Home > EHR, meaningful use, Medicare > CMS’ Timeline to Update the Meaningful Use Attestation System to Cause Problems for Some Physicians

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

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(ONC) published a final rule to allow EHR Incentive Program participants to meaningfully use (MU) EHR technology with outdated (2011 Edition) certification status, coupled with the 2013 iteration of the Stage 1 MU requirements, in CY 2014.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.

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Categories: EHR, meaningful use, Medicare
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