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2017 MIPS Final Score and Performance Feedback Is Out

Posted on June 29, 2018 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Big news just came out for those that are participating in MACRA and MIPS. CMS Announced it on Twitter:

That’s right, you can now visit the QPP website and login to see and verify your 2017 MIPS final score and performance feedback. Interesting that they would choose to push this out late on a Friday. You’ll want to verify this information to make sure you’re paid correctly and to make sure they have the right data for you before they make all the MIPS scores public.

I looked at the Physician Compare website and unless I just didn’t look in the right places, I don’t see the MIPS Quality scores available on the website yet, but I expect they will be soon. Plus, they’re likely going to make the data available for download as a dataset. Once they do, websites like ZocDoc, Vitals, HealthGrades and the rest of the physician ratings and review websites will pull the data and incorporate it into their physician profiles. So, you’ll want to make sure your data is accurate.

I will say that when I was looking at physicians on the Physician Compare website, I was fascinated by the note they put as a popup for someone who had “Used electronic health record”:

To be fair, they did use the word “may”, but I think most doctors would say this is a far cry from what EHR software has accomplished. However, it’s clear what the intent of the legislation and CMS was when it came to adoption of EHR software.

Have you had a chance to look at your MIPS score and performance feedback? We’d love to hear about your experiences. We’ll be interested to see how these MIPS quality scores are used by doctors and patients.

How Will CMS Handle Issues Surrounding MACRA Changes?

Posted on May 14, 2018 I Written By

Anne Zieger is veteran healthcare consultant and analyst with 20 years of industry experience. Zieger formerly served as editor-in-chief of FierceHealthcare.com and her commentaries have appeared in dozens of international business publications, including Forbes, Business Week and Information Week. She has also contributed content to hundreds of healthcare and health IT organizations, including several Fortune 500 companies. Contact her at @ziegerhealth on Twitter or visit her site at Zieger Healthcare.

As most readers will know, when CMS released details on MIPS and the Alternative Payment Model incentives it embarked on a new direction for quality programs generally. As most readers will know, MIPS consolidated PQRS, the Physician Value-based Modifier and the Medicare EHR Incentive Program for EPs (Meaningful Use). But CMS is still updating the Medicaid incentive program.

If I were a physician, I’d be even more interested in the CMS initiative dubbed Promoting Interoperability. In some of the biggest news to come out of the agency in ages, CMS is restructuring the EHR Incentive Programs to become the Promoting Interoperability Programs. Promoting Interoperability replaces the Advancing Care Information category of MIPS.

Whoa. That would be a big enough deal on its own, but the issues the rule raises are an even bigger one.

CMS’s has been working towards this goal for a few years. Per HIMSS, here are some changes suggested in the proposed rule that might have the biggest impact on the health IT world:

  • The rule would cut down measures from 16 to six
  • It would use a new performance-based scoring methodology which would include measures of performance on e-prescribing, health information exchange, provider to patient exchange and public health and clinical data exchange
  • The agency will define and work to prevent “information blocking”

On a related note, CMS has posted a request for information asking for stakeholder feedback on program participation conditions. This is pretty unusual for the agency.

Like many CMS proposals, this one leaves some important questions open. (Apparently, CMS itself wonders how this thing will work, as the request for information suggests.)

For example, the new performance-based scoring method will award providers anywhere from 0 to 100 points. Measuring health IT performance is always a tricky thing to do, and there’s little doubt that if this becomes a final rule, both providers and CMS will have to go through some struggles before they perfect this approach. In the meantime, providers face some big challenges. How will they adapt to them? Its too soon to say.

Addressing so-called “information blocking” should be an even bigger challenge. Everyone from members of Congress to providers to vendors acts as though there’s one way to describe this practice, but there’s still a lot of wiggle room. Honestly, I’ll be amazed if CMS manages to pin it down the first time around.

Still, the time is more than overdue for CMS to take on interoperability directly. Without real data interoperability, many promising digital health schemes will collapse under their own weight. If CMS can figure out how to make it happen, it will be pretty neat.

Find Out if 2016 Exclusions and Alternate Exclusions Apply to You

Posted on September 27, 2016 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

National Health IT Week is September 26-30, 2016. CMS is sharing guidance throughout the week to help providers and industry members participate successfully in ongoing CMS health IT initiatives. Stay tuned all week for the latest news and updates from CMS.

To participate successfully in the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs in 2016, providers must meet the thresholds of all required objectives and measures, or qualify for an exclusion and/or alternate exclusion. Providers who meet the qualifications for an exclusion and/or alternate exclusion will not need to report on that specific objective or measure.

Exclusions

Exclusions exempt you from having to meet specific objectives. If you meet the qualifications for an exclusion, then you will not have to report on that objective and will avoid a payment adjustment in future years.

  • Exclusions are not based on specialty.
  • Specialists must evaluate whether or not they meet the exclusion criteria for each objective.
  • There is no blanket exclusion for any type of eligible professional (EP).

Alternate Exclusions

The final rule released in October 2015 – which outlined requirements for the EHR Incentive Programs in 2015-2017 (Modified Stage 2) and Stage 3 in 2018 and beyond— included additional exclusions known as “alternate exclusions” for certain objectives and measures in 2015 and 2016.

These alternate exclusions are intended to assist providers in the early stages of meaningful use by:

  • Allowing providers to use a lower threshold for certain measures, or to exclude certain measures for which there is no Stage 1 equivalent;
  • Accommodating changes required for the transition to the Modified Stage 2 objectives and measures, especially potential changes to the implementation of certified EHR technology.

In 2016, alternate exclusions are available for the following objectives:

A. Computerized Provider Order Entry

  • Measure 2: Laboratory Orders
  • Measure 3: Radiology Orders

B. Electronic prescribing (Eligible hospitals only)

C. Public Health Reporting

  • Measure 2: Syndromic Surveillance Reporting (EPs)
  • Measure 3: Specialized Registry Reporting (EPs, and Eligible hospitals and CAHs)

Many of the alternate exclusions that were available in 2015 are not applicable in 2016.

Note: Providers may opt to use the alternate exclusions, but they are not required to use them. The registration and attestation system will automatically identify providers who are eligible for alternate exclusions.

CMS Announces Details for MACRA, MIPS, APM – The Future of Meaningful Use

Posted on April 27, 2016 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Seven years ago, Congress passed a law to spur the country to digitize the health care experience for Americans and connect doctors’ practices and hospitals, thereby modernizing patient care through the Electronic Health Records (EHRs) Incentive Programs, also known as “Meaningful Use.” Before this shift began, many providers did not have the capital to invest in health information technology and patient information was siloed in paper records. Since then, we have made incredible progress, with nearly all hospitals and three-quarters of doctors using EHRs. Through the use of health information technology, we are seeing some of the benefits from early applications like safe and accurate prescriptions sent electronically to pharmacies and lab results available from home. But, as many doctors and patients will tell you (and have told us), we remain a long way from fully realizing the potential of these important tools to improve care and health.

That is why, as we mentioned earlier this year, we have conducted a review of the Meaningful Use Program for Medicare physicians as part of our implementation of the Medicare Access and CHIP Reauthorization Act (MACRA), with the aim of reconsidering the program so we could move closer to achieving the full potential health IT offers.

Over the last several months, we have made an unprecedented commitment to listening to and learning from physicians and patients about their experience with health information technology – both the positive and negative. We spoke with over 6,000 stakeholders across the country, including clinicians and patients, in a variety of local communities. Today, based on that feedback, we are proposing to incorporate the program in to the Merit-based Payment System (MIPS) in a way that makes it more patient-centricpractice-driven and focused on connectivity. This new program within MIPS is named Advancing Care Information.

What We’ve Learned

In our extensive sessions and workshops with stakeholders, a near-universal vision of health information technology surfaced: Physicians, patients, and other clinicians collaborating on patient care by sharing and building on relevant information.

Three central priorities to address moving forward:

  1. Improved interoperability and the ability of physicians and patients to easily move and receive information from other physician’s systems;
  2. Increased flexibility in the Meaningful Use program; and
  3. User-friendly technology designed around how a physician works and interacts with patients.

This feedback created a blueprint for how we go forward to replace the Meaningful Use program for Medicare physicians with a more flexible, outcome-oriented and less burdensome proposal.

How We’re Moving Forward

Our goal with Advancing Care Information is to support the vision of a simpler, more connected, less burdensome technology. Compared to the existing Medicare Meaningful Use program for physicians, the new approach increases flexibility, reduces burden, and improves patient outcomes because it would:

  • Allow physicians and other clinicians to choose to select the measures that reflect how technology best suits their day-to-day practice
  • Simplify the process for achievement and provide multiple paths for success
  • Align with the Office of the National Coordinator for Health Information Technology’s 2015 Edition Health IT Certification Criteria
  • Emphasize interoperability, information exchange, and security measures and require patients to access to their health information through of APIs
  • Simplify reporting by no longer requiring all-or-nothing EHR measurement or quality reporting
  • Reduce reporting to a single public health immunization registry
  • Reduce the number of measures to an all-time low of 11 measures, down from 18 measures, and no longer require reporting on the Clinical Decision Support and the Computerized Provider Order Entry measures
  • Exempt certain physicians from reporting when EHR technology is less applicable to their practice and allow physicians to report as a group

A full list of the operational differences included in this new proposal is available here, along with more details on how it would work.

These improvements should increase providers’ ability to use technology in ways that are more relevant to their needs and the needs of their patients. Previously established requirements for APIs in the newly certified technology will open up the physician desktop to allow apps, analytic tools, and medical devices to plug and play. Through this new direction, we look forward to developers and entrepreneurs taking the opportunity to design around the everyday needs of users, rather than designing a one-size-fits-all approach. Already, developers that provide over 90 percent of electronic health records used by U.S. hospitals have made public commitments to make it easier for individuals to access their own data; not block information; and speak the same language. CMS and ONC will continue to use our authorities to eliminate barriers to interoperability.

Under the new law, Advancing Care Information would affect only Medicare payments to physician offices, not Medicare hospitals or Medicaid programs. We are already meeting with hospitals to discuss potential opportunities to align the programs to best serve clinicians and patients, and will be engaging with Medicaid stakeholders as well.

This proposal, if finalized, would replace the current Meaningful Use program and reporting would begin January 1, 2017, along with the other components of the Quality Payment Program. Over the next 60 days, the proposal will be available for public comment. It is summarized here http://www.hhs.gov/about/news/2016/04/27/administration-takes-first-step-implement-legislation-modernizing-how-medicare-pays-physicians.html  and the full text is available here https://s3.amazonaws.com/public-inspection.federalregister.gov/2016-10032.pdf . We will continually revise and improve the program as we gather feedback from patients and physicians providing and receiving care under the Advancing Care Information category – and the Quality Payment Program as a whole. We look forward to hearing from you and working together to continue making progress in the coming months and years.

Providers Must Attest to 2015 EHR Incentive Program Requirements by March 11, 2016 at 11:59 PM EST

Posted on March 8, 2016 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

The attestation deadline for the Medicare Electronic Health Record (EHR) Incentive Program is only 3 days away!

Eligible professionals, eligible hospitals, and critical access hospitals (CAHs) participating in the Medicare EHR Incentive Program must attest using the Medicare & Medicaid EHR Incentive Program Registration and Attestation System no later than Friday, March 11, 2016 at 11:59 p.m. ET.

Medicaid EHR Incentive Program participants should refer to their respective states for attestation information and deadlines. Certain Medicaid eligible professionals may use the Registration and Attestation System as an alternate attestation method to avoid the Medicare payment adjustment (80 FR 62900 through 62901).

To attest to the EHR Incentive Programs in 2015:

  • Eligible Professionals may select an EHR reporting period of any continuous 90 days from January 1, 2015 (the start of the 2015 calendar year) through December 31, 2015.
  • Eligible Hospitals/CAHs may select an EHR reporting period of any continuous 90 days from October 1, 2014 (the start of the federal fiscal year) through December 31, 2015.

CMS Launches Important Changes to the Medicare EHR Incentive Program Hardship Exception Process

Posted on January 22, 2016 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Today, CMS launched important changes to the Medicare EHR Incentive Program hardship exception process that will reduce burden on clinicians, hospitals, and critical access hospitals (CAHs). These changes are a result of recent Medicare legislation – the Patient Access and Medicare Protection Act (PAMPA), Pub. L. No. 114-115 – and our ongoing efforts to improve the program.

CMS has posted new, streamlined hardship applications, reducing the amount of information that eligible professionals (EPs), eligible hospitals, and CAHs must submit to apply for an exception. The new applications and instructions for a hardship exception from the Medicare Electronic Health Records Incentive Program 2017 payment adjustment are available here.

This new, streamlined application process is the result of PAMPA, which established that the Secretary may consider hardship exceptions for “categories” of EPs, eligible hospitals, and CAHs that were identified on CMS’ website as of December 15, 2015. Prior to this law, CMS was required to review all applications on a “case-by-case” basis.

Importantly, EPs, eligible hospitals, and CAHs that wish to use the streamlined application must submit their application according to the timeline established in PAMPA:

  • Eligible Professionals: March 15, 2016
  • Eligible Hospitals & CAHs: April 1, 2016

Please note: CAHs should use the form specific for the CAH hardship exceptions related to an EHR reporting period in 2015. CAHs that have already submitted a form for 2015 are not required to resubmit.

In addition, we have heard from stakeholders that they would like a more efficient approach for submitting applications from groups of providers. Following Congress’ efforts in PAMPA, we have reviewed our administrative authorities and determined that groups of providers may apply for a hardship exception on a single application. Under the group application, multiple providers and provider types may apply together using a single submission. The hardship exception categories are the same as those applicable for the individual provider application.

Providers will have the option to submit an electronic file (in excel or csv formats) with all National Provider Identifiers (NPIs) or CMS Certification Numbers (CCNs) for providers within the group or use a multiple NPI or CCN form to submit their application. In addition, facilities which include both inpatient and outpatient settings may include both the individual NPIs for any eligible professionals and the CCN for the eligible hospitals and CAHs on the same single submission for their organization.

We look forward to further simplifying and continuing to improve the EHR Incentive Programs in collaboration with the provider community and Congress.

Submit Applications for EHR Penalty Reconsiderations by November 30

Posted on November 24, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

In the American Recovery and Reinvestment Act of 2009 (ARRA), Congress mandated that payment adjustments should be applied to Medicare eligible professionals, eligible hospitals, and critical access hospitals (CAH) that are not meaningful users of Certified Electronic Health Record (EHR) Technology under the Medicare EHR Incentive Program. Payment adjustments for eligible hospitals began on October 1, 2014.

2016 Payment Adjustments for Medicare Eligible Hospitals
Eligible hospitals receive the Medicare payment adjustment amount that is tied to a specific fiscal year. For fiscal year 2016, Medicare eligible hospitals that were not meaningful EHR users in 2014, and were not granted a hardship exception, were subject to a payment adjustment beginning October 1, 2015. This payment adjustment is applied as a reduction to the applicable percentage increase to the Inpatient Prospective Payment System (IPPS) payment rate, thus reducing the update to the IPPS standardized amount for these hospitals.

2016 Reconsiderations Application Due November 30
For eligible hospitals who received a Medicare payment adjustment letter for 2016, and believe their hospital was subject to a payment adjustment in error, applications for payment adjustment reconsideration for fiscal year 2016 must be submitted electronically or postmarked by 11:59 PM EST on November 30.

The instructions and application for a payment adjustment reconsideration are available on the Payment Adjustments & Hardship Information page of the CMS website.

New EHR Incentive Program FAQs from CMS

Posted on November 10, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

On October 6, the Centers for Medicare & Medicaid Services (CMS) released the final rule with comment for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. To keep you informed of changes to the programs and how to participate in 2015, CMS has also released three new FAQs providing clarification on how to attest to certain measures for health information exchange, patient electronic access, and other objectives that require patient action.

FAQ 12817
Question: For the Health Information Exchange objective for meaningful use in 2015 through 2017, may an eligible professional (EP), eligible hospital or critical access hospital (CAH) count a transition of care or referral in its numerator for the measure if they electronically create and send a summary of care document using their CEHRT to a third party organization that plays a role in determining the next provider of care and ultimately delivers the summary of care document?

Answer: Yes. An EP, eligible hospital or CAH may count transmissions in this measure’s numerator when a third party organization is involved so long as:

  • The summary of care document is created using certified EHR technology (CEHRT);
  • The summary of care document is transmitted electronically by the EP, eligible hospital or CAH to the third party organization…read the full FAQ.

FAQ 12821
Question: If multiple eligible professionals or eligible hospitals contribute information to a shared portal or to a patient’s online personal health record (PHR), how is it counted for meaningful use when the patient accesses the information on the portal or PHR?

This answer is relevant to the following meaningful use objectives: Patient Specific Education and Patient Electronic Access measure 2.

Answer: If an eligible professional sees a patient during the EHR reporting period, the eligible professional may count the patient in the numerator for this measure if the patient (or an authorized representative) views online, downloads, or transmits to a third party any of the health information from the shared portal or online PHR. The same would apply for an eligible hospital or CAH if a patient is discharged during the EHR reporting period. If patient-specific education resources are provided electronically, it may be counted in the numerator for any provider within the group sharing the CEHRT who has contributed information to the patient’s record if that provider has the patient in their denominator for the EHR reporting period. The respective eligible professional, eligible hospital, or CAH must have contributed at least some of the information identified in the Medicare and Medicaid Programs; Electronic Health Record Incentive Program – Stage 3 and Modifications to Meaningful Use in 2015 Through 2017 final rule (80 FR 62807 through 62809) to the shared portal or online PHR for the patient. However, the respective provider need not have contributed the particular information that was viewed, downloaded, or transmitted by the patient. …Read the full FAQ.

FAQ 12825
Question: In calculating the meaningful use objectives requiring patient action, if a patient sends a message or accesses his/her health information made available by their eligible professional (EP), can the other EPs in the practice get credit for the patient’s action in meeting the objectives?

Answer: Yes. This transitive effect applies to the Secure Electronic Messaging objective, the 2nd measure of the Patient Electronic Access (View, Download and Transmit) objective, and the Patient Specific Education objective.

If a patient sends a secure message about a clinical or health related subject to the group practice of their EP, that patient can be counted in the numerator of the Secure Electronic Messaging measure for any of the EPs at the group practice who use the same certified electronic health records technology (CEHRT) that saw and patient during their EHR reporting period.

Similarly, if a patient views, downloads or transmits to a third party the health information that was made available online by their EP, that patient can be counted in the numerator of the 2nd Patient Electronic Access measure for any of the EPs in that group practice who use the same CEHRT and saw that patient during their EHR reporting period.

If patient-specific education resources are provided electronically, it may be counted in the numerator for any provider within the group sharing the CEHRT who has contributed information to the patient’s record if that provider has the patient in their denominator for the EHR reporting period. … Read the full FAQ.

For more information on accurately calculating the numerator for measures, please visit FAQ 8231.

Learn about New Requirements for Participation in EHR Incentive Programs

Posted on October 7, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

The Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) recently announced the release of final rules for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs and the 2015 Edition Health IT Certification Criteria. The rules will be published on October 16, 2015, and are currently on display in the Federal Register.

The EHR Incentive Programs final rule provides new criteria that eligible professionals, eligible hospitals, and critical access hospitals (CAHs) must meet in order to successfully participate in the EHR Incentive Programs. The final rule outlines program requirements in 2015 through 2017 (Modified Stage 2) and Stage 3 in 2018 and beyond, and includes a comment period for Stage 3.

The 2015 Edition Health IT Certification Criteria final rule builds on past editions of adopted health IT certification criteria, and includes new and updated IT functionality and provisions that support the EHR Incentive Programs’ care improvement, cost reduction, and patient safety across the health system.

EHR Incentive Programs Final Rule Provisions
Through the new requirements of the EHR Incentive Programs, CMS will expand meaningful use of certified EHR technology to promote health information exchange and improved outcomes. The rule also includes changes to the structure of the EHR Incentive Programs to improve efficiency, effectiveness, and flexibility.

Major policy provisions include:

  • Program modifications to reduce reporting burden, eliminate redundant and duplicative reporting, and to better align the objectives and measures of meaningful use with the Stage 3 requirements.
  • A revised single set of objectives and measures, including a reduction of the overall number of objectives to which a provider must attest.
  • Changes in EHR reporting periods, including a shift to calendar year for all providers and 90-day reporting for 2015.
  • Revisions to attestation and payment adjustment deadlines.
  • Optional Stage 3 reporting in 2017.

For more information about the EHR Incentive Programs final rule, view the Final Rule Fact Sheet that highlights key changes to the EHR Incentive Programs.

To learn more about the ONC 2015 Edition Health IT Certification Criteria final rule, visit: https://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2015-Fact-sheets-items/2015-10-06.html

FAQs with Guidance on Switching EHR Vendors Now Available on CMS Website

Posted on September 24, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Question: Can providers that have switched Certified Electronic Health Record (EHR) Technology vendors apply for a hardship exception to avoid the Medicare payment adjustment?

Answer: Yes, if a provider switches EHR vendors during the Program Year and is unable to demonstrate meaningful use, the provider may apply for an Extreme and/or Uncontrollable Circumstances hardship exception and if approved may be exempt from the payment adjustment.

For example, if an eligible professional (EP) switches EHR vendors in 2015 and is unable to demonstrate meaningful use in 2015, the EP can apply for an EHR Vendor Issue hardship, before the July 1, 2016 submission deadline, and be exempt from the payment adjustment in 2017.

Question: What if your product is decertified?

Answer: If your product is decertified, you can still use that product to attest if your EHR reporting period ended before the decertification occurred. If your EHR reporting period ended after the decertification occurred, you can apply for a hardship exception. If the decertification occurs after the hardship exception period has already closed for the payment adjustment year which would be applicable for your reporting period, please contact CMS Hardship Coordinator at EHRinquiries@cms.hhs.gov to apply for a hardship exception under the Extreme and/or Uncontrollable Circumstances category per CMS discretion to allow such an application.

Also, if you are a first time participant at a group practice which is switching products and the product is decertified after the hardship deadline, contact CMS at EHRinquiries@cms.hhs.gov.