Meaningful Use Hardship Exception Process Updates

electronic-filesand a computer mouseIn an earlier blog post titled New MU Exemptions for 2015 Reporting Periods, DataFile alerted you to the new Patient Access and Medicare Protection Act law.  This legislation allows for Eligible Providers who were unable to attest to Meaningful Use for 90 days in 2015 to declare an exception in order to avoid a 2017 payment adjustment.

CMS recently issued guidance that Eligible Providers who experienced an issue with their Certified Electronic Health Record Technology related to the rule timing – and any other provider for whom the timing of the rule caused a significant hardship – should select sub-category 2.2d on the 2017 Hardship Exception Application. No additional documentation is required for this selection according to CMS FAQ 14113.  Additional instructions for completing the Hardship Exception Application can be found here.

If you have questions about how the Hardship Exception may apply to your organization, please contact our Meaningful Use Expert, Kathryn Ayers Wickenhauser, at Kathryn.Wickenhauser@DataFileTechnologies.com for assistance.

Meaningful Use Attestation Deadline Extended

calendar-660670__180The Centers for Medicare & Medicaid Services (CMS) extended the attestation deadline for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs to Friday, March 11, 2016 at 11:59 p.m. ET, from the original deadline of Monday, February 29.

Need assistance attesting to Meaningful Use? Our Meaningful Use and HIPAA Compliance Expert, Kathryn Ayers Wickenhauser, is here to help you!

Contact her at Kathryn.Wickenhauser@DataFileTechnologies.com to set up an appointment to discuss your 2015 reporting!

Meaningful Use Audits — Steps to Prepare and Prevent the Domino Effect (Part 2)

XI_dominos_300xThis article is the second in a Two-Part series and includes helpful and timely tips to help you prepare for a Meaningful Use (MU) Audit. 

Our previous blog post was a list of helpful tips to help you prevent an MU Audit.  And perhaps you followed those steps and tips diligently, but you’re one of the unlucky ones.

According to a report issued by the United States Government Accountability Office, “CMS anticipates sampling roughly 20 percent of professionals, identified through random sampling as well as some targeted selections.”

If you receive an Audit Notification, here’s what to expect:

1 – Audits can be random or triggered. If information was entered incorrectly into the attestation website (such as a numerator that’s larger than a denominator), it’s possible that an Audit may be triggered.  This is why it’s critical to take the time to properly attest.  Additionally, if a provider participates in the program and then stops, due to retirement or lack of meeting a year of MU, it is likely Figliozzi and Company will audit the provider to see what has happened.  However, many Audits are completely luck of the draw and random.

2 – There are different types of Meaningful Use Audits. Audits can be Pre-Payment or Post-Payment.  Pre-payment Audits occur following attestation for a reporting period before CMS issues a check to the organization’s Tax ID number.  Post-Payment Audits can occur following a payment that has been issued up to six years post-attestation.  That means that organizations can be audited for a 2011 reporting period through 2017.  This is why it’s critical to have great files!

3 – Figliozzi CPA Firm will email the email address on file. Ensure that whatever email address you enter with the attestation account is aware of Figliozzi and Company CPA Firm. Included in the email from Figliozzi will be a letter addressing the Audit, including for which provider and what reporting period year.  Additionally, there will be documentation regarding what the Auditor is requesting to verify Meaningful Use was properly met.

4 – The practice will have a set time period to respond. Figliozzi typically gives two weeks from the time of your receipt of the Audit Notification until when your response is due.  In some instances, Figliozzi allows for a longer time period to respond, so check your Audit Letter for the due date.

5 – You can request an extension. Many times, Figliozzi allows an extension for responding to the Audit, especially if the initial request is to respond in two weeks. We’ve found it’s better to provide a reason to why you are requesting the extension, but in our experience, initial requests for extensions are almost always granted.

6 – There are multiple ways to send files. Figliozzi will provide a secure file upload site, as well as the Auditor’s email address. Of course, no Patient Health Information (PHI) should be in either file.  We suggest uploading via the portal and emailing the Auditor, requesting the Auditor provide confirmation that the information was received.

7 – The Auditors will clarify and request additional information. Typically Meaningful Use Audits are not one response requested and done.  If the Auditor does not believe sufficient information is submitted to illustrate successful attestation for MU, the Auditor will email back a secondary request.  In our experience, up to three submissions from the practice are available before the Auditor makes a final decision.  Even so, the practice should do its best to answer and illustrate meeting all of the requested information upfront, the first time.

8 – At the end of the Audit, you will receive an Audit Notification Letter. Following the conclusion of the Audit, the Auditor will send a Final Notification that announces if the provider passed or failed the Audit.  If the provider fails the Audit, CMS will request repayment of the incentive funds (or the funds will not be distributed if a Pre-payment Audit).  Additional penalties could also ensue.  There is the possibility of appealing an Audit, so it’s recommended you engage an experienced professional at that point.

Overwhelmed?  Responding to Meaningful Use Audits appropriately is extremely important.  One misstep could mean that your organization is immediately on the hook to pay back incentive funds received and the Provider will have a penalty against their Medicare Part B reimbursement.  It doesn’t end there though!  A failed Audit will mean additional reporting year Audits for that provider, and perhaps additional Audits for other providers within the organization.

In essence, responding to a MU Audit can incite a domino effect of one provider failing and then additional providers being targeted to see if they will fail as well.  If you’re not completely confident in responding to an Audit, utilize a trusted partner, like your EHR vendor or a Business Associate Consultant who has experience responding to these types of Audits.  Prevent the domino effect and protect the practice’s hard work to collect and retain the incentive funds.

Meaningful Use Audits — Steps to Prepare and Prevent the Domino Effect (Part 1)

This article is a Two-Part series and includes helpful and timely tips to help you prevent (Part 1) or at least begin to prepare for (Part 2) a Meaningful Use (MU) Audit.

Perhaps when you were a kid you had a lot of fun with dominoes and their chain reactions. If you’ve never had fun with dominoes yourself, this YouTube video illustrates the fun.

But with life experience, we’ve all learned that cascading problems (it’s not just falling dominoes anymore!) that begin with a small incident can have big repercussions.

According to a report issued by the United States Government Accountability Office, “CMS anticipates sampling roughly 20 percent of professionals, identified through random sampling as well as some targeted selections.”

It’s that time of year again – time to attest for Meaningful Use!  If you’re the lucky person in your organization that has been entrusted to enter the prior reporting period’s information into the CMS website, congratulations!  Before you click the “submit” button, consider these eight suggestions:

1 – Do have a second set of eyes. Partner up and enter the information as a Team!  It’s helpful to have one person entering the information on the website while a second person is reading the information off of your Meaningful Use Measure Report.

2 – Do allow plenty of time. The website for attestation can be overwhelming.  There are lots of questions about exclusions, so read carefully!  In addition, when many people are on the website, it tends to run slowly.  Attest at off-peak times or allow plenty of time to get your information in.

3 – Do print out the reports and color code them. Have a hard copy of each provider’s Meaningful Use report. Before sitting down to attest, color code each measure.  A suggestion would be to color code passing measures green, and exclusions yellow.  This visual will make it easier to recognize exclusions while entering information on the website.

4 – Do create an Audit folder for each provider. CMS has the right to audit providers for Meaningful Use up to six years post-attestation.  Keep an electronic and a paper folder with the information utilized to attest in case of an Audit.  We suggest keeping all data in both locations to support reportable and self-attestation measures (like your Security Risk Analysis for the year).

5 – Do print out the receipt of attestation. Keep the receipt as proof and add it to the provider’s own Audit file.

6 – Do check the email address for the submission. If the provider is selected for Audit, the initial request for information will go to the address that is registered to the attestation account.  If your practice currently enters the provider’s email address, consider changing it to an Administrator’s email.  This will ensure all emails will be received and responded to in a timely manner.

7 – Do know who your Meaningful Use Audit comes from. If attesting to Medicare Meaningful Use, the CPA firm, Figliozzi and Company, has been contracted to conduct the Audits.  Key members of your organization should recognize the Figliozzi name so that an email from them is not ignored.

8 – Do keep track of which providers have been audited, and when. CMS estimates that 20% of providers (1 out of every 5) will be audited during the course of the Meaningful Use Program.  This means that if your organization has not received an Audit, it’s likely one is on its way to you.  Providers who’ve previously passed Audits are not as likely to receive a second Audit, although it’s possible.  It’s very possible that organizations will be audited for multiple providers and multiple reporting years during the course of the MU Program.

Stay tuned!  Our next blog post (Part 2 of 2) will feature a list of helpful tips about how to prepare for an MU Audit if you happen to be selected.

New MU Exemptions for 2015 Reporting Periods

gavel and law-1063249_1920New Legislation This Week Intended to Offer Eligible Healthcare Providers Relief from Medicare Payment Adjustment Penalties

President Obama signed the “Patient Access and Medicare Protection Act” into law on Monday, December 28, 2015. Congress passed the bill the prior week as one of their final legislative acts before adjourning for the year.

This new legislation aims to alleviate stress placed on Eligible Providers (EPs) after the Modified Stage 2 Rule — which requires 90 consecutive days of EHR data reporting for 2015 — was released in mid-October. With the late release of the modifications, there wasn’t a full 90-day reporting period remaining in the 2015 calendar year and some healthcare providers didn’t have enough time to comply with the updates.

The statute makes it easier for Eligible Providers (EPs) to obtain hardship exemptions to the Modified Stage 2 Meaningful Use requirements for 2015. Under prior legislation, EPs could apply to the Center for Medicare and Medicaid Services (CMS) for a hardship exemption on a “case-by-case” basis.  This new legislation enables CMS to grant hardships to affected healthcare providers for 2015 impacting 2017 payment adjustments.

This new law extends the opportunity for EPs who’re unable to meet Meaningful Use for 2015 to apply for an exemption. To protect themselves from Medicare Part B Penalties that would be applied in 2017, EPs should apply for exemption by March 15, 2016.  CMS will continue to accept hardship applications after the mid-March deadline, but such applications will revert back to the original case-by-case review process.  More information regarding what the exemption process will entail is forthcoming from the Center for Medicare and Medicaid Services.

Wickenhauser to Address National AAOE Annual Conference

golden-gate-bridge-690346_640Kathryn Ayers Wickenhauser will Address Healthcare Executives at the National American Association of Orthopaedic Executives (AAOE) Conference in San Francisco

 

HIPAA Compliance and Meaningful User Expert, Kathryn Ayers Wickenhauser, has been selected as a speaker for the 2016 AAOE National Conference.  Wickenhauser was selected by the AAOE Annual Conference Planning Committee to share her knowledge with attendees through her tailored presentation titled, “Orthopedic HIPAA Hot Topics:  Defining and Utilizing Your Designated Record Set.”

Wickenhauser is a sought after speaker, trainer, consultant and thought leader on a broad range of healthcare topics.  Kathryn is passionate to assist providers and their organizations through healthcare reform hurdles.  She’s coached more 3,000 providers to earn in excess of $45 million in government healthcare incentives and avoid more than $20 million in costly financial penalties.  Kathryn’s past experiences in ambulatory practices, medical research settings and providing user training for EHR systems gives her first-hand knowledge about modern healthcare challenges.  Kathryn guides organizations large and small through complex regulations, each receiving a customized, sustainable approach.

The National AAOE Annual Conference will be held June 9-12, 2016 in San Francisco, CA.

To review our Topic Portfolio or to book Kathryn to design a tailored educational session for your audience, please visit www.DataFileTechnologies.com.

Meaningful Use or Meaningful Confusion? Part 3 of 3

medical-moneyThis is Part 3 of our Three-part Blog Series, “Introduction of Stage 3,” which outlines the objectives finalized for Stage 3 under the October 16, 2015 Final Rule.

Meaningful Use was introduced as part of the HITECH Act as a means to encourage healthcare providers to adopt electronic health records, and also begin to shift to additional quality care metrics. Yet, since Meaningful Use began in 2011, there have been many critics who assert that the program does not achieve the meaning in Meaningful Use.  As such, there have been multiple iterations of the rule and the various stages.  We will present to you the latest changes that you need to know in this three part blog post series.

Part three of the series, “Introduction of Stage 3” outlines the objectives finalized for Stage 3 under the October 16th Final Rule.  You can view Part One of our series, “Changes for 2015” here.  Part Two of our the series, “Changes for 2016-2017” can be viewed here.

 

Optional 2017 Reporting and Required 2018 Reporting

Stage 3 will be available for attestation in 2017, although it won’t be required as previously thought. Eligible Providers will be given the option of attesting to Stage 3 in 2017 for a 90 day reporting period.  In 2018, all Providers, regardless of what stage they were scheduled to be on, are to attest to Stage 3 Objectives for a calendar year reporting period.  The optional year in 2017 will allow providers to “test the waters” with a shorter reporting period and begin preparing for Stage 3 before they are required to implement it.

 

Eight Objectives

Unlike previous iterations of Meaningful Use, there are no Core and Menu Objective Sets, only required Objectives. Modified Stage 2 set the tone by absorbing previous measures into one set of measures, a precedent that Stage 3 will follow. Stage 3 features many measures from previous of versions of Meaningful Use, often with higher thresholds and less exclusions.

 

Stage 3 Objectives Summary

Objective 1 Protect Patient Health Information Conduct a Security Risk Analysis within the Reporting Period (RP)
Objective 2 Electronic Prescribing More than 60% of permissible prescriptions written by the Eligible Provider (EP) in the RP are queried for a drug formulary and transmitted electronically
Objective 3 Clinical Decision Support 1 – Implement five Clinical Decision Support Rules related to four or more Clinical Quality Measures
2 – Enable Drug-Drug and Drug-Allergy interaction checks for the entire RP
Objective 4 Computerized Provider Order Entry (CPOE) 1 – More than 60% of Medication orders during the RP are created through CPOE
2 – More than 60% of lab orders during the RP are created through CPOE
3 – More than 60% of radiology orders during the RP are created through CPOE
Objective 5 Patient Electronic Access 1 – More than 80% of unique patients seen by the EP during the RP are provided timely access to view online, download, or transmit their health records and can be accessed using the application of the patient’s choice
2 – More than 35% of patients seen by the EP in the RP receive patient specific education resources that were identified by the CEHRT and receive electronic access to those materials
Objective 6 Coordination of Care through Patient Engagement 1 – More than 10% of unique patients seen by the EP during the RP views online, downloads, or electronically transmits their health information or accessing their health information from an application of their choice
2 – More than 25% of unique patients seen by the EP during the RP are sent an electronic message using the secure messaging feature of CEHRT
3 – For more than 5% of unique patients seen in the RP by the EP, patient-generated health data or data from a non-clinical setting is incorporated into the CEHRT
Objective 7 Health Information Exchange 1 – For more than 50% of transitions of care and referrals, the EP that refers the patient should create and electronically exchange the summary of care record using CEHRT
2 – For more than 40% of transitions of care or referrals received by the EP where the EP has never encountered the patient, the EP receives and incorporates into the patient’s record an electronic summary of care document
3 – For more than 80% of transitions of care or referrals received by the EP where the EP has never encountered the patient, the EP performs clinical information reconciliation
Objective 8 Public Health and Clinical Data Registry Reporting 1 – Immunization Registry Reporting
2 – Syndromic Surveillance Reporting
3 – Electronic Case Reporting
4 – Public Health Registry Reporting
5 – Clinical Data Registry Reporting

 

Still confused? Do you need one-on-one guidance regarding your organization? We can help!  Please contact our Meaningful Use Expert, Kathryn Ayers Wickenhauser (Kathryn.Wickenhauser@DataFileTechnologies.com) for guidance about how these changes impact you.

Meaningful Use or Meaningful Confusion? Part 2 of 3

medical-moneyThis is Part 2 of our Three-part Blog Series, “Changes for 2016 and 2017” which describes the realignment of Stage 1 and Stage 2 objectives into a single measure set for 2016 and 2017. 

Meaningful Use was introduced as part of the HITECH Act as a means to encourage healthcare providers to adopt electronic health records, and also begin to shift to additional quality care metrics. Yet, since Meaningful Use began in 2011, there have been many critics who assert that the program does not achieve the “meaning” in Meaningful Use.  As a result, there have been multiple iterations of the rule and the various stages.  We will present to you the latest changes that you need to know in this Three-part blog post series.

Part two of the series, “Changes for 2016-2017” describes the realignment of Stage 1 and Stage 2 objectives into a single measure set for 2016 and 2017.  You can view Part One of our series, “Changes for 2015” here.

 

Realignment of Stage 1 and Stage 2, or “Modified Stage 2”

As an effort to realign and prepare providers for Stage 3 of Meaningful Use, CMS has created a “Modified Stage 2.” All Providers on track to attest to Stage 1 or Stage 2 in 2016 and 2017 will attest to this combined set of ten objectives.

 

2016 and 2017 for “Modified Stage 2” are Full Year Reporting Periods

See the detailed chart below for a summary for the “Modified Stage 2” Objectives.  CMS is continuing complete year reporting periods (for providers beyond their first year of attestation) for 2016 and 2017, despite offering a 90-day reporting period for 2015.   The thought behind the longer reporting period is that CMS has adjusted many of the Meaningful Use measures to make them more attainable for many providers.  With more exclusions and the updates to some existing measures, CMS believes that the updated objective set is achievable for providers over a calendar year.

 

Optional Stage 3 in 2017

In 2014, CMS allowed providers who were slated to attest to Stage 2 a flexible year where they could attest to Stage 1 again if they wished. Similarly, CMS is doing the same thing for Stage 3 Meaningful Use by allowing providers the option of attesting to Stage 3 in 2017.  A huge benefit of participating in Stage 3 in 2017 is the provision that it will only be a 90 day reporting period for those participating providers.  When Stage 3 is required for all provides in 2018 (see Part Three in our Blog Post series next week about this topic!), a calendar year reporting period will be required.  The optional year in 2017 will allow providers to “test the waters” with a shorter reporting period and begin preparing for Stage 3 before they are required to implement it.

 

“Modified Stage 2” Objectives Summary

Objective 1 Protect Patient Health Information Conduct a Security Risk Analysis within the Reporting Period (RP)
Objective 2 Clinical Decision Support 1 – Implement five Clinical Decision Support Rules related to four or more Clinical Quality Measures
2 – Enable Drug-Drug and Drug-Allergy interaction checks for the entire RP

Exclusion: Eligible Providers (EP) who write less than 100 prescriptions during the RP

Objective 3 Computerized Provider Order Entry 1 – More than 60% of Medication orders during the RP are created through CPOE

Exclusion: Any EP who writes fewer than 100 prescriptions during the RP

2 – More than 30% of lab orders during the RP are created through CPOE

Exclusion: Any EP who orders fewer than 100 lab orders during the RP or scheduled to be in Stage 1 during the 2016 RP

3 – More than 30% of radiology orders during the RP are created through CPOE

Exclusion: Any EP who orders fewer than 100 radiology orders during the RP or scheduled to be in Stage 1 during the 2016 RP

Objective 4 Electronic Prescribing More than 50% of permissible prescriptions are queried for a drug formulary and transmitted electronically

Exclusions: Any EP who writes fewer than 100 prescriptions within the RP or does not have a pharmacy that accepts electronic prescriptions within 10 miles of the organization

Objective 5 Health Information Exchange An EP who transitions their patient to another setting of care must use Certified Electronic Health Record Technology (CEHRT) to create a summary of care record and electronically transmit the summary to the receiving provider for more than 10% of transitions of care

Exclusion: Any EP who transitions a patient to another setting of care less than 100 times in the RP

Objective 6 Patient Specific Education More than 10% of patients seen by the EP in the RP receive patient specific education resources that were identified by the CEHRT

Exclusion: Any EP who has no office visits in the RP

Objective 7 Medication Reconciliation The EP performs medication reconciliation for more than 50% of transitions of care in which the patient is transitioned into the care of EP

Exclusion: Any EP who was not the recipient of any transitions of care during the RP

Objective 8 Patient Electronic Access (V/D/T) 1 – More than 50% of unique patients seen by the EP during the RP are provided timely access to view online, download, or transmit their health records

Exclusions: Any EP who neither orders nor created any of the information listed for inclusion of the measures or conducts more than 50% of their encounters in a county that does not have 50% or more of its housing units with 4Mbps broadband availability on the first day of the RP

2 – 2016: At least one patient seen by EP in the RP views online, downloads, or electronically transmits their health information.

2017: More than 5% of unique patients seen by the EP during the RP views online, downloads, or electronically transmits their health information.

Exclusions: Any EP who neither orders nor created any of the information listed for inclusion of the measures or conducts more than 50% of their encounters in a county that does not have 50% or more of its housing units with 4Mbps broadband availability on the first day of the RP

Objective 9 Secure Messaging 2016: At least one patient seen by the EP during the RP sent an electronic message using the secure messaging feature of CEHRT

2017: More than 5% of unique patients seen by the EP during the RP sent an electronic message using the secure messaging feature of CEHRT

Objective 10 Public Health Reporting Must meet two of the three measures in 2016 and 2017
1 – Immunization Registry

Exclusions: An EP who does not administer immunizations in the RP, operates in a jurisdiction where no immunization registry has declared readiness or is capable of accepting immunizations aligned with the CEHRT definition

2 – Syndromic Surveillance Registry

Exclusions: An EP who is not in a category of providers from which ambulatory syndromic surveillance data is collected or operates in a jurisdiction that is not capable or ready to collect syndromic surveillance data

3 – Specialized Registry

Exclusions: An EP who does not diagnose or treat any condition associated with a specialized registry

 

See us back here next Friday for Part Three of this Blog Series which will focus specifically on Stage 3.

Still confused? Do you need one-on-one guidance regarding your organization? We can help!  Please contact our Meaningful Use Expert, Kathryn Ayers Wickenhauser (Kathryn.Wickenhauser@DataFileTechnologies.com) for guidance about how these changes impact you.

Don’t Take a Chance Responding to Meaningful Use Audits!

On Wednesday of last week, Figliozzi and Company (on behalf of CMS) started issuing the first round of Pre-Payment Audits for attestations for the 2014 reporting year.  It is estimated that 20% of Providers will be audited for each Reporting Year.  If you have not received a Pre- or Post- Payment Audit yet, it is likely that you will receive one soon.

DataFile Technologies’ authority in Meaningful Use, Kathryn Ayers Wickenhauser, has educated and coached over 3,000 Providers to successfully attest for this subject matter.  Kathryn is also experienced in formulating Audit Response Packets for both Pre- and Post- Payment Audits, as well as conducting Mock Audits.

It is critical to respond to Figliozzi and Company in the appropriate manner and not only pass the initial Audit, but also to prevent future Audits of additional Providers and reporting years.

You’ve worked hard to earn your Meaningful Use dollars.  Don’t risk losing that money because of an Audit.  Contact Kathryn today if you are interested in assistance responding to an Audit or preparing for a future Audit. She could be reached at Kathryn.Wickenhauser@DataFileTechnologies.com or by phone at 816-800-0074.

View our latest Webinar on Meaningful Use Audits:

http://www.datafiletechnologies.com/webinar-meaningful-use-audits-horizon-prepared/#.VPDPm_nF-fY

CMS Extends Meaningful Use Attestation Deadline for Medicare Eligible Providers

CMS announced on Wednesday, February 25 that they would be extending the deadline for Medicare Eligible Professionals to attest to the 2014 reporting year of Meaningful Use to March 20th, 2015. Eligible Professionals should submit Meaningful Use data to CMS on an annual basis to ensure additional incentive payments and avoid payment adjustments.  2014 is the last year to begin the Medicare Meaningful Use program and begin to receive incentive payments.  By successfully achieving Meaningful Use in the 2014 year, Eligible Providers will avoid a negative payment adjustment against their Medicare Part B payments in the 2016 calendar year.

Because of the Flexibility Rule for the 2014 year, the CMS Attestation website is much more complicated than in the past.  DataFile Technologies’ Meaningful Use Subject Matter Expert, Kathryn Ayers Wickenhauser, is experienced in attestations and can guide your organization through choosing the appropriate items during the attestation process.  Selecting the most appropriate choices during attestation helps minimize the chances of accidentally triggering a Meaningful Use Audit.  Contact Kathryn today if you are interested in assistance attesting at Kathryn.Wickenhauser@DataFileTechnologies.com.