Feb. 17, 2016
Meaningful Use (MU) is not going away. If you want to continue providing medical care to your patients, then you must be at the highest stage of MU. To not be there puts your practice at risk.
There is good news this month. CMS made a mistake. Every now and then the government makes a mistake. (OK, you can stop laughing now. Sit down, wipe the tears from your eyes and continue reading). CMS made a mistake last year and created a solution which is actually helpful. Doctors need to take advantage of the solution and get their application in to CMS before the deadline of 11:59 p.m. EST, March 15, 2016.
What happened and what is the solution?
The Stage 2 Meaningful Use Program Final Rule was posted by the Centers for Medicare and Medicaid Services (CMS) in October 2015. Since there were fewer than 90 days left in the year when CMS posted the rule, doctors did not have enough time to meet the Meaningful Use requirements for the year. Realizing its mistake, CMS reported at the beginning of February 2016, that doctors could claim a hardship exception for “extreme and uncontrollable circumstances” because of this problem caused by CMS in order to avoid the 2017 Medicare payment reduction penalty.
AOA is encouraging its “… members to apply for this hardship exception if they suspect they might not meet the Meaningful Use requirements, regardless of whether they attest for 2015 Meaningful Use … [doctors] can apply for the “extreme and uncontrollable circumstances” hardship exception by selecting section 2.2d when completing the 2017 Medicare EHR Incentive Program Payment Adjustment Hardship Exception Application.”
Since CMS decided not to review applications on a case-by-case basis, doctors are not required to submit documentation for the hardship category. That makes the application submission easier, however, doctors do need to create and retain documentation of why they could not meet the Meaningful Use requirements by the end of 2015, as a result of the late posting of the Stage 2 Meaningful Use Program Final Rule. CMS is not going to ask for this documentation unless there is an audit. But if there is an audit, the documentation needs to be in your files.
Your Action Plan this week has three parts:
1) Create a word processing document that explains that because CMS posted the MU rule so late in 2015, you were unable to meet the MU requirements and you needed to apply for the hardship exception. Save this document in a Meaningful Use folder in your computer in case you would ever need it in an audit.
2) File the hardship application this week so you don’t miss the 11:59 p.m. EST, March 15, 2016 deadline.
3) Review your plan to get up to speed with MU this year as soon as possible.
To read more about this subject:
2017 Medicare EHR Incentive Program Payment Adjustment Hardship Exception Application
AOA: Not Meeting, Attesting to MU? Hardship Exceptions Available