CMS Extends 2014 Meaningful Use Attestation and Quality Deadlines

strike before midnightOn November 24, 2014, CMS announced a one-month extension of the deadline for eligible hospitals and Critical Access Hospitals (CAHs) to attest to meaningful use for the Medicare Electronic Health Record (EHR) Incentive Program 2014 reporting year. Medicare eligible hospitals must attest to meeting meaningful use requirements each year to receive an incentive and to avoid a payment adjustment. The deadline is being extended from 11:59 pm EST on November 30, 2014 to 11:59 pm EST on December 31, 2014, and CMS states this will “allow more time for hospitals to submit their meaningful use data and receive an incentive payment for the 2014 program year, as well as avoid the 2016 Medicare payment adjustment.”

CMS also extended the deadline for eligible hospitals and CAHs to electronically submit clinical quality measures (CQMs) until December 31, 2014.

Please note that these extensions are only for the Medicare EHR Incentive Program and will not affect the deadlines for the Medicaid EHR Incentive Program.

Upcoming Deadlines:

  • December 31, 2014 at 11:59 pm ET: Attestation deadline for Medicare eligible hospitals and CAHs for the 2014 program year
  • December 31, 2014: Deadline for hospitals and CAHs to submit eCQMs.
  • December 31, 2014: End of 2014 calendar year and end of the 2014 reporting period for eligible professionals
  • February 28, 2015: Attestation deadline for Medicare eligible professionals.

For additional information, check out the EHR Incentives Programs website.

Stage 2 “Meaningful Use”: Counting Patients Who Access Their Online Information Before Discharge

Under the Health Information Technology for Economic and Clinical Health Act of 2009 (HITECH Act), eligible hospitals and critical access hospitals must make a “meaningful use” of “certified electronic health technology” or face reductions in Medicare reimbursement during Medicare’s 2015 fiscal year (which begins October 1, 2014).  One of the many Stage 2 requirements includes the following one related to patient on-line access to health records:

Accessing Online Health Records
MU Measure Requires 5% of Discharged Patients to Access Health Information Online

Meaningful Use Core Measures, Measure 6 of 16

“More than 5 percent of all unique patients (or their authorized representatives) who are discharged from the inpatient or emergency department (POS 21 or 23) of an eligible hospital or CAH [must] view, download or transmit to a third party their [online] information during the EHR reporting period.” (Emphasis added.)

A literal reading of this measure prompted hospitals to frequently ask whether a patient who accesses their online health information before they are “discharged” will count towards this meaningful use objective.  The Centers for Medicare and Medicaid Services (CMS) posted an answer to this question that we like and think hospitals will like as well.  CMS says “yes”.   Continue reading

AHIMA Issues Guidance on Appropriate Use of Copy and Paste in EHRs

16354859As we have written about in previous posts, the Office of Inspector General (OIG) for the United States Department of Health and Human Services (HHS) has been critical of the copy/paste function that is available in electronic health record (EHR) technology developed by software vendors.  (See “Electronic Health Records in OIG’s Sights for 2013“, October 20, 2012; “OIG recommends fraud safeguards in hospital EHR technology“, December 11, 2013; “OIG Report on CMS’ EHR Audit Practices Concludes The Practices Are Not Very Sophisticated“, February 11, 2014)  As our February 11, 2014 post concludes, while turning off the copy/paste functionalities are not the immediate solution to preventing a misuse of the function, health care providers should implement standards for its use.  The American Health Information Management Association (AHIMA) recently issued guidance, “Appropriate Use of the Copy and Paste Functionality in Electronic Health Records,” dated March 17, 2014, discussing the availability and appropriate use of the copy and paste function.

AHIMA supports maintaining the copy/paste functionality in ONC’s EHR certification standards and allowing for its use in CMS Conditions of Participation.  AHIMA encourages CMS to augment provider education and training materials on the appropriate use of copy/paste in order to reduce the risk that it may pose to quality of care, patient safety and fraudulent documentation.  Importantly, AHIMA recommends that health care providers implement policies and procedures to guide users of EHRs on the proper use of copy/paste functionalities.  To read the AHIMA guidance, click here.

March 31st Attestation Deadline for Eligible Professionals

strike before midnightReminder:  The deadline for Medicare eligible professionals to attest to meaningful use of certified electronic health record technology for the 2013 program year is just two weeks away.  Attestations are due on March 31, 2014 at 11:59 pm EST.  Click here for addition information about the EHR incentive program as well as to register or attest to meaningful use.

CMS Issues EHR Meaningful Use Hardship Exceptions for Health Care Providers Subject to 2015 Medicare Reimbursement Reduction (Includes Automatic One-Year Reprieve for 2013 Meaningful Users)

EHR Meaningful Use Hardship ExemptionOn February 28, 2014, we posted an article about ICD-10 and Stage 2 Meaningful Use (MU) announcements by the Centers for Medicare & Medicaid Services (CMS) at the 2014 HIMSS annual conference.  At that conference, while CMS refused to extend the deadlines for ICD-10 and Stage 2 MU, it promised to be more flexible about providing hardship exemptions on Stage 2 MU for providers and vendors truly struggling to meet the incentive program’s requirements.  CMS said that guidance would be forthcoming.  Yesterday, March 10, 2014, CMS issued such guidance.  The Guidance is directed solely at providers experiencing EHR vendor issues.  Importantly, the Guidance gives an automatic, one-year reprieve for certain providers who demonstrated MU for 2013. Continue reading