Meaningful Use

What Is Meaningful Use?


Meaningful Use Final Rule

September 04, 2014 

CMS released final rule for EHR Incentive Program which allows use of 2011 CEHRT in special cases the final rule for the EHR Incentive Program recently released by the Center for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology is not significantly different from the proposed rule published in May.

The final rule allows providers to use the 2011 Edition of certified electronic health record technology (CEHRT), a combination of the 2011 and 2014 Editions, or the 2014 Edition for participation in 2014. The rule spells out various options for providers who were unable to upgrade to 2014 CEHRT or upgraded to 2014 CEHRT and could not fully implement all of the new functions required for Stage 2.   These options are only applicable for providers whose inability to do either was directly related to vendor capability, such as the availability and timing of product installation, deployment of new processes and workflows, and employee training.

Beginning in 2015, all providers will be required to report using 2014 Edition CEHRT. The rule also indicates that Stage 3 is scheduled to begin in 2017. Click here to read the final rule


Orthopaedists need to meet several requirements to be eligible for the incentive funds, including using a certified EHR system and become a meaningful user, which is explained below. Starting in 2015, physicians who do not participate in adopting certified EHR systems and becoming meaningful users of this technology will risk receiving reduced Medicare payments. View the payment schedule for participation in the Medicare EHR Incentive Program here.

The penalty for not participating in the EHR Incentive Program begins in 2015. The penalty begins at 1 percent in 2015 and increases to 2 percent in 2016, 3 percent in 2017 and can go up to as much as 5 percent of your total Medicare Part B allowed charges. You must participate in the program two years preceeding the penalty year. The following options are available to avoid the penalty in 2015:

If your first year of reporting is 2014:  Attest by Oct. 1, 2014.

Future penalty years will require the following participation schedule.

Additionally, exemptions are available for physicians who lack availability of Internet access, are newly practicing physicians, face unforeseen circumstances (e.g. natural disaster), or have little interaction with patients. Learn how to apply for these exemptions.

Eligibility

CMS defines eligible providers (EP) for the Medicare EHR Incentive Program as:

  • A provider who is a doctor of medicine or osteopathy
  • A doctor of dental surgery or dental medicine
  • A doctor of podiatry
  • A doctor of optometry
  • A chiropractor who is not hospital-based 

CMS defines eligible providers (EP) for the Medicaid EHR Incentive Program as:

  • A physician
  • A nurse practitioner
  • A certified nurse-midwife
  • A dentist
  • A physician assistant who furnishes services in a federally qualified health center (FQHC) or rural health clinic (RHC) that is led by a physician assistant 

To qualify for an EHR incentive payment, Medicaid EPs must not be hospital-based and must have a minimum of 30 percent of their patient volume comprised of Medicaid patients. EPs must also be pediatricians and have at least 20 percent of their patient volume comprised of Medicaid patients or practice predominantly in a FQHC or RHC and have a minimum 30 percent patient volume attributable to needy individuals. Providers only may select one program in which to participate.


Stages

The EHR Incentive Program is divided into stages based on when the physician starts the program. Each stage requires different meaningful use objectives and becomes progressively more difficult as the program progresses. View which stage is relevant for each year of reporting here.

Registration and attestation

The first step for any provider who wishes to participate in the EHR Incentive Program is to ensure he or she selects an EHR software program that is certified for meaningful use  by the Certification Commission for Healthcare Information Technology (CCHIT). 

Orthopaedists can register for the EHR Incentive Program on the CMS website. Participants must be enrolled in the Medicare Provider Enrollment, Chain, and Ownership System (PECOS) and have a National Plan and Provider Enumeration System (NPPES) username and password.

The first year you participate in the program, there is a 90-day reporting period. Therefore, the last day to begin the program in your first year of reporting is on Oct. 1 of the reporting year. Participating from Oct. 1 to Dec. 31 will allow the physician to report for 90 days. Every subsequent year requires the provider to report for the full year, except for 2014 when all providers regardless of the stage they are reporting are allowed to report for a 90-day period.

After your practice has finished performing all of the meaningful use measures for that year, you must log back into the CMS website where you registered and attest. View the CMS guide to attestation here. This guide will help you navigate the attestation module.

Audits

Please note, CMS has up to 6 years to audit any documentation for meaningful use, so this information should be securely stored for at least a decade. Please note, one of the most common ways a physician can be audited is if their denominators for multiple measures do not match. For example, multiple measures have a denominator of unique patients. If this denominator is not the same for each measure that requires it, the physician will be at a higher risk for an audit. CMS requests that practices save any information supporting their attestation through the use of screen shots as well as data reflecting clinical quality measures. For more information, please visit the CMS website.

 

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