Meaningful use (MU), or showing that you are using electronic health records (EHR) in a meaningful way, is the linchpin of Medicare’s EHR incentive program. Retina specialists, like many physicians, are encountering barriers when attempting to meet Medicare’s MU requirements which, beginning in 2015, may result in payment penalties. The costs of switching to an EHR aside, complications arise. The complexities are often because Medicare maintains certain kinds objectives in each stage of MU, but may add, remove, and/or redefine the individual objectives for each stage and from year to year. In order to meet the MU requirements and avoid penalties, you must stay well informed about MU.
Although the program may be complex and the criteria difficult to meet, implementing an EHR system and using it to the best of your ability have long-term payoffs. Having a strong grasp of what is required to demonstrate MU and closely monitoring how well you are meeting the MU requirements can help you to realize those payoffs. Maintaining an understanding of the MU requirements and monitoring your performance will help you to feel more informed about how you are incorporating an important and costly new technology and give you a stronger sense of whether you are moving toward improving quality, lowering costs, and most efficiently saving sight.
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Stage 1: 2011-2012, during which data is captured and shared.
Stage 2: 2014-2015, during which you incorporate EHR into advanced clinical processes.
Stage 3: 2016 and beyond, during which you will show improved outcomes.
In each stage, you must demonstrate meeting predefined core and menu objectives. All providers must meet the core objectives. Menu objectives include options that may be selected from a predetermined list. Core and menu objectives may change from year to year, based on Medicare’s internal assessment of objectives and feedback from public stakeholders.
During 2013, reporting for Stage 1 required that you meet a total of 18 objectives: 13 required core objectives and 5 menu objectives (selected from a list of 10).
If you are reporting for Stage 1 in 2014, you must meet a total of 18 objectives: 13 required core objectives and 5 menu objectives (selected from a list of 9).
If you are in Stage 2, you must meet a total of 20 objectives: 17 core objectives and 3 menu objectives (selected from a list of 6).
You can participate for up to 5 continuous years.
To qualify for incentive payments, you must successfully demonstrate MU for each year of program participation.
By 2012, you must have started participating to receive the maximum incentive payment.
The last year you may begin participation and receive an incentive is 2014.
In 2015, failure to successfully demonstrate MU previously will result in a penalty.
The payment reduction starts at 1% and increases each year in which you fail to demonstrate MU, to a maximum of 5%.
$43,720 is the maximum incentive payment you could receive by demonstrating MU of a certified EHR technology over 5 continuous years.
Before you jump into the EHR incentive program and attempt to show you are using EHR in a meaningful way, it is important to lay the groundwork for success—beginning with selecting an ONC-approved EHR vendor.
In addition to selecting the best, certified EHR vendor for your practice, it is important that you take time to assess your office’s information technology security. This step is often overlooked, but must be completed each year that you participate in the EHR incentive program.
Each practice is required to complete the Security Risk Assessment (SRA) for each year of participation in the EHR Incentive Program/Meaningful Use. Part of ensuring you have an assessment on hand in case of an audit is to accurately assess and document your risks. Several SRAs meet the ONC standard for meeting these criteria. ONC also maintains a webpage devoted to helping you meet SRA requirements, including a tool to perform an SRA.
To demonstrate MU in Stage 1, you will need to meet the 18 objectives (15 core and 5 menu) defined by Medicare. See the complete list of Stage 1 core and menu objectives.
For most providers, Stage 1 will be a 2-year process. In the first year, you must meet the criteria for a 90-day period; in the second year, you must meet the requirements for a full year. You will need to meet the requirements for the 2 years before you can progress to Stage 2.
Getting started can be difficult, from selecting an accredited EHR vendor to successfully completing the attestation process. Medicare provides several resources and guides for getting started, registering, and attesting.
The earliest you may demonstrate Stage 2 MU is for 2014. If you began MU in 2011, you will need to meet 3 consecutive years of Stage 1 MU before heading into Stage 2. If you began in 2012 or later, you will need to meet 2 consecutive years of MU in Stage 1 before moving into Stage 2. In Stage 2, you must meet 20 total objectives: 17 core and 3 menu from a list of 6. The complete list of core and menu objectives are provided starting on page 8 of the Stage 2 Overview Tip Sheet.
While you may feel more comfortable with MU at this point, new roadblocks may arise as you move into Stage 2. If you are moving into this stage, you have worked hard to get there and it is critical to know how to move forward, regardless of how your EHR vendor is progressing or any other changes, such as where you are employed. Visit CMS’ Stage 2 information page for detailed information, including links to tip sheets, guides, and other resources.
For retina specialists the measure-reporting criteria is the most difficult to meet. Medicare is attempting to normalize the quality measures across its programs—including the EHR incentive and Physician Quality Reporting System (PQRS) programs—and it is important to understand each program and how quality-measure reporting differs between them. Medicare provides a full list of measures for all of its different reporting programs. Columns U and V of the complete list indicate whether an individual measure applies to MU.
To demonstrate MU, Medicare requires that you report on Clinical Quality Measures (CQMs), a means to track the quality of care provided and attempt to relate directly to your ability to deliver high-quality care. You must report CQMs during each year of participation, but are not required to report on specific CQMs.
There are 2 sets of CQMs, one for adults and one for children, which are both specialty-agnostic. The measures in each set cover all of Medicare’s National Quality Strategy (NQS) domains and address many aspects of care (eg, health outcomes, clinical process, patient safety, efficient use of resources, care coordination, patient engagements, and adherence to clinical guidelines).
On one hand, CQMs are excellent for hitting the agency’s EHR implementation targets, but on the other hand, selecting CQMs to report on can be difficult when they do not apply well at the physician practice level, as many retina specialists are experiencing. You must fully understand the individual measure requirements and carefully select CQMs to report on to ensure that you are setting yourself up for success.
Participating in the EHR incentive program is arduous; keeping track of your current status in demonstrating MU is critical to ensure you are not missing any deadlines, incentive payments, or opportunities to appeal MU determinations and ask for reconsiderations. You can login at https://ehrincentives.cms.gov to check your MU status, including the years of participation and the status of your incentive payment.
The core objective requiring Computerized Physician Order Entry (CPOE) has garnered a lot of attention due to Medicare redefining who may enter computerized physician orders to include “credentialed medical assistants.” However, Medicare did not provide much additional guidance as to who qualifies as a certified medical assistant, except to require that these professionals have third-party accreditation, can provide appropriate medical decision support based on assessments of any feedback from the entry system (ie, medication error warnings) and—except in the case of ophthalmology—are not scribes.
While Medicare is not constantly monitoring to ensure that the person entering computerized physician orders, all ONC-certified technology monitors who submits orders, and in the event of an audit, you will need to be able to show that only approved health care professionals are submitting orders.
The EHR incentive program can provide a helpful add-on payment, but it also comes at a risk to participants. Starting in 2015 (through 2020) you may be subject to a payment penalty for not previously participating in or demonstrating MU. In short, you must demonstrate MU before the current payment year to avoid the MU penalty tied to the current payment year.
The penalties start at 1% in 2015 and increase 1% each year, going up to 5% in 2019 and beyond. Congress may increase the penalty after it assesses the provider MU adoption rate throughout the country. The table below illustrates how the year in which you receive a penalty is linked to a prior reporting period.