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CMS Releases Final Rule for Participants in EHR Incentive Programs

Posted by Matthew Smith on Sep 2, 2014 2:16:00 PM

EHR Incentive Program, Meaningful UseOn Friday, August 29, CMS released a final rule that allows providers participating in the EHR Incentive Programs to use the 2011 Edition of certified electronic health record technology (CEHRT) for calendar and fiscal year 2014. 

The rule grants flexibility to providers who are unable to fully implement 2014 Edition CEHRT for an EHR reporting period in 2014 due to delays in 2014 CEHRT availability. Providers may now use EHRs that have been certified under the 2011 Edition, a combination of the 2011 and 2014 Editions, or the 2014 Edition for 2014 participation.

Under the modified attestation schedule, providers that were not able to fully implement 2014 Edition certified EHR technology in time to successfully attest to meaningful use due to vendor delays will be able to use 2011 Edition CEHRT or a combination of 2011 and 2014 Edition to attest to either stage 1 or stage 2. Providers will also be able to attest to meaningful use under the 2013 reporting year definition and use 2013's clinical quality measures.

The College of Healthcare Information Management Executives has supported giving providers more options for attesting in what has been a challenging year for CIOs. However, the organization was disappointed the rule will still require a full year of attestation in 2015.

"Roughly 50 percent of eligible hospitals and critical access hospitals were scheduled to meet stage 2 requirements this year and nearly 85 percent of EHs and CAHs will be required to meet stage 2 requirements in 2015,” said CHIME CEO Russ Branzell in a statement. “Most hospitals that take advantage of new pathways made possible through this final rule will not be in a position to meet stage 2 requirements beginning Oct. 1, 2014. This means that penalties avoided in 2014 will come in 2015, and millions of dollars will be lost due to misguided government timelines.”

Beginning in 2015, all eligible providers will be required to report using 2014 Edition CEHRT.

2014 Participation Options

Under the rule, providers are able to use 2011 Edition CEHRT, and have the option to attest to the 2013 Stage 1 meaningful use objectives and the 2013 definition CQMs.

2011 CEHRT

Providers scheduled to meet Stage 1 or Stage 2:

Combination of 2011 & 2014 CEHRT

Providers scheduled to meet Stage 1:

Providers scheduled to meet Stage 2:

  • 2013 Stage 1 objectives and 2013 CQMs; or
  • 2014 Stage 1 objectives and 2014 CQMs; or
  • 2014 Stage 2 objectives and 2014 CQMs

2014 CEHRT

Providers scheduled to meet Stage 1:

  • 2014 Stage 1 objectives and 2014 CQMs

Providers scheduled to meet Stage 2:

  • 2014 Stage 1 objectives and 2014 CQMs; or
  • 2014 Stage 2 objectives and 2014 CQMs

CEHRT Flexibility Resources

To help the public understand the final rule’s changes to 2014 participation, CMS has developed the following resources:

  • CEHRT Interactive Decision Tool – providers answer a few questions about their current stage of meaningful use and Edition of EHR certification, and the tool displays the corresponding 2014 options.
  • 2014 CEHRT Flexibility Chart – chart provides a visual overview of CEHRT participation options for 2014.
  • 2014 CEHRT Rule Quick Guide – guide provides corresponding resources based on the option a provider chooses to participate in the EHR Incentive Programs in 2014.

Extending Stage 2

The rule also finalizes CMS and ONC’s recommended timeline to extend Stage 2 through 2016. The earliest a provider can participate in Stage 3 of meaningful use is now 2017.

For More Information

Visit the CMS Newsroom to read the press release about the final rule. For more EHR Incentive Programs resources, visit the CMS EHR website.

 

Topics: EHR, EMR, Meaningful Use, Electronic Health Records, CMS, HIT, Health IT, Provider, Final Rule

Implications of ACO & Clinical Integration on Provider Planning

Posted by Matthew Smith on Apr 3, 2013 2:28:00 PM

Strategic Provider PlanningHistorically, Medical Staff planning has focused on specialties that drive care to inpatient settings. Creating a strong primary care base to support specialists has been the strategy for many successful healthcare systems.

However, the paradigm is shifting and systems must re-evaluate their provider recruitment plans along the continuum of care.  This means looking at specialists and allied providers who can improve both preventative and post-acute care and thereby reduce admission/readmission rates and ER visits.

A recent survey completed by Jackson Healthcare (December 2012)  indicates that actual and planned practice acquisitions by health systems remain focused on the primary/inpatient care model. Specialties such as geriatric medicine, psychiatry, podiatry, physical medicine, pain medicine, nurse navigators, psychologists and other important outpatient based providers are much less likely to be on a targeted acquisition list.

As systems begin to re-evaluate their specialty mix under shared shavings or risk-based payment contracts, it will be important to look well beyond the high-profile specialists and develop a larger network of providers.

Determining this balance is typically based on a number of factors, including:

  • Local population demographics;
  • The provider specialty mix;
  • Age range and quality of existing physicians;
  • The range of ambulatory and community health services;
  • and the number of health systems in the market.

Claims data helps determine what types of providers are needed by specialty. Local subjective knowledge is also a key component in completing a provider plan since many factors can impact supply and demand.

Once the optimal specialty balance is determined for a health system, strategies for recruitment will be needed.  While acquisitions have been the recent trend, it is not the only avenue for recruiting needed providers. In fact, there are some indications that health systems will begin to divest or ‘off board’ physician practices that do not meet their cost reduction and quality outcome goals. This indicates a need for hospitals to become more creative with their physician alignment strategies, such as forming Management Services Organizations to help manage/integrate affiliated provider practices or PHOs with a more clinically integrated strategy.

Physician engagement is critical to the planning process and requires constant review particularly as systems begin to build their ACO and Clinical Integration programs. Among key questions to be asked are the following:

  • What are the largest disease groups/patient needs in the community?
  • What specialties are needed to address the preventative and post-acute care needs?
  • Does our health system have the appropriate balance or providers to meet these needs?
  • What is the best way to attract providers where gaps exist?
  • What is needed to integrate care delivery along the continuum?
Strategic Provider Planning, Specialty Mix

Topics: ACO, Clinical Integration, Provider, Medical Staff Planning, Strategic Provider Planning

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