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CMS Proposes Adjusting Meaningful Use Timeline

Posted by Matthew Smith on Dec 10, 2013 11:48:00 AM

Meaningful Use, CMS, Meaningful Use DeadlineOn Friday afternoon, federal officials announced that CMS has proposed delaying the start of Stage 3 of the meaningful use program, while the Office of the National Coordinator for Health IT has proposed adjustments to its certification process.

Under the 2009 federal economic stimulus package, health care providers who demonstrate meaningful use of certified electronic health record systems can qualify for Medicaid and Medicare incentive payments.

Revised Meaningful Use Timeline

Under CMS' revised meaningful use timeline:

  • Stage 2 would be extended through 2016; and
  • Stage 3 would begin in 2017 for health care providers who have completed at least two years in Stage 2 of the program.

According to a blog post by Robert Tagalicod -- director of CMS' Office of E-Health Standards and Services -- and acting National Coordinator for Health IT Jacob Reider, the revised timeline would offer a variety of benefits, such as:

  • Allowing for more analysis of stakeholder feedback on Stage 2 progress and outcomes;
  • The availability of more data on Stage 2 adoption and measure calculations;
  • Allowing for more consideration of possible Stage 3 requirements;
  • Providing additional time for preparation for Stage 3 requirements; and
  • Giving vendors adequate time to develop and distribute certified EHR technology ahead of Stage 3 and to incorporate usability and customization lessons.

In the fall of 2014, CMS is expected to release a notice of proposed rulemaking for Stage 3 and ONC will release the corresponding NPRM for the 2017 Edition of ONC Standards and Certification Criteria, according to the blog post.

The NPRMs will offer additional details on the new proposed timeline.

The final rule on Stage 3 of the meaningful use program is expected to be released in the first half of 2015.

Changes to Certification Process

Meanwhile, ONC has proposed a new regulatory approach that would allow certification criteria to be updated more frequently.

According to officials, the change is designed to:

  • Provide public input on policy proposals;
  • Allow the certification processes to more quickly adapt to include newer industry standards; and
  • Provide more predictability for EHR developers.

As part of the new approach to certification, CMS will propose a rule to create a voluntary 2015 edition of certification criteria.

According to the blog post, the voluntary 2015 edition would:

  • Be responsive to stakeholder feedback;
  • Address issues identified in the 2014 certification edition; and
  • Reference updated standards and implementation guides designed to advance interoperability.

Because the 2015 edition would be voluntary, providers participating in the meaningful use incentive program would not be required to upgrade to 2015 edition EHR technology and vendors would not be required to recertify their products (Tagalicod/Reider, CMS blog post, 11/27).

Topics: Meaningful Use, Ambulatory EHR, EHR Adoption Rate, EHR Implementation, Small Practice EHR Adoption, Meaningful Use Deadline, EHR Adoption, MU

6 Things to Know about Meaningful Use and EHR Certification in 2014

Posted by Matthew Smith on Sep 20, 2013 3:50:00 PM

Meaningful Use, EHR, SixWith the 2014 EHR reporting period for meaningful use right around the corner, here are 6 key pieces of information you need to know:

#1. Does Meaningful Use (MU) Stage 1 Change in 2014?

Yes, the 2014 reporting period marks the beginning of a restructured meaningful use Stage 1.

Certain “core” and “menu” objectives have been removed/combined and eligible professionals (EPs), eligible hospitals (EHs), and critical access hospitals (CAHs) can no longer count measure exclusions toward meeting menu objectives. Equally important is that all Stage 1 EPs, EHs, and CAHs now need to provide more than 50% of unique patients with the ability to access their health information online (to meet the new Stage 1 core measure as part of the “View, Download, Transmit to 3rd Party” objective).

Graph 1

#2. Do All EPs, EHs, and CAHs Need to Upgrade to 2014 Edition Certified EHR Technology in 2014?

Yes, starting with the 2014 meaningful use reporting period all EPs, EHs, and CAHs need to upgrade to 2014 Edition EHR technology only – regardless of the meaningful use stage they need to meet.

The 2014 Edition EHR certification criteria support both revised MU Stage 1 and new Stage 2 requirements. They also include important updates that set new baselines for better interoperability, electronic health information exchange, and patient engagement. EHR technology certified to the 2011 Edition will no longer be acceptable for the purposes of meeting the “Certified EHR Technology” definition and from a regulatory perspective 2011 Edition certifications will “expire” come the 2014 MU reporting period.

#3. What is the Meaningful Use Reporting Period Length in 2014?

2014 has a special MU reporting period length for all non-first time EPs, EHs, and CAHs.

As a result, no EP, EH, or CAH (that previously demonstrated MU before 2014) has to start MU at the beginning of the Federal Fiscal Year (FY) [October 1, 2013] or Calendar Year (CY) [January 1, 2014].

The 2014 MU reporting period for both Stage 1 and Stage 2 performance is set to one calendar quarter during a Medicare EP, EH, and CAH’s reporting year (e.g., April 1, 2014 through June 30, 2014 would be a Medicare EP’s 2nd quarter and an EH/CAH’s 3rd quarter). All Medicaid EPs, EHs, and CAHs (as determined by their state) will have an “any continuous 90-day” or 3-month reporting period during 2014. Last, all new EPs, EHs, and CAHs continue to have an “any continuous 90-day” reporting period.

#4. What Happens if a Medicare EP, EH, or CAH Skips Meaningful Use in 2014 or Applies for a Hardship Exception in 2014 (to Avoid the 2016 Payment Adjustment)?

Once a Medicare EP, EH, or CAH starts meaningful use, it is required to continue to meet highermeaningful use stages according to the regulatory schedule set by the Centers for Medicare & Medicaid Services.

This policy applies even if the Medicare EP, EH, or CAH is granted a “hardship exception” for a given reporting year, it skips, or it fails. For example, regardless of whether an EP “passes,” “hardships,” “skips,” or “fails” their “Stage 1, Year 2” performance during 2014 they will be required to move up to “Stage 2, Year 1” in 2015 (with a full year reporting period) and will not get to repeat Stage 1 for a third year.

Medicaid EHR Incentive Program policy is different in two respects. First, the Medicaid program does not have payment adjustments, so hardship exceptions are unnecessary. Second, Medicaid providers are not required to participate in consecutive years of the Medicaid EHR Incentive Program (see Medicaid FAQ). Thus, unlike Medicare providers, Medicaid providers who skip years of participation will resume their meaningful use progression where they left off.  For example, if a Medicaid EP skips 2014 (which would otherwise be their “Stage 1, Year 2”) and also skips 2015 but comes back to the Medicaid program in 2016, they would be required to demonstrate “Stage 1, Year 2” in 2016 as if they never left the Medicaid program for those two years.

#5. When is the Last Year Medicare EPs Can Start Meaningful Use to Get Incentive Payments?

2014 is the last year in which an EP can begin to get incentive payments.

As stated in the Health Information Technology for Economic and Clinical Health (HITECH) Act, no incentives can be paid to Medicare EPs that begin MU after 2014.  EPs that start MU in 2014 could still earn as much as $24,000 in incentives if they demonstrate MU from 2014 through 2016.

#6. How Does 2014 Meaningful Use Performance Relate to Medicare Payment Adjustments?

2014 meaningful use performance is the basis for 2016 Medicare payment adjustments.

For EPs this potentially means a -2% reduction to the Medicare physician fee schedule (PFS) amount for covered professional services furnished by the EP during 2016 (EP tip sheet). The payment adjustment calculation for EHs and CAHs is a little more complicated and different for each. Here’s a link to CMS’ EH/CAH tip sheet.

 

Electronic Health Records EHR Assessment

 

Article courtesty of ONC's Health IT Buzz.

Topics: Meaningful Use, Ambulatory EHR, EHR Adoption Rate, EHR Implementation, Small Practice EHR Adoption, EHR Adoption

MGMA Urges Hold on Meaningful Use Penalties

Posted by Matthew Smith on Aug 26, 2013 10:53:00 AM
Meaningful UseCiting concern about vendor readiness and that "significant investments" in EHR technology could go for naught, MGMA leadership is calling on HHS for an indefinite moratorium on meaningful use penalties for physicians who have completed Stage 1 meaningful use requirements.

The association of physician practice administrators is one of several that has recently called on federal officials to adjust parts of the meaningful use program.

In an Aug. 21 letter to HHS Secretary Kathleen Sebelius, MGMA President and CEO Susan Turney wrote about physician concerns over the diminished opportunity for physician practices to meet the requirements of Stage 2.

MGMA represents 22,500 members who lead 13,200 organizations nationwide. Those physician practices include about 280,000 physicians that provide more than 40 percent of the healthcare services delivered in the United States.

In the letter, Turney notes: "Currently, there are more than 2,200 products and almost 1,400 'complete EHRs' certified under the 2011 criteria for ambulatory EPs. As of this writing, there are only 75 products and 21 complete EHRs certified for the Stage 2 (2014) criteria. This lack of vendor readiness has significant implications for EPs." 

"Without the appropriate software upgrades and timely vendor support," Turney continued, “EPs will be unable to meet the Stage 2 requirements and thus will be unfairly penalized starting in 2015.

Turney stressed the MGMA’s long-term support of federal efforts on meaningful use as a way to improve clinical performance and derive efficiencies.

"However, it has become clear that the alignment between the more rigorous Stage 2 requirements and the ability of the vendor community to produce and deploy Stage 2," she wrote.

In the letter, Turney details concern over marketplace readiness, citing lengthy wait times for installations and training.

"We are also concerned that the current 'all or nothing' approach to achieving meaningful use may prove to be problematic for EPs attempting to meet the more stringent Stage 2 requirements," she stated.

MGMA also put forth four additional recommendations:

  • Extend the reporting period for Stage 2 incentives by a minimum of one year.
  • Extend the reporting period for Stage 1 incentives for EPs whose EHRs have not been recertified by January 2015
  • Conduct a comprehensive vendor survey related to certification and readiness
  • Build additional flexibility in the Stage 2 reporting requirements. MGMA raises concerns over Stage 2 requirements related to patient actions, such as the requirement to provide patients the ability to view online, download and transmit their health information within four business days of the information being available to the EP and that a secure message was sent using the electronic messaging function of the certified EHR by more than 5 percent of unique patients.

MGMA joins several other groups, who have recently asked for adjustments to the meaningful use program.

In an Aug. 15 letter, HIMSS called on federal officials to keep Stage 2 of the program on schedule, while extending the attestation period for the first year. The organization also recommended extending the attestation period through April 2015 for eligible hospitals and through June 2015 for eligible providers.

CHIME has asked for a one-year delay of Stage 2, saying vendors need time to prepare and policymakers need more time to prepare for Stage 3.

The American Academy of Family Physicians asked CMS to delay Stage 2 by a year, asserting the program could "outstrip the capacity of many certified electronic health record technology vendors and ambulatory family medicine practices."

The timeline for physician compliance was too tight, wrote AAFP Board Chair Glen Stream, MD, in an Aug. 7 letter to Sebelius and other federal officials.

Topics: Meaningful Use, Ambulatory EHR, EHR Adoption Rate, EHR Implementation, Small Practice EHR Adoption, EHR Adoption

Important Deadlines Approaching for Meaningful Use Program

Posted by Matthew Smith on Jul 17, 2013 12:14:00 PM

Meaningful Use, Stage 2, EHR, EMRMeaningful use, the government program of financial rewards and penalties for encouraging doctors to use electronic health records (EHRs), has several important deadlines approaching.

October 3, 2013, is the last day doctors and other eligible professionals (EPs) can begin the attestation process to qualify for the first stage of meaningful use (MU1) in 2013.  (The reporting period for MU1 attestation is 90 days.)

February 28, 2014, is the final deadline for reporting attestation results for 2013 and qualifying for the Medicare MU financial bonus. The final 2013 deadline for Medicaid attestation varies from state to state, so EPs need to check with their state Medicaid agency to learn their state’s deadline. EPs qualifying for the first time in 2013 under the Medicare program will receive $15,000, and those qualifying under Medicaid will receive $21,250.

In addition, EPs will be able to begin attesting to the second stage of meaningful use (MU2) on January 1, 2014. The MU2 attestation period for 2014 will be 90 days, but in 2015 and beyond will be for a full calendar year. That’s because the MU certification requirements for EHR systems will change in 2014, says Robert Anthony, deputy director of the health information technology initiatives group in the Centers for Medicare and Medicaid Services. The briefer reporting period will give EPs additional time to acquire or upgrade to MU2-certified technology.

Medicaid EPs can choose any 90-day period in 2014 in which to attest, but Medicare EP attestation periods will start on January 1, April 1, July 1, or October 1.

Like MU1, qualifying for MU 2 requires meeting a series of core (required) and menu (optional) objectives. A complete list of MU2 objectives is available on the CMS Web site at www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Do....

A self-directed timeline showing the length of time required to demonstrate meaningful use at each stage and the maximum incentive payment for each year of participation is available at www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Participation-Timeline.html#.UcoEHOvgKS4.

  EHR, Meaningful Use, Stage 2

Topics: Meaningful Use, Ambulatory EHR, EHR Adoption Rate, EHR Implementation, Small Practice EHR Adoption, EHR Adoption

EHR Meaningful Use Dropout Rate Among Family Docs Hit 21% in 2012

Posted by Matthew Smith on Jul 8, 2013 4:30:00 PM

EHR, Meaningful UseAs US physicians continue to embrace electronic health records (EHRs), data on CMS' EHR incentive program holds both positive and troubling news regarding family physicians' participation and success in achieving meaningful use of their EHRs. 

According to CMS' recently published EHR meaningful use attestation data(healthdata.gov), 23,636 family physicians became first-time meaningful users in 2012. The number represents a 180% increase compared to 2011 EHR statistics.

In an interview with AAFP News Now, Jason Mitchell, MD, director of the AAFP's Center for Health IT, said the latest report confirms family medicine "still has the greatest participation both by percentage and by the numbers."

However, the report also revealed a drop in the retention rate of attesting physicians. In fact, of the 11,578 family physicians who attested to meaningful use in 2011, only 9,188 did so in 2012, a 21% drop in participation.

Mitchell and Steven Waldren, MD, the center's senior strategist for health care IT, crunched the raw numbers -- buried deep in the April attestation data -- and determined that the overall meaningful use dropout rate among all physician specialties was 20%.

Why the Tumbling Numbers?

The new data raise a key question: Why were a good number of physicians unable to maintain meaningful user status, especially since no changes were made in the meaningful use stage one requirements from 2011 to 2012?

Although there's no way to know for sure, Mitchell and Waldren cited some possible reasons for the decline.

Looming large on their list is the length of the reporting period. In 2011, physicians only had to report on measures for 90 consecutive days and could start, stop and shift dates to make that happen. However, during year two, the reporting period stretched to a full year. The extra reporting burden may have discouraged physicians. Others simply may have lost track of their progress during the year.

"For some physicians, the issue likely was a lack of ongoing monitoring of their meaningful use numbers throughout that entire year," said Mitchell.

And unfortunately, some physicians simply missed the two-month attestation window for 2012 reporting that ran from Jan. 1 to Feb. 28, 2013. "A physician could have been a meaningful user the whole year and then missed the attestation deadline," said Mitchell.

"Don't be that guy in the next round," said Waldren. "It's very important to check the timeline for 2013(www.cms.gov) and understand the deadlines for meaningful use."

In addition, 2012 saw a decrease in function of the federally funded regional extension center (REC) programs. According to Mitchell, the state-based organizations were designed to sign physicians on with a REC, assist physicians with EHR implementation, and then help them become meaningful users and successfully attest to MU.

The first year, the RECs were offered incentives to get physicians on board, but there was no built-in incentive for RECs to maintain physicians through the second year, and many of the RECs already were running out of funding to sustain their work, said Mitchell.

AAFP Working to Resolve Issues

To help ensure family physicians' future success with the meaningful use program, the AAFP already is working with CMS and the Office of the National Coordinator for Health IT to investigate, find answers and fix problems.

"Is there one particular measure that is tripping up physicians? If so, let's look at changing that," said Waldren. "Is the 12-month reporting period an obstacle? Do physicians need software that provides a 'dashboard' to enable them to track their progress?

"Let's work on identifying the problems and see what corrections can be made, because we want to be sure that 20% of our 2012 meaningful users don't drop off in 2013," said Waldren.

Mitchell and Waldren said physicians could ease the meaningful use burden by taking a few steps. For example, they encouraged members to

  • plan ahead by checking requirements and deadlines and then stay on top of those obligations,
  • crank out electronic meaningful use reports on a continuous basis to show progress toward meeting standards, and
  • ensure that an EHR's internal tracking mechanism for certain measures, such as the drug formulary and interaction features, are turned on for the entire reporting period.

"Such features could inadvertently be turned off by the vendor during a routine system update," said Waldren.

Mitchell expressed concern about physicians' desire to stay in the game when meaningful use two rules are applied in 2014. "The rules do change significantly, and technology has to be more sophisticated," said Mitchell.

And although the reporting period window collapses back down to three months for the first year of meaningful use two, the reporting must be done quarterly, so there can be no "shifting and shuffling" of dates to attain a consecutive 90-day reporting period. In 2015, meaningful use stage two will once again shift users to that full year of reporting, said Mitchell. 

Meaningful Use, Meaningful Use Incentives

Topics: Meaningful Use, Ambulatory EHR, EHR Adoption Rate, EHR Implementation, Small Practice EHR Adoption, EHR Adoption

New Study Suggests EHR Use Among Docs 60 and Older Below 30%

Posted by Matthew Smith on May 16, 2013 3:44:00 PM

EHR, Meaningful UseEHR use is much lower among older and independently practicing physicians, according to a new survey by the Deloitte Center for Health Solutions, with 30% fewer independent physicians using a meaningful use-capable EHR than their larger practice peers. 

Only half of physicians over the age of 60 use a full EHR, compared to approximately 70% of younger practitioners. With only 30% of solo practitioners using an EHR, and 81% believing that the promise of reduced costs after adoption is false, the EHR Incentive Program has some work to do among the smallest practices to convince them that EHRs are truly in their best interest.

It may be little surprise that EHR adoption is higher among younger age brackets, but coupled with recent research that shows older physicians would rather retire* than go through the bother and expense of an implementation – and the willingness of a quarter of physicians who might stop seeing Medicare and Medicaid patients to avoid the paperwork – it calls into question the effectiveness of the upcoming payment penalties associated with meaningful use.

According to the survey, 71% of solo physicians have no intention of implementing an EHR at the moment.  Already unable to afford the initial outlay costs, this leaves the most vulnerable segment of providers open to being hit hard by the 2015 payment adjustments.  Sixty-seven percent of physicians who do use an EHR say that the software interrupts their face-to-face patient interactions during an exam, something that solo practitioners and their patients tend to value highly.

Among physicians whose practices do have an EHR that meets meaningful use guidelines, overall satisfaction rated a middling 63%.  Faster billing, e-prescribing, and improved communication and care coordination were among the top benefits of using the system, with physicians involved in accountable care organizations significantly more likely to believe that communication and coordination were important highlights of EHR use.

“Skeptical physicians are likely to be more readily influenced by peers with credible firsthand clinical experience using HIT,” the report says, suggesting that providers talk to their neighbors about their trials and successes during adoption to gauge their own risks and rewards.  “Health IT underpins the future health care system and is a required tool for physicians. While apprehension may be understandable, inaction is not an option.”

Nearly half of medical professionals eligible for the meaningful use program have received an incentive check, according to the latest numbers released by the Centers for Medicare & Medicaid Services.

CMS said 255,772 out of an estimated 527,000 health care professionals got a total of $5.2 billion in incentive payments as of March. Of those, 160,890 received payment through Medicare; 83,765 were paid from Medicaid; and 11,117 received payment through the Medicare Advantage program. There are 386,024 physicians and other eligible professionals in the program (link).

CMS said 3,858 eligible hospitals have gotten a total of nearly $8.6 billion in incentive payments.

*Despite high satisfaction with EHR software and continued interest in tools like clinical decision support and e-prescribing, physicians are generally pessimistic about the future of medicine, with half believing that incomes will take a nosedive in the next one to three years, and 60% believing that many physicians will retire earlier than planned due to the frustrations of dealing with Medicare, Medicaid, the loss of independence, and the burdens of malpractice suits and liability laws.

Electronic Health Records EHR Assessment

Topics: Meaningful Use, Ambulatory EHR, EHR Adoption Rate, EHR Implementation, Small Practice EHR Adoption, EHR Adoption

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