Technology

EHR: An Update on Meaningful Use

Know the stages of new regulations

Lisa Shaw, COE, Brookville, Pa.

As regulatory environments evolve, keeping up with meaningful use requirements, incentives and payment adjustments can be a challenge. The issue is also complicated by requirements that EHR vendors must modify, test and certify their products within a narrow timeline. Practice managers are growing understandably concerned about meeting looming deadlines and their ability to access necessary resources.

This article will take a look at meaningful use regulations and deadlines, as well as help you understand how to qualify for the incentives and avoid penalties.

Stage 1 Attestation and Avoiding Penalties

A common complaint among practices involves confusion as to when a practice must attest for Stage 1 Year 1 to avoid penalties. Many practices are mistakenly under the impression they have until the end of 2014 to avoid a 1% payment adjustment. The Stage 2 final rule (published September 4, 2012) established a timeline of October 1, 2014 for completing the required 90-day EHR attestation and reporting in order to avoid the payment adjustment. If you delay your attestation period to the end of 2014, you will be subject to the 1% payment adjustment that takes effect January 1, 2015.

Misunderstanding this deadline can be devastating for a practice trying to develop an implementation timeline. Practices expecting to avoid the penalty in 2015 should already be well on their way to implementing an EHR system. Be sure to allow time to install new hardware, configure software and train new staff. Allow additional time to double check steps in your workflow. Do this by running reports and monitoring progress prior to, and during the practice’s attestation period. You don’t want a surprise when you get down to the last day you can possibly attest and run the report only to find that a measure went unmet.

The Y axis represents the first year of participation for a practice (Stage 1) - the exact year depends on when a practice successfully registers and demonstrates meaningful use. The X axis represents the continuum of meaningful use. For example, a practice that demonstrates meaningful use in 2012 for Stage 1, would be in Stage 1 for 2012 and 2013, progressing (or qualifying) for Stage 2 in 2014, and then progressing/qualifying for Stage 3 in 2016. (Table courtesy of BSM Consulting.)

Qualifying for Stage 2

CMS originally required a provider who first demonstrated meaningful use in 2011 to meet the Stage 2 criteria in 2013. The final rule delayed the onset of Stage 2 to calendar year 2014, giving eligible providers more time to meet the Stage 2 criteria. The table (page 16) highlights the delay to 2014 and illustrates progression of meaningful use stages from when a Medicare provider begins participation in the program.

Attestation Period

In the first year of participation, providers must demonstrate meaningful use for a 90-day EHR reporting period. In all subsequent years, providers will demonstrate meaningful use for a full-year EHR reporting period except in 2014. During 2014, all providers, regardless of their stage of meaningful use, will have a three-month attestation period. This reporting period is fixed to either the first, second, third, or fourth quarter of 2014. This is different from Stage 1 Year 1, in which you could attest for any 90-day period throughout the year. This puts specific time limits on when your attestation will start and stop.

Previously, you were able to randomly choose your start date as long as it was 90 calendar days. Unfortunately, if you are unable to meet one measure during the quarter in which you intend to attest, you will now have to wait and attest in the next quarter, not just change your start date so that you’ve met all measures. CMS is permitting this one-time change because it was determined that most vendors who must upgrade to 2014 Certified EHR Technology would not have a product ready in order to do a full year of Stage 2 in 2014.

Reporting Clinical Quality Measures (CQM)

Another change for 2014 is that you will now be required to submit your CQM electronically. Previously, you were able to attest to the CQM’s when you performed your attestation on the CMS website by manual entry. That will not be permissible in 2014. Check with your software vendor now to find out if they offer a registry product for those submissions. In Stage 2, the CQM’s do not have a threshold to meet; however, that may change.

Patient Engagement

The Stage 2 final rule also adds an element of patient engagement to encourage patients to use health information technology to better understand and participate in their own health care. This requirement was not part of Stage 1. Practices must now engage patients to not only sign up for online portals, but to use the portal to communicate with the practice. Previously, required measures were dependent on what your practice did. Now, it will also depend on what your patients do. OP

Ms. Shaw is the Information Technology Manager at the Laurel Eye Clinic, which serves western and central Pennsylvania. She manages computer security and maintenance as well as the systems that collect and store patient information.