One of the most intriguing aspects of the entire CMS EHR Incentive program has been the meaningful use requirement to calculate and submit clinical quality measures. The Final Rule let us know that “For 2011, an EP would provide the aggregate level data for the numerator, denominator, and exclusions through attestation as discussed in section II.A.3 of this final rule. For 2012, an EP would electronically submit the measures that are discussed in section II.A.3. of this final rule.”
This was true for Eligible Professionals and Eligible Hospitals. So for 2011 EPs and EHs could just attest the quality measures and report them on the CMS web-based attestation forms. No one was quite sure what was going to happen in 2012. The Stage 1 certified EHR vendors had no easy way to transmit these files electronically in 2012 and there was a nagging sense that this could be very complex to pull off in 2012.
CMS is now proposing rules for both EPs and EHs that will allow attesting of quality measures to continue in 2012. Two separate rules will be proposed the week of July 18th to alleviate the 2012 electronic submission requirement. Another good move by the Powers That Be.
Jim Tate is known as the most experienced authority on the CMS Meaningful Use (MU) audit and appeal process. As one hospital CEO stated, “we were notified by CMS that the adverse audit decision was being overturned and we did not have to return the 2011 EHR Incentive Payment. I would recommend the services of Mr. Tate and EMR Advocate in the event your facility is notified that it will be subject to a Meaningful Use audit or your facility is audited, or you have an adverse outcome and need to file an appeal." He blogs at Meaningful Use Audits. If you are a hospital with a question about the MU audit and appeal process, email him at: [email protected]
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