It’s the night before the big exam and you go sleep knowing you are completely prepared. You fall asleep feeling calm and confident, certain that nothing can get in the way of your ability to prove how well you know the material. Unfortunately, you are so tired that you sleep through the alarm and never make it to the test.
Many of us have had this nightmare.
However, for hospitals and other eligible providers who are required to submit reports attesting to their compliance with Stage I Meaningful Use Criteria (MU I), this may be more than just a bad dream. The application for obtaining incentive funds can be daunting and the reality of carrying out all HIPAA requirements to meet the MU Stage I criteria takes constant vigilance of all staff and business associates. In order to help those participating in the incentive programs prepare to implement Stage 2 Meaningful Use criteria (MU 2), those attesting for the first time in 2014 (for the 2013 reporting year) must only show compliance for a three month period.
While many providers breathed a sigh of relief when this was announced, a number of them did not take into account the work involved in the reporting process. Despite fully meeting the criteria for at least a three month period, many professionals found that they lacked the necessary time to complete the report which demonstrated their compliance. In essence, they did the work but were likely to sleep through the exam. Without submitting the required paperwork, eligible providers would be viewed no different than those who had not been compliant for the required time period. They would also be in danger of significant penalties, an adjustment for the amount of money they could receive in 2015 and possibly the loss of eligibility for further incentive funds. In other words, they would be viewed as having failed MU I regardless of their actual compliance status.
“CMS has realized over the time since HIPAA was first implemented that the scope of the rules and regulations as initially proposed aren’t always realistic when implemented or need clarification or modification in order for them to be understood and applied by those required to do so.” Said Bob Grant Chief Compliance Officer Compliancy Group. The deadline for MU I proved to be no exception. A few weeks ago, CMS unexpectedly announced that the deadline for 2013 has been extended until the end of March, due to difficulties discovered with the attestation process and website. Perhaps it seems too little too late especially if staff were already overwhelmed by normal workloads and the need to maintain the necessary work flow. However, the extra time managed appropriately can provide new hope involving the ability to attest for the 2013 reporting year.
It is important to recognize what the extension applies to and what it doesn’t.
• Applies to Medicare incentive 2013 attestation
• Does not apply to Medicaid EHR incentive 2013 attestation
• Does not apply to any other CMS program deadlines including those for the Physician Quality Reporting System EHR Incentive Program Pilot
• Applies to the 2015 incentive amounts received – Successful retroactive reporting for MU I will allow Eligible Providers to avoid incentive adjustments
CMS encourages all Eligible Providers involved in documenting MU 1 compliance to contact the EHR Information Center1for assistance with proper registration and tips on navigating the attestation system to ensure timely reporting and avoid unnecessary audits. Additional resources include the Stage 1 Meaningful Use Calculator, and the Registration and Attestation User Guide.