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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 1 comment

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

ONC Federal Advisory Committees Hold Joint Meeting on Interoperability; Two Senior ONC Staff Leaving the Agency

October 16, 2014 Leave a comment

On October 15, the HHS Office of the National Coordinator for HIT (ONC) held a joint meeting of the HIT Policy Committee and HIT Standards Committee to discuss the draft interoperability roadmap, health information exchange (HIE: the verb, not necessarily the noun) governance, and the JASON Task Force recommendations. The outcome of the meeting was an approved set of broad recommendations to ONC indicating a desire to leverage open Application Programming Interfaces (APIs) as the foundational approach for nationwide HIE.

ONC also announced that two senior ONC staff, Dr. Doug Fridsma and Judy Murphy, would be attending their last federal advisory committee meeting as employees of the agency. Dr. Fridsma has been with the agency for four years and most recently served as Chief Science Officer. Judy Murphy most recently served as Deputy National Coordinator for Programs and Policy.

Categories: EHR, meaningful use, Medicare

CMS Addresses Attestation System Issue by Extending Significant Hardship Exception Application Deadline for Some

October 7, 2014 Leave a comment

Earlier today, the Centers for Medicare and Medicaid Services (CMS) announced that the significant hardship exception application deadline has been extended until November 30, 2014 for physicians who are eligible to use the September 4, 2014 flexibility AND who were unable to attest by the October 1, 2014 deadline for first-year participants.

What does this mean? This was CMS’ answer to the problem recently identified by the Medical Group Management Association (MGMA) pertaining to the timing of a planned update to CMS’ web-based attestation system. CMS plans to implement a system patch in October that would enable the agency to receive online attestations from participants using the September 4, 2014 flexibility. Unfortunately, the deadline for first-year program participants to complete their attestations for a 2014 reporting period already came and went on October 1. Therefore, if a first-year program participant intended to use the September 4 flexibility, they would have missed the deadline because of CMS’ unpatched system.

The number of first-year participants expected to require the latest extension is small. In radiology, most diagnostic radiologists, interventional radiologists, and nuclear medicine physicians did not need to apply for a significant hardship exception because they were automatically given one.

Categories: EHR, meaningful use, Medicare

CMS’ Timeline to Update the Meaningful Use Attestation System to Cause Problems for Some Physicians

September 25, 2014 Leave a comment

The Medical Group Management Association (MGMA) recently discovered an issue with the timing of a planned update to the Centers for Medicare and Medicaid Services’ (CMS) attestation system for the Medicare/Medicaid EHR Incentive Program. Apparently, the agency’s system will not be able to accept attestations tied to recently enabled flexibility until the middle of October 2014 or later.

Earlier this month, CMS and the Office of the National Coordinator for HIT (ONC) published a final rule to allow EHR Incentive Program participants to meaningfully use (MU) EHR technology with outdated (2011 Edition) certification status, coupled with the 2013 iteration of the Stage 1 MU requirements, in CY 2014. While limited in utility because of its late arrival in the calendar year, the rule allows participants who would otherwise miss out on this year’s MU incentive payments to still participate in the program in CY 2014. If audited in the future, participants who leveraged this flexibility would need to defend their inability to implement 2014 Edition certified EHR technology in time for their respective CY 2014 reporting periods.

Meanwhile, rookie EHR Incentive Program participants must have already begun their CY 2014 reporting periods by July, and must attest/report to CMS by October 1, to both get an incentive payment this year and avoid next year’s payment adjustments via compliance. Only those MU rookies who had the foresight to also obtain a significant hardship exception for 2015 will not encounter a timing problem.

Unless CMS expedites the update to the attestation system, or they extend the October 1 attestation deadline for MU rookies, any physicians who meet ALL of the following characteristics will be adversely affected:

  • Those eligible for the Medicare version of the EHR Incentive Program, who:
  • Are rookies in the EHR Incentive Program in 2014, AND,
  • Leverage the flexibility allowed by the September 4 rule, AND,
  • Failed to previously obtain a significant hardship exception to avoid negative payment adjustments in 2015.

Importantly, this problem impacts a relatively small subset of MU participants.  Also note that most (non-radiation oncologist) American College of Radiology members will not be affected because they were automatically granted a significant hardship exception for 2015 by CMS based on their primary specialty code in PECOS.

Categories: EHR, meaningful use, Medicare

Additional Information on MU Stage 1 and 2 “View/Download/ Transmit” (Patient Portal) Objective

September 18, 2014 3 comments

It has been a busy couple of weeks in the Medicare/Medicaid EHR Incentive Program. While everyone’s focus was on the Centers for Medicare and Medicaid Services’ (CMS) final rule to allow a certain subset of participants to meaningfully use (MU) EHR technology with outdated certification status, as well as on the Office of the National Coordinator for HIT’s (ONC) “Release 2” of the 2014 Edition EHR certification criteria, CMS distributed some clarifications regarding the Stage 1 and Stage 2 MU objective for “view/download/transmit (V/D/T),” also known as the “patient portal” or “PHR” objective. Most of this information was included in the September 2012 “Stage 2” final rule and the “Patient Electronic Access Tipsheet,” but it is worth repeating…

First, patients who choose not to access their health information (“opt out”) can be counted in the numerator of the Stage 1 and 2 “provide patients with ability” measure of the V/D/T objective if they are given all information needed to change their minds and access (or “opt in”) without having to reconnect with the provider. CMS’ example of doing this is when a patient is given a user ID and password combined with instructions about how to access the portal/PHR/patient website and how to create an account. Patients who choose not to access/opt out are required to be included in the denominator regardless.

Second, for the Stage 2-only second measure of “patients viewed, downloaded, or transmitted to a 3rd party” of that objective, patients who access their health information via an online personal health record (PHR) during the reporting period can be counted in the numerator for all eligible providers who contributed information to that PHR. The patient does not have to V/D/T the specific information contributed by an individual provider for it to count.

Third—and this is more obvious—everyone in a group practice is able to share credit for the Stage 2-only second measure of “patients actually viewed, downloaded, or transmitted to a 3rd party” if they each saw the patient during the same reporting period and are using the same certified EHR technology.

From a radiology perspective, I am constantly asked if imaging results need to be included in patient portal/PHR for the V/D/T objective. The answer is simply no—doing so would be beyond the minimum MU compliance requirements. The data elements that must be offered for V/D/T when updated are the “Common MU Data Set” in addition to the provider’s name and office contact information. Therefore, if all radiologists did was provide patients with access to key images and/or reports via the portal and did not include the Common MU Data Set, etc., this would actually not be in MU compliance. However, providing radiology information to the patient in addition to the basic data types required for MU may be desirable or even necessary for non-MU reasons, and it could give the patient a motivation to V/D/T their own health information on the radiologist’s portal for credit towards the second measure of the Stage 2 MU V/D/T objective.

Categories: EHR, meaningful use, Medicare
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