On April 18, 2011, CMS began taking attestations of EHR meaningful use from Eligible Providers (EP). Attestation is the last step for physicians in claiming their EHR incentive payments for Phase 1. In order to make an attestation, the EP must have acquired certified EHR technology and meaningfully used that technology for 90 consecutive days. Once the 90-day use period is complete, EPs have 60 days to submit the attestation. EPs who have met the $24,000 threshold for allowed charges for covered professional services for year one can expect to receive payment within six to eight weeks of CMS’s receipt of the attestation. On May 18, 2011, CMS announced that it would begin paying the first incentive payments within the week. Incentive payments will be paid to providers the same way they receive other Medicare payments — either via electronic transfer or paper check. National Government Services Inc. is the contractor who will make the incentive payments.
Attestation can be made via CMS’s web-based Medicare and Medicaid EHR Incentive Program Registration and Attestation System. Many of the measures require patient population data for numerator, denominator and percentage inquires. Others require simply a yes or no. In some instances, an EP may have an exclusion that excuses reporting on the measure. This information can be input directly by the EP, or someone acting on the EP’s behalf into the CMS attestation website.
EPs in a position to make an attestation should anticipate spending significant time and effort to gather the necessary data. The attestation must include a report on the 15 core set meaningful use objectives measures and five out of 10 menu set measures, one of which must relate to public health. Certified EHR technology must have the capability to record the numerator and denominator information required and generate a report of the numerator, denominator and resulting percentage. EPs can use this data for the attestation, but may need to pull information from other resources, including paper records, to get all of the information needed for the attestation.
EPs must also report on Clinical Quality Measures (CQMs). This information must be reported directly from the certified EHR technology and not obtained from an EHR report or other resources for submission by the EP to CMS (as with the other measures). All EPs are eligible to report on core CQMs, e.g., BMI measurements and follow up for adults, and alternate core CQMs, e.g., flu shots for patients 50 years old and older. Other CQMs vary by specialty, e.g., beta blocker therapy for Coronary Artery Disease patients with prior MI. To receive the incentive payment, an EP must attest to three core CQMs; three alternate core CQMs; and three additional CQMs. If the denominator on any of the core CQMs is zero, then the EP may substitute an alternate core CQM. Thus, the EP will need to report on no less than six and up to nine CQMs.
CMS has recently updated its website providing worksheets to assist in attestation. These worksheets can be used for the 15 core measures and five menu measures, but not for the CQMs.