How Critical is the October 1, 2011 Deadline? – Meaningful Use Monday

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money. Check out Lynn’s previous Meaningful Use Monday posts.

As October approaches, providers who want to apply for the 2011 EHR incentive—and their vendors—are scrambling to implement in time to allow for the 90-day reporting period. An EMR and HIPAA reader submitted the following question: 

Under the EHR Incentive program, in order to receive payment for 2011, the 90- day reporting period must begin no later than 1 October 2011 [Technical point: October 3 is the actual deadline]. Does this mean that the ONC Certified EHR must be in place and operational at that time or can it be installed after 1 October 2011 as long as the pertinent patient data is entered into the EHR once it is installed?

 The EHR must be in use during the entire 90-day period. Data must be reported for the entire 90 days; some measures require something to “be enabled” for the entire period, (e.g., a clinical decision support rule, drug formulary); and other measures have time frames attached, (e.g. provide a clinical summary within 3 business days), which would not be possible to accomplish retroactively. 

My suggestion is that you take the pressure off by postponing meaningful use—and the receipt of your incentive—by just 3 months. If you begin reporting on January 1 instead, you will still have the opportunity to earn the full $44,000 over the 2012-2016 period. You can attest at the end of March and expect your incentive by May. This schedule has the additional advantage of allowing you to earn a 1% ePrescribing bonus for 2011, which you would forego if you earn an EHR incentive since you cannot collect both in the same reporting period. Focus your energy this year on ePrescribing for 25 Medicare encounters and on successfully implementing your new EHR in 2012.

About the author

Lynn Scheps

Lynn Scheps

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money.


  • John & readers this is possibly a little self serving as one should note that next years attestation is at a higher level that this years attestation requirements. Physicians taking this wait approach would be disadvantaged vs physicians who move earlier balance of 2011.

    If SRS is unable to assist a Physicians office install an ambulatory EMR system by early October there are other vendors that are more than capable standing by to serve and who do not charge the physician! We also take great pride in assisting physicians along the journey of acheiving MU!

  • Chris,
    I think you might want to take that comment back. It’s not a self serving post on Lynn and SRSsoft’s behalf. I guess it is on mine since I want to provide good information.

    How is next year’s attestation process harder than this year? In some ways, I think you could argue that waiting the year actually makes the attestation easier since you’ll be able to learn from the mistakes of those who attest this year and get screwed over by CMS for some undocumented reason. Plus, if you remember this post, you still get to do two years worth of MU stage 1 even if you start next year: So, how is it harder?

    Plus, I’m sure SRS has no problem with physicians attesting this year. They’ve had their complete EHR certification for quite a while.

  • John and Chris, I think this post is not a bad suggestion but in most cases, it’s case by case. My company offers a MU planning/monitoring product that does some of this analysis of whether to proceed or push back to 2012. A lot depends on not only can they push to get the EHR system in use in time but also what type of EHR system is being deployed (some are not great at producing reports yet or not easy to configure for MU), how well prepared is the provider in achieving MU as well as the “will” and “desire” of the provider to push through.

  • Waiting until next year will not make attesting itself more difficult – it may be slightly easier in that the only real change is CQMs in 2012 must be reported electronically (via the EHR) vs. attestation – BUT, as I’ve dealt with a number of EHRs and attestation, that “automation” may not be any easier.

    Though Lynn recommends waiting — I don’t.

    There are plenty of new requirements that start in January (ICD-10 for one?), so why not get this out of the way? If you can.

    Attesting is more challenging that anyone realizes because there are so many ways to screw things up.

    But delaying won’t make any of this easier.

    Example? Sure:
    More than one EHR I’ve dealt with do not require proper input of MU data (ht/wt/bp for instance) before moving to another screen.

    IF you don’t put all of those in, it doesn’t count…why would a MU certified EHR allow this?

    So many offices think they are doing the right thing, only to find out they left one piece of data out and screwed themselves.

    One last thing to remember: The last day you can start your tracking window for 2011 is Oct 3 – this does NOT mean you can’t start in November yet still use that full window.

    If you don’t have your numbers perfect on Oct 3, so what, still try to fix them.

    MU Stage 1 will create permanent work flow changes in your office – start making those changes now and you may still be able to attest this year…then one less thing to think about next year.

  • Or, instead of delaying, you can get started with Practice Fusion’s free EHR today and start Meaningful Use before October 1. We’re seeing a big surge in doctors signing up before the deadline and have ramped up to handle the demand.


  • Emily,
    You would want your users to miss out the ePrescribing incentive money for this year? That’s not maximizing the incentives.

    That’s interesting that you’re seeing a surge in signups though. I’ll be interested to hear stats on how many of those recent signups attest to MU.

    Do you have an MU dashboard like AthenaHealth has published showing how many of your users meet MU? That’s a good question for all other EHR vendors reading this too. I’d love to see and publish that information if you have it.

  • If you begin your reporting period Jan 2012 and you successfully attest in April 2012 – will CMS pay you based on your 2012 allowables at the time of attestation? What happens if your allowed amounts for – let’s say Jan-April 2012 – are less than the $24,000 benchmark needed to get the full $18,000? Will CMS “pend” paying the incentive until you have hit that $24,000 benchmark in allowables? Just wondering because if CMS does not wait until you’ve hit the benchmark – then you can still do MU the first 90 days of the year but just not do the attestation until you know you’ve hit the benchmark… right?

  • Jolene,
    From my understanding, CMS will wait until you’ve reached the $24,000 before they pay you the incentive. They’ll continue to wait to pay you until you reach the threshold. If you don’t reach the threshold, then they’ll pay you out at the end of the year.

    It raises an interesting point if you have Medicare reimbursement that’s higher in 2011 than 2012 it might matter when you attest. Although, probably not a big deal for most people.

  • Jan 1st, 2012 might make it a little difficult for the provider since they will be affected in two ways at the same time – Meaningful use (if it is delayed) and 5010.

  • Wanted to look at your Buyer’s Toolkit, but could not get it to download. Solo Practice, vasried – Internal medicine, some general practice, addiction medicine with Suboxone, injections, etc. Retired Surgeon not doing any Hospital care – strictly office based practice.

  • The providers I am asssting with MU attestation this year is doing it b/c their eRx incentive amounts to few hundred dollars versus guaranteed $18K this year based on their Medicare Allowable Charges. No brainer for them. Some do it b/c if you achieve MU, you can be excused from any eRX penalties. However, if eRx bonus is large enough, it could make sense to hold off till 2012 as your first attestation.

  • Arthur,
    Try the image at the bottom to get the toolkit. Let me know what happens when you try to do it. It should pop up a box for you to put in your info and get the toolkit.

    That is interesting. For some the amount isn’t that small, so it makes sense to wait to maximize the incentives.

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