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ACR Releases New Pocket Guide to Meaningful Use in 2015

January 15, 2015 Leave a comment

The American College of Radiology (ACR) recently released “ACR’s Pocket Guide to Meaningful Use (MU) in 2015,” a three-page overview of Medicare EHR Incentive Program requirements for radiologists. This free educational resource will be enhanced over time with new information and links to additional materials.

The 2015 version is the third iteration of this educational tool. The continued goal of the “Pocket Guide” series is to translate the vast, enormously complex regulatory framework of the Medicare EHR Incentive Program for eligible professionals into the shortest and most basic of summaries. Approximately 9 out of 10 questions I get from ACR members regarding Meaningful Use can be answered with this simple document and/or using the links provided within.

Note: Physicians interested in the State/Medicaid version of the program have additional fundamentals to learn beyond those discussed in this Medicare EP-specific resource.

Categories: EHR, meaningful use, Medicare

White House Reviewing CMS and ONC Proposed Rules to Update the EHR Incentive Program and HIT Certification Requirements

January 8, 2015 Leave a comment

The HHS Office of the National Coordinator for HIT (ONC) and Centers for Medicare and Medicaid Services (CMS) submitted proposed rules to update the EHR Incentive Program participation and technology certification requirements for White House Office of Management and Budget (OMB) Office of Information and Regulatory Affairs (OIRA) review. OIRA review is one of the final steps in the federal rulemaking process prior to submission to the Government Publishing Office’s (GPO) Office of the Federal Register (OFR). Public stakeholders will be able to access the text of these two Notices of Proposed Rulemaking (NPRMs) for the first time when they are placed on the OFR’s Public Inspection Desk. So, while we know that public release of the NPRMs is imminent (OIRA review could last up to 90 days – usually closer to a month or two), the only information we have about the content at the moment is included in the rough descriptions on OIRA’s website.

The description for CMS’ NRPM, “Electronic Health Record (EHR) Incentive Programs–Stage 3” (RIN: 0938-AS26), indicates that it will propose changes to “the reporting period, timelines, and structure of the program, including providing a single definition of meaningful use.” It goes on to say that “These changes will provide a flexible, yet, clearer framework to ensure future sustainability of the EHR program and reduce confusion stemming from multiple stage requirements.” Hopefully, this means physician participants will be rewarded with a new, much-needed infusion of flexibility this rulemaking cycle.

The description for ONC’s NPRM, “2015 Edition Health Information Technology (Health IT) Certification Criteria, Base Electronic Health Record (EHR) Definition, and ONC Health IT Certification Program Modifications” (RIN 0991-AB93), indicates that, beyond the normal coverage of ONC’s certification criteria rulemakings, it also “proposes a new 2015 Edition Base EHR definition and proposes to modify the ONC Health IT Certification Program to make it more broadly applicable to other types of health IT health care settings and programs that may leverage the ONC Health IT Certification Program.” Some of the proposals from last year’s “2015 Edition EHR Certification Criteria” NPRM—which later evolved into the “2014 Edition Release 2” final rule—indicated the agency’s ambition (despite the lack of an apparent need) to expand the certification program beyond Meaningful Use (MU) applications. Then, there were provisions in a 2014 CMS payment rule that called for certified products in long-term, post-acute care settings. The additional ONC proposals would presumably address the new non-MU certification need in LTPAC settings—or, it could even be more widely applicable. If the latter, the agency would need to be careful about generating undue confusion in a market that needs more MU-ready software.

Categories: EHR, meaningful use, Medicare

Federal HIT Strategic Plan – 2014 Update

December 10, 2014 1 comment

The HIT Policy Committee (HITPC) and HIT Standards Committee (HITSC) of the Office of the National Coordinator for HIT (ONC) focused on the recently updated Federal HIT Strategic Plan in rare back-to-back meetings December 9 and 10.

The revised Federal HIT Strategic Plan (released Monday) is an ARRA/HITECH-mandated, non-binding document to identify broad milestones over certain periods of time for federal agencies related to health IT, including dozens of agencies outside of HHS (NASA, Bureau of Prisons, DOD, Education, and so on). The update released for comment on Monday was the third version (2008 and 2011 being the priors). Critical to understanding the scope of this document, it does not address private sector/physician/industry activities or goals, but rather what outcomes government actors should strive for over the next 3 and 6 years.

Meanwhile, the anticipated “National Interoperability Roadmap” is expected to be published around January. Most importantly, the proposed rules to update the EHR Incentive Program participation and technology certification requirements are on the horizon for early 2015 (probably/maybe).

HHS Announces New ONC Data Brief on EHR Adoption Motivations

December 5, 2014 Leave a comment

Earlier today, the HHS Office of the National Coordinator for HIT (ONC) announced the publication of the ONC Data Brief No. 21, “Physician Motivations for Adoption of Electronic Health Records.” The data brief attempts to explore stakeholder decisions to move forward (or not) with EHR adoption.

Unfortunately, as with all EHR adoption reports based on the Centers for Disease Control and Prevention (CDC) NAMCS survey and supplemental surveys from 2011-2013, a large chunk of the EHR Incentive Program eligible professional (EP) population (nearly 17% if CMS’ EP denominator is to be believed)—anesthesiologists, pathologists, and radiologists—are explicitly not included. Moreover, the CDC/NAMCS concept of an “EHR” is not always aligned with the ONC’s regulatory concept of “certified EHR technology.” So, while the CDC survey data may be useful for some things, it is not particularly helpful for understanding overall physician views of CMS’ EHR Incentive Program.

This is not new.  The CDC’s annual surveys have omitted anesthesiology, pathology, and radiology data for years because they are based on a pre-ARRA understanding of the world. This kind of data would be more helpful if the surveyed population aligned with the real makeup of CMS and ONC’s stakeholders and better reflected the current, post-ARRA landscape.

Reminder: Last Chance to Participate in ACR’s Meaningful Use Survey

November 20, 2014 Leave a comment

This is the final opportunity to participate in the American College of Radiology’s (ACR) one-minute, 3-question survey for radiologists regarding the Medicare/Medicaid EHR Incentive Program. The survey will close shortly after the 2014 RSNA conference. The objective is to get a better understanding of radiologists’ decisions to participate or not participate in the program.

If you are a practicing diagnostic radiologist, interventional radiologist, nuclear medicine physician, or radiation oncologist, please take a moment of your time to complete the survey. Your responses will help inform future ACR advocacy and/or educational efforts.

Click here to participate in the ACR MU Survey

Categories: EHR, meaningful use, Medicare

Meaningful Use in 2014: Early Rookie Participation Numbers Very Low

November 6, 2014 Leave a comment

Every month, representatives from the Centers for Medicare and Medicaid Services (CMS) and Office of the National Coordinator for HIT (ONC) provide a report to the HIT Policy Committee regarding registration and attestation statistics for the EHR Incentive Program, or “Meaningful Use” (MU). These updates are usually unremarkable in that an overly optimistic view is portrayed via registration numbers, month-to-month incremental improvements, and total dollars paid. However, the November 2014 MU attestation statistics were more interesting than usual.

So far, only 43,898 eligible professionals (EPs) have successfully attested for MU in CY 2014. Of those, only 11,478 EPs have attested to Stage 2 MU. While low, the CY 2014 numbers should exponentially rise by the MU attestation deadline of February 28, 2015 for two important reasons: 1) the vast majority of MU attestations historically occur at the last possible minute, and 2) CMS’ September 2014 rule change to allow continued use of 2011 certified EHR technology (CEHRT) for qualifying participants. Therefore, it is hard to conclude anything about the program’s health by just looking at the November totals.

The aforementioned “interesting” part is this… Only 15,481 of those 43,898 attestations were from first-year MU participants. Recall that the attestation deadline for rookie EPs to avoid 2015 payment adjustments via MU compliance passed on October 1, 2014. Therefore, the November 2014 statistics in the report to the HIT Policy Committee included all rookie participants who made that deadline. In other words, these 15.5k rookies appear to represent the highest possible increase that can occur in MU participation rates in CY 2014 beyond the previous years (under the most optimistic of circumstances).

It gets a bit more complicated though… Recall that CMS reopened the significant hardship exception application period until later this month for the specific subset of participants who were unable to fully implement 2014 Edition CEHRT in time for a CY 2014 reporting period. While this “extension” was clearly meant for veteran MU participants who already had 2011 Edition CEHRT, it is unclear how many rookie MU participants might claim that particular hardship exception and have it hold up to audit (I expect at least several thousand will). So, we should anticipate at least a handful of rookies will attest for MU in CY 2014 using 2011 Edition CEHRT, AND will avoid 2015 penalties via the extended hardship exception.

All of that said, my point is this… Unless the “new participant” stat increases by hundreds of thousands, and not merely tens of thousands, the number of U.S. physicians who will be penalized throughout next year for noncompliance with MU is going to be staggeringly high.

Categories: EHR, meaningful use, Medicare

ACR Meaningful Use Survey for Radiologists

October 17, 2014 2 comments

The American College of Radiology (ACR) is conducting a very brief, one-minute, 3-question survey for radiologists regarding the Medicare/Medicaid EHR Incentive Program. The objective of the survey is to get a better understanding of radiologists’ decisions to participate or not participate in the program.

If you are a practicing diagnostic radiologist, interventional radiologist, nuclear medicine physician, or radiation oncologist, please take a moment of your time to complete the survey. Your responses will help inform future ACR advocacy and/or educational efforts.

Click here to participate in the ACR MU Survey

Categories: EHR, meaningful use, Medicare
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