2014 CEHRT Hardship Exception Guidance for EPs

In this month’s post, we take a look at the 2014 CEHRT Hardship Exception Guidance for Eligible Professionals (EPs). 

If you are an eligible professional, and you are unable to implement the 2014 Edition of Certified Electronic Health Record (EHR) Technology in time to successfully demonstrate meaningful use for the 2014 reporting year, you may be eligible for a hardship exception from the applicable Medicare payment adjustment.

When do payment adjustments take effect for the 2014 reporting year?

The Medicare EHR Incentive Program payment adjustment is applied in 2016 for the 2014 reporting year for providers who demonstrated meaningful use in a previous year. New participants in the 2014 reporting year can also apply for an exception to the 2015 payment adjustment. CMS is currently accepting hardship exception applications for the 2015 payment adjustment only.

New Participants in 2014

If you are new to the program and intended to demonstrate meaningful use for the first time in 2014, but you are not able to implement 2014 certified EHR technology for the 2014 reporting year, you may apply for a hardship exception for the 2015 payment adjustment.

  • Use the eligible professional hardship exception form for 2015
  • Indicate the reason you are applying for a hardship (select “2014 Vendor Issues”)
  • Submit your application by July 1, 2014

Returning Meaningful Users in 2014

If you successfully demonstrated meaningful use for the 2013 reporting year, you will not be subject to the 2015 payment adjustment. If you are not able to implement 2014 certified EHR technology for a 2014 reporting period, you may apply for a hardship exception for the 2016 payment adjustment.

  • Use the eligible professional hardship exception form for 2016 which will be available after July 1, 2014
  • Indicate the reason you are applying for a hardship (select “2014 Vendor Issues”)
  • Submit your application by July 1, 2015

For more information, please review the 2014 CEHRT Hardship Exception Guidance for Eligible Professionals documentation posted on the CMS website: http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/CEHRT2014_HEGuidance_EPs.pdf

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It’s 2014, time for Stage 2 MU (and some updates for Stage 1)

In this month’s post, we take a look at 2014, Stage 2 MU, and changes for Stage 1 MU. 

For the radiologists that have already completed two years of Stage 1 MU, 2014 will be the year Stage 2 MU begins. Stage 2 retains the same basic structure as MU Stage 1 and providers must report on 20 objectives (17 core objectives and 3 out of a possible 6 menu objectives) in Stage 2. The meaningful use measures are split into core and menu objectives—eligible professionals must report on all core objectives, but can choose the menu measures that pertain to their practice.

CMS and the ONC have established standards and certification criteria for structured data that EHRs must use in order to successfully capture and calculate objectives for Stage 2 of meaningful use. These new standards and certification criteria will take effect in 2014. EHR technology that is certified to the 2014 standards and certification criteria will allow providers to meet both Stage 1 and Stage 2 meaningful use requirements (for more information about certified EHRs and the new 2014 standards and certification criteria, please visit ONC’s new 2014 Certification Programs and Policy page: http://www.healthit.gov/policy-researchers-implementers/about-certification).

For 2014 Only

Because all providers must upgrade or adopt newly certified EHRs in 2014, all providers regardless of their stage of meaningful use are only required to demonstrate meaningful use for a three-month (or 90-day) EHR reporting period in 2014: Medicare eligible professionals in their first year of meaningful use may select any 90-day reporting period. Medicaid eligible professionals can select any 90-day reporting period that falls within the 2014 calendar year.

Stage 2 MU Requirements

17 Core Objectives – These are objectives that everyone who participates in Stage 2 must meet. Some of the core objectives have exclusions, but many do not.

3 of 6 Menu Objectives – You only have to report on 3 out of the 6 available menu objectives for Stage 2. You can choose objectives that make sense for your workflow or practice. Again, some of these objectives have exclusions.

Many of the objectives in Stage 2 are similar to Stage 1. Some objectives that were in the menu set in Stage 1 have been moved to the core set for Stage 2 and are now required for all providers. Some objectives that were in the core set in Stage 1 now have higher thresholds that you must achieve in order to successfully demonstrate meaningful use of your EHR in Stage 2. There are also new Stage 2 core and menu objectives.

For more information about Stage 2 MU, visit http//www.healthmu.org/radiology/beyondstage1.php.

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MU in Action: Meaningful Use for Radiology

In this month’s post, we highlight an interview conducted with Dr. Wells Mangrum, MU program lead at a small radiology practice in Wisconsin.

Medical X-Ray Consultants is a small practice of 12 radiologists in Eau Claire Wisconsin that services a variety of hospitals across northwest Wisconsin and eastern Minnesota. As part of their commitment to quality, participating in the Meaningful Use program was an important part of their strategic plan.

What was the core challenge you faced in implementing a Meaningful Use program?

Our small radiology group covers many hospitals and each provider organization has a different Electronic Health Record (EHR). Many of these hospital EHRs are certified for Meaningful Use (MU) on the inpatient side, but not outpatient. Accordingly, our radiology group found ourselves in a dilemma as to how to meet MU requirements in the outpatient setting. We also needed to balance the workflow impact of leveraging all the various EHR solutions verses finding a more streamlined solution.

What solution did you find?

After exploring all available options, we found ImagingElements, a radiology-centric EHR provider that offers a complete certified solution to meet outpatient MU requirements. They offered a platform and capability that resolved our dilemma—we use their web-based platform to record outpatient information in a manner that satisfies Meaningful Use requirements. One of ImagingElements unique capabilities is their “denominator reduction” approach. This dramatically reduces our data collection workload and focuses our Meaningful Use efforts towards the specific encounters that matter.

Were there any challenges along the way?

Capturing and recording encounter data was our biggest hurdle. We first considered creating an interface between our hospitals and ImagingElements, but this proved to be challenging given the number of hospitals we cover and the limited technical support that we could obtain from each. The ideal solution then presented itself; our billing company, Cvikota, stepped in to act as an intermediary. They offered to collect the necessary information from the many hospitals—indeed they were already collecting much of the information for billing purpose—and then electronically send the information to ImagingElements. This greatly simplified things by only requiring us to create one new interface, an interface between our billing office and ImagingElements. In the end, this has worked extremely well and frankly was easy to do once we found the right team of ImagingElements and our billing office. I highly recommend that other radiology groups in our situation follow a similar course of action to achieve Meaningful Use.

Anything else to add?

Yes. ImagingElements was not just another company selling a certified MU product. They also provided expert guidance on how the complex rules of the Meaningful Use program apply to radiology practices. This additional consultative element was crucial to our success. They have put together a comprehensive set of policies that have been an excellent step-by-step guide for us to follow to ensure that we meet the requirements of this government program.

Ready to learn more, buy a book today!

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MU Takes the Stage at RSNA 2013

In this month’s post, we take a look at news and industry updates from RSNA 2013.

Meaningful use is one of the most discussed topics across all health care specialties—and radiology is no exception. The challenges that the imaging community faces, and experiences of those that have already tackled this government program, were shared at the recent Radiological Society of North America annual conference.

RSNA 2013 offered a number of educational tracks and sessions dedicated to the subject. From information packed sessions for radiology IT providers, to discussions with leaders in the field, there was something for everyone impacted by the CMS EHR Incentive Programs. What’s more, this year’s conference featured dozens of new solutions designed for, and used for attestation by, radiology professionals.

Furthermore, a number of feature articles have been published over the past 2 weeks that focus on the topic of meaningful use and provide an excellent recap of the sessions and discussions that took place at the conference.

MU News from RSNA 2013

  • HealthDataManagement.com: Radiologists Share Diverse Meaningful Use Experiences –Read more…
  • DiagnosticImaging.com: Should Hospital-based Radiologists Pursue Meaningful Use? – Read more…
  • DiagnosticImaging.com: Some Radiologists Embrace Meaningful Use, Others Wait –Read more…
  • ImagingBiz.com: Take a Long View of MU –Read more…
  • TechTarget.com: New RIS workflows making EHRs look low-tech – Read more…

Ready to learn more, buy a book today! 

Go to http://www.theMUguide.com to learn more. Buy a book from the official e-store (http://buy.theMUguide.com) or Amazon.com (http://amazon.theMUguide.com).

Meaningful Use at RSNA 2013

In this month’s post, we take a look at meaningful use sessions and lectures at RSNA 2013.

Nearly 55,000 radiology professionals from around the world will converge on Chicago to witness the latest discoveries, techniques and innovations for diagnostic imaging – 2,000 education exhibits, 300 peer-reviewed refresher courses, and 2,500 scientific presentations. Below is a list of lectures and sessions about meaningful use that will support your participation in the CMR EHR Incentive Programs.

Monday 12/02/13 (4:30-6:00PM/ICII24): Meaningful Use for Radiology IT Vendors: What your Customers will Demand, and your Competition will Provide

Presenter(s): David E Avrin MD, PhD; Keith J Dreyer DO, PhD 

Even with Phase II rules of Meaningful Use, the fit with Radiology remains a challenge. The focus of the federal agencies remains on the primary care practices of internal medicine, family practice, and pediatrics. However, with recent refinement of the US Federal Health IT rulings for Meaningful Use (MU), it is hoped that some US radiologists will be eligible for substantial CMS incentives. Collectively, these incentives could total over $1 billion for radiologists alone. Up to $44,000 is available per qualifying Eligible Provider. As important, incentives may turn to penalties within a few years. MU was initially targeted towards primary care specialties, but under certain circumstances could apply to diagnostic radiology.  Eligibility for MU will depend upon the individual radiologist’s practice scenario. Some technology will come from existing infrastructure (including RIS, PACS, Reporting Systems) and others will come from new purchases (including Decision Support, Data Mining, Image Sharing and Patient Portals).

In this lecture, the presenters will describe ways to analyze your existing portfolio of products to determine which MU measures they should be eligible for, and to define a pathway toward MU certification of these modules.

Further, we will discuss the ability to determine what additional functionality might be added to your existing products to expand your MU certification offerings. Finally, we will explore ways for your company to provide all remaining MU measures, beyond your existing product portfolio, so that your existing and future customers can achieve Meaningful Use. We will also review results of an RSNA sponsored survey to propose a set of criteria that more appropriately define true MU for radiology to affect future federal rule setting when they move beyond primary care specialties.

Tuesday 12/03/13 (12:30-2:00PM/ICII32): Meaningful Use: Experience from Private Radiology Practices

Presenter(s): J. Raymond Geis MD; James Whitfill MD; Alberto F Goldszal PhD, MBA; Alan D Kaye MD

Learning objectives for this course include: 1) Learn how various radiology practices have approached Meaningful Use to date. 2) Understand the challenges of achieving Meaningful Use compliance with existing vendor products available today. 3) Explore ways to participate with either your hospital or multi-specialty practice to achieve Meaningful Use.

Wednesday 12/04/13 (12:30-2:00PM/ICII42): Meaningful Use: Experience from Radiology Practices in Hospitals and Health Systems

Presenter(s): Ramin Khorasani MD; Curtis P Langlotz MD, PhD 

Learning objectives for this course include: 1) Understand the meaningful use program. 2) Learn how hospitals and health systems have achieved meaningful use for their radiologists. 3) Decide how your practice should respond to the program. 

Thursday 12/05/13 (8:30-10:00AM/RC626): Latest Developments in Meaningful Use: Ask the Experts

Presenter(s): Curtis P Langlotz MD, PhD; Keith J Dreyer DO, PhD; Michael Peters

Learning objectives for this course include: 1) Understand the meaningful use program. 2) Learn how hospitals and health systems have achieved meaningful use for their radiologists. 3) Gain insight into recent and upcoming regulatory changes, and 4) Decide how your practice should respond to the program. 

For more information, search the full RSNA 2013 Meeting Program.

Ready to learn more, buy a book today! 

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Stage 1 Changes in 2013 and What’s Coming in 2014

In this month’s post, we take a look at Stage 1 changes that took effect this year and what’s to come next year. 

As the end of 2013 draws near, we examine Stage 1 changes that went into effect, those that were optional, and those that will take effect in 2014. It is important to familiarize yourself as you prepare to begin, or continue, participation in the program next year.

Removed in 2013

  • Electronic Exchange of Key Clinical Information: This objective was removed for Stage 1 for EPs, EHs, and CAHs.

Required in 2013

  • Public Health Reporting Objectives: Clarification that providers must perform at least one test of their CEHRT’s capability to send data to public health agencies, except where prohibited.

Optional in 2013+

  • Computerized Physician Order Entry (CPOE): Alternative measure added based on the total number of medication orders created during the EHR reporting period (option to choose the alternative measure in 2013 and beyond).
  • ePrescribing: Additional exclusion to the objective for electronic prescribing for providers who are not within a 10 mile radius of a pharmacy that accepts electronic prescriptions (optional to select the additional exclusion starting in 2013 and beyond).

Required in 2014

  • Public Health Reporting Objectives: Clarification that providers must perform at least one test of their CEHRT’s capability to send data to public health agencies, except where prohibited.
  • Electronic Copy of and Electronic Access to Health Information: In order to better align Stage 1 objectives with the new 2014 capabilities of CEHRT, CMS is replacing several Stage 1 objectives for providing electronic copies of and electronic access to health information with objectives to provide patients the ability to view, download, or transmit their health information or hospital admission information online. The capability to provide patients online access to this information will be a part of CEHRT beginning in 2014, therefore new Stage 1 objectives will be required beginning in 2014.
  • Record and Chart Changes in Vital Signs: Increase in age limit for recording blood pressure in patients to age 3; removal of age limit requirement for height and weight (optional in 2013; required in 2014+)
  • Menu Objective Exclusions: Beginning in 2014, eligible professionals (EPs), eligible hospitals (EHs), and critical access hospitals (CAHs) will no longer be permitted to count an exclusion toward the minimum of 5 menu objectives on which they must report if there are other menu objectives which they can select. EPs, EHs, and CAHs will not be penalized for selecting a menu objective and claiming the exclusion if they would also qualify for the exclusions for all the remaining menu objectives.

In addition to the updates above, beginning this year, the Stage 1 objective requiring clinical quality measure (CQM) reporting has been incorporated directly into the definition of a meaningful EHR user.

For more information, visit the CMS EHR Incentive Programs website.

Ready to learn more, buy a book today!

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Office of the Inspector General MU Report

In this month’s post, we take a look at the HHS Office of the Inspector General’s (OIG) early (November 2012) assessment of the CMS oversight of the Medicare EHR Incentive Program. The following is an excerpt from the executive summary of the report, Early Assessment Find That CMS Faces Obstacles In Overseeing The Medicare EHR Incentive Program (OEI-05-11-00250).

Why did the OIG do this study?

This study is an early assessment of CMS’s oversight of the Medicare electronic health record (EHR) incentive program, for which CMS estimates it will pay $6.6 billion in incentive payments between 2011 and 2016. Because professionals and hospitals self- report data to demonstrate that they meet program requirements, CMS’s efforts to verify these data will help ensure the integrity of Medicare EHR incentive payments.

How did the OIG do this study?

This study reviewed CMS’s oversight of professionals’ and hospitals’ self-reported meaningful use of certified EHR technology in 2011, the first year of the program. To address our objective, OIG analyzed self-reported information to ensure it met program requirements. OIG also reviewed CMS’s audit planning documents, regulations, and guidance for the program, and conducted structured interviews with CMS staff regarding CMS’s oversight.

What did the OIG find?

CMS faces obstacles to overseeing the Medicare EHR incentive program that leave the program vulnerable to paying incentives to professionals and hospitals that do not fully meet the meaningful use requirements. Currently, CMS has not implemented strong prepayment safeguards, and its ability to safeguard incentive payments postpayment is also limited. The Office of the National Coordinator for Health Information Technology (ONC) requirements for EHR reports may contribute to CMS’s oversight obstacles.

To read the entire report, and learn about the OIG’s recommendation, go to https://oig.hhs.gov/oei/reports/oei-05-11-00250.asp

Ready to learn more, buy a book today!

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