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The most frequently asked questions about 2015 MU attestation

Many providers are finishing up their 2014 attestation period for Meaningful Use, the Centers for Medicare and Medicaid (CMS) incentive program for successful use of electronic health record (EHR) technology.

Several changes in the regulations in 2014 have prompted questions. Using information available today, I’ve answered some of the most frequently-asked questions here:

Q. Do we need to attest several times throughout 2015, or do we attest only one time after the end of 2015?

As of today, if you’ve attested for Meaningful Use before, you only need to attest once. You will demonstrate for all of 2015 and attest before February 29, 2016.  (Exception: people who have never demonstrated before will have a 90-day demonstration period.)

However, on January 29, 2015, the Chief Medical Officer of CMS issued a significant communication about some possible future adjustments to the Meaningful Use program. Two of the more noteworthy changes are shortening the 2015 reporting periods from a year to 90 days, and aligning reporting periods to the calendar year (not Federal fiscal year).

We anticipate the proposed changes will be released in the spring. In the meantime, we recommend that people continue to move toward full adoption of current requirements.

Q. Can I use the Flexibility option and get an extension?

Providers can apply for a Flexibility option if they have had some combination of software and operational issues that prevented full implementation. It does not relieve them of demonstrating Meaningful Use or change the attestation period; it just allows them to demonstrate Stage 1 instead of Stage 2.

I encourage people who exercise this option to have good documentation to support their claims. The criteria are not very precise, and CMS will require this information.

Q. Should I claim exclusions when measures don’t apply to me?

You must do the minimum number of core and menu measures to successfully attest in both Stage 1 and Stage 2. Unlike previous years, you cannot “get credit” for claiming an exclusion in either stage. We recommend (with the exception below) that you do not claim exclusions if you don’t need them for Stage 1, because it has caused issues for some clients on the CMS website.

However, there is a flaw on the CMS’ website that may affect Stage 1 participants. If you should happen to qualify for exclusions in both Immunization Registries (IR) and Syndromic Surveillance (SS), you should only have to demonstrate four other menu measures to successfully attest. The website, however, will not allow you to proceed unless you claim exclusions for all remaining measures – even though you have met four (plus the two exclusions for IR & SS).

In this case, CMS directs participants to claim exclusions to all remaining menu measures, even if they are not entitled to them, as a workaround (read more in a related FAQ here).

Q. How should I prepare for Stage 3?

The proposed rule that will define Stage 3, and redefine the other stages, is due in March of 2015. It will likely become a final rule late in 2015. At this point in time, current rule would start in 2017, but that may be delayed.

You’ll repeat Stage 2 until Stage 3 is available, through at least 2016. My advice? Don’t worry about Stage 3 now, just keep working to continuously improve.

Q. How does PQRS figure in to Meaningful Use attestations?

PQRS is a separate CMS program with its own incentives, requirements and penalties.

Q. What types of messages count towards the “Secure Messaging” measure that requires 5% patient participation?

Messages must be clinically relevant, but what that means has been a matter of some debate. CMS did not define what is clinically relevant and left it up to providers to determine. Some portals (such as FollowMyHealth®) may classify messages for you.

Remember that it is perfectly acceptable to send patients a message to which they reply, as long as the reply is clinically relevant. Those messages will count toward this measure.

Q. Can I skip a year of MU?

You can always skip a year, but you will pay a price. Medicare providers forfeit that year’s incentive and incur a penalty. Medicaid providers can skip a year and pick up where you left off with no penalty. The only limit there is that they have to take their last incentive payment by 2021, and could potentially run out of opportunity to collect payments.

The best advice I can give is to keep your foot to the pedal, and keep moving forward. If you’re a client, you can view a recent webinar or contact us to learn more about Meaningful Use consulting services.

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