Eligible professionals (EPs) still have time to demonstrate meaningful use of certified EHR technology (CEHRT) for the 2014 reporting period of the Medicare EHR Incentive Program. In 2013, the Centers for Medicare & Medicaid Services (CMS) decided that providers would only be required to demonstrate meaningful use for a three-month (90-day) reporting period in 2014, granting flexibility to providers while upgrading from 2011 CEHRT to 2014 CEHRT. This 90-day requirement applies to all EPs, regardless of what stage of the program the EP is fulfilling.
The upcoming 90-day window, October 1, 2014 – December 31, 2014, is the last opportunity for EPs to initiate participation in the EHR Incentive Program in order to receive future payments for successful demonstration of meaningful use. If EPs wait to initiate meaningful use attestation until 2015, they will not be eligible to receive any incentive payment under the Medicare EHR Incentive Program. EPs that are prepared to attest, but have yet to begin measuring, should push forward to meet Stage 1 requirements of meaningful use.
Additionally, EPs who have not successfully demonstrated and attested meaningful use for the 2014 reporting period by October 1, 2014, will be subject to a downward payment adjustment on all Medicare claims starting on January 1, 2015. However, EPs can avoid a downward adjustment in 2016 by using the last 90 days in the 2014 reporting period to demonstrate meaningful use. In 2015 and beyond, EPs should plan to fully demonstrate meaningful use in order to avoid payment adjustments lasting through 2020.
What do I need to do?
If you are an:
- Eligible professional that has attested to Stage 1 prior to 2014: re-attest no later than February 28, 2015, to avoid 2016 downward payment adjustment and earn your 2014 incentive payment.
- Eligible professional that has not attested prior to 2014, but has already met 2014 requirements: attest your meaningful use by October 1, 2014, to avoid 2015 downward payment adjustment and qualify for your incentive payment.
- Eligible professional that has not attested prior to 2014, and has not yet met 2014 requirements: begin measuring no later than October 1, 2014, for 90 days and attest meaningful use by February 28, 2015, to avoid a 2016 downward payment adjustment and qualify for your incentive payment. You will be assessed a 1% or 2% penalty in 2015.
Considering this potential downward payment adjustment and potential penalties for not participating in the Physician Quality Reporting System (PQRS) program, along with the value-based payment modifier based on cost and quality outcomes, professionals could face a substantial decrease in Medicare payments over the next several years without careful attention to these programs.
If you have additional questions about the EHR Incentive Program or other CMS Quality Initiatives, contact the expert listed below at PYA, (404) 266‑9876 or (800) 270-9629.
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