Tag: EHR Incentives
Providers taking part in the EHR incentive program face an Oct. 1 deadline to file a hardship exemption or pay a penalty.
The Medicare EHR Incentive Program ended with the 2016 reporting period.
Providers now report to the quality payment program.
Those transitioning to the merit-based incentive payment system, or MIPS, may file for a hardship exemption for not meeting the requirements of meaningful use in prior years to avoid penalties in 2018, according to the Centers for Medicare and Medicaid Services. The deadline is Oct. 1.
It’s also the deadline for eligible hospitals that have not successfully demonstrated meaningful use in a prior year, and are seeking to demonstrate meaningful use for the first time in 2017, to avoid the 2018 payment adjustment.
For critical access hospitals, Oct. 1 is the deadline for those that have not successfully demonstrated meaningful use, and are looking to demonstrate meaningful use for the first time in 2017, to avoid the payment adjustment for 2017.
Eligible hospitals and CAHs can create an account in QNet to report their 2017 data. Those that have already created an account can add meaningful use option to their accounts, CMS said.
Also on Oct. 1, the Medicare hospital inpatient prospective payment system and long term acute care hospital prospective payment system final rule takes effect. The rule contains several changes that will directly affect the Medicare and Medicaid EHR incentive programs.
A new market report addresses areas where EHR vendors will need to improve their systems in order to stay competitive through 2018.
According to Kalorama Information, the $28-billion EHR market dominated by a score large vendors and hundreds of smaller competitors is set for a change as a result of emerging challenges voiced by healthcare professionals such as health IT-related administrative burden and negative perceptions of specific EHR vendors and products.
“Small trends that in the past were noted but not addressed, like usability and interoperability, have bubbled up we believe to where they are no longer side issues,” said Bruce Carlson, Publisher of Kalorama Information. “A few policy, industry and medical practice changes will change how the revenue grows or who earns it, and what the EMR market looks like in 2018.”
The following are six factors likely to affect EHR use and development in the coming years:
1. Physician dissatisfaction and burnout
Physician dissatisfaction with EHR systems is not a new phenomenon. High rates of dissatisfaction are common among physicians working with EHRs due to administrative burden. EHR solutions that streamline administrative processes to free up time in a physician’s workday could greatly reduce dissatisfaction.
2. New Trump Administration policy goals
Newly-appointed HHS Secretary Tom Price is disappointed with meaningful use requirements and interested in readjusting federal reporting requirements to impose less of an administrative burden on providers. In its report, Kalorama examines potential policy changes offering a departure from these stringent requirements and what these changes might mean for EHR vendors.
3. Ransomware attacks and health data breaches
With ransomware attacks and data breaches becoming more and more common, providers are increasingly wary of relying entirely on EHR and health IT systems to run their institutions. EHR systems may increase efficiency and allow for faster, better-informed patient care delivery, but the risk of ransomware has cast a dark shadow over EHR systems in the eyes of many.
4. Dashboarding, blockchain, and other new infrastructure advancements
New health IT designs will allow providers new ways to ensure a more efficient approach to daily clinical tasks and tighter data security. Dashboarding gives healthcare providers an interactive view of real-time data to inform patient care equipped with valuable insights. Additionally, blockchain is becoming increasingly common as a way to improve the standardization and security of health data.
5. IT staff shortages
Having IT experts on staff or through a vendor partnership is becoming a necessity as technology becomes increasingly integral to daily processes. Without qualified IT staff, healthcare organizations could be unable to reap the full benefits of their EHR systems or find themselves faced with technology issues they are unprepared to handle.
6. Room to grow
EHR giants such Cerner and Epic may dominate the market, but research shows no single company comprises even 20% of the EHR industry. Because no single vendor monopolizes the entire market, smaller vendors, local sales, and web-based offerings still have a chance of getting a reasonable foothold in the industry.
The EHR Incentive Programs attestation system will be open from January 3 – February 28, 2017. Providers must attest by the attestation deadline to avoid a 2018 payment adjustment.
To help providers prepare for the 2016 EHR Incentive Programs attestation period, the Centers for Medicare & Medicaid Services (CMS) has released two attestation worksheets.
Providers can log their meaningful use measures for each objective in the worksheet and use it as a reference when attesting for the 2016 Medicare EHR Incentive Program in CMS’ Registration and Attestation System.
Reporting Objectives and Measures
- All providers are required to attest to a single set of objectives and measures.
- For eligible professionals (EPs), there are 10 objectives, and for eligible hospitals and critical access hospitals (CAHs), there are 9 objectives.
- View the 2016 Specification Sheets for EPs and hospitals and CAHs.
- In 2016, all providers must attest to objectives and measures using EHR technology certified to the 2014 Edition. If it is available, providers may also attest using EHR technology certified to the 2015 Edition, or a combination of the two.
For More Information
CMS encourages providers to visit the CMS 2016 Program Requirements webpage on the CMS website to access the worksheets and review additional resources for providers to be successful in the 2016 EHR Incentive Program participation.
As the new year quickly approaches, so does the start of meaningful use attestation under the new final Stage 2 Modifications Rule. With that final rule comes many changes to Stage 2 Meaningful Use that providers will need to take into account as they attest in 2016.
What are these changes? What information do providers need to know about attestation? Below is a roundup of materials from the Centers for Medicare & Medicaid Services (CMS) and EHRIntelligence.com articles to help providers prepare for meaningful use attestation in 2016:
Stage 2 Meaningful Use Attestation Timeframes
Under the final rule, which was released in early October of this year, attestation timeframes were adjusted to align with the full calendar year. Starting in 2016, both eligible professionals (EPs) and eligible hospitals (EHs) will need to attest to Stage 2 Meaningful Use between January 1 and December 31 of 2016.
However, all first-time Stage 2 participants, as well as those attesting for 2015, will only need to attest to a 90-day timeframe. These 90 days must be consecutive and occur between January 1 and December 31 of 2016.
Streamlining Objectives Measures
In a webinar following the release of the Modifications Rule, CMS provided a comprehensive summary to the various changes to Stage 2, as well as the rationale behind it. Specifically, CMS discussed Stage 2 objectives measures and the way they have been compressed.
Under the Stage 2 Modifications rule, EPs attesting for 2016 will only need to attest to 10 core objectives. One of these core objectives must be an overarching public health reporting objective that includes three reporting measures.
The Modifications Rule also streamlines objectives for EHs and critical access hospitals (CAHs), reducing the number of objectives to nine, with one overarching public health reporting objective that includes four reporting measures.
These objectives were changed to align better with the goals and requirements of Stage 3 Meaningful Use, as well as to get rid of “redundant and duplicative” requirements.
Certified EHR Technology
Although 2015 attestations required providers to use the 2014 edition of Certified EHR Technology, the 2016 attestation requirements provide more flexibility. According to CMS, providers may attest using either the 2014 certification edition, or the newly-released 2015 edition.
The Department of Health and Human Services (HHS) Office of the National Coordinator for Health IT (ONC) released the 2015 EHR certification criteria at the same time as the Meaningful Use final rule. The 2015 criteria put an emphasis on interoperability and health information exchange (HIE).
Specifically, the criteria call for mandatory HIE testing reports, as well as updated data export to facilitate adequate interoperability.
As stated above, attesting with these EHR certification criteria is optional in 2016, but becomes mandatory in 2018.
Because providers may not have EHR systems that can support the new provisions in the Modified Stage 2 Meaningful Use guidelines, CMS is offering several alternate exclusions. CMS has released a comprehensive list of alternate exclusions for EPs, EHs, and CAHs as an attachment to other Meaningful Use attestation guidelines.
However, CMS has addressed notable exclusions including those for public health reporting. Due to an influx of concern regarding the ability to attest to public health reporting measures, CMS is offering alternate exclusions stating that EPs may report on only two of the three measures, but that one of the two measures must be measure 1, which pertains to immunization registry reporting.
EHs and CAHs applying for an alternate exclusion may attest to only three of four measures, but one of the measures must be measure 3, which involves specialized registry reporting.
When attesting to Stage 2 in 2016, providers and hospitals alike will need to bear in mind these changes to the program in order to ensure a smooth attestation. Provided CMS’s rationale for the Stage 2 modifications — which includes the consistency between Stage 2 and Stage 3 requirements — adhering to these new modifications will allow for a better transition to Stage 3 come 2018.
The Centers for Medicare & Medicaid Services (CMS) released final Meaningful Use rules that simplify requirements and add new flexibilities for providers to make, electronic health information available when and where it matters most and for health care providers and consumers to be able to readily, safely, and securely exchange that information. The final rules for 2015 Edition Health IT Certification Criteria (2015 Edition) and final rules with comment period for the Medicare and Medicaid Electronic Health Records (EHRs) Incentive Programs will help continue to move the health care industry from a paper-based system, where a doctor’s hand-writing had to be interpreted and patient files could be misplaced.
CMS heard from physicians and other providers about the challenges and burdens they face making this technology work well for their individual practices and for their patients. In recognition of these concerns, the final regulations make significant changes to current requirements by easing the reporting burden for providers, supporting interoperability, and improving patient outcomes. CMS is also encouraging providers to apply for exemptions if they had difficulty with or needed to switch their EHR vendor or experienced challenges due to the timing of the rules and EHR implementation. Additionally, the new rules will enable the development of user-friendly technology, allowing individuals easier access to their information so they can be engaged and empowered in their care.
Overview of Rule Provisions
CMS reviewed and considered more than 2,500 comments on the two proposed rules to create the final policies, with the opportunity for additional comment, for participation in the EHR Incentive Programs. In recognition of the issues raised, CMMS made significant changes to ease reporting burden for all providers, supporting health information exchange, and improving patient outcomes. For example, the regulations:
- Shift the paradigm so health IT becomes a tool for care improvement, not an end in itself.
- Provide simplicity and flexibility so that providers can choose measures that use in their practices and report progress that are most meaningful to their practice.
- Give providers and state Medicaid agencies more time – 27 months, until January 1, 2018 – to comply with the new requirements and prepare for the next set of system improvements.
- Give developers more time to create the next advancements in technology that will be easier to use and more appropriate to new models of care and access to data by consumers.
- Support provider exchange of health information and a more useful interoperable infrastructure for information exchange between providers and with patients
- Give developers more time to create the next advancements in technology that will be easier to use and more appropriate to new models of care and access to data by consumers.
- Address health information blocking and interoperability between providers and with patients.
For the EHR Incentive Programs in 2015 through 2017, major provisions include:
- 10 objectives for eligible professionals including one public health reporting objective, down from 18 total objectives in prior stages.
- 9 objectives for eligible hospitals and critical access hospitals (CAHs) including one public health reporting objective, down from 20 total objectives in prior stages.
- Clinical Quality Measures (CQM) reporting for both eligible professionals (EPs) and eligible hospitals/CAHs remains as previously finalized.
CMS evaluated the current programs and identified areas where modifications could be made to align with the long-term vision and goals for Stage 3. CMS restructured the objectives and measures of the EHR Incentive Programs in 2015 through 2017 to align with Stage 3, and modified “patient action” measures in Stage 2 objectives. These changes recognize the progress providers have made and realign with long term goals.
For Stage 3 of the EHR Incentive Programs in 2017 and subsequent years, major provisions include:
- 8 objectives for eligible professionals, eligible hospitals, and CAHs: In Stage 3, more than 60 percent of the proposed measures require interoperability, up from 33 percent in Stage 2.
- Public health reporting with flexible options for measure selection.
- CQM reporting aligned with the CMS quality reporting programs.
- Finalize the use of application program interfaces (APIs) that enable the development of new functionalities to build bridges across systems and provide increased data access. This will help patients have unprecedented access to their own health records, empowering individuals to make key health decisions.
The Stage 3 requirements are optional in 2017. Providers who choose to begin Stage 3 in 2017 will have a 90-day reporting period. All providers will be required to comply with Stage 3 requirements beginning in 2018 using EHR technology certified to the 2015 Edition. Objectives and measures for Stage 3 include increased thresholds, advanced use of health information exchange functionality, and an overall focus on continuous quality improvement.
In addition, the final rule adopts flexible reporting periods that are aligned with other programs to reduce burden, including moving from fiscal year to calendar year reporting for all providers beginning in 2015, and offering a 90-day reporting period in 2015 for all providers, for new participants in 2016 and 2017, and for any provider moving to Stage 3 in 2017.
As part of today’s regulations, CMS announced a 60-day public comment period to facilitate additional feedback about Stage 3 of the EHR Incentive Programs going forward, in particular with the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), which established the Merit-based Incentive Payment System (MIPS) and consolidates certain aspects of a number of quality measurement and federal incentive programs into one more efficient framework. We will use this feedback to inform future policy developments for the EHR Incentive Programs, as well as consider it during rulemaking to implement MACRA, which we expect to release in the spring of 2016.
New data published by the Office of the National Coordinator for Health Information Technology shows high levels of office-based physician EHR use of certified EHR technology (CEHRT) and even greater EHR adoption numbers in 2014.
The most recent ONC brief puts the percentage of office-based physician CEHRT users at 74 percent as compared to 51 percent using a basic EHR and a total of 83 percent using any type of EHR technology.
Of those physician EHR users with CEHRTs, more than half (56%) have plans to participate in the EHR Incentive Programs although one-third that number (18%) have no plans or remain unsure as to their participation in meaningful use.
As for the basic EHR functionalities being used by office-based physicians, the figures hovered around 80 percent with the exception of viewing imaging results. Less than two-thirds of office-based physician EHR users reported have the ability to view imaging results electronically, 25-percentage points fewer than the most common computerized functionalities of recording demographic information (86%) and computerized prescription order entry (85%). Other functionalities topping the 80-percent mark were:
- Recording patient’s medications and allergies (84%)
- Recording clinical notes (83%)
- Recording patient problem lists (82%)
Based on specialty, primary care physicians reported the highest rates of EHR adoption across all types of EHR technology — 87 percent. Medical specialists and surgical specialists were not too far behind at 80 percent and 78 percent, respectively, and equal in terms of physician CEHRT users (70%).
Generally an indicator of EHR adoption, practice size proved to be a significant differentiator in 2014 for office-based physician EHR adoption.
Solo practitioners reported the lowest percent of EHR adoption across the board, at a total of 64 percent for all EHR technology and 55 percent for CEHRT. The highest percentage of EHR adoption was reported by practices of 11 or more physicians, 97 percent of which had adopted EHR technology of any type and 86 percent of CEHRT. Sandwiched between these two sets of physicians were 6-10 physician practices and 2-5 physician practices.
A rather ambiguous finding in the report deals with physician EHR adoption by practice setting:
- 98 percent of physicians in community health centers had adopted EHR technology; 76 percent CEHRT
- 44 percent of physicians in community health centers and physician or group-owned practices were using all Basic EHR functionalities
- Physicians in physician- or group-owned practices reported the lowest EHR adoption rates across all EHR types
- HMO-owned or other healthcare corporation-owned physician practices reported the highest adoption rates of certified EHRs at 87%
“These findings may be related to the fact that the Basic EHR definition includes functionalities that apply primarily to certain physician specialties and may not be broadly applicable across the care continuum,” the ONC report states.