Upcoming Meaningful Use Hardship Exception Deadline

Summer’s here, and the July 4 holiday weekend is around the corner. Before packing your bags or lighting up the grill, take a moment to review the meaningful use hardship exception guidelines. The deadline to apply for a hardship exception and avoid a 2017 payment adjustment is July 1 at 11:59 pm ET.

You do not need to file a hardship exception if any one of these scenarios applies to you:

  • You successfully demonstrated meaningful use in 2015;
  • You’re a hospital-based provider; or
  • You’re a new eligible professional who began filing Medicare or Medicaid claims in 2015.

A hardship exception could exempt you from Medicare payment penalties in 2017 if you failed to achieve meaningful use in 2015 and you met one of the following circumstances:

  • Insufficient internet connectivity
  • Extreme and uncontrollable circumstances (a natural disaster, practice closure, bankruptcy, failure of your certified EHR)
  • Lack of certified EHR availability
  • Lack of face-to-face interaction or follow up

There’s no hardship exemption for not knowing about the Modified Stage 2 meaningful use changes that were published in October.

The timeline for hardship exceptions and payment adjustments can be confusing since the payment adjustments occur two years after the participation year.

If you failed to participate in this calendar year… File for a hardship exception by this date… To avoid a payment adjustment in this year…
2015 July 1, 2016 2017
2016 TBD 2017 2018

For more information, refer to the following resources:

Meaningful Use Hardship Exception Requirements Announced

CMS has released the requirements for filing hardship exception applications for the 2015 reporting year. The good news is that CMS has reduced the amount of detailed information needed to complete the application. Additionally, CMS is allowing groups of providers to file a single hardship exception application. Hardship exception applications are due by March 15.

A hardship exception could exempt you from Medicare payment penalties in 2017 if you failed to achieve meaningful use in 2015 and you met one of the following circumstances:

  • Insufficient internet connectivity
  • Extreme and uncontrollable circumstances (a natural disaster, practice closure, bankruptcy, failure of your certified EHR)
  • Lack of certified EHR availability
  • Lack of face-to-face interaction or follow up

There’s no hardship exemption for not knowing about the Modified Stage 2 meaningful use changes that were published in October.

While this isn’t the blanket hardship exception that many had hoped, the application requires less information than in years past, which will make the application less burdensome. Additionally, the Modified Stage 2 requirements lowered the bar on many of the more onerous measures, which should make it easier for eligible providers (EPs) to attest to meaningful use rather than applying for a hardship exception.

If you’re able to successfully attest to meaningful use for 2015, you do not need to file a hardship exception. New EPs who began submitting Medicare claims in 2015, hospital-based EPs, and EPs in five specialties unrelated to eyecare automatically receive an exemption and don’t have to file an application.

For more information, refer to the following resources:

Important Meaningful Use Deadline Quickly (and Quietly) Approaching

To Do: Meaningful UseYou must register with public health registries before December 1 to fulfill the public health objective of meaningful use in 2015. The objective requires that you be registered to submit data to public health agencies within 60 days of starting your attestation period, which for most providers, was October 1, 2015.1

The public health objective is divided into three measures, from which you must choose two:

  • Measure 1: Immunization Registry Reporting
  • Measure 2: Syndromic Surveillance Reporting
  • Measure 3: Specialized Registry Reporting

There are eligible exclusions, but you must exhaust all available options before you can satisfy this objective by exclusion. First, let’s determine whether you’re eligible for an exclusion for any of the three measures.

Are You Eligible to Claim an Exclusion?

Answer the following questions to determine your eligibility to claim an exclusion from one or more of these measures.

Continue reading

CMS Extends Medicare EHR Attestation Deadline

announcementIn a surprise announcement this morning, CMS extended the 2014 attestation deadline for the EHR Incentive Program, popularly known as “meaningful use.” The submission deadline is now March 20, 2015, at 11:59pm (ET).

This extension gives providers a chance to breathe and a little more time to gather their meaningful use data from 2014 and attest. This is fantastic news for all participating providers who want to avoid Medicare payment adjustments in 2016. This is particularly good news to those who are attesting to meaningful use for the first time, since this is their last chance to receive any incentive money for meaningful use under Medicare.

CMS was careful to point out that this extension applies only to the Medicare EHR Incentive Program. This extension does not affect those providers who are participating under the Medicaid EHR Incentive Program. CMS also urged providers to attest as soon as possible despite the extension.

PQRS vs. CQMs—What’s the Difference and How Do I Report Them?

There’s a lot of confusion and frustration in the healthcare industry right now about the government quality programs, where they overlap (and where they still don’t), and how to report the correct information.

A (Brief) History

The Physician Quality Reporting System (PQRS) has been around since 2007. Traditionally providers voluntarily reported at least three measures by including level II CPT codes on their Medicare Part B claims, and they received an incentive payment from CMS.

Clinical Quality Measures (CQMs) were introduced in 2011 as part of the EHR Incentive Program, better known as meaningful use. This program required providers to manually enter a calculated percentage for six to nine measures to receive an incentive as part of meaningful use.

A Confluence of Program Changes

Recently, the Centers for Medicare and Medicaid Services (CMS) initiated plans to align the PQRS and the CQM measures to make reporting easier for providers. At the same time, CMS is laying the groundwork to discontinue the claims-based PQRS reporting that providers have become accustomed to. CMS’ goal is for providers to electronically submit a file that contains all of their yearly quality data to satisfy the requirements for both PQRS and CQMs. You may have heard of this file referred to as QRDA. Continue reading

Meaningful Use Hardship Exceptions Extended

Featured imageCMS has reopened the submission period for hardship exception applications, allowing eligible providers (EPs), like you, one last chance to avoid the 1% Medicare payment penalty in 2015. The new deadline is November 30 at 9:59 pm Pacific. You must complete the Hardship Exception Application and email it to ehrhardship@provider-resources.com.

Chasing Deadlines

October 1 was a frenzied rush as thousands of EPs attempted to attest to meaningful use to avoid the 1% Medicare penalty in 2015. The crushing volume strained the attestation system as well as the call centers of EHR vendors. Frustration increased when EPs attempted to attest to the 2011 Edition criteria under the recent delay because CMS’s attestation system had not been retrofitted to accommodate the revised rules.

Breathing a Collective Sigh of Relief

To alleviate the situation, CMS has decided to reopen the submission period for hardship exception applications after a three-month hiatus. EPs who were stuck in the snarl of October 1 will surely appreciate this extension.

Reading the Fine Print

This extension is not an outright postponement of Medicare penalties in 2015. To be eligible for a hardship exception, you must meet the following criteria:

  • You were unable to fully implement a 2014 Edition certified EHR because your certified software was not available soon enough for you to install, train, and use prior to July 1
  • You were unable to attest by October 1, 2014, using the flexibility options provided in the 2014 Flexibility Rule

Visit the Payment Adjustments and Hardship Exceptions webpage for more information about Medicare EHR Incentive Program payment adjustments.

Closing Out 2012 Meaningful Use

MSMU VerticalAs 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:

  1. 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.
  2. 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.
  3. 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

Getting Paid

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).