December 3, 2013
Implementing Electronic Medical Records (EMRs) is one of the broadest organizational tasks most IT shops will ever tackle. EMRs may be complex technology, but the real challenge is to implement clinical workflows that support the broad range of care activities that happen in a typical hospital. To be successful, the implementation must be well accepted by the nursing and medical staff, and must meet the CMS requirements for Meaningful Use / MIPS.
2014 is a critical year for healthcare providers participating in the Meaningful Use / MIPS program, with 3 key factors converging:
The combination of these three factors has caused many healthcare executives to sit up and take notice of the potential costs for not making Meaningful Use / MIPS certification this year. Unfortunately, many that I’ve spoken to are confused about which dates are critical for their organization.
Understanding Reporting Periods
To really understand how the deadlines stack up for Meaningful Use / MIPS, you have to understand reporting periods. The attestation process isn’t just a snapshot of a point in time, but a measurement of, dare I say it, Meaningful Use / MIPS, over a period of time.
For first time attesters, your Meaningful Use / MIPS attestation must cover a 90 day period, and it can be any 90 day period you choose.
For anyone attesting for the second (or third time if you’re an early adopter) the attestation period would normally be the whole year, but for 2014, CMS shortened that period to 90 days, with the restriction that it be a calendar quarter. That means that there are four possible reporting periods for the Medicare Meaningful Use / MIPS Program for 2014. This is dependent upon whether you are a provider (physicians) or a hospital.
Reporting periods for providers and hospitals:
|For Eligible Providers||For Eligible Hospitals|
|January 1, 2014 – March 31, 2014||October 1 2013 – December 31, 2013|
|April 1, 2014 – June 30, 2014||January 1 2014 – March 31, 2014|
|July 1, 2014 – September 30, 2014||April 1, 2014 – June 30, 2014|
|October 1, 2014 – December 31, 2014||July 1, 2014 – September 30, 2014|
Deadlines to avoid Medicare Penalties
If you attested to Meaningful Use / MIPS in 2013, your 2015 Medicare payments are safe. Your attestation in 2013 means you avoid the payment reduction in 2015. Future years will follow the same two year cycle, e.g. 2014 attestation protects you from reduction in 2016, and so forth.
If 2014 will be your first year of attestation, however, special rules apply. As indicated above, you are free to choose your reporting period in the first year. However, in order to complete your measurement period and attestation in time to avoid 2015 Medicare Payment reductions, you must follow these timeline requirements:
The guidelines for Meaningful Use / MIPS, the deadlines for participation, and the institutional effort required to meet them are all particularly complex. CMS has provided a number of excellent resources.
There are a number of companies out there with the experience to guide you through this process and Phoenix Health Systems is one of them.
Need assistance, or want to talk to an expert? Let us know. We’re happy to help!
If you’re looking for more information on Meaningful Use / MIPS, read our latest blog posts on the topic >>