To qualify for the EHR incentive payments, you must report on the various requirements for a set period of time. Under the regulation, physicians must report on the metrics for 90 consecutive calendar days during the first year of participation. This is to allow physicians the opportunity to adjust to the new program. The assumption is that once you begin collecting the information and using the EHR, you will continue to do so. Thus, if you begin participating in January, the assumption is that the program will permanently change your workflow and you will incorporate these requirements into your everyday practice. The 90 days must be contained within the same calendar year. After the physician’s first year of participation, the reporting period increases to the full calendar year with one exception. For 2014, individuals in their first year of Stage 2 or second year of Stage 1 were able to attest using a reporting period of one continuous calendar quarter. Physician organizations, including the ACC, expressed concern to CMS about the requirement for a full year of reporting in 2015 for individuals implementing Stage 2 because of difficulties physicians and hospitals have experienced upgrading to 2014 Edition certified EHRs. The College and others urged CMS and ONC to reduce the reporting period to one calendar quarter instead. On April 10, 2015, CMS released a proposed rule to modify Stage 2 of the EHR Incentive Program by shortening the 2015 reporting period from a full year to 90 days. According to CMS, “the proposed rules align and merge the ‘stages’ of meaningful use requirements by streamlining reporting by removing redundant, duplicative, and topped-out measures; modifying patient action measures in Stage 2 objectives related to patient engagement; and aligning the EHR reporting period for eligible hospitals and critical access hospitals with the full calendar year.”
Physicians participating in the EHR Incentive Program in 2011 or 2012 reported successful fulfillment of program requirements through a web portal and attested to meeting all of the requirements. This will continue to be the case for the core and menu criteria. Going forward, those in their first year of Stage 1, regardless of the year in which you begin participating, will report CQMs through attestation. After that, participants will have the option of continuing to use the attestation system to report CQMs or through the PQRS portal. These reporting mechanisms are described in more detail here.
As mentioned earlier, CMS requires physicians to report successful completion of program requirements through attestation. For more information about attesting for the EHR Incentive Program, CMS has prepared a helpful User Guide to Attestation for Eligible Professionals. Additional information on attestation for Medicaid and other provider types can be obtained from the CMS website.
CMS is required to publicly post online the names of meaningful users of EHRs on an annual basis. Information is posted at the individual physician level and includes the individual’s name, business address and business phone number. It can also be found on the CMS website.