By Rachna Chaudhari, December 01, 2015
If you have been participating in the Centers for Medicare and Medicaid Services (CMS)’ EHR Incentive Program, otherwise known as “meaningful use,” or were planning on participating in 2015, please be aware that the program has been significantly changed for 2015, 2016 and 2017. CMS released a final rule in October regarding modifications to the meaningful use program which allows providers to report for only 90 calendar days in 2015 rather than a full year. The reporting period can be any 90-day calendar period, as long as the measures were performed during the full reporting period. The last reporting period for 2015 would be Oct. 3 Dec. 31, 2015. All providers would then move to a full year of reporting in 2016 and 2017 except for those who are starting the program for the first time. First-time participants in meaningful use would still be able to report for only 90 calendar days in their first year as long as they attest to the measures on the CMS website by Oct. 1 of that year. Everyone else would still be able to attest until Feb. 28 of the following year.
Besides the reporting period, CMS also significantly changed the measures providers would be required to report. If you were planning on reporting for Stage 2 in 2015 (that is you started meaningful use in 2011, 2012, or 2013), you now only have to complete 10 total measures. If you were planning on reporting for Stage 1 in 2015 (that is you started meaningful use in 2014 or 2015), you now only have to complete six total measures as opposed to 18 previously. Additionally, CMS dropped the burdensome patient engagement measures which required 5 percent of patients to log into a practice’s patient portal and send a secure electronic message to the provider. The 10 measures are outlined in the table that follows.
In addition to the 10 meaningful use measures, providers must still report on nine clinical quality measures (CQMs). Dermatologists do not need to perform any CQMs that are not relevant to their practice. This measure simply requires the physician to report his or her numerators and denominators for each CQM. There are 44 CQMs, none of which are directly relevant to dermatology. The physician can report zero numerators, zero denominators, or any combination of such if a measure does not apply. You should speak with your EHR vendor to determine how they plan on allowing your practice to report the CQMs. [pagebreak]
If you are successful at completing the measures and attesting to them on the CMS website by the deadlines outlined in the sidebar, you would avoid meaningful use penalties in future years. CMS also allows providers the ability to apply for a hardship exemption if they are unable to complete the program due to lack of Internet access, face unforeseen circumstances such as a natural disaster, or have little interaction with patients. Providers should check the CMS website for opportunities to apply for these hardship exemptions. CMS has noted that it plans to allow providers to claim a hardship exemption under the “extreme and uncontrollable circumstances” category if a provider could not attest due to the lateness of the final MU rule. Additional details will be available on the CMS website in early 2016.