Ever Attested?
If this is your first year to attest for Meaningful Use – You need to be working it now! Literally.
Payment Adjustments for NOT being a Meaningful User kick in January 1, 2015.
As part of the 2009 ARRA “Stimulus” program, if you DO NOT attest for meaningful use, by this year, your Medicare payments will be reduced by 1% for each year you are not a meaningful user. [Up to 5% loss, “depending on the total number of eligible meaningful user providers after 2018”, assuming less than 75% meaningful users the reductions are set to cap off at 5%.]
Technically, for 2014, everyone is only attesting for 90-days because this year is a “transition” year into Phase 2 meaningful use and all providers must upgrade or adopt newly certified Phase 2 EHRs. (To attest for meaningful use, offices have to be using a certified EHR and unfortunately a lot of Phase 1 certified EHRs have dropped out and decided not to do Phase 2 development or testing. If an EHR doesn’t upgrade and certify for Phase2 they have left their clients high and dry – necessitating that many will have to get a NEW EHR to comply with the new standards and not lose their money.)
Important things to note (if you don’t want to be docked that 1% on January 1st):
If you have never attested before you need to get your 90-days in and attest within the first 9 months of 2014 (i.e. BEFORE OCTOBER 1st, 2014).
This means that you need to be doing your 90-day reporting period by June, to give yourself time to get 90-days in and go through the attestation registration and reporting.
If you attested in 2013 then the payment reduction won’t hit you until 2016 (if you don’t demonstrate meaningful use with a Phase 2 certified EHR). Odds are you will have to certify for a whole year next year, not just 90-days (but I didn’t see that in the document).
There are exceptions to the attestation rule and more details (Look at the original CMS document for further explanation and details): http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/PaymentAdj_HardshipExcepTipSheetforEP.pdf
Notice that this coincides with the ICD-10 changeover, also scheduled to begin October 1st, 2014.
And NOW for yet another Weird and Wacky Alert…
House Bill 4302
We just received an e-mail from the AAPC (American Academy of Professional Coders) yesterday (3/27/14) stating that House Bill 4302 passed congress. This bill is the one that proposes to extend the Medicare Sustainable Growth Rate (SGR) to April 15th. Somehow there are some other things tied in with this bill and there is a possibility that some other Medicare deadlines might be delayed if this extension goes through. This includes the possible postponement of ICD-10-CM implementation. (It didn’t say in the note if the Medicare stimulus 1% reductions were tied in with this – they are Medicare, but they are attached to the 2009 ARRA “stimulus” act, so who knows.)
In order for House Bill 4302 to become law – it would still have to get approval from the Senate (who may also change it or send it back to Congress), and then once through the Senate, the President would still have to sign it.
We have seen in the past several years that getting these things through in a timely manner is nearly impossible. Previous extensions always seemed to run out and get passed late. Many years have seen these things go one month at a time for half a year. There is also no statement on how long or what kind of ICD-10 delay MIGHT ensue from this bill. They may even scrap the entire SGR percent increase withhold idea and finally make a permanent adjustment to it like everyone is truly hoping for.
Our recommendation is like that of the AAPC – we recommend that you continue to prepare now for ICD-10 implementation, just like we are. If there is a delay, you might get more time to refine, if not you would be woefully behind with no money coming into your office.
As always, Genius Solutions is working and preparing both for ICD-10 and Phase 2 certification. We always say, “We Care!” and we are showing this to you every day by backing you up and taking care of these things for and with you. We won’t leave you high and dry and we’ve got nearly 28 years of “showing” rather than telling you that we are in this with you, for the long haul.
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