Attestation

Am I able to count an exclusion as a menu item?
  • MU-EH-Stage 1-Attestation
  • MU-EP-Stage 1-Attestation

Beginning in 2014, EHs and CAHs will no longer be permitted to count an exclusion toward the minimum of five menu objectives on which they must report if there are other menu objectives which they can select.

Do I need to have to have an installed EHR system in order to register for the Medicare and Medicaid EHR Incentive Programs?
  • MU-EH-Stage 1-Attestation
  • MU-EP-Stage 1-Attestation

No, you do not need to have a certified EHR in order to register for the Medicare and Medicaid EHR Incentive Programs.

Is there a website I can go to see if my facility will meet the objectives required for Stage 1?
  • MU-EH-Stage 1-Attestation
  • MU-EP-Stage 1-Attestation

Yes, this online tool assists providers and hospitals to test whether or not they would successfully demonstrate Meaningful Use for the EHR Incentive Programs.

How long after I attest should my Medicare incentive payment arrive?
  • MU-EH-Stage 1-Attestation
  • MU-EH-Stage 2-Attestation
  • MU-EP-Stage 1-Attestation
  • MU-EP-Stage 2-Attestation

Your facility will need to contact CMS for payment information.

If our hospital “aims” to meet Meaningful Use in one quarter, but we don’t succeed, can our facility attest in a different quarter?
  • MU-EH-Stage 1-Attestation
  • MU-EH-Stage 2-Attestation

Yes, attestation does not occur on the CMS website until your attestation period has been completed. Therefore, if you do not meet your numbers in one quarter, you can defer to another quarter. However, if you are to meet Meaningful Use in Federal Fiscal Year (FFY) 2014, this must be accomplished the last quarter of the Federal Fiscal Year: July 1 - Sept. 30, 2014.

What patient types are to be included for Meaningful Use?
  • MU-EH-Stage 1-Objectives
  • MU-EH-Stage 1-Attestation
  • MU-EH-Stage 2-Objectives
  • MU-EH-Stage 2-Attestation

There are two methods for calculating ED admissions for the denominators for measures associated with Stage 1 and Stage 2 of Meaningful Use objectives. EHs and CAHs must select one of the methods below for calculating ED admissions to be applied consistently to all denominators for the measures. That is, EHs and CAHs must choose either the “Observation Services method” or the “All ED Visits method” to be used with all measures.

Observation Services method: The patient is admitted to the inpatient setting (place of service (POS) 21) through the ED. The patient initially presented to the ED and is treated in the ED’s observation unit or otherwise receives observation services. Details on observation services can be found in the Medicare Benefit Policy Manual, Chapter 6, Section 20.6. Patients who receive observation services under both POS 22 and POS 23 should be included in the denominator.

All ED Visits method: An alternate method for computing admissions to the ED is to include all ED visits (POS 23 only) in the denominator for all measures requiring inclusion of ED admissions. All actions taken in the inpatient or emergency departments (POS 21 and 23) of the hospital would count for purposes of determining meaningful use.

Is there somewhere I can review documentation on how my Medicare Incentive Payment will be calculated?
  • MU-EH-Stage 1-Attestation
  • MU-EH-Stage 2-Attestation
  • MU-EP-Stage 1-Attestation
  • MU-EP-Stage 2-Attestation

Yes, CMS created tip sheets for EPsEHs and CAHs to assist with explaining Medicare reimbursement.

Are nursery days and discharges (for newborns) to be included as acute-inpatients in the calculation of hospital statistics?
  • MU-EH-Stage 1-Attestation
  • MU-EH-Stage 2-Attestation

No, nursery days and discharges are not included in inpatient bed-day or discharge counts in calculating hospital incentives. We exclude nursery days and discharges because they are not considered acute inpatient services based on the level of care provided during a normal nursery stay. In addition, nursery day patients should not be included in the denominators of Meaningful Use measures. However, if the EHs (or CAHs) certified EHR technology cannot readily identify and exclude nursery day patients, those patients may be included in the calculations for the denominators of Meaningful Use measures.

How can I change my attestation information after I have attested and/or received an incentive payment?
  • MU-EH-Stage 1-Attestation
  • MU-EH-Stage 2-Attestation
  • MU-EP-Stage 1-Attestation
  • MU-EP-Stage 2-Attestation

Your facility would have to contact CMS to determine the error and re-attest with the correct information.

What is the timeline for Meaningful Use in 2014?
  • MU-EH-Stage 1-Attestation
  • MU-EH-Stage 2-Attestation

Meaningful Use in 2014 for Stage 1 and Stage 2 has a 90-day period of attestation.  However, in 2014, these 90 days will have to be tied to a Fiscal Year Quarter. The CMS-defined Fiscal year is Oct. 1 - Sept. 30.  The quarters are as follows:
• Oct. 1 - Dec. 31, 2013
• Jan. 1 - March 31, 2014
• April 1 - June 30, 2014
• July 1 - Sept. 30, 2014

View the CMS timeline.

We are a critical access hospital with a psychiatric unit that bills under POS code 21 but are excluded from the IPPS. Should these patients be included in the denominator for the Meaningful Use measures?
  • MU-EH-Stage 1-Attestation
  • MU-EH-Stage 1-Misc.
  • MU-EH-Stage 2-Attestation
  • MU-EH-Stage 2-Misc

No. According to the final rule, the definition of hospital used for Meaningful Use measures does not apply to hospitals excluded from the inpatient prospective payment system (IPPS), such as psychiatric or rehabilitation units. If patients treated in the psychiatric unit are also admitted to areas of the inpatient department that are not excluded from IPPS, then they should be counted in the denominator (and numerator) for Meaningful Use measures.

For more information, see the CMS FAQ on this topic.

What costs can be included in the Medicare EHR Incentive Payment for CAHs?
  • MU-EH-Stage 1-Attestation
  • MU-EH-Stage 2-Attestation

The EHR incentive payment shall only include reasonable costs for the purchase of certified EHR technology to which purchase depreciation would apply. This would include the computers, and associated hardware and software, necessary to administer certified EHR technology. If the cost cannot be included as a depreciable asset under normal Medicare cost reporting principles, it cannot be included in the EHR incentive payment. However, the CAH may continue to report all other costs on the Medicare Cost Report, and be reimbursed under reasonable costs principles.
Since the reasonable costs of the depreciable assets being included in the EHR incentive payment are allowed to be expensed in their entirety in the year incurred, the CAH must ensure that the resulting depreciation on those assets is not included in subsequent cost reports.