By Jim Tate, EMR Advocate
Meaningful Use Audit Expert
Twitter: @JimTate, eMail: Inquiry@meaningfuluseaudits.com
I read it almost every day. “Meaningful Use (MU) is over”. “The incentives are almost all paid out”. Everyone is acting like the entire CMS EHR Incentive Program is slipping away and with it the entire concept of MU.
Better hold your horses. The death knell of MU has been overplayed. MU is not finished, it is in the process of being reborn and enshrined by regulations that will continue for the foreseeable future. We are on the precipice of Medicare Part B reimbursement shifting to a system based on pay-for-quality. Welcome to MIPS (Merit-Based Incentive Payment System).
MIPS is currently set to impact Part B reimbursement in 2019 but will be based on a composite score based on 2017 actions. 2017 isn’t really that far away. The composite score for each Eligible Professional (EP) will range from 0 – 100 and 25 of those points will be earned by MU of CEHRT. Decide to ignore MU and your score will immediately drop to a maximum of 75. Many EPs opted to ignore what they considered the hassle of MU and were willing to forego the incentives and accept what they considered minimal penalties. Under MIPS the “swing” of received Part B payments in 2019 (based on a 2017 generated composite score) could be as much as 12%. That is looking to go to 15% in in 2020, 21% in 2022, and 27% in 2022. This is a zero sum process. Reimbursement funds will be taken from low scoring EPs and be given to high scorers. In 2022 for submitting the exact same Part B charges, say $1,000,000, some EPs might receive $1,180,000 and others down the street might be receiving $910,000. Moolah, wampum, greenbacks. Whatever you want to call them some practices will be leaving a lot of them on the table only to picked up by other practices.
Over the next few year MU will being decoupled from the CMS EHR Incentive Program and incorporated into MIPS. The avoidance of MU will become more and more painful. The rules and regulations of MIPS are being worked out now and much has yet to be determined but the timeline has been set. For more information on MIPS, feel free to download my recently authored with paper, MIPS for the Rest of Us.
Jim Tate is known as the most experienced authority on the CMS Meaningful Use (MU) audit and appeal process. His unique combination of skills has brought successful outcomes to hospitals at risk of having their CMS EHR incentives recouped. He led the first appeal challenge in the nation for a client hospital that had received a negative audit determination. That appeal was decided in favor of the hospital. He has also been successful in leading the effort to reverse a failed appeal, even after the hospital had received notification of the failure with the statement, “This decision is final and not subject to further appeal”. That “final” decision was reversed in less than a week. If you are a hospital with questions or concerns about the meaningful use audit process, contact him at: audits@emradvocate.com.