The passage and presidential signature of HR 4302, “Protecting Access Medicare Act of 2014” extended a number of SGR (Sustainable Growth Rate) rules beneficial for providers. Most notable are the delay in the 24% cut to Medicare reimbursements (reduced to 0.5% for the remainder 2014 and 0% the first quarter of 2015), Medicare volume hospital payments, and Medicare SNP (Special Needs Plans) among others. Included in HR 4302 was the delay of the use of ICD10 coding in CMS transactions by an additional year to 01 Oct 2015. Nothing in HR 4302 changes or delays Meaningful Use!
Meaningful Use deadlines for stage 1 and stage 2 remain in effect. For EP’s (both providers and hospitals) the last MU1 (MU stage 1) attestation deadline for 2013 incentive and quality payments for 2013 was 28 Feb 2014. To avoid the first CMS 1% penalty for stage 1 your practice must attest no later the third quarter of 2014. MU2 (MU stage 2) deadlines for reporting attestation to reduce Medicare penalties occur on 01 April 2014, 01 July 2014, and 01 October 2014. The passage of HR 4302 and the ICD10 delay does not affect any MU attestation deadline. Any hospital or practice that provides care to Medicare patients and chooses does not participate in MU or fails to achieve MU target thresholds will have reductions in Medicare reimbursements rates as described by the ARRA which are approximately 1.0% each year.
Thresholds targets for attestation declared for MU stage 1 have increased at MU stage 2. A sampling of selected quantitate measures for EP (Eligible Professionals) are presented below to illustrate these trends:
|Core Objective (EP’s Hospitals & Practices)||Stage 1||Stage 2|
|CPOE||>30% of all patients withmedication orders||>60% medication orders>30% LAB orders>30% RAD orders|
|Clinical Summary||>50% within 3 business days||>50% within 1 day|
|Provide Patient view, download, & transmit|
|Protect PHI on CEHRT certified applications||Conduct security reviews||Conduct security reviewsEncrypt PHI in storageInternal audits|
System implementers have daunting challenges first established in MU1 that continue under CHERT into stage 2. Problem lists must utilize SNOMED CT rather instead of ICD code sets. All CQM’s (Clinical Quality Measures) also require use SNOMED CT. Under CHERT 2014 rules the use of HL7 2.5.1 or CDA R2 messaging standards and the vocabularies of SNOMED CT, ICD-10, and LOINC 2.38 are mandated. ONC has sponsored several S&I LAB initiatives that are currently developing the required HL7 IG’s (Implementation Guides) for these technical efforts.
CMS regulations do allow for hardships exemptions from payment reimbursements adjustments. The major categories for filing exemption are: (1) Lack of Infrastructure, (2) Unforeseen or Uncontrollable Circumstances, and (3) 2014 EHR Vendor Issues. These exemptions must be filed annually and cannot be sustained beyond 5 years. The documents you need to file a Hardship Exemption are the CMS TipSheet and the Hardship Exemptions Form which can be found on the CMS web site at www.cms.gov.