As 2012 comes to a close, many of you, who are participating in the Medicare and Medicaid EHR Incentive Programs, are going to be attesting to meaningful use for the first time. While attesting or reporting your meaningful use might seem like a daunting and nerve-wracking process, it only seems that way because it’s a new experience.
Here are some things to keep in mind and links to additional resources where you can find complete information about meaningful use, attestation, and the EHR Incentive Programs.
Attesting on Time
You must attest to meaningful use after your reporting period, and not during your reporting period. If your attestation period continues through December 31, you may then complete your attestation beginning January 1. For the Medicare EHR Incentive Program you must complete your attestation by February 28, 2013. If you are participating in the Medicaid EHR Incentive Program, check with your state’s Medicaid for applicable deadlines.
Even if you can’t officially attest until January 1, you will want to perform steps 1 and 2 below to head off any potential shortcomings.
Navigating the Attestation System
Each doctor must attest individually, you cannot attest as a practice. Follow these steps to ensure your attestation goes smoothly:
- In ExamWRITER, click the Reports menu and run the CMS Meaningful Use Reporting and CMS Quality Reporting. For complete instructions, press F1 for help.
– The meaningful use report lists only those measures that require percentages. The unlisted measures require a simple yes or no answer.
– If your percentages are low in some of the menu measures, don’t fret. You only need to report on 5 out of the 10 menu set measures, provided one of them is menu 9 or 10.
– Many of the measures may be satisfied by claiming an allowable exclusion.
– The clinical quality measures may show low percentages. That’s okay. They don’t have minimum thresholds.
- Practice your attestation using CMS’ Meaningful Use Attestation Calculator.
– If your numbers are low review the “Achieving Meaningful Use with OfficeMate/ExamWRITER” or “Tracking CMS Quality Measures in ExamWRITER” documents, which can be found on our Meaningful Use Starter Kit page. If your attestation period has not ended, there may still be time to correct some shortcomings.
– If didn’t realize that you were short in a measure until after 2012 was over, look for allowable exclusions. If no exclusion applies to you, it is too late to correct any shortcomings.
- Attest to your meaningful use through the Medicare & Medicaid EHR Incentive Program Registration and Attestation System.
– Use the Attestation User Guide for Eligible Professionals for visual, step-by-step instructions.
– Attestation is self-reported. You do not need to furnish documentation when you attest. Documentation may be required later (see “Surviving an Audit,” below).
– If you are asked for your EHR Certification Number, refer to this knowledge base article.
Surviving an Audit
Since the EHR incentive programs are government-funded initiatives, audits are an important part of abating fraud and waste in the program. CMS will not release specific information about the nature of the audits, but they have posted some general guidelines on their Frequently Asked Questions page. While OfficeMate/ExamWRITER users have nothing to fear from these audits, we encourage you to save a printed or electronic copy of your meaningful use calculations and any communications that you have had regarding meaningful use. For example, you’ll want to save copies of the following:
- Meaningful use report calculations
- Clinical quality report calculations
- Email showing that you transmitted a CCR to a colleague (core 14)
- Checklist or documentation from your security audit (core 15)
- A full screenshot of OfficeMate or ExamWRITER with the About window open (showing the date and the practice license information)
- Any other documents or communications you have regarding meaningful use
In theory, you can expect to see your check between six to eight weeks after attesting to meaningful use.
In reality, there are a number of factors that could delay your payment:
- If you have not yet reached $24,000 in Medicare Part B billings, your payment will be held until you do. Your incentive payment for 2012 is based on 75% of your Part B billings up to a ceiling of $24,000, making the maximum payment $18,000.
- If you do not bill $24,000 in Medicare Part B billings in 2012, your payment will be sent six to eight weeks after the final day to bill for 2012, which is February 28. So, you won’t see your check until April.
- If you participated in a state Medicaid incentive program, the payment timeframe varies drastically.
Payments are made on a per-provider basis, and not per practice. Payments are based on a percentage of your allowable Medicare Part B billings. Even if your practice bills under one NPI, the incentive is determined by the rendering provider’s NPI on the CMS 1500.
Continuing Meaningful Use
For 2013, you will once again attest to stage 1, but for the entire calendar year.
For 2014, you will attest to 90 days of stage 2 meaningful use (we’ll be communicating with you about that throughout 2013 and 2014).