HHS announces proposed rules to support the path to nationwide interoperability

The following is taken from www.hhs.gov in a press release dated March 20, 2015:

Electronic Health Record Incentive Programs and 2015 Edition Health IT Certification Criteria rules proposed

The U.S. Department of Health and Human Services, Centers for Medicare & Medicaid Services (CMS) and Office of the National Coordinator for Health Information Technology (ONC) today announced the release of the Stage 3 notice of proposed rulemaking for the Medicare and Medicaid Electronic Health Records (EHRs) Incentive Programs and 2015 Edition Health IT Certification Criteria to improve the way electronic health information is shared and ultimately improve the way care is delivered and experienced. Together, these proposed rules will give providers additional flexibility, make the program simpler, and drive interoperability among electronic health records, and increase the focus on patient outcomes to improve care.

The proposed rules are one part of a larger effort across HHS to deliver better care, spend health dollars more wisely, and have healthier people and communities by working in three core areas: to improve the way providers are paid; improve the way care is delivered; and improve the way information is shared. Together, these improvements can support better care and lower costs in the health care system.

“The flow of information is fundamental to achieving a health system that delivers better care, smarter spending, and healthier people. The steps we are taking today will help to create more transparency on cost and quality information, bring electronic health information to inform care and decision making, and support population health,” said HHS Secretary Sylvia M. Burwell.

The Meaningful Use Stage 3 proposed rule issued by CMS specifies new criteria that eligible professionals, eligible hospitals, and critical access hospitals must meet to qualify for Medicaid EHR incentive payments. The rule also proposes criteria that providers must meet to avoid Medicare payment adjustments (Medicaid has no payment adjustments) based on program performance beginning in payment year 2018. The rule gives more flexibility and simplifies requirements for providers by focusing on advanced use of electronic health records and eliminating requirements that are no longer relevant.

The 2015 Edition Health IT Certification Criteria proposed rule aligns with the path toward interoperability – the secure, efficient, and effective sharing and use of health information –identified in ONC’s draft shared Nationwide Interoperability Roadmap. The proposed rule builds on past editions of adopted health IT certification criteria, and includes new and updated IT functionality and provisions that support the EHR Incentive Programs care improvement, cost reduction, and patient safety across the health system.

“This Stage 3 proposed rule does three things: it helps simplify the meaningful use program, advances the use of health IT toward our vision for improving health delivery, and further aligns the program with other quality and value programs,” said Dr. Patrick Conway, M.D., M.Sc., CMS acting principal deputy administrator and chief medical officer. “And, in an effort to make reporting easier for health care providers, we will be proposing a new meaningful use reporting deadline soon.”

“ONC’s proposed rule will be an integral component in the shared nationwide effort to achieve an interoperable health system,” said Karen DeSalvo, M.D., M.P.H, M.Sc., national coordinator for health IT. “The certification criteria we have proposed in the 2015 Edition will help achieve that vision through provisions that consider the range of health IT users and uses across the care continuum, including those focused on interoperable standards, data portability, improved transparency, privacy and security capabilities, and increased oversight through ONC’s Health IT Certification Program.”

Under the Health Information Technology for Economic and Clinical Health Act, doctors, health care professionals and hospitals, including critical access hospitals, can qualify for Medicare and Medicaid incentive payments when they adopt and meaningfully use health IT technology certified by ONC. Since the programs began in 2011, more than 433,000 eligible professionals and eligible hospitals have received an incentive payment representing about 60 percent of eligible professionals in either the Medicare or Medicaid programs and about 95 percent of eligible hospitals.

The Stage 3 proposed rule’s scope is generally limited to the requirements and criteria for meaningful use in 2017 and subsequent years. CMS is considering additional changes to meaningful use beginning in 2015 through separate rulemaking. Read more about this announcement on Dr. Conway's blog.

The Stage 3 proposed rule may be viewed at here and the comment period ends on May 29, 2015. The 2015 Edition proposed rule may be viewed at here and the comment period ends on May 29, 2015. The Draft 2015 Edition Certification Test Procedures may be viewed at HealthIT.gov, and the comment period ends on June 30, 2015.

More information on meaningful use can be found on the CMS EHR Incentive Programs website.

For more information on ONC’s editions of certification criteria click here.

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Deadline for 2014 attestation fast approaching!

Tomorrow is the Deadline for Medicare Eligible Professionals to Attest for 2014 Participation

Eligible professionals have until 11:59 pm ET tomorrow, March 20, 2015, to attest to meaningful use for the Medicare Electronic Health Record (EHR) Incentive Program 2014 reporting year.

Medicare eligible professionals must attest to meaningful use every year to receive an incentive and avoid a payment adjustment. Providers who successfully attest for the 2014 program year will:
• Receive an incentive payment
• Avoid the Medicare payment adjustment, which will be applied January 1, 2016

Note: The Medicare extension does not affect deadlines for the Medicaid EHR Incentive Program. Additionally, the EHR reporting option for PQRS has been extended until March 20, 2015. 

How to Attest

Submit your data to the Registration and Attestation System, which includes 2014 Certified EHR Technology (CEHRT) Flexibility Rule options.

Tips to ensure successful attestation

• Before you register- make sure you have an active and approved enrollment record in the Provider Enrollment, Chain and Ownership System (PECOS)
• When registering- be sure to have your NPI, Identity and Access Management (I&A) ID and Password, Payee TIN, and Payee NPI information available, along with your EHR Certification Number
• Before you attest- make sure you have a successful and active registration status in the Registration and Attestation System
• Registration status will read “Active” when all validations pass
• After you attest- click on the status tab to see your progress, and then click the appropriate tab to see your registration, attestation, and payment status

CMS recommends you review all of your attestation information before submitting.
To learn more, see the Educational Resources on the CMS EHR Incentive Programs website.

For help, call the EHR Information Center: 1-888-734-6433
TTY for people with hearing impairments: 1-888-734-6563
Monday – Friday, 8:30 am – 7:30 pm (ET)

Hardship Exception Applications to Avoid the 2015 Medicare Payment Adjustment Due November 30, 2014

CMS is announcing its intent to reopen the submission period for hardship exception applications for eligible professionals and eligible hospitals to avoid the 2015 Medicare payment adjustments for not demonstrating meaningful use of Certified Electronic Health Record Technology (CEHRT). The new deadline will be November 30, 2014. Previously, the hardship exception application deadline was April 1, 2014 for eligible hospitals and July 1, 2014 for eligible professionals.

As part of the American Recovery and Reinvestment Act of 2009 (Recovery Act), Congress mandated payment adjustments under Medicare for eligible hospitals, critical access hospitals, and eligible professionals that are not meaningful users of CEHRT. The Recovery Act allows the Secretary to consider, on a case-by-case basis, hardship exceptions for eligible hospitals, critical access hospitals, and eligible professionals to avoid the payment adjustments.

This reopened hardship exception application submission period is for eligible professionals and eligible hospitals that:

• Have been unable to fully implement 2014 Edition CEHRT due to delays in 2014 Edition CEHRT availability; AND
• Eligible professionals who were unable to attest by October 1, 2014 and eligible hospitals that were unable to attest by July 1, 2014 using the flexibility options provided in the CMS 2014 CEHRT Flexibility Rule.  

These are the only circumstances that will be considered for this reopened hardship exception application submission period. Applications must be submitted by 11:59 PM EST November 30, 2014.

More Information
More information about the application process will be shared soon. We intend to address this issue in upcoming rulemaking. Visit the Payment Adjustments and Hardship Exceptions webpage for more information about Medicare EHR Incentive Program payment adjustments.

Earlier this year, CMS and the ONC released a proposed bill for the EHR Incentive Programs.  In August of 2014 they finalized this bill.  If you have a spare hour or two, and want to read the bill, click here.

To help clear up any confusion over which certification year (2011 or 2014) a practice should use,  CMS has created a Quick Reference Guide that helps to clear up any questions you may have about what to do this year.  Time is ticking by, and realistically if a practice hasn't started its reporting quarter, October 3rd would be the final date to start.

Remember-2014 is the LAST year an EP can begin to receive incentives.  As stated in the Health Information Technology for Economic and Clinical Health (HITECH) Act, no incentives can be paid to Medicare EPs that begin MU after 2014.  EPs that start MU in 2014 could still earn as much as $24,000 in incentives if they demonstrate MU from 2014 through 2016.

2014 meaningful use performance is the basis for 2016 Medicare payment adjustments. For EPs this potentially means a -2% reduction to the Medicare physician fee schedule (PFS) amount for covered professional services furnished by the EP during 2016 (EP tip sheet). The payment adjustment calculation for EHs and CAHs is a little more complicated and different for each. 

Here’s a link to CMS’ EH/CAH tip sheet.

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www.sunrize.com

New CMS rule allows flexibility in certified EHR technology for 2014

The Department of Health and Human Services (HHS) published a final rule on August 29, 2014, that allows health care providers more flexibility in how they use certified electronic health record (EHR) technology (CEHRT) to meet meaningful use for an EHR Incentive Program reporting period for 2014. By providing this flexibility, more providers will be able to participate and meet important meaningful use objectives like drug interaction and drug allergy checks, providing clinical summaries to patients, electronic prescribing, reporting on key public health data and reporting on quality measures.

“We listened to stakeholder feedback and provided CEHRT flexibility for 2014 to help ensure providers can continue to participate in the EHR Incentive Programs forward,” said Marilyn Tavenner, CMS administrator. “We were excited to see that there is overwhelming support for this change.”

Based on public comments and feedback from stakeholders, the Centers for Medicare & Medicaid Services (CMS) identified ways to help eligible professionals, eligible hospitals, and critical access hospitals (CAHs) implement and meaningfully use Certified EHR Technology. Specifically, eligible providers can use the 2011 Edition CEHRT or a combination of 2011 and 2014 Edition CEHRT for an EHR reporting period in 2014 for the Medicare and Medicaid EHR Incentive Programs; All eligible professionals, eligible hospitals, and CAHs are required to use the 2014 Edition CEHRT in 2015.

These updates to the EHR Incentive Programs support HHS’ commitment to implementing an effective health information technology infrastructure that elevates patient-centered care, improves health outcomes, and supports the providers that care for patients.

The rule also finalizes the extension of Stage 2 through 2016 for certain providers and announces the Stage 3 timeline, which will begin in 2017 for providers who first became meaningful EHR users in 2011 or 2012.

See the full press release here:  http://cms.gov/Newsroom/MediaReleaseDatabase/Press-releases/2014-Press-releases-items/2014-08-29.html

See the EHR Incentive Programs 2014 CEHRT Ruke: Quick Guide here:  http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/CEHRT2014_FinalRule_QuickGuide.pdf

See the CEHRT Flexibility Decision Tool here:  http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/CEHRT_Rule_DecisionTool.pdf

The goal of meaningful use is to improve health care in the United States.

The benefits:

·        Electronic health records allows providers have the information they need to provide the best possible care. Providers will know more about their patients and their health history before they walk into the examination room.

      Electronic health records will empower patients to take a more active role in their health and in the health of their families. Patients can receive electronic copies of their medical records and share their health information securely over the Internet with their families.

·         Electronic health records allow their healthcare providers the ability to diagnose health problems earlier and improve the health outcomes of their patients. Electronic health records also allow information to be shared more easily among doctors' offices, hospitals, and across health systems, leading to better coordination of care.

·                Stage 1 requires meeting both core and menu objectives. All of the core objectives are required. EPs and hospitals may choose which objectives to meet from the meaningful use menu set.

     Meaningful use criteria for eligible professionals

1.    15 core objectives

2.    5 out of 10 from menu set objectives

3.    6 total clinical quality measures

                                3 core or alternate core

                                3 out of 38 from additional set

     Meaningful use criteria for eligible hospitals/CAHs

1.    14 core objectives

2.    5 out of 10 from menu set objectives

3.    15 clinical quality measures

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What is Meaningful Use

Simply, Health Information Technology for Economic and Clinical Health (HITECH) Act, hospitals and eligible health care professionals can qualify for Medicare and Medicaid incentive payments when they adopt certified Electronic Health Records (EHR) technology and use it to achieve specified objectives referred to as "Meaningful Use"; simply, providers must meet the objectives to qualify for the incentive payments.

To qualify for incentive payments, meaningful use requirements must be met in the following ways:

·         Medicare EHR Incentive Program – Hospitals and Eligible professionals (EP) is a doctor of medicine or osteopathy, dentist or dental surgeon, podiatrist, optometrist, or chiropractor.  EPs can register for the program starting in January 2011.  and hospitals must demonstrate successful meaningful use of certified electronic health record technology for every year they participate in the program.

·         Medicaid EHR Incentive Program – Hospitals and Eligible professionals (EP) are Physicians, dentists, certified nurse-midwives, nurse practitioners, and physician assistants practicing in an Federally Qualified Health Center (FQHC) or a Rural Health Clinic (RHC) led by a physician assistant can qualify for incentive payments for the adoption, implementation, upgrade or the demonstration of meaningful use in their first year of participation. They also need to successfully demonstrate meaningful use for the remaining years they participate in the program.

One thing to note: If the Eligible Professionals qualify for both Medicare and Medicaid they decide on just one, but they may switch between the two only once prior to 2015. Furthermore, an Eligible Professionals who selects Medicaid must only receive incentive payments from a single state in any payment year.

 Year One:

• January 1, 2011 – Reporting year begins for eligible professionals.

• October 1, 2011 – Last day for eligible professionals to begin their 90-day reporting period for calendar year 2011 for the Medicare EHR Incentive Program.

• December 31, 2011 – Reporting year ends for eligible professionals.

• February 29, 2012 – Last day for eligible professionals to register and attest to receive an Incentive Payment for calendar year (CY) 2011.

Second year: (one year reporting period)

• January 1, 2012 – Reporting period begins.

• December 31, 2012 – Reporting period ends.

• February 2013 for attestation in CY 2013.

MeaningfulUseTimeline:

www.cdph.ca.gov/programs/cclho/Documents/MeaningfulUseTimeline.pdf

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