- PY2017 Attestation Availability and Deadlines
- Alternate Attestations
- MU Specifications and Guidance
- EHR Reporting Periods
- Changes to MU Measures in PY2017
- Public Health Objective
- CMS Resources
- What's Next for Providers Concluding the Medicaid EHRIP
Providers will not be able to start an attestation until MAPIR is upgraded to accommodate changes to the EHRIP requirements for Program Year 2017. The rule finalized and published by CMS on August 2nd, 2017 contains changes to Program Year 2017, which has already been programmed to the scheduled MAPIR update. The MAPIR Collaborative is quickly working on a system patch that will accommodate the revised rule logic, but it is not likely to be available for providers to start their 2017 applications until after January 1st, 2018. The deadline to submit will also be extended, and we will keep you apprised as the timing is clarified.
Alternate Attestations: EPs who will first demonstrate meaningful use in PY2017 must demonstrate Meaningful Use for a 90-day reporting period in 2017 to avoid payment adjustments in 2018. This reporting period must occur in the first 9 months of calendar year 2017, and EP must attest to Meaningful Use no later than October 1, 2017, in order to avoid the payment adjustments in calendar year 2018. Since the MAPIR upgrade will not be available by this date to accommodate Program Year 2017 attestations, EPs needing to avoid Payment Adjustments can submit an Alternate Attestation at the Medicare R&A Site. This Alternate Attestation method will NOT issue an incentive payment, but EPs may subsequently ALSO attest for a Vermont Medicaid EHRIP payment when MAPIR is ready to accept 2017 applications.
CMS has comprehensive resources available at their Program Year 2017 website:
- 2017 Specification Sheets for Eligible Professionals: Modified Meaningful Use Stage 2
- For those providers who have opted to upgrade their CEHRT, they may attest to Meaningful Use Stage 3
Meaningful Use EHR Reporting Period - 90 Days: For all returning participants, the EHR reporting period is a minimum of any continuous 90-days between January 1 and December 31, 2017.
CQM Reporting Period: - 90 Days: The rule recently published on 8/2/17 by CMS modifies the CQM reporting period for CQMs.
- Eligible Hospitals: For eligible hospitals and CAHs reporting CQMs electronically that demonstrate meaningful use for the first time in 2017 or that have demonstrated meaningful use in any year prior to 2017, the reporting period will be one self‑selected quarter of CQM data in CY 2017
- Eligible Professionals: For 2017, CMS is modifying the CQM reporting period for EPs in the Medicaid EHR Incentive Program to be a minimum of a continuous 90-day period during calendar year 2017.
Stage 3 of Meaningful Use is an option for the first time in 2017, for those providers who have upgraded their Certified EHR Systems to the 2015 Edition, or are using a combination of 2014 and 20115 CEHRT. More information about Stage 3 criteria can be found at the CMS Website: MU3 Guidance for Medicaid EHRIP.
Most providers will still be attesting to the Modified-MU2 criteria in Program Year 2017. However, please keep in mind that certain measures and requirements have evolved for PY2017:
Changes to Specific Objectives in Modified-MU2 in PY2017
- Objective 0, ONC Questions: A CMS final rule effective 1/1/2017 requires the EP to attest to cooperating with ONC’s EHR system surveillance and review activities. Objective 0 has been added to capture this requirement. For a preview of the screenshot of the attestation questions Objective 0, click here.
- Objective 1, Protect ePHI: It is acceptable for the security risk analysis (or review of the SRA) to be conducted outside the EHR reporting period; however, the analysis must be unique for each EHR reporting period, the scope must include the full EHR reporting period, and must be conducted within the calendar year of the EHR reporting period (January 1st – December 31st).
- Objective 8, Measure 2, Patient Electronic Access: For an EHR reporting period in 2017, more than 5 percent of unique patients seen by the EP during the EHR reporting period (or his or her authorized representatives) view, download or transmit to a third party their health information during the EHR reporting period.
- Objective 9, Secure Messaging: For an EHR reporting period in 2017, for more than 5 percent of unique patients seen by the EP during the EHR reporting period, a secure message was sent using the electronic messaging function of CEHRT to the patient (or the patient-authorized representative), or in response to a secure message sent by the patient (or the patient-authorized representative) during the EHR reporting period. PLEASE NOTE that provider-initiated action and interactions with a patient, or patient-authorized representative, are acceptable for the measure and are included in the numerator.
- Objective 10, Public Health Reporting: For an EHR reporting period in 2017, all EPs must attest to at least two measures, or document exclusions if they cannot meet one or more measures. The Alternate Exclusion for Specialty Registry reporting is no longer available (“the EP did not plan to report on special registry data, therefore the EP is able to claim an exclusion”).
All EPs attesting for Program Year 2017 must meet two of the three Public Health Objective Measure Options for Modified-MU2. A provider may utilize a combination of measure reporting and measure exclusions to pass the Public Health Objective. Please review the detailed guidance, screenshots and Documentation Aids available at our webpage: Public Health Reporting in PY2017 for Modified-MU2.
- Health Information Exchange Fact Sheet
- Security Risk Analysis Tip Sheet
- Patient Electronic Access Tip Sheet
- Public Health Reporting in 2017 for Medicaid EHRIP EPs
- 2017 Payment Adjustment Fact Sheet for EPs
Congratulations to the 62 providers scheduled to complete all six years of their eligibity with the Medicaid EHR Incentive Program as of their Program Year 2016 payment! Providers finishing their incentive payments for meeting Meaningful Use in the EHRIP, please keep in mind that other quality programs still exist. For 2017 and beyond, if providers also see Medicare patients, the Merit-based Incentive Payment System will replace Medicare reporting for the Medicare EHR program, Physician Quality Reporting System and the Value-Based Payment Modifier. The Quality Payment Program is part of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) and includes two tracks — Advanced Alternative Payment Models (APMs) and the Merit-based Incentive Payment System (MIPS). If you have questions or need assistance with determining eligibility or requirements, visit the Quality Payment Program to find out if providers should participate in MIPS at https://qpp.cms.gov.
For questions, contact the Vermont EHRIP Team at ahs.dvhaEHRIP@vermont.gov
(Page last updated 08/17/2017)