CMS Provides Guidance on Meaningful Use Appeals Process
CMS has released additional guidance for hospitals and eligible professionals on the Medicare EHR Incentive Program appeals process. The CMS Office of Clinical Standards and Quality (OCSQ), together with Provider Resources, Inc., the CMS appeals support contractor, will accept and review appeals filed by eligible professionals and hospitals. For those individuals and organizations participating in the Medicaid EHR Incentive Program, each state will have its own process for Medicaid appeals.
CMS began accepting appeals December 1, 2011. Appeals may be filed by eligible professionals and hospitals through an online web portal. In addition to eligibility determinations, eligible professionals and hospitals may appeal denials of status as a meaningful user as well as incentive payment calculations.
For hospitals, the deadline to appeal eligibility determinations has been extended to January 30, 2012. In general, a hospital or eligible professional has sixty (60) days after the issuance of an incentive payment to appeal the amount of the payment made. Additionally, hospitals and eligible professionals have thirty (30) days to appeal denials of their status as a meaningful user after receipt of a letter with the results of a meaningful use audit conducted by CMS. Limited extensions will be granted on a case-by-case basis under extenuating circumstances.
The first OCSQ informal review determination was released on January 19, 2012. CMS plans on making this and other OCSQ appeals opinions available in February on its EHR Incentive Program Appeals website. These opinions may provide additional guidance to eligible professionals and hosptials seeking to attest in 2012 for their first payment year.
