Medicare Payment Adjustments
meaningful use understanding 2014 deadlinesStarting January 1, 2015, Eligible Providers (EPs) that bill Medicare and have not successfully attested for meaningful use are subject to a 1% adjustment to their Medicare reimbursements. Adjustments are scheduled to increase to 2% in 2016, and 3% in 2017. Penalties in 2018 and beyond may vary depending on whether or not enough EPs become meaningful users, but the maximum it can reach is 5%.
Providers that ONLY bill Medicaid
Currently there are no scheduled Medicaid Adjustments for providers that fail to become meaningful users.
Providers that bill Medicare and Medicaid
Providers that are eligible to participate in both the Medicaid and Medicare programs may choose which program to demonstrate meaningful use under. Successfully attesting to meaningful use under the EHR Incentive program would exempt a provider from the Medicare payment adjustment as long as the provider has demonstrated meaningful use prior to 2015.
Keep in mind that the first year Medicaid incentive payment, which is based on simply “adopting, implementing and upgrading”, is not considered Meaningful Use.
Therefore, a provider that receives the Medicaid incentive for their first year in 2014 will still be subject to the Medicare payment adjustment in 2015. Providers that participated in the Medicaid Incentive Program for the first time in 2011, 2012, or 2013 and then continued to successfully attest to meaningful use in each subsequent year will be exempt from the Medicare payment adjustment.
All Providers that Bill Medicare – The last 90-day reporting period begins July 1, 2014.
Because the payment adjustment is mandated to begin January 1, 2015, CMS must determine whether or not a provider is subject to the payment adjustment based reporting periods prior to 2015.
Providers that successfully attested to meaningful use in 2013 (regardless of whether or not it was their first year) are exempt from the payment adjustment in 2015 and will not be subject to future payment adjustments as long as they continue to demonstrate meaningful use each subsequent year.
Providers that participate in the Medicare EHR Incentive program for the first time in 2014 must demonstrate meaningful use for a 90-day reporting period and attest to meaningful use NO LATER THAN OCTOBER 1, 2014, in order to avoid the payment adjustment. The last 90-day reporting period begins July 1, 2014.
Under special circumstances some providers may avoid payment adjustments by demonstrating that there are circumstances that pose a significant barrier to their ability to achieve meaningful use.
The Last Year for Incentives!
2014 marks the last year that providers can begin participating in the Medicare EHR Incentive program and receive incentive payments which can be as much as $24,000!
ACT NOW! If you wait it may be too late!
All users that are attesting for Meaningful Use in 2014 regardless of which stage they are in must upgrade to the 2014 certified versions of their EHR.
If you have not attested for meaningful use prior to 2014 you must install, implement and train your staff on the new EHR prior to starting your 90 day reporting period, and complete a Security Risk Analysis either prior to or during your reporting period. Remember- the last reporting period you can choose for 2014 begins July 1st! You can not wait any longer to get started as an average implementation timeline is 1-2 months and trainers schedules are filling up FAST!!
If you successfully attested to meaningful use in 2013 you must continue to attest each year in order to avoid payment adjustments.
Checklist for Existing EMR Users:
Choose a Reporting Period: Regardless of which stage you are in this year you will attest for a 90 day reporting period that is tied to a quarter. The two remaining reporting periods are July 1-Sept 30, and October 1-Dec 31.
Upgrade: Prior to your reporting period you must upgrade to the 2014 certified version of your EHR.
Review System Requirements: There are new system requirements for Medisoft Clinical and LytecMD Users that may require hardware or network upgrades. In addition all providers are required to implement an online patient portal in order to meet meaningful use which may in turn require new hardware. Please contact us for a Hardware/Network Analysis prior to upgrading.
Plan for Configuration and Training: Prior to your reporting period you must configure your software and train your staff on the new requirements for the applicable Stage of meaningful use you are in. Even if you are still in Stage 1 there are NEW REQUIREMENTS that take effect this year! We offer meaningful use assessments that can be done prior to upgrading so you can properly plan for the configuration and training that will be involved in your implementation.
Complete a Security Risk Analysis: Not only is this a meaningful use requirement, all providers who are “covered entities” under HIPAA are required to perform a security risk analysis (SRA). Security requirements address Physical Safeguards, Administrative Safeguards, Technical Safeguards, Policies and Procedures, Organizational Requirements, and all electronic protected health information you maintain, not just what is in your EHR. The SRA can be done PRIOR to or during your reporting period and must be conducted every year you attest to meaningful use. AZCOMP encourages practices to complete a thorough and professional risk analysis that will stand up to a HIPAA compliance review, as well as a Meaningful Use Audit. We offer complete security risk analysis completed by an ONC Certified Professional.
Contact your AZCOMP sales representative NOW at 888-799-4777 to discuss an action plan tailored to your practice!