APMA News - September/October 2016 - 48

IT Consultant By James R. Christina, DPM Time to Reconsider Sitting Out Meaningful Use CMS released the following on July 14 in a proposed rule that affects reporting meaningful use (MU) of an Office of the National Coordinator (ONC)-certified EHR: Therefore, we are proposing to change the EHR reporting periods in 2016 for returning participants from the full CY 2016 to any continuous 90-day period within CY 2016. This would mean that all EPs [eligible professionals], eligible hospitals, and CAHs [critical access hospitals] may attest to meaningful use for an EHR reporting period of any continuous 90day period from January 1, 2016 through December 31, 2016. The applicable incentive payment year and payment adjustment years for the EHR reporting period in 2016, as well as the deadlines for attestation and other related program requirements, would remain the same as established in prior rulemaking. We are proposing corresponding changes to the definition of 'EHR reporting period' 'and EHR reporting period for a payment adjustment year' ... . So what are the implications for providers who decided it was not worth trying to meet MU requirements in 2016 (which was the entire year) if this proposal is finalized? The proposed changes allow providers to select any consecutive 90-day reporting period to meet MU requirements. That would mean an EP could still meet MU requirements if he or she chose a 90day reporting period starting as late as October 1, 2016. But why bother to try to meet those requirements? If you do not meet the requirements for MU in 2016, you will incur a 3-percent payment reduction on all of your Medicare Part B payments in 2018, which, for the average podiatrist, probably represents a loss of income from $3,000-$4,000. For a practice with a more heavily Medicare-based patient population, the income lost could be significantly greater. Also, if you are already using an ONC-certified EHR, meeting MU requirements for 90 days is much less challenging than the requirements for the entire year. Let's break down why 90 days is so much easier. There are 10 objectives for Modified Stage 2 of MU in 2016 (and yes, everyone is in Modified Stage 2 with some specific exclusion[s] if you qualify to be in Stage 1). Each objective may have multiple measures. It is the exclusions under some of the objectives that make 90 days much easier to report than the entire year: Objective 3 Computerized Physician Order Entry (CPOE): This objective has three measures that deal with medication orders, laboratory orders, and radiology orders. Each mea48 APMA News September/October 2016 sure allows an exclusion if you write fewer than 100 of each particular order during the reporting period (which potentially will be 90 days). Most podiatrists will be able to claim an exclusion for all three measures, or at the very least, the laboratory and radiology orders. Objective 4 Electronic Prescribing (eRx): Again, there is an exclusion if you write fewer than 100 prescriptions during the reporting period. Objective 5 Health Information Exchange: An exclusion exists if an eligible provider transfers a patient to another setting of care or refers a patient to another provider fewer than 100 times during the reporting period. Objective 10 Public Health Reporting: This objective has three measures. Podiatrists are exempt from the first measure, immunization registry reporting, because they do not give immunizations for which data is collected by immunization registries. Regarding the second measure, syndromic surveillance reporting, most states will exempt podiatrists from the requirement to register with the public health agency (PHA) because generally podiatrists do not treat the diseases that must be reported to these agencies. However, apparently some states do still require podiatrists to register, so before assuming you are exempt, confirm with your state PHA that you do not have to register. If the PHA does require and allow podiatrists to register, you should do it, and you will then have met the requirements for this measure (the objective requires reporting to at least two registries unless you are excluded). The final measure is specialized registry reporting. There was much confusion about this measure, because it stipulates you should register with the specialty registry within 60 days of the start of the reporting period. If the reporting period is the entire year, then 60 days was February 29, 2016. However, if the 90-day reporting period is finalized and you choose to start your 90-day reporting period on October 1, 2016, then the 60-day registration deadline would be November 30, 2016. If you registered with the specialty registry on November 30, it is doubtful you would get beyond the testing phase for transmitting data, so you would meet the measure requirement without ever having to actually report any patient data. Each of these measures requires "active engagement" to meet the measure requirements. Active engagement means that the provider is in the process of moving toward sending "production data" to a PHA or

Table of Contents for the Digital Edition of APMA News - September/October 2016