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For clinics participating in the Medicare Electronic Health Record (EHR) Incentive Programs, the Centers for Medicare & Medicaid Services (CMS) the 2016 deadline is March 13th, 2017.
Participants who do not file their data by the deadline may receive lower payments from CMS in 2018, so clinics who use the Medicare EHR Incentive should do their own research to determine which requirements apply to them.¹
If your practice bills Medicare for patient services and you participated in the Incentive Programs, you should investigate the data submission requirements to ensure you are fully complying with the Incentive regulations. A hardship exemption is also available for some practices and this exemption waives the data submission requirement for qualifying clinics. More information about Meaningful Use payment adjustments for Medicare is available at the CMS website.¹
Submission requirements
This deadline is for clinics submitting electronic Clinical Quality Measure (eCQM) data to CMS. These clinics are expected to submit at least four measures that reflect use of certified EHR technology (CEHRT). Each submission must contain Quality Reporting Document Architecture (QRDA) Category I files, case threshold exemptions and/or zero denominator declarations. This information should reflect use of CEHRT in your practice and should show that you protect patient data and use a certified EHR meeting CMS criteria. T
he measures you submit for your practice may vary by specialty and other clinic characteristics, so you should do your own research to determine how these requirements apply to your clinic. For the 2016 reporting period, EHR must be certified to the 2014 or 2015 edition at a minimum. Interoperability is a central goal of EHR Meaningful Use requirements, and over time will become a more important measurement.¹ ²
Right now, compliance with Modified Stage 2 Meaningful Use is required. Starting in 2018, Stage 3 compliance will be required of all participating providers. Meaningful Use requirements are transitioning to the Merit-Based Incentive Payment System (MIPS) and adjustments are being made to reporting requirements and procedures with each new reporting year. Efforts are being made to reduce the complexity of reporting requirements and offer more flexibility for practices. ²
Meaningful use transition to MIPS
MIPS is an attempt to combine multiple programs and regulations under a single program. One standard becoming part of MIPS is Meaningful Use, an EHR technology requirement that ensures EHR is used properly and plays a real role in practices. Meaningful Use is part of MIPS and will remain a significant measure that influences Medicare reimbursement rates.
As one of the four key measurements, Meaningful Use is now part of the overall score a provider receives. This scoring determines how the provider is reimbursed, with an added incentive payment offered or part of the overall reimbursement reduced in cases where scores are low or reporting is not submitted. Providers can directly impact the reimbursements they receive from CMS based on their performance on the measures they submit each year. Since the 2015 reporting period, reporting for Meaningful Use based on the entire year is required.² ³
Prepare for the meaningful use deadline
If you participate in the Medicare EHR Incentive Programs, be sure to do your own research to determine which measures you are required to submit. Find out which regulations apply to your clinic and how you should submit your data to remain compliant with Meaningful Use requirements and upcoming MIPS standards. Based on your practice, these standards and measurements may vary, so it is important to receive customized advice that fits your practice.³
As Meaningful Use transitions into part of MIPS, your requirements may change and you should be prepared for new standards. Finding a certified EHR vendor can help you become prepared for MIPS deadlines and appropriate reporting.³
References
¹Goedert, J. “New EHR Meaningful Use deadline nears.” Health Data Management. http://www.healthdatamanagement.com/news/new-ehr-meaningful-use-deadline-nears. Published: January 2017. Accessed: February 2017.
²CMS. “Medicare and Medicaid Programs; Electronic Health Record Incentive Program- Stage 3 and Modifications to Meaningful Use in 2015 through 2017.” Centers for Medicare & Medicaid Services. Federal Register. https://www.federalregister.gov/documents/2015/10/16/2015-25595/medicare-and-medicaid-programs-electronic-health-record-incentive-program-stage-3-and-modifications. Published: October 2015. Accessed: February 2017.
³Miliard, M. “Meaningful Use will still be part of MIPS reimbursement, CMS official says.” Healthcare IT News. http://www.healthcareitnews.com/news/meaningful-use-will-still-be-part-mips-reimbursement-cms-official-says. Published: March 2016. Accessed: February 2017.
