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Archive for May, 2014

Reminder: Meaningful Use Penalty Avoidance Deadline Approaching

May 28, 2014 1 comment

The application deadline for obtaining one of the significant hardship exception options from calendar year (CY) 2015 EHR Incentive Program penalties is July 1, 2014. Beyond the application-based hardship exception options, there are automatically-granted significant hardship exception options for newly practicing physicians and physicians whose primary specialty codes in PECOS are “diagnostic radiology” (30), “nuclear medicine” (36), “interventional radiology” (94), anesthesiology (05), or pathology (22) as determined approximately six months prior to the penalty year (so, also July 1, 2014).

Importantly, most American College of Radiology members will not need to take any further action to avoid the CY 2015 penalties other than to double-check their own PECOS data to make sure their primary specialty code is 30, 36, or 94. Radiation oncologists and other radiologists with different primary specialty codes will need to either demonstrate Meaningful Use (MU) by the appropriate deadline in 2014 or manually apply for one of the other significant hardship exceptions before July 1.

ACR Resources

Government Resources

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Categories: EHR, meaningful use, Medicare

CMS to Publish Proposed Rule to Allow Continued Meaningful Use of 2011 Edition Certified EHR Technology in 2014

May 21, 2014 1 comment

On May 23, 2014, the Centers for Medicare and Medicaid Services (CMS) will publish a Notice of Proposed Rulemaking (NPRM or “proposed rule”) that, if finalized, would allow EHR Incentive Program participants to continue to “meaningfully use” 2011 Edition certified EHR technology (CEHRT) in 2014, among other things. Currently, all participants in Stage 1 or Stage 2 Meaningful Use (MU) need 2014 Edition CEHRT in 2014 and beyond.

As a reminder, there is also a separate, ongoing rulemaking within the Office of the National Coordinator for HIT (ONC) that would introduce the availability of “2015 Edition” EHR certification criteria as an alternative to the 2014 Edition criteria for the certification of products used in the program. The American College of Radiology’s comments on the 2015 Edition rulemaking are available online.

The May 23 NPRM will have a public comment period of 60 days, so CMS and Office of Management and Budget will need to expedite the subsequent finalization and review processes to promulgate a final rule before the 4th CY quarter (October) final reporting period start time for prior MU participants. There has been no explanation as to why CMS used a NPRM process for something this time sensitive versus the quicker interim final rule or direct final rule processes.

Categories: EHR, meaningful use, Medicare

Busy Week: Federal HIT Policy Review

On May 14, the American College of Radiology (ACR) participated in the Food and Drug Administration (FDA), Office of the National Coordinator for HIT (ONC), and Federal Communications Commission public workshop on a risk-based strategy and framework for ensuring HIT safety and innovation. Dr. David Hirschorn (member, ACR IT and Informatics Committee) represented ACR on the expert panel that addressed clinical decision support subtopics. A webcast recording of the meeting should be available on the FDA’s website within the coming weeks.

On May 8, the American Medical Association (AMA) sent a letter to the Centers for Medicare and Medicaid Services (CMS) and ONC in response to a request for feedback on the Medicare/Medicaid EHR Incentive Program. The ACR and other national specialty societies provided input to the AMA in preparation for this letter. The letter calls for a radical reinvention of the EHR Incentive Program starting with a more flexible modification of the existing framework and ending with a return to the basic MU parameters of the statute.

On May 15, ONC announced that the HIT Policy Committee-MU Workgroup will convene two listening sessions for EHR Incentive Program participants, vendors, and other stakeholders. The May 20 listening session will include participating eligible professionals and eligible hospitals. The May 27 listening session will include payers, Regional Extension Centers, industry, and others. A series of questions to guide these sessions are available on ONC’s Health IT Buzz blog.

On May 16, CMS announced the availability of attestation process guidance for EHR Incentive Program participants in Stage 2. The relatively new resources include a robust guide and abbreviated worksheet.

Categories: EHR, FDA, meaningful use, Medicare

First Wave of Original HIT Policy Committee Members Rotate Off; Lead Member Reappointed

In accordance with the Office of the National Coordinator for HIT’s (ONC) new policy to limit HIT Policy Committee (HITPC) members’ service to six years, three members of the original 2009 roster rotated off after yesterday’s monthly meeting. Leaving are Dr. Arthur Davidson (Denver Public Health Department), representing advocates for patients or consumers; Dr. Neil Calman (The Institute for Family Health), representing expertise in improving the health of vulnerable populations; and Judith Faulkner (Epic Systems Corporation), representing IT vendors. Replacing them are Kim J. Schofield (Lupus Foundation), Dr. Christoph Lehmann (American Academy of Pediatrics), and Neal Patterson (Cerner Corporation), respectively. Individual HITPC members have left in the past due to career changes or other voluntary reasons.

Interestingly, Dr. Paul Tang was reappointed without an opportunity for public nominations for a third consecutive term as the physician representative and vice chair of the HITPC. Dr. Tang is the leading non-staff member of the HITPC and chair of the Meaningful Use (MU) Workgroup. Arguably, no other private sector individual has played a bigger role in helping shape CMS and ONC’s regulatory implementation of the EHR Incentive Program. It appears Dr. Tang will continue to lead the HITPC until his latest three-year term expires in 2017—eight years after the committee’s establishment, and two years beyond the service limit imposed on the other members.

Categories: EHR, meaningful use, Medicare