By Jim Tate, EMR Advocate
Meaningful Use Audit Expert
Twitter: @JimTate, eMail: Inquiry@meaningfuluseaudits.com
It is not often we are given the opportunity to make a clear-cut decision. If you are anything like me, you chew on the bone of indecision until there is nothing left but the marrow. I make lists of the pros and cons of every major (and not so major) decision I need to make. Even after pulling the trigger and moving forward I am usually left with a sense that maybe I didn’t make the “perfect” choice. Whether you call it “20/20 hindsight” or “buyer’s regret” I am always haunted by the Father of All Questions, “What if?”. Even poets speak of the dilemma when “two roads diverged in a yellow wood”. Well Dear Reader, I will not leave you at the crossroads tossing coins for divine inspiration. For 2017 and MIPS, I will tell you exactly what to do. If you listen to me, all will be well, and there will be no regret.
For MIPS, eligible clinicians who are not able to participate in an Alternative Payment Model, the choices are clear. In the transition year of 2017 there are four options, and only two of them make any sense. Hear me now, because this is important.
2017 Options
Option 1: Submit Nothing. Make this your choice and will have a 4% negative Part B payment adjustment and a MIPS Composite Performance Score (CPS) of “0” in 2019. Taking this route should be grounds for a 30-day suspension from school.
Option 2: Submit Something. Don’t get fooled here. You only must submit a miniscule amount of data and you will avoid a negative adjustment in 2019. However, you will have a public CPS of “3”. Scoring three on a one-hundred-point scale doesn’t sound too good to me. If this is your option you should be required to stay after class for 2 weeks of detention. Your parents will be notified.
Option 3: Submit a Partial Year. Now we are getting real. Submit data for 90 days and CMS says, “you may earn a neutral or positive payment adjustment and may even earn the max adjustment.” This is the first acceptable option and you will be allowed to graduate from high school.
Option 4: Full Submission. Take the plunge and send a full year of data to Medicare. CMS states, “The best way to get the maximum MIPS payment adjustment is to participate full year. By participating the full year, you have the most measures to pick from to submit, more reliable data submissions, and the ability to get bonus points.” If you can pull this one off, you will receive a 4-year scholarship to the college of your choice.
So, there it is in black and white. Options 1 and 2 are worst practices. Number 3 is acceptable but if you have what it takes, go for number 4. That’s it! Choose 3 or 4 and don’t look back.
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: Inquiry@meaningfuluseaudits.com.