Attestation

How long after I attest should my Medicare incentive payment arrive?

Your facility will need to contact CMS for payment information.

Now that CMS has released the Modified Stage 2 final ruling (2015-2017) and Meaningful Use Stage 3 final ruling, what does this mean with regards to 2015 reporting period, attestation and subsequent reporting/attestation periods?

The Modified Stage 2 (2015-2017) final ruling that was released made changes to a few things for 2015-2017. Listed below are some of the high points:

• 2015 only: will now become a continuous 90-day reporting period that can range from Oct 1 2014  -Dec 31 2015.
• For hospitals, their reporting period has now been moved to a calendar year instead of a fiscal year.
• Actual attestation for 2015 cannot take place until Jan. 4, 2016 and will run through Feb. 29, 2016.
• 2016: the reporting period will be a 365-day calendar year and attestation will not take place until January - February 2017.
• 2017: the reporting period for modified Stage 2 will be a 365 day calendar year and attestation will not take place until January - February 2018.
• Stage 3 will not be mandatory until 2018.

Please note: There will no longer be core vs menu objectives or stages. All facilities will align into reporting the same objectives.

I hear there is a new timeline for Meaningful Use. Does this change anything with Stage 2?

Per Centers for Medicare and Medicaid Services (CMS), there will be a new, revised timeline for Stage 2. This will be extended through 2016, and Stage 3 will begin in 2017 for those hospitals and providers that have completed at least two years in Stage 2. For those that are to start Stage 2 in 2014, this does not change when you start Stage 2, only that you will now be at Stage 2 for three years, instead of two. In the fall of 2014, it is expected that CMS will release a notice of proposed Stage 3 Rulemaking and corresponding ONC Standards will be released in the fall of 2014. The final rule for Stage 2 would then follow in 2015.

Is the attestation period different for 2014?

Yes. For 2014 only, all providers are only required to demonstrate Meaningful Use for a 3-month EHR reporting period, regardless of their stage. For Medicare providers, this 3-month reporting period is fixed to the quarter of the calendar year in order to align with existing CMS quality measurement programs, such as the Physician Quality Reporting System (PQRS). The 3-month reporting period is not fixed for Medicaid EPs that are only eligible to receive Medicaid EHR incentives, where providers do not have the same alignment needs. CMS is permitting this one-time, 3-month reporting period in 2014 only so that all providers who must upgrade to 2014 certified EHR technology will have adequate time to implement their new, certified EHR systems.

Is there somewhere I can review documentation on how my Medicare Incentive Payment will be calculated?

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

How can I change my attestation information after I have attested and/or received an incentive payment?

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