Most doctors of chiropractic have heard of the EHR Incentive Program that pays eligible providers (EP) up to $24,000 for adopting and completing meaningful use (MU) with a certified electronic health record (EHR) in their practices. What most doctors do not know is that the rules have changed across the board for 2014. This includes first-time participants and all EPs. no matter what stage of MU participation for 2014. Even more alarming, all prior participants in the program need to get their EHR upgraded to the new 2014 standards before they can start MU in 2014. To top it off. payment reductions (penalties) start on January 1. 2015. First, lets provide a brief background of the program. Main articles have been written on this subject and more details can be obtained at www.chrresourccccntcr.com for those who are new to the subject. There are five types of eligible providers for the Medicare Part B EHR Incentive Program: MD/ DO. DDS. DPM. OD. and DC. More than 5.100 chiropractors have already received over $77 million dollars from the CMS EHR Incentive Program as of November 2013. It is estimated that more than $ 140 million will be distributed by May 2014 to chiropractors alone. More than $18 billion has been paid out in the program already to all EPs and hospitals. About 11.000 DCs have registered for the program with nearly half of those just in the past year. Therefore, most of those DCs will receive their first incentive check in April 2014 for their participation in 2013. The amount paid for the incentive is based on 75% of the allowed submitted cliargcs during an entire calendar year (January 1 through December 31) by an individual DC for (Medicare Part B only) allowed services (98940. 98941. 98942 CPT codes). The maximum amount that can be paid for a first-year participant for 2014 is $ 12.000. The good news is that first-time participants only have to perform the meaningful use (MU) measures for a 90-day contiguous period within 2014 to qualify. This lias been a standard rule for all EPs for whatever their first year of participation may be: they only need to comply with the MU measures for 90 days, yet they still can count the full calendar year of allowed charges submitted to determine the incentive payment amount they are eligible to receive from CMS. (Sec chart for maximum amounts to be paid out based on first year started in the program.) The absolute last year you can start the program and still receive the incentive of up to a maximum of $24,000 over the next 2.3 years of MU work is 2014. Up to $12,000 of that can come in 2014 for only 90 days of work. That's not a bad payday considering your staff can do 90% of the work, which is mostly data capture or testing of the EHR capabilities. Most DCs who invested several hours of training have stated it was not that difficult and that their second year was much easier than the first because it became second nature with proper training. Medicare Eligible Provider EHR Incentive Payment Schedule Now. lets get back to the new rule changes. Since we've established that first-time participants in 2014 can still choose any 90-day contiguous reporting period, one caveat exists. The EHR that they perfonn the MU criteria upon for that entire 90-day reporting period must be performed on certified 2014-cdition EHR software. The EHR vendors who were originally certified for the 2011 edition have all had their 2011 - 2013 certifications expire. All EHR systems must be certified for the new 2014 edition's standards before any EP can perfonn or report the MU measures on that EHR system. This is tnie for Stage 1 and Stage 2. so basically all EPs. to qualify for any incentive checks for the 2014 participation years. In addition, all EPs in their second year of Stage 1 or in their first year of Stage 2 must also perfonn their MU on a 2014 edition, but those EPs cannot choose just any timeframe for their reporting period in 2014. The new mlc that was released in December 2013 has resulted in a reporting period that is limited to a calendar quarter (note tliat it is not necessarily 90 days) and that calendar quarter must begin on one of the following four dates: January 1. April 1. July 1. or October 1. All EPs (except for first-time participants who begin in 2014) must choose one of these four quarters to perfonn MU in 2014. Remember, the EHR they arc using must be certified for the 2014 edition's standards before they can begin MU. This means tliat most chiropractors will not use the first or second quarters of 2014 since they have to wait for their EHR vendor to become certified for the 2014 edition's standards. This is why CMS and ONC changed the reporting period niles for 2014—to give vendors time since the nilcs were not released until late August 2013 for the Stage 2 criteria. So. many DCs will be performing their MU in 2014 from July 1 all the way through September 30 as their selected quarter reporting period, or from October 1 to December 31. Now. here's one more major rule to be aware of: payment adjustments (a kinder and gentler way to say "penalties") begin January 1.2015 for first-time participating DCs who do not attest for MU by October 1. 2014. This means you can still get your incentive money and avoid payment reductions as a first-time participant in MU in 2014 as long as you complete MU in your 90-day reporting period by September 30 and then attest on October 1. All DCs who do not participate in the MU program and successfully attest by October 1. 2014. will be penalized 1% on all of Medicare reimbursement payments for regular Medicare sen ices for the entire 2015 calendar year. So if you arc new to MU. the goal is to start your MU no later than July 1 because it is the last day to start MU to avoid 2015 penalties. Then no later than October 1. attest to the completion of the MU by going to the website Core Objectives for Eligible Professionals Stage 2: Meaningful Use :17 Core Objectives of CMS and attest at the same website where you initially registered for the EHR Incentive Program. You can go to the CMS website to register for the program: https://chrinccntivcs.cms.go\7hitcch/login.action. All other DCs who are in their second year of Stage 1 or first year of Stage 2 must perform MU in or be penalized in 2016 for not participating in 2014. Those same EPs who performed MU in 2013 and attested will avoid the penalties because they par ticipated in 2013. These penalties compound each year and increase each subsequent year by an ad ditional percentage point. There are other changes to the actual measures themselves for Stage 2 compared to Stage 1 criteria. Some of the main differences arc that a number of menu-set measures arc now core measures in Stage 2. Overall, the number of measures that DCs arc required to perfonn remains about the same when comparing Stage 1 to Stage 2. Most doctors of chiropractic will be eligible for about three or four exclusions from the new set of 17 core measures for Stage 2. Of the six menu-set measures, the EP must choose three that arc relevant to their scope of practice and cannot take an exclusion for the menu items because there arc certainly three menu measures that fall into most all DCs scopes. So there arc about 14 core measures and three menu measures fora total of 17 measures that most DCs will perfonn. In addition to the measures, there are nine clinical quality measures (CQM) in Stage 2. which is an increase from six CQMs in Stage 1. In a follow-up article, we will break down the actual measures for Stage 2 (see overview graph). Use computerized provider order entry (CPOE) for medication laboratory and radiology orders Generate and transmit permissible pre scriptions electronically (eRx) Record demographic information Record and chart changes in vital signs Record smoking status for patients 13 years old or older Use clinical decision support to improve performance on high-priority health conditions Provide patients the ability to view on line, download and transmit their health information Provide clinical summaries for patients for each office visit Protect electronic health information created or maintained by Certified EHR Technology Incorporate clinical lab -test results into Certified EHR Technology Generate lists of patients by spe cific conditions lo use for quality improvement, reduction of dispari ties, research, or outreach Use clinically relevant information to indentify patients who should receive reminders forprevenlilivc/ follow-up care Use certified EHR technology to identify patient-specific education resources Perform medication reconciliation Provide summary of care record for each transition of care or referral Submit electronic data to immuni zation registries Use secure electronic messaging lo communicate with patients on relevant health information 6 Menu Objectives for EP's in Stage 2 You cannot take ANY Exclusions in Stage 2 Menu Set The good new s is that everybody can relax to some degree for a few months since nobody has to perform MU for the full calendar year in 2014. Be sure to have your vendor become certified no later than July 1. 2014 to avoid penalties and payment reductions for first-time EPs. Begin your training by June so that you arc prepared to perform MU beginning in July. The absolute last year to join the EHR Incentive Program to be paid for performing MU is 2014. If you wait until after October 3. 2014. to begin your first year of MU. you cannot receive any incentive payments in the future for EHR adoption. Yet. all DCs who choose to wait will be penalized starting January 1.2015. and these payment reductions will increase each year. When you combine these payment reductions with another separate Medicare program called PQRS. those penalties combined with the MU penalties over the next few years could result in a 7% annual payment reduction for all subsequent Medicare reimbursement checks in your future. Why not be paid fordoing something that the standard of care is going to require at some point in the future? Its not difficult with proper training. Educate yourself on the rules, invest in training, and learn about mam real stories of DCs who are growing in their practices because of MU with more referrals from patients. Ill share those stories in my next article to show you how MU measures can result in practice growth, better patient care, and a sense of empowerment with your staff. Steven J. Kraus, DC, DIBCN, FIBCN, FASA, FICC, is Founder and CEO of Future Health — a chiropractic management software firm that focuses on helping doctors utilize technology, including EHR, to effectively enhance overall practice success. He is an acknowledged expert in Health IT, including EHR (electronic health records) and the up-to-$24,000ARRsi incentive program to implement EHR. lie lectures to state associations and al industry events regarding I'.IIR and the relationship to documentation, lie presents monthly webmars on how El Hi usage will impact doctors oj chiropractic. You can reach Future Health at l-HHH-919-9919 or www.FutureHeaIthSoftware.com Meaningful Use: 6 Menu Objectives Submit electronic syndromic surveillance data to public health Record electronic notes in patient records Imaging results accessible through CEHRT Record patient family health history Report cancer cases to a public health central cancer registry Report specific cases to a specialized registry
