I’m helping an ophthalmologist in the United States set up OpenEMR for a new, small, part-time practice. From what I understand, at this point, compliance with Meaningful Use Stage I could be considered mandatory. Could anyone provide insight on any upcoming dates for compliance with Stage II? I’m new to this and I can’t find any hard data on deadlines, or even whether ophthalmologists have any exceptions to the rules.
Maybe I’m thinking about this wrong. Can a practice be in compliance with Stage II even if their management/EMR systems aren’t officially certified for Stage II?
If the Ophthalmologist is beyond his first year of practice, if he qualifies for a hardship exception & the application is submitted by July 1st; he can avoid the penalty reduction in 2016.
Bear in mind that the penalty is in addition to the 2% sequester, across-the-board, reduction in Medicare reimbursement.
MU had been a carrot & stick program. In 2015 it became only stick.
Compliance with MU happens only through attestation, not merely by the fact that the EHR has been certified. OpenEMR has not achieved full certification for MU2. Version 4.2.0 (2) cannot be used for MU2 attestation.
First, thank you for your invaluable assistance. It’s a lot to digest, and I’ll start with this: Does this mean any U.S. physician presently using OpenEMR must accept penalties because their practice can’t attest to MU2?
Physicians & developers, alike, are confused periodically by this MU stuff.
No, if OpenEMR is fully certified & all bugs are fixed by Sept. 30, 2015; the user can attest to MU2, thus avoiding the 1% penalty. The user must have attested to MU1 beforehand.
Aside from the exceptions, a practice can avoid the penalty by not participating in Medicare; not very practical in a new Ophthalmic practice, where many of the patients are elderly.
Sequestration is the result of Congress’ inability to get its act together. Instead of going through the budget & deciding what to cut in an effort to reduce the national debt of $18.628 trillion, we ended up with the sequester.
This ophthalmologist should be granted an exception because he will be starting a practice for the first time. But, for the sake of discussion, let’s assume this exception didn’t exist. I just want to be certain I have properly understood some of the points above.
If a practice installs OpenEMR and attests to MU1, they will not currently face any penalty. Then, if OpenEMR does not obtain MU2 certification by Sept. 30, 2015, and therefore the practice cannot attest to MU2, that practice will face a 1% penalty in 2016.
CMS is constantly changing the rules, so any answer will depend on what they will change next. Only when an attester gets inside of the website, does he have any degree of certainty. If CMS does not inform the webmaster of the changes, all bets are off.
The way things are today, if the Ophthalmologist (with none of the exceptions in the link above) attests to MU1 for any 90 day period in 2015 (say June 1st to August 30th), he should be penalty-free for 2016. I’ll be happy to walk you folks through the MU1 attestation.
I don’t think CMS will allow him to attest to MU2 for a 90 day period in 2015. Attestation is done once per year.
If OpenEMR is not fully certified & bug-free by December 31, 2015, the Eye Guy cannot attest to MU2 for the entire year of 2016. Generally the reporting period for the second attestation year is one full calendar year.
CMS has been changing the reporting period between any 90 days, one quarter & one calendar over the past 2 years.
It’s less messy to use 4.1.2’s AMC, Standard Measures, & Clinical Quality Measures Reports that will be needed for MU1 attestation. It has worked well for forum members who attested in the past. I’ve seen no post of anyone attesting to MU1 with 4.2.0.
Permit me to make a few suggestions to the Eye M.D.
Since MU1 will not become an issue until the first part of 2016, ask him to concentrate on getting to know OpenEMR via the Users Guide & DIY guide. OpenEMR is excellent even if MU is not.
He’s already poked around the wiki quite a bit. Today he will setup OpenEMR on his Windows system to tinker around with. Fortunately, he’s quite capable technically, but a lot of this can still be quite daunting, especially given the other stresses of opening a new practice. I want to be comfortable myself with the basics and installation/administration process and then I’m certain he’ll be here asking questions as he explores OpenERM further.
For some reason I thought only 4.2.0 was MU1-certified, but I can’t remember how I arrived at that assumption.
I couldn’t find updates patches for 4.1.2 to address security issues like those patched in 4.2.0 (2). Are these unofficially available? The installation will be private, so it’s not that big a deal I guess.
So would you recommend upgrading to 4.2.0 after MU1 attestation?
Patch 7 is the last & only one needed for 4.1.2. I did not look at security issues addressed in the second patch for 4.2.0, so can’t comment. My production copy is used offline.
Hopefully when you are done with MU1, there will be 4.3.0, which should be MU2 fully certified.
4.2.0 has some nice features like a Day Sheet & very soon, Dunning Messages. Highlights.
This is another example of CMS’ constant changes & the reason why the answer about a MU question depends on the date.
For all of 2013 & for much of 2014; 2013 MU1 Core Measure 11 & 2014 MU1 Core Measure 11 were one & the same, namely:
Implement one clinical decision rule relevant to specialty or high clinical priority along with the ability to track compliance with that rule.
while Menu Measure 5 for both years:
Provide patients with timely electronic access to their health information (including lab results, problem list, medication lists, all allergies) within 4 business days of the information being available to the EP.
Your revised list of 2014 MU1 Core & Menu Measures probably did not replace our older list in the CMS website & definitely not in the attestation website until the end of 2014.
5/20/15 Edit
The Attestation User Guides on this page helped with the chronology.
Prior to May 2014 this measure requiring a portal was not a Core Measure, but one of 10 Menu Measures. An attester, who had not enabled Patient Portal, had the choice of selecting 5 other Menu Measures & avoiding this one.
Your second link, under “Additional Information” does make a point that the new Core Measure 11 replaced the old Menu Measure 5 & changing the exclusion as well.
So glad that I’m in the autumnal years.
Will do my best to help the beleaguered young folks.
When attestation time comes around; print everything, preferably with timestamps, including tables of contents, explanations, worksheets & most importantly, every page of the attestation itself.
So there’s no way a physician can use the older requirements, right?
The portal requirement adds an extra burden. The HIPAA/BAA requirements will take some time to parse through. Fortunately, it looks like ZH Healthcare provides a free portal option, but I’d like to understand what’s involved before using even a free service. I like the concept: Have your own offline production server and have just the online portal hosted somewhere it can be managed (security updates/etc) by a third-party.
Unfortunately, the practice where my brother (the ophthalmologist) currently works used his NPI number when requesting an exemption for this year. We are asking from a few sources, but so far a reply from the AMA indicates he will not get an exemption for 2016, even though he will be starting a new practice for the first time. We have been unofficially advised to submit a hardship exemption application anyway and see what happens. At the moment, however, we plan to start the 90-day MU1 “documentation process” this year.
Is it fair to say 4.1.2 is as “portal-ready” as 4.2.0?
Also, is it likely upgrading from 4.1.2 to 4.3.0 will require upgrading to 4.2.0 first?
It’s between Practice Fusion and OpenEMR right now. I think it’s a no brainer, obviously, but Practice Fusion is attractive at first because it’s prettier and so simple to get started.