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Small Meaningful Use Penalties for Small Practices

Posted on February 17, 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.

Michelle has posted an interesting CMS analysis of the price of EHR penalties for physicians:

CMS reports that the majority of physicians who will be penalized this year for not having met MU requirements will lose less than $1,000 of their Medicare reimbursement; 34% of the penalties will be $250 or less, while 31% will exceed $2,000.

The adjustments will impact approximately 257,000 eligible providers. While no one likes losing money, the CMS penalty “stick” is pretty small compared to the overall cost of implementing an EHR.

Unfortunately her link to the CMS report seemed to be the wrong link. I’d love to dig into the 31% of doctors who will exceed $2000 in penalties. $2000 still isn’t very compelling to most doctors I know, but if it scales from there we could see how many doctors are really going to suffer from the EHR penalties.

What’s also not clear to me is if this includes the PQRS penalties as well. All of the penalties start to add up. I also heard one doctor talk about the feared 22% Medicare cut that’s been delayed for a decade or so (I lose track of the number of years). I’ll be surprised if those cuts aren’t delayed again, but it’s interesting that many doctors fear these cuts even if they’re likely to be delayed. Perception is still very important.

Back to the meaningful use penalties, $1000 penalty is not something most doctors will bat an eye at. Even those who have an EHR are opting out of meaningful use stage 2. The math doesn’t work out for small practices. $1000 of penalties certainly won’t balance the equation either. I expect a very small number of small practices to do meaningful use stage 2. Hospitals on the other hand are a different story.

Meaningful Use Is Dead?

Posted on January 29, 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.

Over on EMR and HIPAA, I got the following passionate response on my post titled Meaningful Use Created A Big Need for Certified MAs that I thought many readers on this site would enjoy.

In the EP world, MU is dead. There are some larger groups, especially primary care still struggling to overcome the huge hurdles of MU2, but most I know have given up and running for the hills. There is a ginormous gap between what ONC is peddling in terms of numbers and real MU use.

This is good example of another hidden cost of trying to MU. We have some excellent MA’s, and I could not tell you which are and are not certified. Makes no difference. Sadly, CMS and ONC, do not realize that they are literally driving EPs from accepting Medicare patients, especially us specialists. And once we are gone, or severely limit new patients with Medicare, we are not coming back.

So the 17 times in 11 years fix for SGR, PQRS, VBM, MU, CPQ, ICD10, HIPAA, RAC audits, sequester cuts, etc. Its too much cost. clicking, paper work to take care of these patients. We actually had a serious discussion with our hospital about cutting back severely on doing Medicare total knees and hips next year due to all this. And the hospital initiated the conversation. So its not just us, even EHs are looking into this.

We all know that CMS and ONC want something, anything in terms of numbers to report anything to Congress, but this is the wrong way to do it. Again, everyone out there that is sitting in their cubicle Monday morning quarterbacking our care for these patients, will be very sad, very soon as we will just stop seeing them.

You can see by the numbers, if 250,000 EPs are taking the first MU hit this year, just wait until the rest give up. EPs can see that MU does not equate to better care, safer care, or more efficient care. We all may use an EHR, but could care less about attestations and audit risks and counting numerators/denominators forever. Again now that at least half the EPS are out, the rest will be right behind.

CMS and ONC need to realize that penalties NEVER work. Incentives like the heady days of MU1, got people to try EHR, but the costs are now piling up, big time. Everyone wants their piece of the pie. But as the incentives have gone away and the clerk like data entry has gone up, EPs have left the program. And are never, I mean never, coming back.

This provider makes an interesting assertion about meaningful use being dead. Do you think that MU is dead?

I thought this post’s timing was interesting given the announcement that CMS is changing the meaningful use stage 2 reporting period to 90 days. Correction…they intend to change it, but I think we all see that it’s going to happen. Just let the rule making process take it’s course.

Before this announcement, I would have largely agreed that meaningful use was pretty close to dead. I know some people have sifted through the meaningful use stage 2 attestations and have said it’s better than we thought, but I think those are the early birds and not the majority. With this announcement, I think the majority will take a much deeper look at taking on MU stage 2. If CMS can simplify some things, I could see many participating to get the incentive money, but to also avoid the penalties. Penalties aren’t the end all be all for doctors, but they represent a big chunk of money for many doctors.

I’d love to hear your thoughts. What are you seeing in the trenches?

Timeline and Details of Medicare EHR Penalties

Posted on February 3, 2014 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.

Eligible professionals (EPs) participating in the Medicare EHR Incentive Program may be subject to payment adjustments beginning on January 1, 2015. CMS will determine the payment adjustment based on meaningful use data submitted prior to the 2015 calendar year. EPs must demonstrate meaningful use prior to 2015 to avoid payment adjustments.

Determine how your EHR Incentive Program participation start year will affect the 2015 payment adjustments:

If you began in 2011 or 2012…
If you first demonstrated meaningful use in 2011 or 2012, you must demonstrate meaningful use for a full year in 2013 to avoid the payment adjustment in 2015.

If you began in 2013…
If you first demonstrate meaningful use in 2013, you must demonstrate meaningful use for a 90-day reporting period in 2013 to avoid the payment adjustment in 2015.

If you plan to begin in 2014…
If you first demonstrate meaningful use in 2014, you must demonstrate meaningful use for a 90-day reporting period in 2014 to avoid the payment adjustment in 2015. This reporting period must occur in the first 9 months of calendar year 2014, and EPs must attest to meaningful use no later than October 1, 2014, to avoid the payment adjustment.

Avoiding Payment Adjustments in the Future
You must continue to demonstrate meaningful use every year to avoid payment adjustments in subsequent years.

If you are eligible to participate in both the Medicare and Medicaid EHR Incentive Programs, you MUST demonstrate meaningful use to avoid the payment adjustments. You may demonstrate meaningful use under either Medicare or Medicaid.

If you are only eligible to participate in the Medicaid EHR Incentive Program, you are not subject to these payment adjustments.

How to Avoid Medicaid EHR Penalties (Payment Adjustments)

Posted on May 30, 2013 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.

I got an email from CMS which does a great job summarizing the coming EHR Medicaid penalties (they prefer to call them Medicaid payment adjustments). I thought many of my readers would find the information useful.

Medicare eligible professionals (EPs) who do not demonstrate meaningful use for the Medicare Electronic Health Record (EHR) Incentive Program may be subject to payment adjustments beginning on January 1, 2015. Because payment adjustments are mandated to begin on the first day of the 2015 calendar year, CMS will determine the payment adjustments based on meaningful use data submitted prior to the 2015 calendar year.

These payment adjustments will be applied to the Medicare physician fee schedule amount for covered professional services furnished by the EP in 2015. EPs who do not demonstrate meaningful use is subsequent years will be subject to increased payment adjustments in 2016 and beyond.

EPs that began participation in 2011 or 2012
EPs who first demonstrated meaningful use in 2011 or 2012 must demonstrate meaningful use for a full year in 2013 to avoid payment adjustments in 2015.

EPs that begin participation this year (2013)         
EPs who first demonstrate meaningful use in 2013 must demonstrate meaningful use for a 90-day reporting period in 2013 to avoid payment adjustments in 2015.

EPs that plan to begin participation in 2014 
EPs who first demonstrate meaningful use in 2014 must demonstrate meaningful use for a 90-day reporting period in 2014 to avoid payment adjustments in 2015. This reporting period must occur in the first 9 months of calendar year 2014, and EPs must attest to meaningful use no later than October 1, 2014, in order to avoid the payment adjustments.

Note: EPs must continue to demonstrate meaningful use every year to avoid payment adjustments in subsequent years.

Eligibility
Only EPs that are eligible for the Medicare EHR Incentive Program are subject to payment adjustments. Use CMS’ Eligibility Widget to determine for which programs you are eligible. Medicaid EPs who can only participate in the Medicaid EHR Incentive Program and do not bill Medicare are not subject to these payment adjustments.

Resources
For more information on EP payment adjustments, view the Payment Adjustments and Hardship Exceptions Tipsheet for EPs and the How Payment Adjustments Affect Providers Tipsheet.

Bill Would Provide Exemptions From Meaningful Use Penalties

Posted on April 1, 2013 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.

A bill has been introduced in the U.S. House of Representatives (HR 1309) which would eliminate Medicare reimbursement penalties for some physicians who don’t fully participate in the Meaningful Use program, iHealthBeat reports. The bill, which is called the EHR Improvements Act, was introduced by Rep. Diane Black (R-Tenn.).

As readers of this blog know, healthcare providers are being offered both a carrot and a stick when it comes to Meaningful Use compliance. On the one hand, they’re eligible for incentive payments if they can demonstrate that they’ve met Meaningful Use goals.  On the other, starting in 2015 they’ll be subject to a 1 percent reduction in Medicare reimbursement rates every year that they don’t meet those goals, up to a maximum of 5 percent.

Rep. Black’s bill would remove the penalties for some classes of providers:

* Solo practitioners could apply for a hardship exemption from the MU program if they have limited capital, time or staff resources
* Physicians who’d be eligible to take Social Security payments by 2015 would get a retirement exemption of up to three years
* Eligible professionals who don’t fully meet Medicare Meaningful Use requirements but successfully participate in the Medicaid portion of the program would be excused from Medicare penalties
* Some physicians would be allowed to meet the MU program’s quality reporting requirements by participating in HHS-recognized disease or practice registry programs in their specialty

I don’t know about you folks, but to me these sound like sensible modifications to the Meaningful Use program. I don’t see any reason to punish impoverished solo practitioners, retiring doctors, EPs who meet Medicaid MU requirements or doctors reporting quality data through alternate channels.

Nobody out there — as far as I know — thinks Meaningful Use is perfect. Let’s hope these and other tweaks come along to avoid steamrolling those who can’t or shouldn’t have to comply with Medicare Meaningful Use completely.