For those hospitals interested in applying for the Medicare EHR Incentive Payments for 2011, the last day to begin the 90-day reporting period is July 3rd. Hospitals and CAHs must demonstrate meaningful use for 90-days during the 2011 fiscal year (which ends September 30, 2011). Hospitals and CAHs have until November 30, 2011 to register and attest to meaningful use.
$12 Million in New Grant Funding to Assist Physicians with EHRs
May 4, 2011 By
As reported in Healthcare IT News “The Health Resources and Service Administration has made available $12 million in grants for rural healthcare network organizations to help them become meaningful users of certified electronic health records.” According to HRSA officials “the grants may support health IT activities, such as development of a strategic plan for electronic health records (EHRs), workforce analysis, purchase of health IT equipment and installation of broadband for connectivity.” For more details see http://www.healthcareitnews.com/news/hrsa-puts-12m-rural-health-networks.
Attestation for EHR Incentive Programs Available
April 27, 2011 By
Earlier this month, CMS launched the attestation portion of the EHR Incentive Payment Program. Beginning on April 18th, eligible professionals and hospitals are now able to attest to meaningful use (or adopt, implement or upgrade for Medicaid). Along with the attestation itself, CMS launched its Meaningful Use Attestation Calculator, a wizard which walks eligible professionals and hospitals through the meaningful use objectives and enables the entity to determine if it can successfully meet the meaningful use standards prior to filling out the registration form.
For those providers that are able to begin the registration and attestation process, access to registration and attestation is available here. The CMS website also has a user guide that is helpful when registering as well as FAQs. To be eligible for either the Medicare or Medicaid EHR Incentive Programs an eligible professional or hospital must be using certified EHR technology. The ONC provides a list of which EHR systems are “certified.”
In addition, CMS is offering teleconferences regarding registration and attestation:
- Tuesday, May 3, 2:00 – 3:30 p.m. ET – Register to join this call if you are an eligible hospital or CAH who wants to learn more about the attestation process for the Medicare EHR Incentive Program.
- Thursday, May 5, 1:30 – 3:00 p.m. ET- Register to join this call if you are an EP who wants to learn more about the attestation process for the Medicare EHR Incentive Program.
Some states are also offering webinars about the Medicaid EHR Incentive Payment Program and how to register. Registration for the Medicaid EHR Incentive Program requires both registration with CMS and on the state level. However, eligible professionals and hospitals will not be able to register with CMS for the Medicaid EHR Incentive Program until their state is ready to start its Medicaid EHR Incentive Program. Washington expects to go-live in June 2010; California plans to go-live this Summer for eligible professionals.
If you have questions regarding the Medicare or Medicaid EHR Incentive Programs or would like some assistance with understanding meaningful use or calculating patient volume (Medicaid) please contact Elana Zana or Dave Schoolcraft.
Registration for Medicare EHR Incentive Payments Starts January 3rd
December 28, 2010 By
Starting on January 3rd, 2011, registration for the HITECH Electronic Health Record Medicare Incentive Payments will open. This registration is available for both eligible professionals and eligible hospitals, including Critical Access Hospitals. The registration link will be available starting on January 3rd and can be accessed here. Registration for the Medicaid EHR Incentive Payments will be available for the following states: Alaska, Iowa, Kentucky, Louisiana, Oklahoma, Michigan, Mississippi, North Carolina, South Carolina, Tennessee, and Texas. In February, registration will likely open in California, Missouri, and North Dakota. It is anticipated that other states, including Washington, will launch their Medicaid EHR Incentive Programs during the spring and summer of 2011.
For mor information regarding the Medicare Incentive Payments see the CMS press release. For a general overview of the HITECH incentive payments please read our previous blog posts for physicians and hospitals. As a disclaimer, these blog posts were written prior to the issuance of the Final Rules but provide a good overview of the statutory requirements.
CMS has also issued tip sheet regarding Stage 1 Meaningful Use for hospitals, and Critical Access Hospitals, click here to access the tip sheet. The tip sheet for eligible professionals can be accessed here. Additional information may be obtained by contacting CMS or your State directly (CMS and State Medicaid Contact List & Information).
If you would like further information regarding achieving Meaningful Use, registering for the Medicare Incentive Payments, or assistance calculating the Medicare or Medicaid incentive payments please contact Dave Schoolcraft or Elana Zana.
Critical Access Hospital Incentive Payments
August 30, 2010 By
CMS has issued a Critical Access Hospital (CAH) Tip Sheet to assist CAH’s in evaluating eligibility under the Medicare EHR Incentive Payment program. Though, CAH’s are now eligible for Medicaid EHR Incentive Payments, this eligibility is similar to all other acute care hospitals. CAH’s are not entitled to a different calculation formula for Medicaid EHR Incentive Payments.
To view the Medicare CAH Tip Sheet click here.
To view the Medicaid Tip Sheet for Acute Care Hospitals click here.
If you have questions or need assistance in calculating the estimated Medicare or Medicaid Incentive Payments for your hospital or with achieving meaningful use please contact Elana Zana.
CMS Presentation on Meaningful Use & EHR Incentives Final Rules
July 22, 2010 By
On July 13, CMS issued the Medicare and Medicaid Programs Electronic Health Record Incentive Program Final Rules. These final rules were published in the Federal Register on July 28th.
On July 22nd, CMS hosted a conference call to explain the changes in the Final Rules as compared to the Proposed Rules. Some key changes include:
- Inclusion of Critical Access Hospitals in the definition of eligible hospital for Medicaid incentives.
- A revised definition of hospital based eligible professionals to exclude only those physicians that provide 90% or more of their services in either an inpatient or emergency department.
- Eligible Professionals and Eligible Hospitals may defer 5 optional “menu set” Meaningful Use reporting objectives.
- Reduction in measure thresholds for Meaningful Use reporting objectives.
To view the CMS slide presentation click here. ONC has also published a slide deck entitled “Supporting Meaningful Use” that provides helpful guidance. CMS has also launched an EHR Incentives website which has fact sheets, press releases, general information, and instructions on how to participate, also on the website will be the transcript of the CMS conference call.
In addition, CMS has published the Health Information Technology: Initial Set of Standards, Implementation Specifications, and Certification Criteria for EHR Technology. For more information on these Standards click here.
If you have questions regarding how these final rules will affect your practice please contact Elana Zana.
Comments on Meaningful Use and EHR Incentives Proposed Rule Accepted Through March 15th
March 2, 2010 By
At the end of the year, CMS finally issued the much anticipated Electronic Health Record Incentive Payments proposed rule, including the definition of “meaningful use.” CMS has also published fact sheets to help distill the information:
Fact Sheet on Medicaid Incentive Payments
Fact Sheet on Medicare Incentive Payments
Fact Sheet on the Definition of Meaningful Use
Physicians and Hospitals are encouraged to comment on the proposed rule through March 15th. Some specific hot topics include: the definition of meaningful use, the exclusion of provider-based physicians from incentive payments, calculation for Critical Access Hospital Medicare incentive payments, exclusion of Critical Access Hospitals in Medicaid incentive payments, and the requirements for certified EHR systems.
To view some of the submitted comments so far go to: www.regulations.gov.
The American Hospital Association also encourages hospitals to send out this comment letter.
If you are interested in drafting your own comment and require some assistance please contact Elana Zana or Dave Schoolcraft.
Final Physician Supervision Rules for Hospital Outpatient Therapeutic and Diagnostic Services for CY 2010
December 2, 2009 By
CMS recently released the CY 2010 Outpatient Prospective Payment System Final Rule. The Final Rule finalized, among many other items, several provisions concerning physician supervision of hospital outpatient therapeutic and diagnostic services which CMS had previously proposed. The physician supervision provisions finalized for CY 2010 were in response to industry concerns raised regarding the “clarifications” to the physician supervision requirements issued in CMS’s CY 2009 OPPS Final Rule. The new physician supervision requirements for hospital outpatient therapeutic and diagnostic services include the following:
- CMS expanded the direct supervision of hospital outpatient therapeutic services to licensed clinical social workers, physician assistants, nurse practitioners, clinical nurse specialists, and certified nurse-midwives. These non-physician practitioners may directly supervise all hospital outpatient therapeutic services that they may perform themselves within their scope of practice under State law and hospital privileges, provided that they meet all additional requirements, including any other collaboration or supervision requirements. However, CMS did not extend the direct supervision by non-physician practitioners to pulmonary rehabilitation, cardiac rehabilitation, or intensive cardiac rehabilitation. Direct physician supervision for these services must be furnished by a doctor of medicine or osteopathy. CMS also did not extend direct supervision by non-physician practitioners to hospital outpatient diagnostic services – only physicians may directly supervise these services, when required.
- All hospital outpatient diagnostic services provided directly or under arrangement, whether provided in the main hospital buildings, in a provider-based department, or other nonhospital location, must follow the physician supervision requirements for the individual tests as listed in the Medicare Physician Fee Schedule (MPFS) Relative Value File.
- For services furnished on a hospital’s main campus (i.e., in the hospital or in an on-campus outpatient department), the supervising physician or non-physician practitioner may be located anywhere on the hospital campus, including a physician’s office or other nonhospital space, so long as he/she is on the same campus and immediately available to furnish assistance and direction throughout the procedure. This standard applies to all hospital outpatient therapeutic services, and to the subset of hospital outpatient diagnostic services requiring direct physician supervision as specified in the MPFS Relative Value File.
- For services furnished in off-campus provider based departments of hospitals, the physician or non-physician practitioner must be physically present in the off-campus provider-based department (versus the previous requirement to be “present and on the premises of the location”) and be immediately available to furnish assistance and direction throughout the procedure. Again, this standard applies to all hospital outpatient therapeutic services, and to the subset of hospital outpatient diagnostic services requiring direct physician supervision as specified in the MPFS Relative Value File.
The Final Rule also made “technical corrections” to the regulation concerning therapeutic services to clarify that the supervision (and other) requirements required for payment of outpatient therapeutic services applies to both hospitals and critical access hospitals (CAHs). CMS explained that the prior absence of specific reference to CAHs was simply a drafting oversight, but that it has always applied the requirements to CAHs.
The Final Rules offer increased flexibility to hospitals in meeting the physician supervision requirements for hospital outpatient therapeutic and diagnostic services, and are applicable to services furnished on or after January 1, 2010. A full copy of the CY 2010 OPPS Final Rule is available here. (For a PDF version, click here (this will take awhile to download).)
Critical Access Hospital Bed Limit Temporarily Waived for H1N1
November 1, 2009 By
This past week, President Obama and HHS Secretary Kathleen Sebelius officially declared a national state of emergency allowing Critical Access Hospitals (CAH) to exceed the daily limit of 25 occupied beds. This is not an indefinite waiver of the limit, and this exception does not apply where H1N1 patients are not a contributing factor to the bed capacity. The waiver is temporary and is only granted upon a submission from the CAH requesting the increase in bed limits.
The following information must be included with the request and sent to the regional CMS office:
- Name
- City and State
- Provider Number
- Hospital Main Contact Person and Contact Information – Phone number, etc
- Explanation/Reason for waiver request
- Number of beds over the limit and duration of beds occupied as a result of the reason for which you are filing the waiver
It is unclear how long CMS will allow this bed limit waiver. In addition, CMS will not issue the waiver prior to the point at which the CAH exceeds the bed count.
To read more about this waiver and other Section 1135 waivers please read the links below:
President Obama’s Declaration of a National Emergency
CMS Explanation of Section 1135 Waivers
Waiver issued by Secretary Sebelius
Further Explanation of Waiver from Flu.gov
