Next year could be a big turning point for the healthcare industry with its ambitious goals to improve care quality and safety, reduce care costs, ensure adequate privacy and security of personal health information, and engage patients and families in their health. For many physicians, however, implementing all of these changes could be make or break, especially when it comes to one of the more immediate threats: Meaningful Use.
As part of the Medicare and Medicaid EHR Incentive Programs, eligible professionals (EPs), hospitals and critical access hospitals can qualify for incentive payments of up to $44,000 for Medicare or $63,750 for Medicaid as they adopt, implement, upgrade or demonstrate meaningful use of certified electronic health record technology. (To get the maximum incentive payment, Medicare eligible professionals must have begun participation by 2012.) There are specific requirements that hospitals and EPs must meet in order to participate in one of the Incentive Programs, in addition to criteria they must meet in order to qualify for incentive payments.
Meaningful Use objectives are designed to be met over the course of three stages, which span several years. Stage 1 started in 2011, Stage 2 is set to begin in 2014, and Stage 3 is scheduled to start in 2016. The Centers for Medicare & Medicaid Services (CMS) administers the EHR Incentive Programs with the help of the Office of the National Coordinator for Health IT (ONC).
If you are eligible to participate in one of the two programs, 2014 is going to be a decisive year – regardless of whether you are a Meaningful Use veteran, finishing up your first year of reporting, or still contemplating signing up for the program at all. Here are eight important things that you should know:
1. You need to upgrade to 2014 Edition certified EHR software.
Starting in 2014, all Meaningful Use reporting (for Stages 1 and 2) must be done using 2014 Edition certified EHR software. This certification criterion ensures that an EHR supports revised Stage 1 requirements, in addition to requirements for Stage 2. Systems that are 2014 Edition certified also include updates that set new baselines for interoperability, electronic health information exchange, and patient engagement.
Contact your EHR vendor to find out whether their software will meet certification criteria by 2014. You don’t want to be left empty-handed when your EHR’s 2011 Edition certification expires at the end of the year.
2. You can attest to Meaningful Use with multiple systems.
Some of the criteria for Stage 2 Meaningful Use require using patient portal technology, yet many EHRs either lack built-in patient portal capabilities or are limited in their ability to meet Meaningful Use measures. If your EHR does not have a patient portal, or if you are simply unhappy with the portal’s usability, you can choose to use an EHR-independent third-party patient portal solution and still attest to Meaningful Use, as long as both systems have 2014 Edition certification. Talk to your EHR and patient portal vendors about developing an interface to ensure both systems are connected.
3. There will be a special, 90-day reporting period in 2014 only.
The first year an EP participates in the Meaningful Use program, they must report for 90 days; however, they are required to report for 365 days each year thereafter. In order to accommodate providers whose EHRs are not yet 2014 Edition certified, in 2014 only, the ONC is allowing all EPs (regardless of which stage of Meaningful Use they are on) to report for just 90 days.
For those participating in the Medicare EHR Incentive Program, the reporting period is set to one calendar quarter during the eligible professional, hospital, or critical access hospital’s reporting year. What does this mean for EPs? They can begin reporting as late as October 1, 2014.
Medicaid EHR Program participants, on the other hand, in addition to those participating in the Meaningful Use program for the first time, will have an “any continuous 90-day” reporting period. Keep in mind, however, that providers are urged not to wait until the last minute to begin reporting.
4. 2014 is the last year you can begin participation in the Medicare EHR Incentive Program.
If you want to hold out a bit longer and register for the Meaningful Use program in 2015, you can do so but you won’t get any federal stimulus money out of it. In order to qualify for incentive payments through 2016, you must attest to Meaningful Use in 2014. Even if it’s your first year participating in the program, you can still qualify for up to $24,000 in incentives, paid out over three years.
5. If you don’t attest to Meaningful Use in 2014, you could face a penalty.
Not only can you lose out on incentive payments altogether by failing to attest to Meaningful Use next year, you also stand to receive a “penalty” in the form of a payment adjustment to Medicare reimbursements starting January 1, 2015. For EPs, the payment adjustment starts at 1 percent the first year, though it can be as high as much as 2 percent. Penalties will go up incrementally each year, to a maximum of 5 percent. To learn more about payment adjustments for hospitals, click here.
6. There will be changes to Meaningful Use Stage 1 objectives starting next year.
The chart below outlines the number of core and menu objectives for Meaningful Use Stage 1 that eligible professionals, hospitals and critical access hospitals must meet starting in 2014, compared to what those numbers were from 2011 to 2013. This tipsheet from CMS provides more information about the changes.
7. EPs will no longer be allowed to claim an exclusion as one of their menu objectives.
Before 2014, an EP could claim an exclusion to a menu objective and have it count as one of his or her five required objectives. Starting in 2014, however, EPs will no longer be permitted to do that if there are other menu objectives that they can meet. The only way an EP will be able to claim an exclusion is if they also qualify for the exclusions for all remaining menu objectives.
8. Be prepared for a Meaningful Use audit.
Just because you have submitted your attestation data, it doesn’t mean you’re in the clear. CMS may conduct audits before sending out incentive payments – and even after. Post-payment audits are meant to detect instances of fraud, in addition to inaccuracies in eligibility, reporting and payment. Up to 10 percent of EPs are audited each year, so be sure to save documentation that supports your attestation and payment calculations in case you are selected for an audit.