The CMS EHR Incentive Program attestation for Medicare eligible hospitals and critical access hospitals (CAHs) has moved to a new platform, the QualityNet Secure Portal (QNet). Starting this year, eligible hospitals and CAHs must use QNet to report both meaningful use and quality attestations. Successfully attesting every payment year remains important to avoid Medicare payment adjustments (more information is available from CMS here). The deadline to attest for calendar year 2017 is February 28, 2018. In advance of this deadline, CMS hosted a Q&A session on February 8, 2018, to field questions about the transition to QNet and about the Medicare attestation process. Once available, CMS will post its slide deck from the presentation here.
The session was led by CMS representative Nichole Davick and also included several representatives from the QNet Help Desk. Ms. Davick opened with an overview of the QNet changes and process. Highlights of her presentation include:
- QNet Live January 2, 2018. As of January 2, 2018, Eligible Hospitals and CAHs must use QNet to submit their EHR Incentive Program attestations for calendar year 2017.
- Limited Functionality for Previous System. The previous system (the CMS EHR Incentive Program Registration & Attestation System) will be available only for Medicare eligible hospitals and CAHs to register for the EHR incentive program and will house prior year attestations in view only format. This system will still be available for Medicaid-only hospital and CAH attestations, but such hospitals and CAHs should contact their state Medicaid agencies directly for specific information on how to attest.
- Vendors Cannot Electronically Attest for Clients. Vendors will not be able to electronically attest in QNet on behalf of hospital clients. Data output received from vendors will have to be entered into the system manually, so eligible hospitals and CAHs should allow enough time for this process before the attestation deadline. Ms. Davick did note that CMS and QNet are working toward improving this functionality in the future.
- Creating an Account. To use the QNet system, eligible hospitals and CAHs will either need to create an account on QNet or update their existing accounts by adding the “Meaningful Use” role. There are a variety of QNet user guides and hospital transition resources available on the CMS.gov eligible hospital information webpage.
In addition to Ms. Davick’s overview, CMS representatives on the call also answered a number of pre-submitted questions, as well as additional questions submitted during the webinar. Many of the questions dealt with specific technical issues encountered by various submitters, or were only relevant to the submitter’s specific situation. However, there were several key takeaways that are generally applicable for all QNet users:
- Leave Sufficient Time to Meet the Deadline. As with any new system, various submitters encountered difficulty navigating QNet for the first time. In addition, the system itself has had a few technical issues in the first few weeks it has been live for this attestation process. Accordingly, eligible hospitals and CAHs should start the submission process as soon as possible to allow time for resolving any issues that may arise.
- Enter a Help Desk Ticket. A number of the questions were about issues or circumstances specific to individual submitters. The consistent answer from CMS to these types of questions—whether technical or substantive—was to submit a ticket to the QNet Help Desk.
- Confirming Submission. There were repeated questions about how a submitter will know that their submission was successful. In contrast to the previous system, QNet does not provide a “passed” status after completion. Instead, providers must carefully review the fields in the application and may also review a summary report to confirm that all fields were completed. Such review of the provider’s entered data or the summary report are the only methods available to confirm that all fields have been completed. The summary report can be run from the secure QNet portal site. The representatives did note that providers will be able to go back in to the system and correct any errors prior to the February 28, 2018 deadline, but no affirmative confirmation of completion is provided in QNet. No explanation was given as to why this functionality is not available or whether it will be available in future years.
- Hardship Exception Application. Several questions focused on the 2017 Hardship Exception application. CMS provides greater detail on its website, but in short, the Hardship Exception application is available to eligible hospitals or CAHs to apply for an exemption for one calendar year from the Medicare payment adjustments if they: 1) are unable to demonstrate meaningful use of Certified Electronic Health Record (EHR) Technology under the Medicare EHR Incentive Program, and 2) can show that demonstrating meaningful use would result in a significant hardship. CMS anticipates that the application and the email address where it should be filed will be available in mid to late Spring 2018. CMS will announce via listserv when the application is available and will post it to the CMS EHR website. CMS anticipates that the hardship deadline will be in July 2018 for eligible hospitals and November 2018 for CAHs (which is consistent with the timing in 2017 for the hardship applications for the 2016 reporting year). This information will also be published via CMS’s listservs and posted on the CMS website.
Eligible hospitals and CAHs that plan to complete the CMS EHR Incentive Program attestation for calendar year 2017 should move quickly to create an account in QNet and begin the attestation process. The application will remain open until the February 28, 2018 deadline, so starting early should allow time to address any technical issues that may arise during the first time attesting on QNet. Providers should also register for CMS’s listservs and monitor CMS’s website, as CMS will use them to disseminate important information in the coming months.