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    Deadline approaching for submission of Promoting Interoperability data: Are you ready?

    Eligible hospitals and Critical Access Hospitals (CAHs) must demonstrate meaningful use of certified electronic health record technology (CEHRT) to avoid negative Medicare payment adjustments under the Promoting Interoperability (PI) program. In order to demonstrate meaningful use for 2019, hospitals must register and submit meaningful use data through the QualityNet Secure Portal by March 2, 2020.   

    In preparing for data submission, hospitals should consider the following:

    • Reporting period: The Centers for Medicare and Medicaid Services (CMS) continues to provide hospitals with flexibility in selecting their reporting period. Eligible hospitals and CAHs can select any continuous 90-day period as their reporting period. Hospitals should select a reporting period that meets the CEHRT requirements and provides them with the best chance of meeting the minimum scoring threshold necessary to avoid negative Medicare payment adjustments. The 90-day reporting period will continue for calendar years 2020 and 2021.   
    • 2015 Edition CEHRT: Participants in the PI program were required to utilize 2015 Edition CEHRT during 2019. The 2015 Edition CEHRT did not have to be implemented on January 1, 2019, but the functionality needed to be in place by the first day of the selected reporting period. Eligible hospitals and CAHs should ensure that they were utilizing 2015 Edition CEHRT for their selected reporting periods. 
    • New scoring methodology: CMS has modified its scoring methodology from prior years to shift to performance-based scoring with fewer measures. Under the new methodology, a hospital’s performance on individual measures is added to calculate a score out of the total possible 100 points. Eligible hospitals and CHAs must receive a total score of at least 50 points to satisfy the requirements of meaningful use and avoid a negative Medicare payment adjustment.
    • Bonus measures: CMS has added two optional measures to the Electronic Prescribing Objective. The Query of Prescription Drug Monitoring Program (PDMP) and Verify Opioid Treatment Agreement measures are each worth an additional five bonus points. Eligible hospitals and CAHs that can attest to these measures should utilize the additional bonus points to assist with meeting the scoring threshold.
    • Prepare for audit: Providers that are participating in the PI program may be subject to an audit by CMS and its contractor, Figliozzi and Company. Documentation to support Medicare attestation data should be retained for six years post-attestation. States may perform audits on Medicaid providers participating in the Medicaid PI Program and may have longer document retention periods. 

    This is for informational purposes only. It is not intended to be legal advice and does not create or imply an attorney-client relationship.

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