This month, the Department of Health and Human Services (“HHS”) announced it is redefining the 2014 certification criteria for Certified Electronic Health Record Technology (“CEHRT”) for the Meaningful Use Incentive Program. The previous 2011 CEHRT criteria required that eligible providers have complete CEHRT capable of meeting all certification criteria for an inpatient or ambulatory setting. However, some stakeholders felt that the 2011 CEHRT criteria did not account for eligible providers’ scope of practice and required purchasing CEHRT capabilities that were not necessary to successfully attest as a Meaningful User. Continue Reading →
If you are facing a meaningful use audit, you are not alone. Medicare private contractors are out in force as they carefully review supporting documentation for a meaningful use attestation. Providers who are utilizing a certified electronic health record (“EHR”) technology may find surprising challenges as they attempt to extract necessary information from the EHR in response to auditor requests.
If you are facing a meaningful use audit or have questions regarding the deployment of a certified EHR technology in support of meaningful use, please contact Ammon Fillmore at 317-977-1492 or email@example.com or your regular Hall Render attorney.
Effective October 1, 2013, Texas Health and Human Services Commission (“HHSC”) will begin reimbursing eligible distant site professionals providing home telemonitoring services as a benefit of the Texas Medicaid Program, making it one of the first states to provide direct reimbursement for home telemonitoring services. Such services will be reimbursed in the same manner as reimbursement for Home Health Services (see Rule 355.7001 and Rule 355.8021). Continue Reading →
FCC Form 460 (Eligibility and Registration Form) is now available for use by health care providers (“HCPs”) to certify their eligibility to participate in the Healthcare Connect Fund (“HCF”) program.
The U.S. Court of Appeals for the D.C. Circuit is set to hear oral arguments this week in Verizon v. FCC. At issue is “net neutrality” and to what extent the FCC is allowed to regulate Internet traffic. The case is the latest stage in a long-running legal battle over the idea that Internet providers should not be able to selectively limit the bandwidth of particular websites or applications. The FCC set out guidelines for Internet providers in the 2010 Open Internet Order, and Verizon challenged the Order on constitutional grounds. Continue to read the Hall Render Health Information Technology blog for updates on this important case.
If you have any questions about net neutrality, please contact William Dummett at firstname.lastname@example.org or your regular Hall Render attorney.
On August 1, 2013, bill H.R. 2957 was introduced to the House of Representatives, which would extend health information technology meaningful use incentives to behavioral health, mental health and substance abuse professionals and facilities. The term “additional eligible professional” would be added to meaningful use legislation to cover clinical psychologists providing qualified psychologist services. Such additional eligible professionals would receive meaningful use incentive payments on the same payment schedule as other eligible professionals but from years 2019 through 2022. The bill has been referred to the Committee on Energy and Commerce and the Committee on Ways and Means for consideration. Click here to see full text of the bill.
If you have any questions about this proposed legistation please contact Alisa Kuehn at 317-977-1475 or email@example.com or your regular Hall Render attorney.
Health information technology solutions that are remotely hosted or cloud based are becoming more common. In these scenarios, a health care provider is allowing its data – often times including protected health information (“PHI”) – to flow through or be stored in the vendor’s data center. If PHI is involved, the parties should determine whether a Business Associate Agreement (“BAA”) is necessary for HIPAA compliance. But knowing a vendor’s security standard – regardless of whether a BAA is in place – can provide the health care provider confidence that its data will be protected, with a lower risk of damaging breaches occurring. Continue Reading →
Under the Meaningful Use Stage 2 Measures both Eligible Professionals and Eligible Hospitals must use Computerized Provider Order Entry (“CPOE”) for medication, laboratory and radiology orders directly entered by any licensed health care professional who can enter orders into the medical record per state, local and professional guidelines. Previously, the Centers for Medicare & Medicaid Services (“CMS”) clarified that a licensed health care professional includes licensed nurses, as well as adding that credentialed medical assistants may also enter CPOE and have the order count towards meeting the applicable meaningful use measure. CMS does require that a credentialed medical assistant receive his or her credentiality from an organization other than the eligible provider. Continue Reading →
As we get further into the 2013 Atlantic hurricane season and experience more severe weather and wildfires, now is the time to review and refresh your IT disaster recovery plans and business continuity plans. The Federal Emergency Management Agency Ready website and U.S. Department of Health and Human Services HRSA website provide example business continuity plans and business impact analysis considerations that can be useful within your own organization to plan for disruptions in communications and clinical application availability.
Bureau of National Affairs is reporting that CMS and the OIG have submitted proposed regulations to extend the exception from the physician self-referral law and the safe harbor under the anti-kickback statute for EHR donations. The report indicates that proposed regulations have been sumitted to the White House Office of Management and Budget (“OMB”) for review. Submission to the OMB is typically the final step to proposed regulations being issued.