Stages 1, 2, And Now 3, Meaningful Use Criteria

The Centers for Medicare & Medicaid Services (“CMS”) proposed Meaningful Use criteria to implement Stage 3 and allow eligible professionals, eligible hospitals and critical access hospitals (“CAHs”) to qualify for incentive payments (or avoid downward payment adjustments) under the Medicare and Medicaid Electronic Health Record (EHR) Incentive Program implemented by the Health Information Technology for Economic and Clinical Health (“HITECH”) Act of 2009. stethoscope, keyboardThen CMS made changes to Stage 1 and Stage 2 Meaningful Use criteria to better align with the proposed Stage 3 criteria just two weeks later.

On March 30, 2015, CMS published a long-awaited proposed rule which, if finalized, would implement Stage 3, making changes to the objectives and measures of meaningful use for providers effective in Continue reading

April 1 Deadline for Hospitals to Earn EHR Incentives

The Centers for Medicare & Medicaid Services (CMS) reminds hospitals that 2015 is the last year for eligible hospitals to begin participating in the Medicare Electronic Health Record (EHR) Incentive Program and earn incentive payments.

In order to earn a 2015 incentive payment, be eligible for a 2016 incentive payment, and avoid a 2016 payment reduction (called an “adjustment”), first-time hospital participants should:

  • Begin their 90-day reporting period no later than April 1, 2015 and
  • Attest by July 1, 2015.

Eligible hospitals that do not start their 90-day reporting period on April 1, 2015 have one last chance to earn a 2015 incentive payment if they begin their reporting period by July 1, 2015 and attest by Continue reading

FTC Releases Report and Practical Advice on the Internet of Things

On January 27, 2015, the Federal Trade Commission (FTC) released a staff report entitled “Internet of Things: Privacy & Security in a Connected World.” This report suggests steps businesses can take to protect consumers’ privacy and security as they use objects that connect and send data to the Internet.

InternetOfThings-01The FTC Staff Report defines the Internet of Things (IoT) as “the ability of everyday objects to connect to the Internet and to send and receive data.” Examples of such objects are bracelets that track fitness activities and share the data with friends, cameras that post pictures online, RFID tags to monitor inventory, and home automation systems to monitor lights, temperature and security and report to homeowners when they are away. In health care, such objects include medical devices that monitor vital signs and other patient data, such as insulin pumps and blood pressure cuffs, and then share this data with physicians and caregivers. Basically, the IoT is “essentially any other Internet-connected device that isn’t a mobile phone, tablet, or traditional computer.”

The number of “things” connected to the Internet is greater than the number of people, and, as of this year, there will be 25 billion devices connected to the Internet. But this increased connectivity comes with increased privacy and security risks. First, financial and personal data stored on these devices can be stolen. Second, when the objects are connected to a network, security vulnerabilities in the objects may Continue reading

Providers Talk, CMS Listens: CMS Announces Plan to Modify Meaningful Use Requirements

On January 29, 2015, Centers for Medicare & Medicaid Services (CMS) electronic health recordannounced its intent to make changes to the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs beginning in 2015, which aim to “help to reduce the reporting burden on providers.”

Providers have expressed concerns about the EHR Incentive Programs’ requirements and their burden on providers. In response to those concerns, CMS is considering whether to:

  • Shorten the EHR reporting period in 2015 to 90 days to accommodate these changes.
  • Realign hospital EHR reporting periods to the calendar year to allow eligible hospitals more time to incorporate 2014 Edition software into their workflows and to better align with other CMS quality programs.
  • Modify other aspects of the program to match long-term goals, reduce complexity, and lessen providers’ reporting burdens.

CMS is expected to engage in rulemaking this spring to implement these changes to the EHR Incentive Programs. These changes will not be included in the proposed regulations regarding Stage 3 meaningful use requirements and criteria that CMS plans to issue by early March 2015 and which will apply in 2017 and subsequent years.

 

THE HIPAA SECURITY RISK ANALYSIS

businessman looking over his glasses with clipboard on hand - frUnder the Health Information Technology for Economic and Clinical Health Act of 2009 (HITECH Act), eligible hospitals and critical access hospitals and eligible professionals must make a “meaningful use” of “certified electronic health technology” or face reductions in Medicare reimbursement. Conducting or reviewing a security risk analysis is a core objective in the meaningful use requirements of the Medicare and Medicaid electronic health record (“EHR”) incentive programs. These security risk analyses have been Continue reading