What’s the Probability you’ll receive EHR Stimulus Payments?
Posted on 25. Feb, 2010 by Brad Rourke in General Information
Kathleen Sebelius, Secretary Health and Human Services (HHS), was required to issue initial guidance on ‘Certification’ and ‘Meaningful Use’ of Electronic Health Records (EHRs) by December 31, 2009. This requirement is pursuant to the 787 billion dollar American Recovery and Reinvestment Act (ARRA), also referred to as the stimulus plan.
Per the HHS website, on December 30, 2009, the Office of the National Coordinator for Health Information Technology (ONC) issued an Interim Final Rule (IFR) that specifies the Secretary’s adoption of an initial set of standards, implementation specifications, and certification criteria for health record technology.
In short, although there is still much work to be done in 2010, the HHS stimulus program is on track, and therefore the probability is increasing that EHR technology adoption stimulus funds will be available to you in 2011.
What Stimulus Funds are available for Optometrists?
A component of the February 2009 Stimulus Plan was enacted to improve health of all Americans as well as improve the efficiency of healthcare delivery. To this end, qualifying providers (e.g. Optometric Doctors), who demonstrate ‘Meaningful Use’ of a ‘Certified EHR’, are eligible under the Medicare program for up to $44,000 in incentive payments. The incentive payments are meant to offset the cost of acquiring, deploying, training and using EHR technology.
Beginning in 2011, incentive payments will be made to Providers through Centers for Medicare and Medicaid Services (CMS) provided adoption and Meaningful Use of Certified EHR technology is demonstrated. The fundamental terms of payment are as follows:
• Up to $18,000, $12,000, $8,000, $4,000, $2,000 for years 1 through 5, respectively beginning in 2011 paid out via bonus payments of 75% of your Medicare reimbursements.
• Adoption and demonstration of meaningful use of Certified EHR technology is required by 2012 in order to be eligible for the full $44,000 incentive.
• A penalty of 1% per year of your Medicare reimbursements will go into effect if you have not demonstrated meaningful use of Certified EHR technology by 2015; the penalty is restricted to a maximum of 5 years.
• There are no stated restrictions on the use of incentive payments received.
What is Meaningful Use of a Certified EHR Technology?
The Interim Final Rule (IFR) regulation filings of December 30, 2009 bring us much closer to definitively answering this question.
The two IFR regulation documents that were filed with the Office of the Federal Register by HHS are:
1. Medicaid & Medicare Programs; Electronic Health Record Incentive Program; 556 pages in .pdf format.
2. Health Information Technology: Initial Set of Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology; 136 pages in .pdf format.
They are available at: http://www.federalregister.gov/inspection.aspx#special
Much of the content is based on the work done by the Health Information Technology (HIT) Policy Committee. The HIT Policy Committee was created by Stimulus Plan legislation and is charged with recommending definitions of Certified EHR Technology and Meaningful Use.
The first document sets out what will be required to demonstrate Meaningful Use. HHS has deemed it appropriate to define the requirements for Meaningful Use in three stages:
Stage-1 defines what Meaningful Use of Certified EHR technology is for purposes of 2011 or year 1 incentive payments. There are 25 Stage-1 one criteria for Providers, a reliable summary of the 25 criteria along with measures can be viewed at:
http://www.healthcareitnews.com/news/eligible-provider-Meaningful Use-criteria
Stage-1 Criteria Examples include:
• 80% of orders must be computer physician order entry (CPOE).
• 80% of all patients must have at least one ‘electronic documentation’ of allergy and medication or an indication of ‘none’.
• 75% of prescriptions written must be transmitted electronically.
• 80% of patients who request a copy of their health record electronically must receive it with in 48 hours.
Stages 2 and 3, which are not fully defined, will focus on the exchange of clinical data and decision support tools respectively. Stage-2 definitions are expected by the end of 2011 and Stage-3, by the end of 2013.
Are Certified EHRs are available now?
As of January 2010 there are no HHS certified EHRs available for purposes of the stimulus plan incentive payments. It is quite likely there may not be HHS Certified EHRs available until very late in 2010 or perhaps early 2011.
The second document filed with the Federal Registrar, mentioned above, which covers the Interim Final Rule of certification criteria for EHR technology must be finalized before you will see HHS certified EHRs.
The IFR document makes an important distinction of ‘certified EHR technology’ as apposed to ‘certified EHRs’. The distinction is important because providers can use multiple vendors of EHR technology to satisfy the 25 stage-1 criteria rather than adopting one certified EHR that satisfies all 25.
What should ODs be doing?
Before CMS will cut you a check, you’ll need to demonstrate you are using certified EHR technology in a “meaningful way”.
First, I recommend you become familiar with the 25-Stage 1 Meaningful Use criteria. To do this you can read the Health Care IT news above or other similar summary sources. As an alternative you can work your way through the Interim Final Rule. The latter is a daunting task, but it is certainly more reliable to obtain the information from the original source versus reviewing another’s summary.
Secondly, although there are no HHS certified EHR technologies available now I still recommend, if you haven’t done so already, that you adopt a Practice Management system with an embedded EHR. The EHR should be from a reputable vendor who is moving toward certification, and it’s critically important that you have an indefinite contractual right to access patient data with the EHR software. The benefits and advantages of using electronic health records over paper records are well documented.
As a final point on this subject, using Certified EHR Technology is not a legislated requirement that requires your compliance. The stimulus plan legislation explicitly sets out that adoption is voluntary (Section 3006, Title VIII), but as mentioned above, providers that do not adopt will be charged a 1% penalty of Medicare reimbursements.
What is the Williams Group / Practice Director Doing to help you?
I’d like to assure you we will follow Meaningful Use and Certification developments closely. We will do our best to help our clients and interested parties understand what is involved and what must be done to satisfy EHR certified technology requirements. The integrated EHR that is embedded into Practice Director’s practice management software system is developed to help you with this endeavor.
For more information contact:
Brad Rourke, CPA
http://twitter.com/bradleyrourke
Vice President, Williams Group
Practice Director Software
Optometry EHR & Practice Management Software
www.practicedirector.com
brourke@practicedirector.com
1-800-676-9096 ext 38