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Stage 2 and ICD 10: A challenge to juggle
e-Reports, April 7, 2014
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If you’re trying to figure out how to pay for technology costs for achieving Stage 2 meaningful use of electronic health records (EHRs) while paying for the transition to ICD-10 – you’re not alone. Practices here and nationwide are feeling the financial pinch; some are even juggling the added demands of Medicare’s Physician Quality Reporting System (PQRS).

“I have been busy getting ready for ICD-10,” said one ISMA member and family medicine physician from Mishawaka.

“ICD-10 preparations were expensive, requiring a new server; the price for the server and migration were well in the thousands. Meaningful use Stage 2 has not been a priority.”

The physician indicated he may start working toward Stage 2 in the coming months, but he’s not motivated by the bonus. “When the bonuses were bigger it was easier to justify the work,” he commented, questioning whether the cost-benefit ratio was worth the effort for his solo practice.

Larger practices more able to spread the expense may make a different business decision.

Vendor issues keeping you from Stage 2?
If you’re unable to make progress on achieving Stage 2 meaningful use of your electronic health record (EHR) because your vendor couldn’t obtain 2014 certification, you can now declare a hardship.

Hearing from health care professionals with similar vendor roadblocks, the Centers for Medicare & Medicaid Services (CMS) issued new guidance March 11.

CMS provided a list of qualifying hardship exceptions for participants in the meaningful use program. You can apply for an exemption if you are experiencing:
  • Lack of Infrastructure
  • Unforeseen and/or uncontrollable circumstances
  • Lack of control over availability of certified EHR technology
  • Lack of face-to-face interaction
  • 2014 EHR vendor issues

You have until July 1 to apply and the exemption, if granted, will be valid for one payment year. If you are denied, no appeals process exists.

Learn more and apply here.


For Medicaid Stage 2
Indiana begins accepting program year 2014 meaningful use attestations for eligible professionals on April 17. All meaningful use Indiana Health Coverage Programs providers have a 90-day reporting period within the calendar year for program year 2014.

Taking up the challenge
Premier Healthcare in Bloomington, with more than 80 physicians, has an EHR that’s been operational since June 2007. They see meaningful use and ICD-10 as benefiting the practice as well as its patients – despite a loss of productivity.

Premier is handling all Stage 2 training in-house but is using outside consultants for training for the ICD-10 conversion. A core group of staff, both clinical and clerical, have been meeting regularly since the meaningful use final rules were published.

EMR Compliance Manager Keetah Clouse discussed lessons learned from their Stage 1 meaningful use attestation. “Monitor, monitor, monitor!!!” she said. “Our EMR has the capability to produce reports from the dashboard. We did this monthly and were in constant contact with our providers and staff. It was much easier for them to address their deficits as they occurred instead of at the end of the year.”

Two significant challenges presented quickly this time for Stage 2. Clouse noted those were: “knowing exactly what our Stage 2 certified software needed in order to ‘check the box’ and meet the measure criteria, and making workflow changes for staff and providers to accommodate the measures.”


Thinking of skipping meaningful use in 2014? Here are some considerations
Allison Bryan, managing advisor, Special Projects with Purdue Healthcare Advisors, calls this a ”very resource-intensive period” for physicians. The Purdue organization assists physician practices with achieving meaningful use and offers other key services.

Bryan noted many practices report being overwhelmed this year with Stage 2 meaningful use, the ICD-10 transition and PQRS.

While skipping 2014 is a business decision each practice needs to make, Bryan suggested factors to consider for an educated decision:

You may be penalized. Medicaid providers can skip 2014 without a penalty. However, if a Medicaid provider also maintains a Medicare panel, a penalty will be assessed on Medicare reimbursements for not achieving meaningful use in 2014. Medicare providers who skip attestation this year will be penalized 1 percent of all Medicare allowable charges in 2016.

You forfeit some incentive money. Depending on how long you’ve been in the EHR incentive program, you will forfeit either $4,000 (2011 starters) or $8,000 (2012 starters). Not attesting in 2014 leaves money on the table that is no longer available. The next incentive payment in line ($2,000/$4,000 respectively) would actually be your next payment.

You literally skip a year. In 2014 all providers are required to attest to only a 90-day window. If you don’t attest in 2014, you are responsible for meeting all Stage 2 measures for the full 2015 calendar year – no 90-day grace period. If you skip this year, also be certain to have all components of your 2014-certified EHR fully installed and functioning by Jan. 1, 2015.

To discuss timing or the impact on your practice, call Bryan at the Purdue Regional Extension Center, (765) 496-9791 or visit here.

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