22 May Meaningful Use 2 Delay: What it Means for OP
You may have heard that on Tuesday CMS and ONC proposed additional “flexibility” in attesting for Meaningful Use in 2014. If you participate in MU, you probably have a lot of questions about the impact of this delay on your practice. Assuming the proposed rule becomes official sometime shortly after the 60-day comment period, here is our read of the situation and how it affects your use of Office Practicum in 2014 and 2015.
Q: What are my options in 2014?
Contrary to previous guidance, you may keep using OP11 for the entirety of 2014 and use it to submit your attestation at the end of the year. Regardless of whether you are currently in Stage 1 or Stage 2 (based on how many years you have been enrolled), your 2014 attestation would follow the 2013 Stage 1 requirements.
If you choose, you may upgrade to OP14 when it becomes available and use it to submit your 2014 attestation. If you attended our recent User Conference, you know there are a lot of compelling reasons to upgrade, apart from the MU2 considerations. On this path, you may choose to continue attesting according to 2013 guidelines, or you may move up to the 2014 Stage 1 OR Stage 2 guidelines. Keep in mind that the 2014 Stage 2 guidelines are significantly more onerous – especially with respect to CQMs – so that may not be in your best interest. But if you meet all the requirements, you can submit them.
In all cases, you will only need to submit statistics for a 90-day period, not the full year.
Q: When can I receive my 2014 MU payment?
Good news! If you implemented OP in 2013 or earlier, you have already completed a 90-day reporting period in 2014 with OP11. As such, you can attest as soon as the proposed rule is finalized – assuming you meet all of the minimum thresholds for Medicaid visit volume and measure benchmarks. You will not need to wait until you upgrade to OP14 in order to claim your 2014 MU payment.
There is one exception: If you purchased OP11 in 2014 and had never participated in MU before, you cannot attest for your first-year AIU (adopt, implement, upgrade) payment until you upgrade to OP14. CMS/ONC cleverly inserted this requirement to keep new participants from buying systems that would become obsolete in subsequent years. We expect OP14 will be fully certified prior to adoption of the proposed rule, so this should have no practical impact on the earliest date you can attest for reimbursement.
Q: When will OP14 be available?
As announced at the User Conference, OP14 will begin reaching beta testers in June. In early July, we expect to roll it out to a second collection of early adopters. We will proceed to General Availability as soon as feedback from early adopters indicates its readiness for wide deployment.
Q: What are my options in 2015?
There will be only one option in 2015: You must be using OP14 as of January 1, 2015, and you must use it for an entire year to submit your 2015 attestation. Therefore, you must perform your OP14 upgrade in time to acclimate yourself and your staff to it before that start date.
In anticipation of the latest ICD-10 implementation date (October 1, 2015), an incremental build of OP14 will be published in 2015 that exposes its hidden ICD-10 features. You should plan to adopt that version no later than the summer of 2015. Regular use of OP14 will prepare you for the additional requirements of this release, because it uses the same diagnosis mapping system.
Q: What are my options beyond 2015?
“Who knows?” So far 2014 has brought us a series of hurry-up-and-wait scenarios that shows no signs of abating. The current MU plan shows 2016 being the same as 2015, and 2017 as the initial year of Stage 3. Numerous HIT stakeholders have begun to question the sequence, timing, measure definitions, and (dis)incentives embedded in the MU program. Only time will tell whether the program survives over the long term in its current form.
One thing does not change: The Office Practicum commitment to keeping you informed and current with the technology you need to keep pace in an ever-changing world. If you have any additional questions, please contact your Client Advocate or a member of our Support team.
As usual, thanks for your ongoing support and commitment to Office Practicum!
Greg Anderson, CEO