The Last Mile of Meaningful Use
Don’t overlook it By Tom Lee, PhD, MBA, and Abel Kho, MD
As the Feb. 28 deadline fast approaches for eligible providers in the Medicare incentive program to attest to Meaningful Use, the term “fire drill” may come to mind. Medicare incentive program participants attesting to MU Payment Year 1 will lose $5,000 per provider from their available incentive payments if they miss the February deadline. If you’re in this category, it means you must meet MU for 90 days in 2012 and attest by Feb. 28 to receive the maximum $44,000 reimbursement over five years.
Providers in the Medicaid program don’t have the February 2013 attestation deadline for receiving maximum incentive payments. However, to avoid risking penalties on Medicare claims, if they have any, Medicaid incentive program participants should meet MU for 90 days in 2013 and attest by March 30, 2014. Because 2014 is the first year penalties can be given, the Centers for Medicare and Medicaid Services is offering a special extension. Medicaid providers who attest to Adoption, Upgrading and Implementation in 2013 have the option to complete their 90 days of Meaningful Use in 2014 and attest by Oct. 1, 2014, to avoid penalties.
Increasingly, practices are finding that, even after the MU measures are met, organizing MU data, archiving it to prepare for CMS audits, and submitting it to Medicare or Medicaid is not as easy nor as quick as anticipated. These final activities standing in the way of providers and their incentive dollars can be called the “last mile of Meaningful Use” and are often overlooked in planning and staffing.
Luckily, if you make a plan for walking that last mile, you can be rewarded with your incentive dollars and a smoother attestation process. Paying attention to reporting and maintaining accurate records can make all the difference in how prepared you will be.
After MU measures are met, organizing MU data involves compiling a list of activities not generally automated by EHR vendor reporting tools. For example, practice leadership often wants to see easy-to-read summaries of MU performance and projections of future performance. Creating these views usually requires copying and pasting data from vendor reports into custom-built spreadsheets to generate charts. For multi-provider practices, it has become increasingly difficult to track each provider’s MU program (Medicare or Medicaid), payment year, 90-day MU reporting window, and, soon, the current stage of MU (Stage 1 or Stage 2). If a provider joined the practice in the middle of the year, it may be necessary to access and import MU data from the previous practice to derive a complete set of attestable measures.
CMS and state Medicaid agencies are starting to audit a random selection of practices for MU compliance and asking to see supporting information for the measure values that were attested. It is important that there be no discrepancies between the attested values and those found within the source EHR. However, in practice, it is common for EHR historical data to be modified, even for legitimate reasons such as open visits in the reporting period being signed off slightly after the 90-day MU reporting window. Therefore, it is critical to capture a static snapshot of the MU measure values calculated by the EHR and used for attestation. However, this can be a manual, error-prone process that should be carried out with care. For example, it is important to store the snapshots in a secure location that can be accessed even if there is staff turnover.
Once these activities are completed, there is the final step of submitting the MU functional and quality measures to the CMS or state Medicaid websites. Practice staff must manually enter each provider’s measure values into the websites and verify them against input errors before completing the process. The CMS website may be slow during peak periods—anticipate heavy usage on the few days leading up to the Feb. 28 deadline. If a practice decides to carry out the submission process manually, staff should plan to set aside adequate time to learn how the attestation websites work and iron out any issues well ahead of the deadline.
Chicago practices interested in getting assistance for this or any of the aforementioned last-mile MU activities are welcome to contact the Chicago Health IT Regional Extension Center for assistance. In addition to providing tools and educational materials to help practices prepare for the MU attestation process, CHITREC has recently entered into a contract with SA Ignite, Inc., which provides a software platform for automating MU monitoring and submission as a one-click process. To find out more, call us at 312-503-2986 or visit www.chitrec.org
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