Wednesday, January 16, 2019

2015 Meaningful Use Exception Deadline: July 1, 2016

Because of a delay in the publication of regulations governing the Medicare meaningful use program, CMS is allowing eligible physicians and hospitals to apply for an exception under the “extreme and uncontrollable circumstances” category.

Physicians are urged to preemptively file for a 2015 hardship exception to avoid penalties in 2016.  Physicians are encouraged to apply even if they are uncertain whether they will meet the program requirements this year. Doing so will not preclude physicians from receiving an incentive if they do meet meaningful use requirements, but applying can serve as a safety net in staving off a penalty.

ACTION

Physicians who wish to apply for an exception under the “extreme and uncontrollable circumstances” category need to do the following:

  1. Go to the CMS website and download an application.
  2. Complete the application and check box 2.2.d in order to avoid a penalty under the meaningful use program.
  3. Submit the application.  The deadlines for submitting applications for hardship exceptions are:

For Eligible Physicians: July 1, 2016

 

BACKGROUND

New rules released in 2015 stated that eligible professionals must attest that they met the requirements for meaningful use stage 2 for a period of 90 consecutive days during calendar year 2015. However, the Centers for Medicare and Medicaid Services (CMS) did not publish the updated regulations for stage 2 meaningful use until October 16, 2015. As a result, eligible professionals were not informed of the revised program requirements until fewer than the 90 required days remained in the calendar year.

FOR MORE INFORMATION

 

For more information on the electronic health record (EHR) incentive program, see the CMS tipsheet, "EHR Incentive Programs for Eligible Professionals: What You Need to Know for 2015."

 



Meaningful Use Relief

Additional relief for eligible providers participating in the meaningful use program has arrived in two forms – expanded payment adjustment exemptions and extended assistance.

Expanded Exemptions – Providers who are eligible for the Medicare EHR Incentive Program and have been unable to successfully demonstrate meaningful use for either the 2013 or 2014 reporting year due to circumstances beyond their control may apply for a hardship exemption. The deadline to apply is July 1, 2014. An organization whose hardship application is approved would be exempt from payment adjustments which take effect in 2015. CMS is currently accepting applications from both new and returning program participants whose circumstance meets one of the following hardship exemptions:

1.       Lack of infrastructure

2.       New Eligible Professionals

3.       Unforeseen and/or uncontrollable circumstances

4.       Lack of face-to-face interaction

5.       Lack of control over availability of EHR certified technology

6.       2014 EHR Vendor Issues

Visit the CMS Payment Adjustment and Hardship Exemption webpage for downloadable tip sheets that detail the qualifications of each hardship exemption. The webpage also includes a link to the application and further instructions.

Extended Assistance – Eligible professionals may still seek subsidized assistance from CalHIPSO to meet meaningful use in 2014. CalHIPSO is the federally funded regional extension center serving clinicians in all California counties except Orange and LA. CalHIPSO is continuing to provide technical services through December 31, 2014 to both current and new members. However, there is limited availability for new enrollments. Contact CalHIPSO for more information at 510.302.3364 or email organization name, contact info, zip code and NPIs to info@calhipso.org.

Riverside County Public Health Ready For Meaningful Use Stage 2

Download Letter

Dear Health Care Provider:

The County of Riverside Department of Public Health (DOPH) is committed to the improvement of our health information systems and to ensuring our local providers and medical facilities attain meaningful use certification as defined by the Health Information Technology for Economic and Clinical Health (HITECH) Act. As part of this process, this letter is to inform you that DOPH is declaring readiness for Meaningful Use Stage 2 (hereafter MUS2). Incentive payments you may receive or will receive under meaningful use may be affected if you or your facility is not able to meet the requirements for MUS2, including the public health integration objectives. In addition, your Medicare payments may be adversely adjusted in 2015 if you are not a meaningful user of electronic health record (EHR) technology, which include MUS2 requirements.

DOPH has partnered with the Inland Empire Health Information Exchange (IEHIE) to facilitate health care facilities’ compliance with the public health integration requirements of MUS2. DOPH believes that IEHIE is a vital part of improving coordinated care in the Inland Empire and encourages all health care facilities to join. The use of the IEHIE is not required to attain MUS2 requirements, but is strongly encouraged, and may greatly reduce the implementation cost and effort required for your facility to be compliant with MUS2. For more information on joining the IEHIE, please visit www.iehie.org

MUS2 has five public health objectives, three of which in the County of Riverside rest with DOPH. Eligible professionals (EPs) must meet the core public health objective of immunization reporting, and must meet three of six “menu set” requirements, two of which are public health objectives. Critical access hospitals (CAHs) must meet three core public health objectives, namely immunization reporting, reportable lab results/electronic lab reporting, and syndromic surveillance. Even if the IEHIE transmits this information on your behalf, you alone are responsible for ensuring the objectives are met. Please note that if your facility covers or operates in multiple jurisdictions, you may be responsible for different implementation requirements in jurisdictions outside of the County of Riverside. The five objectives are implemented for the County of Riverside as follows:

1.  Electronic immunization reporting is to be done to the California Immunization Registry (CAIR), Region 8. Your facility or medical office is responsible for the registration and onboarding process with CAIR if you are not already registered. You may submit this information yourself from your own EHR system; contact the CAIR Gateway for technical requirements. DOPH cannot offer technical support for implementation. If you are a “live” member of the IEHIE, this information is submitted to CAIR for you; self-registration is still required. Registration for all submitters, including IEHIE members, is through the CDPH Health Information Exchange Portal. 

This objective is a Stage 2 core requirement for both EPs and CAHs. For more information, visit http://cairweb.org/cair-regions/ 

2.  Electronic laboratory reporting of reportable results is to be done to the California Reportable Disease Information Exchange (CalREDIE-ELR). Your facility is responsible for the registration and onboarding process with CalREDIE-ELR if you are not already registered. You may submit this information yourself from your own ELR system; contact CalREDIE for technical requirements. This process is distinct from the CalREDIE Provider Portal. Enrollment for the Provider Portal is a separate process, does not meet this meaningful use requirement, and must go through DOPH. DOPH cannot offer technical support for implementation. If you are a “live” member of the IEHIE, this information is submitted to CalREDIE for you; self-registration is still required. Registration for all submitters, including IEHIE members, is through the CDPH Health Information Exchange Portal.

Please note that this requirement is specific to electronic laboratory reporting of reportable results under title 17 §2505 et seq. if your health care facility or medical office is not participating in reporting title 17 reportable conditions through the calredie provider portal, reporting must still occur via confidential morbidity report. the calredie provider portal and reporting of title 17 conditions is distinct from calredie-elr. also, under all circumstances, doph still must receive telephone notification on conditions designated as “report immediately by telephone.

This objective is a Stage 2 core requirement for CAHs only. For more information, visit http://www.cdph.ca.gov/data/information/tech/Pages/CALREDIE.aspx

 3.  Syndromic surveillance reporting is to be done to CDC BioSense. You must first register an operational relationship with our BioSense Data Steward, Rick Lopez (rilopez@rivcocha.org), to ensure that data you transmit is available to DOPH for review. Only emergency departments may apply at this time; non-EDs and provider offices must select another menu set option (see https://questions.cms.gov/faq.php?faqId=2903). Non-EDs cannot onboard with BioSense currently, but this may change in the future. This statement is not a waiver from this requirement.

Once you have established an operational relationship with DOPH, you may then transmit data to BioSense from your own EHR. Unlike other Meaningful Use information, this data is de-identified. Although DOPH will assist you with constructing this relationship, it cannot offer technical support for actual implementation. If you are a “live” member of the IEHIE, this information is submitted to BioSense for you; self-registration is still required. Certain aspects of county syndromic surveillance will still be maintained in the ReddiNet system, but use of ReddiNet by itself does not meet MUS2 objectives. Registration for this objective is not through the CDPH HIE Portal. All submitters, including IEHIE members, must register with the DOPH Data Steward directly.

This objective is a Stage 2 core requirement for CAHs. For more information, visit http://www.cdc.gov/biosense/ and http://biosenseredesign.org/

4.  Cancer reporting is not operated by DOPH. The California Cancer Registry (CCR) is operated by the California Department of Public Health (CDPH), not by the County of Riverside Department of Public Health. If you select this menu set option, you must specifically contact CCR. DOPH does not monitor CCR’s readiness status and cannot offer technical support for implementation; it is expected that CCR will be ready to receive electronic reporting by January 1st, 2014. As of this letter, there is currently no interface between the IEHIE and the CCR. Regardless of whether you select this option, you are still mandated to report certain cancer diagnoses to the CCR in general. This objective is a Stage 2 menu set option for EPs only. For more information, visit http://www.ccrcal.org 

5.  DOPH does not currently operate specialized disease registries. This may change in the future. DOPH will provide advance notification of any specialized disease registry we plan to operate and how to integrate with them. This does not change any existing reporting requirements to other state or federal disease registries which may still apply. This objective is a Stage 2 menu set option for EPs only. 

Although DOPH does not offer technical support for implementation, we do wish to ensure that all providers and facilities in the county are able to comply. We are working with both the IEHIE and the Riverside County Medical Association (RCMA) to make this possible. The Department is available for questions regarding public health meaningful use requirements and I may be reached by telephone personally at (951) 358-7036 or by E-mail at ckaiser@rivcocha.org

I look forward to our cooperatively improving the health of all county residents through the superior technical interaction and care coordination meaningful use will make possible. 

 Sincerely, 

Cameron Kaiser, M.D.
Public Health Officer



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