A reminder that the deadline for the 2015 EHR Incentive Program is Friday, March 11. Eligible professionals can choose any 90-day reporting period in 2015. Most physicians have $8,000 in incentive payments available, so please report if you can. Here’s a link to the requirements for the 2015 reporting year. If you were scheduled to attest to Stage One, you can take advantage of the “alternative” objectives or measures, which leave only five criteria, plus the public health reporting. Regardless of your stage, you’ll also be required to report the clinical quality measures (CQMs).
For public health reporting, there are important considerations for both 2015 and 2016:
For 2015, the Centers for Medicare & Medicaid Services (CMS) is allowing an exemption for both measures with the statement: “we will allow providers to claim an alternate exclusion for a measure if they did not intend to attest to the equivalent prior menu objective consistent with our policy for other objectives and measures.” To take advantage of this exclusion, I recommend that you print CMS’ FAQ for your meaningful use file, and then write a letter for the file that reads: “To whom it may concern, I did not intend to attest to the public health reporting in 2015… [Feel free to add more details here].” Have the physician sign it, and attach it to the printed copy of the FAQ. CMS changes the FAQs on a consistent basis; this one, for example, was changed three times. Should you be audited, this documentation will come in handy, as you can prove that you followed the rules at the time of reporting! Without an audit, this will just be a few papers in the file.
Just two weeks ago, the government extended a similar exemption for 2016 with these words: “We will allow providers to claim an alternate exclusion for the Public Health Reporting measure(s) which might require the acquisition of additional technologies providers did not previously have or did not previously intend to include in their activities for meaningful use.” CMS goes on to state: “EPs scheduled to be in Stage 1 and Stage 2: Must attest to at least 2 measures from the Public Health Reporting Objective Measures 1-3… May claim an Alternate Exclusion for Measure 2 and Measure 3 (Syndromic Surveillance and Specialized Registry Reporting).” Again, my suggestion is to print the FAQ, and, if applicable, document your “intention” not to participate in an attached letter signed by the physician. This isn’t required, per se, but it will serve as your rationale for declaring the exclusion(s) in the event that you are audited.
With more than 60 days under our belts in 2016, it’s an opportune time to ensure that you are well on your way to successfully attesting for 2016. The reporting period is the full year, and the 2016 requirements are much the same, although the alternate objectives or measures available in 2015 have been all but eliminated. The big change in measures is the fact that the secure electronic messaging must feature one patient, noting that you can send or receive the message.
Finally, if you have not yet already done so, take 10 minutes out of your busy schedule to apply for the financial hardship exception for 2015. As we learned in my previous post, CMS announced that the application will not impact you from receiving an incentive payment. Unless another category applies, choose 2.2.d., which includes “issues related to insufficient time to make changes…” based on the government’s delayed release of the Final Rule outlining the 2015 reporting requirements. Last week, the government extended the deadline until July 1, 2016, so you can take your time. That said, 3% of your Medicare reimbursement in 2017 is on the line, so it may behoove you to get it done today!
If you’re interested in some great in-office training, check out my practice management DVDs! I’m teaming up with Greenbranch Publishing to present a webinar on Patient No-Shows on April 28. I hope that you’ll consider joining me!