The Medicare Learning Network (MLN) held a National Provider Call yesterday and addressed some of the most frequently asked questions about the EHR Incentive Program, specifically Meaningful Use (MU) and Stage 2…now that the deadline for Stage 2 participation is looming on the horizon. (The reporting period for 2014 is a calendar quarter, so there are 2 remaining quarters in which you can participate: either July-Aug-Sept, or Oct-Nov-Dec.)
Information about Meaningful Use is thankfully becoming easier to find as time passes, but sometimes it’s still difficult to find answers to tricky questions. The following questions are just a few of those tricky ones–with answers straight from MLN.
1. If an eligible professional (EP) has already successfully attested to MU in Stage 1, are there any additional registration requirements for attesting to Stage 2? Is the attestation process the same?
EPs register using the Medicare and Medicaid EHR Incentive Program Registration and Attestation System their first year only. If none of your basic registration information has changed (that is, you’re still at the same address, billing under the same TIN, haven’t changed clinics, etc.), then you can attest to later stages without changing your registration info. If any of your registration information has changed, you must update it before attesting in the current year.
2. If an EP attested to MU for the first time in 2012, but for some reason did not attest in 2013, which stage does the EP attest to in 2014?
Progression along the EHR Incentive Program timeline is based on the first year that the EP attests. A provider will progress through the stages following the CMS-established timeline, regardless of whether s/he meets MU each subsequent year. (So in the above situation, the EP would attest to Stage 2 in 2014…first year of Stage 1 in 2012, second year of Stage 1 in 2013 even though the EP didn’t attest, and then first year of Stage 2 in 2014.)
3. If all existing physicians in a practice have completed two years of Stage 1, and the clinic hires a new physician, do all physicians, including the newly-hired one, report for Stage 2 in the following year?
Every EP registers and attests to MU individually and thus progresses through the stages of MU in accordance with the CMS-established timeline based on the first year s/he attested, regardless of whether that happened with the EP’s current practice or a former practice. Also, new EPs are automatically granted a hardship exception for their first year of practice.
4. If an EP first attested to MU in 2013, but does not participate in 2014, what will the penalty be?
Payment adjustments (a.k.a. penalties) are offset by 2 years: the 2015 payment adjustment is based on 2013 participation; the 2016 payment adjustment is based on 2014 participation; and so on. A provider who successfully met MU in 2013 would avoid the 2015 payment adjustment, but in order to continue avoiding payment adjustments, s/he would have to continue meeting MU every subsequent year. The payment adjustment at this point is 1% per year (which means you’d receive a 1% reduction in your Medicare payments), and it is cumulative for each year an EP does not meet MU (potentially up to 5%).
As always, if you have questions about the EHR Incentive Program, you can call the EHR Incentive Hotline at 888.734.6433. The professionals who work on the hotline are knowledgeable about the ins and outs of both the Medicare and Medicaid incentive programs.
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