the message that providers offer after they’ve implemented is that they love their EHR. If they start telling their colleagues that they hate the EHR that they were “forced” to implement because of the government carrots and sticks, then it will be quite disappointing.

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February 27, 2012 I Written By John

Filed Under: EHR EHR Incentive Electronic Health Record Electronic Medical Record EMR EMR Companies Healthcare IT HITECH Meaningful Use

Tags:CMS EHR Incentive EMR Stimulus Farzad Mostashari HHS Meaningful Use Meaningful Use Stage 2 Meaningful Use Stages ONC

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