Meaningful Use Attestation Deadline Fast Approaching for 2013

Meaningful Use Stage 2

Meaningful Use Attestation CheckAn important deadline is coming up for Eligible Professionals and Eligible Hospitals who are planning to complete meaningful use attestation for certified EHR technology (CEHRT) for 2013.  The last day to begin the 90–day meaningful use attestation period for calendar year 2013 would be October 3, 2013.

Meaningful use attestation … five facts

Fact #1:  To begin begin the 90-day meaningful use attestation period, providers have to implement certified EHR technology software and begin utilizing it.  Providers must monitor their performance with respect to the 14 Meaningful Use Core Objectives, less any exclusions they can claim.  Providers must also be selecting and monitoring 5 of the 10 Menu Objectives they choose.

Fact #2:  One of the Core Objectives requires providers to perform an assessment of their compliance with the HIPAA Security Rule.  This is not a function of the EHR software;  instead, the assessment covers approximately 40 areas of compliance with the Security Rule.  This is an area of confusion for many providers, who simply ask the software vendor if the software is HIPAA compliant.  Software cannot be HIPAA compliant; only covered entities (providers) and business associates can be HIPAA compliant.  EHR Software should facilitate compliance by covered entities, with features such as unique user IDs and automatic log-offs, but it is not in and of itself HIPAA compliant.

Fact #3:  Hospital-based Eligible Professionals are defined as those who perform 90% or more of their services in inpatient or emergency department settings.  They are not eligible for meaningful use incentives on a personal basis.

Fact #4:  Eligible Professionals first completing Meaningful Use attestation in 2013 are eligible for up to four Meaningful Use incentive payments, over a period of four years, for a total of $39,000.  For Eligible Professionals completing Meaningful use attestation in 2014, up to three years of incentive payments are available, totaling $24,000.

Fact #5:  Eligible Professionals who successfully completed the Meaningful Use attestation in 2013 can attest again in 2014 based on using CEHRT that meets the Stage One CHERT criteria.  But by 2015, they must be using CEHRT that meets the Stage Two criteria for CHERT and achieving the Stage 2 Meaningful Use Objectives.  This means software vendors have to upgrade their software and be certified as meeting Stage Two CEHRT by the end of 2014.  This will allow providers who complete their meaningful use attestation in 2013 to have a system available to continue attesting and receiving incentive payments in 2015 and 2016.

Meaningful use attestation $’s at stake

So, a deadline is approaching, and providers who have been in an implementation phase for CEHRT would do well to push themselves to be ready to begin their meaningful use attestation period by October 3.  For eligible professionals, there’s $15,000 on the table – each!

When you need proven expertise and performance

Jim Hook, MPH

Mr. James D. Hook has over 30 years of healthcare executive management and consulting experience in medical groups, hospitals, IPA’s, MSO’s, and other healthcare organizations.

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