A Meaningful Use Holiday Surprise for Hospitals?
Everybody is always wishing and hoping for something. Will the Eagle land? Will it rain on the garden? Will she say “yes”?
Every day I speak with hospitals involved in the CMS EHR Incentive program. Some are at Stage 1 and some have moved on to Stage 2. For all of them their 2015 meaningful use (MU) year began October 1, 2014. No matter the Stage, they had to be using 2014 Edition certified electronic health record technology (CEHRT). If 2015 is a hospital’s initial year of MU they only need the ring the bell for 90 days. However, there are not too many of those. Most hospitals will need to do a full year of MU with 2014 technology. That is where many of the eligible hospitals (EHs) hit the wall.
All those EHs past their first year of MU had to be using 2014 CEHRT October 1, 2014 or they are simply out of luck. I hear lots of wishing and hoping for a reprieve. The dice are tumbling and no amount of MU strategy can save the day. There is still a mountain of incentive money on the table and don’t forget that falling off the MU track will bring those Medicare “fee adjustments”. Who wants to have to explain that to the CFO of a hospital? Those penalties are bound to cause a few problems with the budget.
The pressure is on for a fix and the large associations and lobbyists for hospitals are issuing white papers and writing open letters to anyone that will listen. Lord only know what is happening behind closed doors. My money for the best “Hail Mary” pass is a bill introduced September 16, 2014 by Renee Ellmers of North Carolina’s 2nd congressional district.
The bill, H.R. 5481, goes straight to the point of bringing relief. “To continue the use of a 3-month quarter EHR reporting period for health care providers to demonstrate meaningful use for 2015 under the Medicare and Medicaid EHR incentive payment programs, and for other purposes.” Passage of this bill would immediately remove the requirement that EHs had to be doing anything beginning October 1, 2014. Relief would also be bestowed on eligible professionals who could then face 2015 with a lot of MU breathing room.
So H.R. 5481 appears to be the best chance to modify the 2015 requirements. What are the odds of this happening? I give it greater that 50%. The bill now has 19 cosponsors (18 R, 1 D). Twelve of those came onboard November 12, 2014. I can see this bill being tucked inside a larger appropriations bill and passed quickly without comment. That is how the ICD-10 delay was handled and I see no difference in process here.
Jim Tate is known as the most experienced authority on the CMS Meaningful Use (MU) audit and appeal process. His unique combination of skills has brought successful outcomes to hospitals at risk of having their CMS EHR incentives recouped. He led the first appeal challenge in the nation for a client hospital that had received a negative audit determination. That appeal was decided in favor of the hospital. He has also been successful in leading the effort to reverse a failed appeal, even after the hospital had received notification of the failure with the statement, “This decision is final and not subject to further appeal”. That “final” decision was reversed in less than a week. If you are a hospital with questions or concerns about the meaningful use audit process, contact him at: Inquiry@meaningfuluseaudits.com. This post was original published on MeaningfulUseAudits.com.