Meaningful Use Resource Center
Get the maximum incentive available and avoid penalties by using our full-featured EHR.
Learn More about Meaningful Use
Kareo has the education and tools to help you attest for Meaningful Use. Learn all about why you should participate and how to get started.
Prepare to Attest with Kareo Boot Camp
Eligible professionals starting Medicare Meaningful Use in 2016 may avoid penalties.
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Medical Billing Newsletter December 2015
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Frequently Asked Questions
What Is New with MU?
On October 6, 2015, CMS published a final rule that specifies criteria that EPs must meet in order to participate in the Medicare and Medicaid Electronic Health Record Incentive Programs. The final rule’s provisions encompass 2015 through 2017 (Modified Stage 2) as well as Stage 3 in 2018 and beyond.
Can MU only be done if you have a certified EHR?
Yes. It is a program specifically designed to provide incentives and avoid payment adjustment for meaningfully using a certified EHR. The incentives are intended to help offset the cost of purchasing and maintaining an EHR. 2014 was the last year that an EP could join the Medicare program and still receive incentives. Medicare EPs can still join the program in 2015, 2016, or 2017 to avoid future Medicare payment adjustments. If an EP has elected to join the Medicaid EHR program, incentives are still available for 2015 and 2016.
How can a provider avoid penalties?
New participants – 90 continuous days for reporting period in each year:
- In CY 2015, new participants who successfully demonstrate meaningful use for this period and satisfy all other program requirements will avoid the payment adjustments in CYs 2016 and 2017 if the EP successfully attests by February 29, 2016.
- In CY 2016, new participants who attest prior to October 1, 2016 will avoid the payment adjustments for CY 2017 and CY 2018. If new participants attest between October 1, 2016 and February 28, 2017, they will avoid the CY2018 payment adjustment.
- In CY 2017, new participants who attest prior to October 1, 2017 will avoid the payment adjustment for CY 2018.
Returning Participants – 90 continuous days in 2015, 365 days in 2016:
- In CY 2015, returning participants who successfully demonstrate meaningful use for this period and satisfy all other program requirements will avoid the payment adjustment in CY 2017 if the EP successfully attests by February 29, 2016.
- In CY 2016, returning participants will avoid the CY 2018 payment adjustment if successfully attested by February 28, 2017.
Are the vendors allowed to opt out of certification for any of the years? For example, they were certified for 2011 but not for 2012 but certified again in 2013?
The vendors' EHRs are certified for the stages of MU broken into 'editions'. So, if they were certified for Stage 1 with their 2011 Edition then they are certified for the years in which you can attest to Stage 1 before January 1, 2014. Same goes for Stage 2. A vendor could opt to not certify for Stage 2 with a 2014 Edition, or for Stage 3 with a 2015 Edition even after certifying for Stage 1 with a 2011 Edition. Vendor plans for Stage 2 would be something to ask about in your selection process. At the same time, keep in mind that certification includes not only the MU measures but also the Clinical Quality Measures the vendor chooses to have certified. You want to be sure that the EHR you choose is certified for clinical quality measures that are a fit with your practice specialty.
How is MU reported to CMS?
Your EHR should provide the ability to generate reports that show the data needed to report on quality measures for MU to CMS. Once you have the data, the EP registers on the CMS site and manually types in the 'answers' for the objectives. The 'answers' MUST be as reported by the certified EHR technology but there is not an electronic connection between your EHR and the CMS attestation program.
I have one physician who uses paper charts while seeing patients but also uses the EHR program. Is he still eligible?
If the physician qualifies as an EP, enrolls for MU, and is entering the data needed to meet the requirements then he or she can attest to MU. Since MU requires that many measures be tracked it may not make sense to be documenting in both a paper chart (where there is no incentive benefit) and in the electronic record.
How does this incentive work if the individual physicians work within a managed services arrangement (MSO)?
The incentive is paid to one tax ID per physician, so the employed physician and the MSO would need to review their contracts to see if the employed physician must (or has already agreed to) assign payments, including EHR incentives to the MSO tax ID. If not, in the attestation process, the employed physician may determine the tax ID to which the incentive should be paid.
Where do the funds come from to incentivize physicians to participate in MU?
This program was passed as part of the American Recovery & Reinvestment Act of 2009. The incentives are paid for by Medicare and Medicaid and funded through the federal and state governments. All of the money comes from our taxes as part of the federal budgeting process.
What is structured data?
The term “structured data” typically implies that a piece of information has been entered into a specific field within the electronic health record.
For instance, if there is a field for blood pressure and you enter 120/80, the ‘120’ and the ’80’ are structured data. If a field in the EHR is structured data, then there are 'rules' about what you could type into that field. For example a "date" could be an 8 numeric character field meaning you could only type 04242013, NOT April 24, 2013. If a field is un-structured, you could type anything—letters, numbers symbols, spaces, etc. Structured data is easier to find, to sort, and to count and move between systems.
We are using a couple of EMR's. I see folks in nursing homes, hospitals, skilled nursing facilities. Where do I qualify for the incentives?
There are some guidelines for how you qualify for MU if you are seeing patients in more than one location. There must be a certified EHR at the location, and you must spend at least 50% of your time at that location and the measures are only looking at patients where the POS billing code is either 11 (office), 20 (urgent care facility), 49 (independent clinic) and 24 (Ambulatory Surgery Center). So you would need to do an analysis of the places where you see patients and determine which location fits the requirements. For more details, visit www.cms.gov.
What if a provider is new and does not start his new practice until 2016?
You should get started as soon as possible. New practice EPs get a two year grace period without the penalty kicking in. For more details, look at www.cms.gov because eventually the penalty does take effect if the new EP is not participating as a Medicare meaningful user.
If the MD was previously billing at a hospital for 90% of the year can the MD be considered as an EP?
No, if the provider sees most of his or her patients at a hospital and the billing is done through the hospital using place of service codes not approved for EPs, then that provider is not eligible to be an EP. The hospital may be eligible, however. If the physician is office based in the new calendar year and meets the requirements, then he or she may be able attest to MU for EPs. To attest, the physician needs to have 90 days of reporting and meet any other minimum requirements for time spent at the service location, number of patients seen, etc.
Can NPs, PAs, PTs, OTs, SLPs, or social workers qualify for MU Medicare incentives?
None of these can qualify for Medicare incentives. The one exception to this is the case of a PA or NP who is the primary provider and/or owner of a rural health clinic. Mid-level providers (NPs) can qualify for Medicaid incentives. However, to do so requires that the provider have a minimum of 30% of their visits billed to Medicaid. EPs in a pediatric practice must only meet a 20% Medicaid visit threshold to receive 2/3 of the Medicaid incentive that an EP who has 30% or more Medicaid visits earns.
Do you have to ‘register’ for each new stage and if so how does one register?
If you are enrolled as an EP for Stage 1, you are already enrolled for future stages. If you still need to enroll, visit the EHR Incentive Program website. There are tools to assess eligibility and to enroll along with timelines and all the details of the program.
If we switch EHR’s after we attested for Stage 1, will we be penalized for using a new EHR for the next year?
No, you will not be penalized for changing to a new EHR. What matters is that the new EHR is 2014 certified.
What are the changes for 2016?
The previous measure structure of core and menu objectives has been replaced with 10 objectives, including one consolidated public health reporting objective. The objectives are the same regardless of what year of attestation you are in.
Why has CMS changed the objectives of Stage 1 and Stage 2?
- Align with Stage 3 to achieve overall goals of programs
- Synchronize reporting period objectives and measures to reduce burden
- Continue to support advanced use of health IT to improve outcomes for patients
Do I need to look for a new EHR?
The Modified Stage 2 objectives require all providers to use an EHR that is certified to the 2014 Edition. Kareo was certified in March 2014 and this certification will be valid through 2017.
What is the 2015 Reporting Period?
In 2015 only, the EHR reporting period for all providers will be any continuous 90-day period between January 1, 2015 and December 31, 2015.
Does the reporting period change for 2016 and forward?
Beginning in 2016, the reporting period for all providers will be based on the calendar year. Any provider who is attesting for the first time will report on any 90 consecutive days. All returning providers will attest for the full calendar year—365 days.
When can I begin my attestation reporting for 2015?
The CMS Attestation System will be open from January 4, 2016 through February 29, 2016. Anyone who is attesting for the 2015 calendar year must attest during this time frame.
Are there any considerations if I already began working on meaningful use in 2015?
To assist providers who may have already started working on meaningful use in 2015, there are alternate exclusions and specifications within individual objectives for providers who were previously scheduled to be in Stage 1 of meaningful use. These include:
- Allowing providers who were previously scheduled to be in a Stage 1 EHR reporting period for 2015 to use a lower threshold for certain measures.
- Retaining different specifications between Stage 1 and Stage 2
- Allowing providers to exclude for Stage 2 measures in 2015 for which there is no Stage 1 equivalent.
What are the 10 Objectives?
- Protect Patient Health Information: conduct or review a security risk analysis
- Clinical Decision Support: implement five clinical decision support interventions
- Computer Provider Order Entry:
- Record medication orders using computer provider order entry
- Record laboratory orders using computer provider order entry
- Record radiology orders using computer provider order entry
- Electronic prescribing: Rx queried for a drug formulary and transmitted electronically
- Health Information Exchange:
- Create summary of care for transition of care patient
- Transmit summary for transition to a receiving provider
- Patient Specific Education: provide patients with patient specific education
- Medication Reconciliation: perform medication reconciliation for transitions of care
- Patient Electronic Access (VDT):
- Provide patients timely access to view online, download and transmit their health information
- One patient views, downloads or transmits
- Secure Messaging: ability to send and receive a secure electronic message to/from patients
- Public Health Reporting: meet two of the following
- Immunization Registry Reporting: active engagement in submission
- Syndromic Surveillance Reporting: active engagement in submission
- Specialized Registry Reporting: active engagement in submission
Have any of the objectives changed from previous measures?
For the most part, the new objectives are identical to the previous Stage 1 and Stage 2 measures. The only exceptions are as follows:
- Patient Electronic Access (VDT): The threshold for the Stage 2 objective for Patient Electronic Access measure #2 has been changed from 5% of the patient population to “equal to or greater than 1 patient seen by the provider”. This means that only 1 patient will need to view, download, or transmit their medical information via the Patient Portal.
- Secure Electronic Messaging: The threshold for the Stage 2 objective Secure Electronic Messaging has been changed to “functionality fully enabled (yes/no).” This means that a provider will only need to indicate by a yes or no whether their patients have the capability to send him/her secure messages.
- Public Health Reporting: The public health reporting objectives have been consolidated into one objective with three measure options for EPs.
Have the Clinical Quality Measures changed with the Modified Stage 2 rules?
No, the clinical quality measures are unchanged. Providers still need to report on 9 CQMs.
If I was planning to attest to Stage 1, Year 1 in 2015, will I still be considered in Stage 1 in 2016?
No, unlike the previous rules, all providers will be on Modified Stage 2 regardless of their previous scheduled stage and year. The previous rules stated that a provider shall participate in each stage for a minimum of two years. In order to ease the transition, Modified Stage 2 does allow for some alternate exclusions for providers who intended to participate in Stage 1 in 2015.
|First year as a meaningful EHR user||Stage of Meaningful Use|
|2011||Modified Stage 2||Modified Stage 2||Modified Stage 2 or Stage 3|
|2012||Modified Stage 2||Modified Stage 2||Modified Stage 2 or Stage 3|
|2013||Modified Stage 2||Modified Stage 2||Modified Stage 2 or Stage 3|
|2014||Modified Stage 2*||Modified Stage 2||Modified Stage 2 or Stage 3|
|2015||Modified Stage 2*||Modified Stage 2||Modified Stage 2 or Stage 3|
|2016||Modified Stage 2||Modified Stage 2 or Stage 3|
What are the goals of Stage 3?
- Provide a flexible, clear framework to simply the meaningful use program and reduce provider burden
- Ensure future sustainability of Medicare and Medicaid EHR Incentive Programs
- Advance the use of health IT to promote health information exchange and improved outcomes for patients
What are the Stage 2 Objectives?
- Protect Electronic Health Information
- Electronic Prescribing (eRx)
- Clinical Decision Support
- Computerized Provider Order Entry (CPOE)
- Patient Electronic Access to Health Information
- Coordination of Care through Patient Engagement
- Health Information Exchange
- Public Health Reporting
2015 Edition Certification
This Health IT Module is 2015 Edition compliant and has been certified by an ONC-ACB in accordance with the applicable certification criteria adopted by the Secretary of Health and Human Services. This certification does not represent an endorsement by the U.S. Department of Health and Human Services. Vendor name: Kareo, Inc., Product Version: Kareo EHR version 4.0, Date certified: 12/31/17, Drummond Group Inc. Certification No: 15.04.04.2777.Kare.04.00.1.171231, Tested and Certified Modules: 170.315 (a)(1-14); (b)(1-3, 6); (c)(1-3); (d)(1-9); (e)(1-3); (g)(3-9), Tested and Certified Clinical Quality Measures: 2v6; 50v5; 68v6; 75v5; 117v5; 122v5; 123v5; 125v5; 127v5; 128v5; 130v5; 131v5; 135v5; 144v5; 146v5; 147v6; 153v5; 154v5; 155v5; 156v5; 164v5; 165v5; 166v6, Additional Software Required: LabSoft, Updox Direct 2014, Rcopia (DrFirst)
Website: www.kareo.com, Address: 3353 Michelson, Suite 400 Irvine CA 92612, Contact Name: Beth Onofri, Advisor, Healthcare Market, Email: firstname.lastname@example.org, Phone: 949-509-2472.
Any additional types of costs that an EP, EH, or CAH would pay to implement the Complete EHR’s or Health IT Module’s capabilities in order to attempt to meet meaningful use objectives and measures. Developers must also include any material product technical or contractual limitations. Refer to the Drummond Group Mandatory Disclosure Statement document for more details. EHR technology self-developers are excluded from this requirement.
Cost and Limitations
The monthly subscription fee for Kareo Clinical (Kareo EHR v. 4.0) includes all tested and certified modules listed above with exception of a one-time small set-up for implementation of e-prescribing of controlled substances. For a detailed explanation of costs and limitations, click here. For information on Kareo’s patient API, click here. Optional services, which are not required for CMS Incentive Programs, are available for a nominal fee. These services include custom template development and private CMS Incentive Programs coaching.