Plan for Looming Meaningful Use Deadlines

More than likely, most physicians are well aware of meaningful use. What they are probably less certain of - through no fault of their own - are all the deadlines surrounding the program.

More than likely, most physicians are well aware of meaningful use, the government incentive program that encourages physicians to use electronic health records. What they are probably less certain of — through no fault of their own — are all the deadlines surrounding the program.

“There are a lot of complexities and nuances, and different deadlines and timetables for hospitals and physicians,” explains Jason Fortin, senior advisor at Impact Advisors, a health care information technology consulting firm. “And it’s not like [meaningful use] is the only program that physicians are responsible for.”

But that doesn’t make the deadlines, or the potential penalties, less important.

The attestation process

Fortin explains that Oct. 3, 2013, is the last day that physicians and other eligible health care professionals can begin collecting data to attest for the 2013 payment period — the first stage of meaningful use. Those who qualify under the Medicare program receive $15,000; those qualifying under Medicaid receive $21,250.

“If you miss [the Oct. 3] deadline, you’re leaving a lot of money on the table,” Fortin says. “But if you rush through it and cut some corners to get everything in place to start attesting, and then you’re unable to meet meaningful use in subsequent years, then there’s the potential you will be penalized for multiple years. And that $15,000 might seem small.”

Penalties can vary, Fortin says. Physicians who see a lot of Medicare patients are susceptible to greater penalties. So despite the missed financial opportunity by not beginning the attestation process by Oct. 3, 2013, it’s more important that everything is done correctly.

“You don’t want to rush, because meaningful use penalties after 2015 are an annual thing, and if you don’t meet meaningful use in one year, that’s a penalty,” Fortin says. “If you don’t meet it in the next year, that’s a penalty. Meaningful use is something that needs to be met every year in order to avoid penalties. So it’s definitely the kind of thing that you want to get right.”

Physicians can still attest for Stage 1 of meaningful use in 2014. The catch there, Fortin says, is that there is a significant drop off in potential incentive money. In addition, medical practices that begin the Stage 1 attestation process after July 3, 2014, could be subject to penalties.

Complexities of Stage 2

Highlighting the importance of engaging in the attestation process correctly at the start is the challenge presented by some of the measures in Stage 2. For example, Fortin explains that to achieve the patient engagement measure, 5% of patients need to send a secure message to the medical practice, and 5% need to access their information line. To some degree, enforcing those measures is out of a physician’s direct control.

“There has to be a strategy and planning in place as to how to reach out to patients in the community, and how to get them engaged and ready,” Fortin says. “Because it’s the first time with meaningful use that physicians are being held accountable for something that’s not necessarily directly under their control.”

One deadline that Fortin says has snuck up on people just a bit is that in 2014, regardless of whether or not your practice has attested for Stage 1, all physicians will have to use electronic health records that are certified to the 2014 certification criteria. The misconception is that medical practices don’t have to make that switch until they’re in Stage 2, which is not the case.

“Everyone has to make those upgrades for the 2014 payment year,” Fortin says. “In terms of deadlines, that’s one that can be tricky to digest.”

Where to start

Fortin acknowledges that if medical practices have not yet begun to prepare to collect data to attest for the 2013 payment period, it may be too late to do so, and do it properly, by the October 3, 2013 deadline. But regardless of when you start the attestation process, planning is imperative.

“If physicians haven’t already done so, they need to reach out to their EHR vendor and make sure that they understand what capabilities are going to be certified; understand the planned timing and rollout of those capabilities,” Fortin says. “Make sure that the timing the practice is planning for implementation and upgrade is aligned with the software vendor’s timeline and resources that may be required.”

In addition, don’t forget to reach out to the community.

“That’s going to be one of the tricky measures, even for a small practice. They are still going to have to make sure to get to that 5% threshold for those two measures.”