WASHINGTON – Feeling confused about how to attest to meaningful use or how to claim a hardship exemption in 2014?
You’re not alone. Federal officials say they’ve gotten lots of questions and comments in the wake of allowing flexibility on the version of certified electronic health record that can be used and on hardship exemptions for a subset of meaningful users.
Elizabeth Myers, Policy and Outreach Lead for the Centers for Medicare & Medicaid Services’ Office of E-Health Standards and Services, tried to provide some clarity to what those rules mean for practicing physicians at the annual symposium of the American Medical Informatics Association.
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Meaningful use and hardship rules were 'pretty vague,' said Ms. Myers.
On the first rule on certified EHRs, “all we did is delay the expiration of 2011 edition software,” Ms. Myers said.
Physicians who have used the 2011 edition all year will be attesting to the 2013 definition of meaningful use, using those specific objectives and clinical quality measures. Those using the 2014 edition will be attesting to the 2014 definition.
The rule was “pretty vague” on what was expected for those using a combination of the 2011 and 2014 editions, Ms. Myers said. “That’s not trying to be confusing or difficult, much as it may seem that way sometimes,” she said. “It’s really on purpose, because we recognize it will be different for every provider.”
The first step for any meaningful user seeking to attest is to visit the Office of the National Coordinator’s Certified Health IT Product website. Once there, enter in all the product names used. The system will determine whether you are using the 2011 or 2014 version, or a combination.
Users of the 2011 version are taken directly to the 2013 definitions and measures, and can follow through on attestation. Those using the 2014 version are taken to the 2014 definitions and measures for attestation.
Combination users are given a unique identifier. Once that’s entered, the system asks whether the user wants to use the 2013 or 2014 measures for attestation. The meaningful user is then walked through one of those two paths, Ms. Myers said.
Hospitals have until Nov. 30 to attest. Physicians and other eligible health care providers can start attesting now. They have the option of attesting all the way through end of February, Ms. Myers said.
She also sought to clear up confusion about the hardship exemptions. For first-time participants in 2014, applying for a hardship this year was necessary to avoid a penalty in 2015.
“The reopened, extended period for hardship applications ... is for those new participants who are still struggling to get their 2014 software in place,” Ms. Myers said. “If you are unable to fully implement 2014 edition software in 2014 and you have participated in the program in the past, your application for your hardship is due in 2015 to avoid the 2016 payment adjustment.”
Those hardship applications are due April 1 for hospitals and July 1 for eligible professionals, Ms. Myers said.
In terms of what can be claimed as a hardship, the reason has to be related to the functioning of the software – not that “I didn’t feel like paying for it,” or “I was on vacation,” she said. It has to be that you were unable to implement the software to fully meet meaningful use.
Be ready to document the request, but certified letters from vendors saying it was their fault aren’t necessary. “You need the documentation that demonstrates your circumstances,” she said. That means being able to show the certified software used, your approach for meeting objectives and measures, and how the system may have failed you.
“Keep those records,” Ms. Myers said.
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