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    For CY 2018, Meaningful Use reporting period is once again 90 days

    Recently, the Centers for Medicare & Medicaid Services (CMS) gave in to health care provider and industry demands by issuing a final rule that modifies the Electronic Health Record (EHR) Incentive Program reporting period for 2018 from the full year to a minimum of any continuous 90-day period during the calendar year. The FY 2018 Medicare Hospital Inpatient Prospective Payment System (IPPS) and Long Term Acute Care Hospital (LTCH) Prospective Payment System Final Rule is effective October 1, 2017.

    Included in the rule is a new exception from the Medicare payment adjustments for eligible professionals (EPs), eligible hospitals (EHs) and critical access hospitals (CAHs).  This exception allows providers to utilize an application process to demonstrate that compliance with the requirement for being a meaningful EHR user is not possible, because the provider’s certified EHR technology has been decertified under the Office of the National Coordinator (ONC) Health IT Certification Program. While providers who utilize this exception would avoid a Medicare payment adjustment, they would also be precluded from any EHR incentive payment.

    In addition, CMS finalized an exception to the 2017 and 2018 Medicare payment adjustments for ambulatory surgical center (ASC)-based EPs. CMS defined ACS-based EPs as those who furnish 75 percent or more of their covered professional services in an ASC, using Place of Service (POS) code 24 to identify those services.

    In response to feedback from providers that the transition to 2015 certified EHR technology (CEHRT) will require additional time, CMS adopted final policies that give providers more flexibility in their choice of CEHRT. The new policies allow health care providers to use either 2014 Edition CEHRT, 2015 Edition CEHRT, or a combination of 2014 Edition and 2015 Edition CEHRT for an EHR reporting period in 2018.

    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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