Meaningful Use: Registration and Attestation
Providers must register for the EHR Incentive Program and then attest to meeting all of the requirements. Both of these are accomplished via the Medicare and Medicaid EHR Incentive Program Registration and Attestation System.
When to Register:
Eligible Professionals (EPs) can register any time prior to—or at the same time as—attestation. EPs only have to register once for the duration of the program, unless they want to change any of their information or switch from one program to another, (i.e., Medicare vs. Medicaid Incentives).
- National Provider Identifier (NPI)
- National Plan and Provider Enumeration System (NPPES) web user account
- NPPES user ID and password are used to log in to the registration system
- Selection of Medicare or Medicaid incentives program
- For Medicare providers, enrollment in the Provider Enrollment, Chain, and Ownership System (PECOS) is required
- For Medicaid providers, select your state and continue on its EHR Incentives site
- Personal Information
- Social Security Number
- Taxpayer ID to which incentive payment should be made, i.e., EP’s SSN or Group’s EIN (Note: EP can receive the payment directly only if he/she has not reassigned Medicare benefits in PECOS.)
- Business information
- Populated from NPPES, but EPs can make changes if desired
- EHR Certification ID
- Optional at registration, required at attestation
How to Authorize a Surrogate to Attest for EP:
In response to numerous requests from the provider community, CMS allows physicians to assign a third party to complete the registration and attestation process for them, i.e., “work on behalf of the EP.” This person must have an Identity and Access (I&A) management system web user account (user ID and password) and be associated to the EP’s NPI. There is a link to create a login for the I&A system within the EHR Incentives registration process.
- CMS Registration and Attestation Page
- CMS Registration User Guide for the Medicare EHR Incentive Program
- CMS Registration User Guide for the Medicaid EHR Incentive Program
Attestation is the process by which Eligible Professionals (EPs) report to CMS that they have met the measures required to demonstrate meaningful use and therefore qualify for the incentive payment. Attestation is based on the honor system – however incentives are subject to potential pre- or post-payment audits. EPs attest on the Medicare and Medicaid EHR Incentive Program Registration and Attestation System—the same system used for registration.
When to Attest:
EPs attest at the conclusion of each reporting period. At the end of the attestation process, EPs are advised whether their attestation is accepted (i.e., successful) or rejected.
Note: The attestation deadline for 2015 MU is February 29, 2016 at 11:59 PM ET.
- Attestation Information
- Certification ID# created on the Certified Health IT Product List (CHPL Website) for the products you use to demonstrate MU.
- Reporting Period
- Meaningful Use Objectives & Measures
- Clinical Quality Measures – report on 9 over 3 domains (options exist to report MU CQMs together with PQRS, e.g. via EHR (QRDA file), web-interface, ACO, etc.)
What to Report:
Depending on the measure, EPs will be asked to attest:
- Whether they are reporting based on all patient records or only those maintained in their EHR
- Whether any exclusion—if available—applies to them; if no exclusion applies, then EPs must either:
- Provide numerator and denominator for the measure, or
- Attest that EP has taken the required action, e.g., conduct a security review, enabled the functionality, submitted to registry(ies), etc.
- That data submitted for clinical quality measures was generated as output from the identified certified EHR technology
Expect updated resources from CMS
- CMS Attestation User Guide, 2015-2017 (Modified Stage 2)
- CMS Guidance on Supporting Documentation for Meaningful Use Audits