Interim Final Rule Makes changes to Stage 2

This week CMS and ONC have released an Interim Final Rule with public comment period. The rule makes changes to both the Medicare and Medicaid EHR Incentive programs and the 2014 EHR Certification Criteria September rule affecting hospitals. It also states CMS’s intention to issue technical corrections to the electronic specifications for clinical quality measures (CQMs) released on October 25, 2012. The effective date will be 30 days after the publication in the federal register. Comments will be accepted during the 60 day period following the publication in the federal register.

CMS reports the major changes in the Interim Final Rule are:

• Revising the regulation text for the hospital measures for the objective of making patient information available online. The measure will now base the denominator not on all patients, but all unique patients.
• Expanding the denominator options for the objective of sending electronic lab results to ambulatory providers. It now allows hospitals to choose between a denominator of all lab orders received from ambulatory providers or all lab orders received electronically from ambulatory providers.
• Moving the CQM minimum denominator threshold effective date from 2014 to 2013, so hospitals can begin taking advantage of this flexibility right away

Summary from the IFR: The Department of Health and Human Services (HHS) is issuing this interim final rule with comment period to replace the Data Element Catalog (DEC) standard and the Quality Reporting Document Architecture (QRDA) Category III standard adopted in the final rule published on September 4, 2012 in the Federal Register with updated versions of those standards. This interim final rule with comment period also revises the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs by adding an alternative measure for the Stage 2 meaningful use (MU) objective for hospitals to provide structured electronic laboratory results to ambulatory providers, correcting the regulation text for the measures associated with the objective for hospitals to provide patients the ability to view online, download, and transmit information about a hospital admission, and making the case number threshold exemption for clinical quality measure (CQM) reporting applicable for eligible hospitals and critical access hospitals (CAHs) beginning with FY 2013. This rule also provides notice of CMS’s intention to issue technical corrections to the electronic specifications for CQMs released on October 25, 2012.

CMS Offers Advise on EHR Incentive Program Registration

To successfully register for Medicare or Medicaid EHR Incentive programs you must be enrolled in the Provider Enrollment, Chain and Ownership System (PECOS). Your registration to the EHR Incentive Programs will continue to have a status of “issue pending” until your PECOS enrollment record is active.

To enroll in PECOS you will need:

• An active NPI
• NPPES User ID and password. Internet-based PECOS can be accessed with the same User ID and password that a physician or non-physician practitioner uses for NPPES
• Personal identifying information (legal name, Social-Security Number, and date of birth)
• School information (name of school and graduation year)
• Professional license/certification information
• Practice location information
• Information about any final adverse action(s), if applicable
• Drug Enforcement Agency (DEA) number

If you are already enrolled in PECOS you can confirm your enrollment record and its information through your Medicare Administrative Contractors (MAC). Be sure your information is current and matches that in the CMS EHR Registration & Attestation System.

You do not have to be registered to begin your meaningful use reporting period but CMS does recomend to register as early as possible to resolve any pending issues that would delay your attestation.