In part 1, we discussed some of the nuances of registering for Meaningful Use (MU) reporting and why most practices would be better off waiting until 2012 – such as still being able to qualify for E-Prescribing incentives. In part 2, we give you an action plan for getting your practice ready for MU.
How is the MU Reporting Actually Done?
For 2011, practices could merely report they are using EHR in a Meaningful Use without actually sending anything to CMS – this is known as attestation. For 2012, attestation alone is insufficient. CMS will require practices to report on their meaningful use criteria, which for most practices will be a total of 20 (all 15 Core Set and 5 out of the 10 Menu Set items). Some items in the Core Set only need to have functionality enabled (such as Exchanging Critical Information) or performed at least once (Security Risk Analysis). Others will become a daily part of a practice’s workflow (such as Smoking Status or Demographics) and must meet a certain threshold (such as 50% of the number of unique patients seen for the year), unless they are not appropriate for a physician in a particular specialty. For example, an ophthalmology practice does not routinely check vital signs so would report a denominator of zero for that criterion. For a list of the Core and Menu Set objectives see EHR Incentive Programs
Many certified EHR systems will have a means to upload the report files to CMS, either directly or using report-generating software such as Crystal Reports, while other practices may use a third party solution such as registries, the same ones that were helping physicians report PQRI. But while Stage 1 may consist of simply requiring a practice to report on a specific criterion, Stage 2 may contain additional requirements and higher thresholds.
An example of this would be providing a Clinical Summary Report for a patient: In Stage 1, you can document the patient’s preferred format but do not necessarily need to supply it to them in that format, whereas in Stage 2, you might have to comply with that request. And this can make the reporting process that much more onerous.
Advice from a Practice Ready for MU
Sandra Regenye, Director of Billing for Horizon Eye Care in NJ, has these recommendations for getting a start on Meaningful Use:
- Make sure you are using a certified EHR (EMR) system (click here for a list of ONC-certified EMR systems).
- Make sure you have a solid understanding of the MU requirements.
- Do your homework. Don’t count on any one resource to base your plan on. Check your EMR vendor’s resources, CMS, or OMB, for example, for webinars, podcasts, and white papers.
- Go through all of the measures to see which ones apply specifically to your practice. For example, vital signs would not be an appropriate measurement for an ophthalmology practice, so the denominator for reporting purposes would be zero.
- Take a look at your workflow processes and see how they are potentially impacted by the collection of data for the requirements. An example would be the preferred language of the patient – when is it collected, by whom, where is the information stored, and is it a required field in your system (it should be).
- Then check your EMR templates to see where this information is entered and stored. It may not be where you need it, when you need it.
Getting Ready for the Reporting Process
For this year, the first year of Meaningful Use, practices are only required to attest to the fact that they are meeting the MU requirements. Attestation means you are collecting the data in some fashion, even if you are only doing it manually, as on a spreadsheet. For 2012, practices will need to actually collect and submit the data to CMS. The attestation process officially began on April 18, 2011. CMS offers webinars and updates with specific details. Ms. Regenye says these have not been real clear, “but they are getting better.” She recommends that all practices register with Medicare now, even if they don’t have an EMR system yet.