In a provider call on Aug. 25, CMS reminded providers of their reporting responsibilities in the final year of meaningful use – including a short reporting window for first-time attesters.
The program for the final year of the EHR Incentive Program was laid out in a final rule posted last October. As previously reported at Part B News (subscription), 2016 is the last year in which Medicare providers will be subject to the program -- MIPS takes its place, and that of other quality-reporting measures, in 2017. (The Medicaid version of the program continues through 2021.)
Timing for the final year of attestation for all Medicare EPs (eligible providers) was clarified in the Outpatient Prospective Payment System (OPPS) proposed rule released in July (subscription). At the time, CMS proposed that the EHR reporting period for all EPs would be any continuous 90-day period between Jan. 1 and Dec. 31, 2016.
However, CMS spokespeople told listeners at the call that while providers attesting for the first time will be expected to attest to any 90-day period during the year, these providers must do their attesting between July 4 and Oct. 1 -- meaning their 90-day period must be finished by Oct. 1.
Returning attesters must attest between Jan. 3 and Feb 28, 2017. They are at this point officially expected to attest for the entire 2016 calendar year, though this is expected to be reduced to 90 days in the OPPS final rule.
When asked what to do with a new doctor who had just joined a practice, CMS said if the doctor is new to medicine and won’t get 90 days of practice in before Oct. 1, he would be automatically excluded from the payment adjustment. But if they were doing meaningful use before, they would need to demonstrate modified stage 2 meaningful use in some 90-day period in 2016 before Oct. 1.
“If they had practiced before, the onus is on each of them to attest for their reporting period,” one of the spokespeople said. “It’s based on NPI [national provider number], not TIN [taxpayer identification number] or group. If they’re joining [your practice] in September and were eligible before and need to attest, I would recommend they make sure their meaningful use information is collected at the beginning of the reporting period so they can attest appropriately.”