3 Tips to Achieving Meaningful Use and Avoid the Appeals ProcessJanuary 26, 2012
The Centers for Medicare and Medicaid (CMS) began accepting appeals for EHR Incentive Program payments from eligible professionals and eligible hospitals on December 1, 2011.
A startling statistic referenced in the article link is that of the 33,595 Medicare physicians that had attested to meeting Meaningful Use requirements, 355 were unsuccessful. At Environmental Intelligence, we believe that is 355 physicians too many that may have to go through the appeals process in order to receive or keep their incentive payment.
Here are three tips to avoid the appeals process and to achieve Meaningful Use:
#1 – The first tip for eligible providers to avoid the appeals process is to develop an end-to-end comprehensive EHR implementation plan. An effective EHR implementation plan needs to include every aspect of the project from initial EHR vendor selection to post adjustment activities. Within the plan itself, there must be absolute clarity as to who will be responsible for monitoring every milestone of the plan including Meaningful Use objectives and measures post go-live. Successful EHR implementations follow a basic fundamental rule: Plan Your Work then Work Your Plan.
#2 – The next tip is being in the know. The CMS EHR Incentive Program appeals process allows providers to appeal based on eligibility, Meaningful Use, and incentive payment calculation. After attestation, if an eligible provider is denied incentive payment because of eligibility or incentive payment calculation, the reality is either the provider was poorly consulted or the designated person or persons in the practice responsible for the project was not well informed of the incentive program and its requirements. There are many places to go on the web to obtain the information needed to successfully accomplish all of the CMS EHR Incentive Program requirements including how to achieve Meaningful Use. The best place to find constant up-to-date complete information on the CMS EHR Incentive Program is located on the CMS Attestation page of their website.
If an eligible provider is denied incentive payment because of not meeting all Meaningful Use required objectives and associated measures (Currently Stage 1), the root cause will most likely be an internal breakdown of not effectively executing the process of tracking and measuring results and progress. The way to avoid this situation is for the practice to build out a routine (should be part of the EHR implementation planning process) to pull and analyze Meaningful Use data in order to stay on track and provide feedback to clinicians on a consistent basis. CMS offers The Meaningful Use Attestation Calculator which allows a practice to monitor their progress to successfully achieve Meaningful Use. This calculator requires the practice or provider to compile and input data from their EHR into the tool. On the other hand, many EHR’s provide Meaningful Use reporting functionality. The frequency Meaningful Use reporting is available to providers range from daily, weekly, or monthly depending on the EHR platform. It is important for providers to choose the reporting frequency and routines that will work best for them.
#3 – Providers and medical practices need to determine whether they will manage the complete EHR implementation process internally or look to outsource the project to an outside firm. Many providers and practices hire an outside consultant to help with EHR vendor selection and the development of the implementation plan. This approach requires either a member of the staff or a provider or both will be responsible for managing and executing the EHR implementation plan. It is important to consider workflows, staffing, and capacity when taking this approach in implementing an EHR. There are Health IT firms, like Environmental Intelligence, that provide EHR technical and implementation consulting along with EHR installation and deployment, and will work side-by-side the designated person in the practice, post go-live, to insure all goals and objectives are being met including Meaningful Use.
There many factors providers and practices have to consider when deciding which direction to take when implementing or upgrading an EHR platform. The end goal for providers and practices is to successfully implement an EHR, successfully attest to Meaningful Use, and improve patient’s overall health and outcomes.
For a great recap and background of the CMS EHR Incentive Program appeals process see: CMS fills out details for EHR incentive appeals