KENTUCKY REGIONAL EXTENSION CENTER

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Closing 2015 Program Year

  • Eligible Providers (EPs) in the Medicare EHR Incentive Program finished attestations for the 2015 program on March 11, 2016.
  • EPs in the Kentucky Medicaid EHR Incentive Program just finished their 2015 program year submissions on May 31, 2016.
  • If you did not attest or attested to AIU only, make sure you have filed your hardship application if you are a dual eligible provider who has both Medicare Part B charges and Medicaid charges OR if you are a Medicare Part B eligible provider.
  • The deadline for the hardship application is July 1, 2016. Hardship application and instructions available here.
  • If you did attest or submitted an AIU with Medicaid, you need to keep all documentation used for 6 years in case of an audit. This includes anything used to compile summary reports.

Action Plan for 2016 Program Year

 Medicare EHR Incentive Program:

  • 2016 is the last year for EPs to receive an incentive payment in the Medicare EHR Incentive Program.
  • 2016 EPs in last year will continue to submit current Modified Stage 2 measures.
  • EPs meeting the criteria will move to the Medicare Access and Chip Reauthorization Act (MACRA) value-based reimbursement system currently in Notice of Proposed Rule Making (NPRM) for the 2017 Program year.
  • For 2016, EPs will continue to submit PQRS per the current guidelines; which can count for the Medicare EHR Incentive Program if using particular reporting mechanisms.

Kentucky Medicaid EHR Incentive Program:

  • 2016 will be the last year providers can enroll in the Kentucky Medicaid EHR Incentive Program.
  • This program will continue with incentive payments through 2021.
  • Please make sure you register for this program as soon as possible to ensure you reserve your Medicaid Incentive enrollment.

EHR Reporting Period:

  • The EHR reporting period must be completed within January 1 and December 31 of 2016 calendar year.
  •  For all returning participants, EHR reporting period will be a full calendar year from January 1, 2016 through December 31, 2016.
  •  For EPs, eligible hospitals, and CAHs that have not successfully demonstrated meaningful use in a prior year will be any continuous 90-day period.

Payment Adjustments and Attestation Deadlines:

  • For the 2016 EHR reporting period, all returning participants must attest by February 28, 2017.
  • New participants who successfully demonstrate meaningful use for 2016 and satisfy all other program requirements will avoid the payment adjustment in CY 2017 and CY 2018 if the EP successfully attests by October 1, 2016, and will avoid the payment adjustment in CY 2018 if the EP successfully attests by February 28, 2017.
  • Returning participants who successfully demonstrate meaningful use for this CY 2016 and satisfy all other program requirements will avoid the payment adjustment in CY 2018 if the EP successfully attests by February 28, 2017.

Measures Where Known Barriers are Noted in Kentucky:

  • Health Information Exchange (formerly Summary of Care/Transitions of Care)
  • Patient Electronic Access – commonly known as the Patient Portal
  • Secure Messaging
  • Public Health Measures
  • Clinical Quality Measures

Important Dates:

  • 2016 – Last year to initiate participation in the Medicaid EHR Incentive program
  • 2016 – Last year to participate in the Medicare EHR Incentive program (You will report through MIPS in the years to follow)
  • Jan 1, 2016 – Reporting Period begins for 2016
  • First-time participants and those providers that attested to AIU only may use EHR reporting period of any continuous 90-day period within calendar year but must attest by Oct 1, 2016 to avoid the 2017 Payment Adjustment.
  • All returning participants must use EHR reporting period of full calendar year
  • Public Health intent to register signed documents and all KHIE signed agreements must be submitted 60 days from the start of the EHR Reporting Period
  • June 30, 2016 – PQRS group deadline
  • July 1, 2016 – Streamlined Hardship application for PY 2015 due, to avoid 2017 payment adjustment
  • December 31, 2016 – Reporting Period ends for 2016
  • Jan 1, 2017 – MACRA MIPS begins.