Last month, I commented on data analytics related to the “oldest old” – or people over the age of 90. This month, I would like to digress and talk about the recent Centers for Medicare & Medicaid Services (CMS) and Office of the National Coordinator for Health Information Technology (ONC) Notice of Proposed Rule Making (NPRM) (05/20/2014) as it related to the CMS electronic health record (EHR) meaningful use (MU) incentive program. Why? Because the EHR ultimately becomes the data collection tool for data analytics in your practice, whether you treat premature infants or the “oldest old” senior citizens!
Background on NPRM
The recent issued NPRM would provide eligible professionals and hospitals more flexibility in how they use certified electronic health record (EHR) technology (CEHRT) to meet MU. When finalized, the rule would let providers use the 2011 Edition CEHRT or a combination of 2011 and 2014 Edition CEHRT for the MU attestation reporting period to qualify for the CMS EHR Incentive Program. Beginning in 2015, all eligible professionals and hospitals would still be required to report using 2014 Edition CEHRT.
Requirements to Meet MU in 2014
Before the NPRM, a physician would be required to use 2014 Edition CEHRT to meet MU and qualify for the CMS incentive program. A major problem with this requirement is that many software vendors were not ready with the new MU Stage 1 and Stage 2 requirements and/or did not complete their certification process from ONC. Therefore, as a physician using the previous 2011 Edition CEHRT, you could not continue to qualify for MU incentive program in 2014. With this NPRM, you can now use 2011 Edition CEHRT to qualify and continue in the CMS MU incentive program.
The MU attestation period in 2014 is 90 days. CMS also extended the deadline to complete the 90 day attestation period to avoid 2015 CMS Medicare penalties to September 30, 2014 or Q3 of 2014. The big advantage of attesting before this deadline date is that you avoid the CMS Medicare penalties for BOTH 2015 and 2016, and also qualify for the 2014 CMS incentive payments.
Advantages to Meeting MU in 2014
So the question is: If you are not going to complete your 90 day attestation period by end of Q3 2014, should I just stop trying and drop out of the MU incentive program? NO! Even if you complete your 90 day attestation period in Q4 of 2014, you still qualify for the CMS incentive payments for 2014 and “avoid” the 2016 CMS Medicare penalties. Even as a first time CMS MU Stage 1 participant, you would still qualify to receive approximately $23,520 by completing your 90 day attestation period in Q4 2014.
A big advantage of getting on an EHR in 2014 is that you not only qualify for the CMS incentive program, but you have set the stage for future use of your EHR for data analytics. The key is just to start, get on an EHR, and collect MU data and other pertinent patient information. You have then started to build the data analytics tools for your practice. Don’t wait – get the CMS incentive money and get started on your data analytics program at the same time!
The North Texas Regional Extension Center (NTREC) has grant-subsidized services to help you implement an EHR. For a preview of our services, check out this video: