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You now have rules, timetable to shoot for EHR incentives
e-Reports, August 9, 2010
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Centers for Medicare & Medicaid Services (CMS) laid out a map to direct you to ‘meaningful use’ of electronic health records, along with definitions, timetables and certification rules

Meaningful Use: Core Objectives

  1. Computerized physician order entry (CPOE)
  2. E-prescribing
  3. Report ambulatory clinical quality measures to CMS/states
  4. Implement one clinical decision support rule
  5. Provide patient with electronic copy of their health information on request
  6. Provide clinical summaries for patients for each office visit
  7. Drug-drug and drug-allergy interaction checks
  8. Record demographics
  9. Maintain up-to-date problem list of current, active diagnoses
  10. Maintain active medication list
  11. Maintain active medication allergy list
  12. Record and chart changes in vital signs
  13. Record smoking status for patients 13 and older
  14. Capability to exchange key clinical information among providers of care and patient-authorized entities electronically
  15. Protect electronic health information

Meaningful Use: Menu Objectives (select 5)

  • Drug formulary checks
  • Incorporate clinical lab test results as structured data
  • Generate lists of patients by specific conditions
  • Send reminders to patients per patient preference for preventive/follow-up care
  • Provide patients with timely electronic access to their health information
  • Use certified EHR technology to identify patient-specific education resources and provide to patient, if appropriate
  • Medication reconciliation
  • Summary of care record for each transition of care/referral
  • Capability to submit electronic data to immunization registries/systems*
  • Capability to provide electronic syndromic surveillance data to public health agencies*

*At least one public health objective must be selected.

Technology assistance available for three key EHR vendors
The Indiana Health Information Technology Extension Center (I-HITEC), one of Indiana’s two regional extension centers funded by federal health care legislation, announced it will aid small practices with selecting and implementing health information technology from three select vendors.

Those three vendors are: athenahealth, iSALUS Healthcare and MDLand.

I-HITEC vetted more than 200 vendors and chose the three for their ability to meet the needs of small and/or rural health care practices. The vendors have agreed to provide preferred pricing and terms.

athenahealth is also an ISMA preferred vendor. Practices can qualify for a discount on purchases when all members of the practice are ISMA members. To learn more, visit here.

I-HITEC began operating in April and currently accepts physician practices into its program; see details at this website.

A second Tri-State Regional Extension Center serves practices in some Indiana counties and is operated by HealthBridge. Visit HealthBridge's website for more information.

If you’d like some help paying for an electronic health record (EHR), federal money is available – if you follow the rules. You can qualify for incentives under either Medicare or Medicaid and net a portion of the $27 billion the government will spend over the next 10 years.

But you must comply with “meaningful use” standards, submit details on core clinical quality measures and use a system that meets federal certification requirements.

After issuing proposed rules last December, CMS poured through more than 2,000 comments and announced final rules for the program in July. Officials said comments indicated criteria were set too high, flexibility was lacking and administrative tasks too numerous.

The HITECH Act specified three components to meaningful use; an EHR must be used:

  1. In a meaningful manner (e.g., e-prescribing)
  2. For electronic exchange of health information to improve quality of care
  3. For submitting clinical quality and other measures

Changes to make the incentives more achievable include reducing the percent of medications that must be sent electronically from 75 to 40 percent. The term “hospital-based” physician was clarified as “one who performs substantially all of his or her services in an inpatient setting.”

Plus, greater flexibility was allowed in meeting quality measures. Data submission on three core clinical quality measures and three additional measures is now required.

“It’s all about outcomes,” said John Clark, M.D., J.D., director for Quality and Informatics for Clarian Health System. He noted the differentiation between the technical piece, with which a vendor can assist, and the clinical side where you must demonstrate you are using technology in a way that helps patients. “If you don’t prove that, you will not get the funds.”

Stage 1 (2011-12) rules include:

  • Eligible professionals must report on 20 of 25 meaningful use objectives.
  • The 20 objectives include a core 15 and another five from a menu of 10 options.
  • A reporting period was determined as 90 days for the first year and one year subsequently.
  • To meet objectives/measures, 80 percent of patients must have a record in a certified EHR.

Some objectives will not be applicable to every physician’s clinical practice; in such cases, participants would be excused from meeting that measure. Additional requirements in Stage 2 and 3 will “raise the bar for performance on IT and quality objectives in later years.”

“CMS has broadly indicated penalties are coming in 2016,” said Dr. Clark. His colleagues in smaller independent practices believe the costs to set up data reporting would not be recouped in bonus payments.

He said their choices may be either align with a hospital in a legal arrangement that allows the hospital to sponsor an EHR, join a larger group that has resources to support IT requirements for meaningful use reporting, or simply accept the reimbursement cuts. Some small practices may be forced to consider dropping out of Medicare completely when penalties begin.

And then there’s certification
Qualifying for the federal incentives also means using a “certified” EHR system, but none yet exist. While final certification criteria became available July 13, it will likely be fall before EHR products clearly meeting certification standards are available.

Experts agree that waiting is not a good thing. Physicians seeking the incentives should be examining work processes and potential vendors NOW. But be cautious about whom you turn to for answers.

Some vendors, like ISMA’s partner athenahealth, are guaranteeing today’s purchasers their technology will meet federal certification standards.

Guidance is available from an unbiased, vetted source, Maxwell IT, another of the ISMA’s preferred vendors.

Get help, learn more
Remember that Indiana has two Regional Extension Centers to help you qualify for EHR incentives. Learn more about them from this June 1 ISMA Reports article.

Keep reading ISMA Reports for more information. Visit the AMA website on health IT and EHR for more information.

Also, plan to attend the CME programming at the ISMA annual convention in Indianapolis on Friday, Sept. 24. Learn more on the ISMA Convention website.

Want more details?
Official site for the EHR inventive programs 
Press release on meaningful use 

Final rules in the Federal Register 
Final Rule information (large file)
More information 

Information from HIMSS 

Summary from the New England Journal of Medicine
Timeline for EHR Incentive Program
January 2011 Registration begins
For Medicaid, states may launch programs
April 2011 Attestation for Medicare EHR program begins
May 2011  EHR incentive payments begin 
Feb. 29, 2012  Last day for physicians (and other eligible professionals) to register and attest to receive incentive in 2011
2015  Medicare payment adjustments begin for non-meaningful users of EHR
2016 Last year to receive Medicare EHR incentive; last year to initiate participation in Medicaid EHR incentive program
2021  Last year to receive Medicaid EHR incentive payment
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