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New CMS rule allows flexibility in certified EHR technology for 2014

The Department of Health and Human Services (HHS) published a final rule on August 29, 2014, that allows health care providers more flexibility in how they use certified electronic health record (EHR) technology (CEHRT) to meet meaningful use for an EHR Incentive Program reporting period for 2014. By providing this flexibility, more providers will be able to participate and meet important meaningful use objectives like drug interaction and drug allergy checks, providing clinical summaries to patients, electronic prescribing, reporting on key public health data and reporting on quality measures.

“We listened to stakeholder feedback and provided CEHRT flexibility for 2014 to help ensure providers can continue to participate in the EHR Incentive Programs forward,” said Marilyn Tavenner, CMS administrator. “We were excited to see that there is overwhelming support for this change.”

Based on public comments and feedback from stakeholders, the Centers for Medicare & Medicaid Services (CMS) identified ways to help eligible professionals, eligible hospitals, and critical access hospitals (CAHs) implement and meaningfully use Certified EHR Technology. Specifically, eligible providers can use the 2011 Edition CEHRT or a combination of 2011 and 2014 Edition CEHRT for an EHR reporting period in 2014 for the Medicare and Medicaid EHR Incentive Programs; All eligible professionals, eligible hospitals, and CAHs are required to use the 2014 Edition CEHRT in 2015.

These updates to the EHR Incentive Programs support HHS’ commitment to implementing an effective health information technology infrastructure that elevates patient-centered care, improves health outcomes, and supports the providers that care for patients.

The rule also finalizes the extension of Stage 2 through 2016 for certain providers and announces the Stage 3 timeline, which will begin in 2017 for providers who first became meaningful EHR users in 2011 or 2012.

See the full press release here:  http://cms.gov/Newsroom/MediaReleaseDatabase/Press-releases/2014-Press-releases-items/2014-08-29.html

See the EHR Incentive Programs 2014 CEHRT Ruke: Quick Guide here:  http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/CEHRT2014_FinalRule_QuickGuide.pdf

See the CEHRT Flexibility Decision Tool here:  http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/CEHRT_Rule_DecisionTool.pdf

Kelly Meeks

Sunrise Services, LLC

http://www.sunrize.com

Does the July 1, 2014 MU deadline apply to you?

Are you a bit confused on whether or not you should file an exception this year?  And what about that July 1, 2014 “deadline” fast approaching? 

With so much money…..both in incentives received and fear of losing money due to audits and penalties, we’ve summarized some information surrounding this “deadline” and what it may (or may not) mean for you and your practice.

New participants in 2014

If you are new to the program and intended to demonstrate meaningful use for the first time in 2014, but you are not able to implement 2014 certified EHR technology for the 2014 reporting year, you may apply for a hardship exception for the 2015 payment adjustment.  

An interactive tool is available to help you determine if you will avoid upcoming 2015 and 2016 Medicare EHR Incentive Program payment adjustments by demonstrating meaningful use, or if you should apply for a hardship exception.  The deadline to do this is JULY 1, 2014.  Please bear in mind that if you are a returning eligible professional, you will not need to file an exemption for 2014.

Applying for Hardship Exception When submitting hardship exception applications, entries must include supporting documentation that proves demonstrating meaningful use presented significant hardship.

CMS has posted hardship exception applications on the EHR website for:

Please read and follow the submission instructions on the application. Note that all required supporting documentation must be included at the time of submission. Completing your application online and submitting it electronically to EHRhardship@provider-resources.com, with all required supporting documentation, will reduce the application processing time. Please do not submit hand-written applications.

Hardship Exception Tip sheets You can also avoid payment adjustments by successfully demonstrating meaningful use prior to the payment adjustment.  Tip sheets are available on the CMS website that outline when eligible professionals must demonstrate meaningful use in order to avoid the payment adjustments.

Returning meaningful users in 2014

If you successfully demonstrated meaningful use for the 2013 reporting year, you will not be subject to the 2015 payment adjustment.  If you are not able to implement 2014 certified EHR technology for a 2014 reporting period, you may apply for a hardship for the 2016 payment adjustment.

  • Use the eligible professional hardship exception for 2016 which will be available after July 1, 2014
  • Indicate that you are applying for a hardship because of 2014 vendor issues
  • Submit your application by July 1, 2015

 Want more information about the EHR Incentive Programs? Make sure to visit the Medicare and Medicaid EHR Incentive Programs website for the latest news and updates on the EHR Incentive Programs.

Why this doctor loves electronic medical records

Medisoft Clinical is a fully integrated EMR system.

Dr. Jen Gunter

There is a recent and interesting piece in the Washington Post by an orthopedic surgeon, Dr. Craviotto, about the maddening aspect of forced mandates and bureaucratic requirements in medicine that seem to have very little to do with actual medical care and more about hoops through which we must jump that seemingly lead to nowhere.

While I do find the bureaucracy of medicine in the United States insane versus the Canadian system (for example) I was interested in Dr. Craviotto’s take on the burden of the forced electronic health record (EHR) mandate and the time that doctors spend filling out “unnecessary fields” to satisfy regulatory measures. Dr. Craviotto writes that his isn’t an unique complaint, quoting a study commissioned by the American Medical Association that identified “Poor EHR usability, time-consuming data entry, interference with face-to-face patient care, inefficient and less fulfilling work content, inability to exchange health information between EHR products, and…

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Other changes for 2014

sunriselogo2009With all the chatter going on with ICD-10, I thought it appropriate to write something that doesn’t revolve around ICD-10.  There are changes in Meaningful Use stage 1, and new criteria for Stage 2 Meaningful Use, Clinical Quality Measures and PQRS.  Happy reading!

If you have attested for at least 2 years for stage 1 meaningful use, then stage 2 is next on the docket for your practice. If you have attested once for stage 1 then all those things you attested to before now will change this year. Stage 1 requirements change in 2014 as well as Stage 2 Meaningful Use objectives for those of you who have successfully completed two years of Stage 1.

 Let’s first tackle those changes in 2014 to Stage one Meaningful Use:
1. Electronic Health Record (EHR) software systems have to re-certify their product to meet new regulations for 2014. Right now your current EHR has undergone the certification process for 2014 and will be available early spring of 2014.
2. For those of you that plan on doing stage 1 in 2014, certain “core” and “menu” objectives have been removed/combined and you can no longer count measure exclusions toward meeting menu objectives. You will have to meet 5 of the 9 menu items and 13 (as opposed to 15 in previous years) core objectives.
3. Clinical Quality Measure reporting will change as well. You will have to report on 9 and those 9 need to cover at least 3 of the 6 National Quality Strategy Domains. I’ve explained more later on.
4. Reporting is done in one calendar quarter, as opposed to 90 consecutive days previously (for example, April 1 2014- June 30, 2014). Rules for Medicaid incentive have not changed for 2014 so you can report for any continuous 90 days under Medicaid.
5. This is the last year you are eligible to begin to get incentive payments. If you are planning to start your first year this year you can still earn as much as $24,000 in incentives. AND your meaningful use performance in 2014 will be the basis for 2016 payment adjustments.
6. CPOE Denominator changes-now required (you will not be able to exclude from this measure).
7. Vital sign age limit is 3 years and older (changed from 2 years and older) for blood pressure and no age limit on height and weight. Since BP is separate, you can exclude from the BP measure.
8. The old stage 1 requirement for providing patients with an electronic copy of their health information upon request will be changed in 2014 to “Provide patients the ability to view online, download and transmit their health information within 4 business days of the information being available to the EP”.
9. The old stage 1 requirement for providing patients timely electronic access to their health information within 4 business days will be changed in 2014 to “More than 50 percent of all unique patients seen by the EP during the EHR reporting period are provided timely (within 4 business days after the information is available to the EP) online access to their health information subject to the EP’s discretion to withhold certain information”.

Moving on to what is next with Stage 2 Meaningful Use.

Stage 2 retains the same basic structure as Stage 1; however, all those Menu items in stage 1 become CORE items for Stage 2 with higher thresholds that you must achieve. There are also some new Stage 2 core and menu objectives.

STAGE 1

STAGE 2

 

13 Core Objectives 17 Core Objectives
5 of 10 Menu Objectives + 3 of 6 Menu Objectives
18 total objectives 20 total objectives

+CQM’S

=STAGE 2 MEANINGFUL USE

What are the requirements?
17 Core Objectives – These are objectives that everyone who participates in Stage 2 must meet. Some of the core objectives have exclusions, but many do not.
3 of 6 Menu Objectives – You only have to report on 3 out of the 6 available menu objectives for Stage 2. You can choose objectives that make sense for your workflow or practice. Again, some of these objectives have exclusions.

The following is a list of the Stage 2 Meaningful Use 17 Core Objectives
1. Use computerized provider order entry (CPOE) for medication, laboratory and radiology orders
2. Generate and transmit permissible prescriptions electronically (eRx)
3. Record demographic information
4. Record and chart changes in vital signs
5. Record smoking status for patients 13 years old or older
6. Use clinical decision support to improve performance on high-priority health conditions
7. Provide patients the ability to view online, download and transmit their health information
8. Provide clinical summaries for patients for each office visit
9. Protect electronic health information created or maintained by Certified EHR Technology
10. Incorporate clinical lab-test results into Certified EHR Technology
11. Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research, or outreach
12. Use clinically relevant information to identify patients who should receive reminders for preventive/follow-up care
13. Use certified EHR technology to identify patient-specific education resources
14. Perform medication reconciliation
15. Provide summary of care record for each transition of care or referral
16. Submit electronic data to immunization registries
17. Use secure electronic messaging to communicate with patients on relevant health information
In addition to the 17 core objectives, there are 6 Menu Objectives (and remember, you’ll only have to do 3 of the 6).
1. Submit electronic syndromic surveillance data to public health agencies ($-for the additional interface)
2. Record electronic notes in patient records
3. Imaging results accessible through CEHRT
4. Record patient family health history
5. Report cancer cases to a public health central cancer registry
6. Report specific cases to a specialized registry
Important Note: While there are exclusions provided for some of these menu objectives, you cannot select a menu objective and claim the exclusion if there are other menu objectives that you could report on instead.

Changes to Clinical Quality Measures
Beginning in 2014, the reporting of clinical quality measures (CQMs) will change for all providers.
You have the option of submitting three months of CQM data online through the CMS Registration & Attestation System. This will be the same website you go to for attestation now.
You also have the option to submit a full year of data electronically using the QRDA format to receive credit for the EHR Incentive Program and the Physician Quality Reporting System.
Please note that your attestation for the Medicare EHR Incentive Program is not complete until you submit clinical quality measure data, so your EHR incentive payment will be held until your electronic submission is processed.
If you are a provider using Medicaid, you must submit your clinical quality measurement data to your State Medicaid Agency.
How to Select CQM’s in 2014
Beginning in 2014, eligible professionals must select and report on 9 of a possible list of 64 approved CQMs for the EHR Incentive Programs.
There is also a new requirement in 2014 that the quality measures selected must cover at least 3 of the 6 available National Quality Strategy (NQS) domains, which represent the Department of Health and Human Services’ NQS priorities for health care quality improvement. The 6 domains are:
• Patient and Family Engagement
• Patient Safety
• Care Coordination
• Population and Public Health
• Efficient Use of Health Care Resources
• Clinical Processes/Effectiveness
In short there are a lot of changes this year in addition to ICD-10 implementation.

Stay tuned….

Sunrise Services, LLC

 

Submit Quality Data for 2013 PQRS-Medicare EHR Incentive Pilot by February 28, 2014

Are you an eligible professional who is participating or wishes to participate in the 2013 PQRS-Medicare EHR Incentive Pilot? You can now submit your 2013 quality data.

 If you would like to participate in the pilot you must submit 12 months of CQM data by February 28, 2014 at 11:59 pm ET.

To successfully participate in the pilot, you must do the following by February 28, 2014:

  1. Register for an IACS account (for EHR submission only)
  2. Indicate intent to report CQMs using pilot in EHR Registration & Attestation System
  3. Generate required reporting files
  4. Test data submission
  5. Submit quality data

If you cannot submit your CQM data for 12 months electronically through PQRS, you must return to the EHR Attestation System and deselect the electronic reporting option.  Please note: if you do not submit your 2013 quality data or deselect the electronic reporting option in the EHR Attestation System, you will not receive an EHR incentive payment.

Didn’t participate in eRx in 2012 or 2013? Here’s what you need to know.

Didn’t participate in eRx in 2012 or 2013? Here’s what you need to know.

If you were not a successful electronic prescriber under the 2012 or 2013 eRx, or Electronic Prescribing Incentive Program:
• You will be subject to a payment adjustment in 2014.
• The final 2.0% eRx payment adjustment will be applied during the 2014 calendar year.
That means you will only receive 98% of your Medicare Part B PFS amount for covered professional service in 2014. CMS will notify you if you are subject to the 2014 eRx payment adjustment.

Medicare EHR Payment Adjustments

If you are eligible to participate in the Medicare EHR Incentive Program:
• If you have not successfully demonstrated meaningful use, payment adjustments will be applied beginning January 1, 2015.
• The adjustment is determined by the reporting period in a prior year.

Additional eRx Impact for Medicare EHR providers with a 2015 Payment Adjustment
If you were not subject to the 2014 eRx payment adjustment:
• Your 2015 EHR payment adjustment will be 1%.
If you were subject to the eRx adjustment:
• Your 2015 EHR payment adjustment will be 2%.

To Avoid Medicare Payment Adjustments

If you successfully participated in the Medicaid or Medicare EHR Incentive Program and demonstrate meaningful use before 2015 or if you are eligible for a hardship exemption, you may be able to avoid the payment adjustment.

Note: If you are eligible to participate in both the Medicare and Medicaid EHR Incentive Programs, you MUST demonstrate meaningful use to avoid the payment adjustments. You may demonstrate meaningful use under either Medicare or Medicaid.
Learn more by reviewing the Payment Adjustments & Hardship Exceptions Tipsheet for Eligible Professionals.
Request an eRx Informal Review
You can request an informal review if you were notified that you will be subject to the 2014 eRx payment adjustment. Informal review requests can be submitted to eRxInformalReview@cms.hhs.gov through February 28, 2014.

For More Information
Make sure to visit the EHR Incentive Programs website for the latest news and updates on the EHR Incentive Programs.

Visit the CMS EHR Incentive Programs website

www.sunrize.com

ICD-10 Testing Week: March 3-7, 2014

On October 1, 2014, the ICD-9 code sets used to report medical diagnoses and inpatient procedures will be replaced by ICD-10 code sets. To help you prepare for this transition, CMS announces a national testing week for current direct submitters (providers and clearinghouses) from March 3 through 7, 2014.
This testing week will give trading partners access to the Medicare Administrative Contractor’s (MACs) and Common Electronic Data Interchange (CEDI) for testing with real-time help desk support. The event will be conducted virtually. Registration is required.
What you can expect during testing:
• Test claims with ICD-10 codes must be submitted with current dates of service (i.e. October 1, 2013 through March 3, 2014), since testing does not support future dated claims.
• Test claims will receive the 277CA or 999 acknowledgement as appropriate, to confirm that the claim was accepted or rejected in the system.
• Testing will not confirm claim payment or produce remittance advice.
• MACs and CEDI will be staffed to handle increased call volume during this week.
More information is available in MLN Matters® Article MM8465, “ICD-10 Testing with Providers through the Common Edits and Enhancements Module (CEM) and Common Electronic Data Interchange (CEDI).”

www.sunrize.com

Gov. Officials: Meaningful Use Timeline Delay Not a Setback

Federal health IT officials announced last week that stage 2 of the “meaningful use” EHR Incentive Program will be extended through 2016, with stage 3 starting in 2017 for those who have completed two years of stage 2. The move extends stage 2 for one year beyond the original end date, and pushes back the start date of stage 3.

The delay was welcomed by lawmakers and provider groups who had been pushing for delays for months. But back in July, former Office of the National Coordinator for Health Information Technology (ONC) head Farzad Mostashari, MD, insisted that the meaningful use program stay on its original timeline in a Senate hearing. In the hearing, Mostashari said he feared that delaying implementation of the program “would stall progress that’s been hard fought.”

Judy Murphy, RN, FACMI, FHIMSS, FAAN, deputy national coordinator for programs and policy at ONC, does not view the delay in meaningful use’s timeline as a setback. Instead, she points to the program’s successes to date.

“We actually have a joint goal that we monitor and track against with CMS and I think we’re both very pleased with the numbers, particularly in the provider space,” Murphy said in an interview with the Journal of AHIMA. “Look at the kind of progress we’re getting, and to know we’re already outlaying $17 billion (in incentive payments) is actually quite good, and that is the October number given at a policy committee meeting last week.”

In a jointly written blog post announcing the program’s altered timeline, Robert Tagalicod, director of the office of e-health standards and services at the Centers for Medicare and Medicaid Services, and Jacob Reider, MD, acting ONC national coordinator, outlined benefits of the proposed delay:

• More analysis of feedback from stakeholders on stage 2 progress and outcomes
• More available data on stage 2 adoption and measure calculations—especially on new patient engagement measures and health information exchange objectives
• More consideration of potential stage 3 requirements
• Additional time for preparation for enhanced stage 3 requirements
• Ample time for developers to create and distribute certified EHR technology before stage 3 begins, and incorporate lessons learned about usability and customization

Taken from: http://journal.ahima.org/2013/12/10/cms-onc-delay-stage-2-meaningful-use-timeline/#!

Learn How to Avoid the 2015 PQRS Payment Adjustment

Providers considered eligible and able to participate in the Physician Quality Reporting System (PQRS) may be subject to payment adjustments beginning in 2015. Eligible professionals (EPs) and group practices that fail to satisfactorily report data on quality measures during the 2013 program year will be subject to a 1.5% payment adjustment of their Physician Fee Schedule (PFS) charges beginning in 2015.
Individuals and group practices participating in PQRS must meet one of the following criteria to avoid payment adjustments in 2015.

Criteria for Individual EPs

EPs can avoid the 2015 payment adjustment if one of the following criteria is met during the 2013 PQRS program year:
1. Meet the requirements outlined in the 2013 PQRS measure specifications* (this will enable the EP to earn a 2013 PQRS incentive payment of 0.5% of their covered Medicare Part B charges)
2. Report at least:
One valid measure via claims, participating registry, or through a qualified Electronic Health Record (EHR) OR
One valid measures group via claims or participating registry
3. Elected to participate in the administrative claims-based reporting mechanism October 18, 2013

Criteria for Registered Groups (ACO/PQRS GPRO)

Group practices participating in the Group Practice Reporting Option (GPRO) can avoid 2015 payment adjustments if one of the following criteria is met during the 2013 PQRS program year:
1. Group meets the following requirements, outlined in the 2013 PQRS GPRO Fact Sheet
Report specific ACO/GPRO measures through the Web Interface OR
Report at least 3 registry measures (for 80% of the group’s eligible patients for each measure) for the GPRO outlined in the 2013 PQRS Measure Specification for Claims/Registry Reporting of Individual Measures
2. Report at least one valid measure through the Web Interface OR participating registry
3. Elected to participate as a GPRO in the administrative claims-based reporting mechanism by October 18, 2013

Note: Administrative claims-based reporting is not available to ACO GPROs

Resources
View the PQRS Payment Adjustments Tip Sheet for more information on how to avoid the 2015 payment adjustment.
For more information or support on the PQRS program, please visit the PQRS Incentive Program website or the Help Desk.
*Note: The asterisk indicates resources are in a zip file.