February 28th Deadline for EPs To File Attestation for EHR Incentives and CQMs

The deadline is fast approaching for eligible professionals (“EPs”) to file attestations to receive electronic health record (“EHR”) incentives available under Medicare’s Health Information Technology for Economic and Clinical Health Act of 2009 (“HITECH Act”). 

To receive an EHR incentive payment, EPs, such as physicians, dentists, podiatrists, optometrists and chiropractors, must show they are “meaningfully using” their EHRs in ways that can positively improve patient care by meeting certain objectives and reporting certain clinical quality measures (“CQMs”).  EPs must also file an attestation that they have met the thresholds and all of the requirements of the Medicare EHR Incentive Program.  EPs who participate in the Medicare EHR Incentive Program in 2012 must submit the CQMs and file an attestation with CMS for the 2012 program year by February 28, 2013. 

If you are participating in the pilot program to submit your CQM data electronically, please be aware that your window to file is limited because of a planned system downtime.  You will be unable to file your CQM data beginning at 11:59 p.m. ET tomorrow, Friday, February 22 through Sunday, February 24 at 11:59 p.m. ET because CMS has a system outage already scheduled that will affect CQM filing.  (We understand, but have been unable to verify, that you may still file an attestation during the outage.)  The Centers for Medicare & Medicaid Services (“CMS”) warns that “[f]ailure to submit your CQMs electronically by 11:59pm ET on February 28 will result in your attestation being rejected for the 2012 program year.” 

We also recommend you not wait until the last minute—as CMS expects a high volume of users on both the Physician Quality Reporting System (“PQRS”) and EHR Incentive Program systems over the next week.  Please keep this in mind when planning for your CQM data submission and completion of your 2012 attestation. 

For additional information regarding the EHR Incentive Program, check out CMS’ EHR Incentive Programs website.  Its Educational Materials in particular are quite helpful.  In addition, CMS has recently updated its frequently asked questions (“FAQs”) related to the EHR Incentive Programs.    

Leave a reply. Please note that although this blog may be helpful in informing clients and others who have an interest in information privacy and security, it is not intended to be legal advice. The information on this blog also should not be relied upon to form an attorney-client relationship.

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