As the time approaches when potential financial incentives for the widespread use of electronic medical records (EMR) finally kick in, there is increasing excitement and anxiety among medical practices. Unfortunately, there is also a lot of confusion.

What is the difference between the financial incentives from the Stimulus Bill and bonuses from ePrescribing or those from PQRI (Physicians Quality Reporting Initiative)?

And what do you need to do to qualify for and then claim these incentives and/or bonuses?

Meaningful Use Incentives. Healthcare providers are eligible for certain incentives if they can demonstrate “meaningful use” of EMR, which is based on a set of goals and objectives spelled out in a matrix that is being developed by the Department of Health and Human Services, with input from various government and industry work groups. At this time, some of these goals and objectives are more clearly defined than others. But the first of these will not go into effect until 2011.

Medical practices must demonstrate a certain level of adoption and proficiency within these categories of objectives in order to qualify for the federal incentives, which can range from about $2000 to $18,000 per provider within a given year (depending on the year of adoption). There is also a maximum of $44,000 per provider over about five years. Providers who do not adopt EMR within the specified time-line will not only fail to qualify for incentives but will also face eventual financial penalties in the form of reimbursement cuts.

ePrescribing. Also known as eRx, this is “the electronic generation, transmission, and filling of a medicinal prescription using either an EMR or practice management system or a web interface system”. This is facilitated by the Surescripts/RxHub electronic prescribing network, which links the prescriber to a most retail pharmacies. If a provider is using an EMR system, the process automatically checks for such things as drug allergies, drug-drug interactions, and formulary issues. Enhancements to the system will allow for two-way communication between provider and pharmacy so patients in your office can be told when their prescriptions will be ready for pick-up.

In 2008, eRx was actually part of the PQRI program (see below). In 2009, this was spun off from PQRI resulting in a separate bonus for eRx reporting. In 2010, providers who use eRx at least 25 times can earn a bonus worth 2% of their allowable professional Medicare charges – all providers within a practice must meet this threshold to qualify. In 2011, however, ePrescribing will be folded into the meaningful use standards and providers will need to eRx at least 80% of their patients to qualify for the bonus. Beginning in 2012, there will be increasing financial penalties for those providers who do not participate.

PQRI Incentives. The Physician Quality Reporting Initiative (PQRI) gave physicians their first exposure to what was informally called P4P or “pay-for-performance”. Specific objectives were listed for certain diagnosis codes and providers could initially earn a 1.5% bonus. This year it will increase to 2%, after which it will probably decrease and then, as with eRx, become part of the meaningful use criteria.

What all of this means is that this year practices can still earn a 4% bonus of allowable Medicare charges for professional services. And that is no small potatoes for any practice, regardless of its size. So, why are most practices still not participating? Many practices have complained about technical problems with the program as well as trouble getting information about whether or not they met the threshold for their bonus payment.

We have been using a program developed by Protodrone LLC called PQRI Toolset that audits practice billing before it is sent, in order to verify qualification for both PQRI and eRx incentives. For 2009, we hit a reporting threshold of 99.7% for PQRI, and our bonus was the highest of any other practice that reported PQRI measures for our specialty. For more information on the PQRI Toolset call Protodrone at 1-888-569-5593 or go to www.pqritoolset.com (ed. note: some of our partners have a financial interest in Protodrone LLC).

[This article first appeared in the March issue of Ophthalmology Management magazine]

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EMR Update 6 – eRx and PQRI: Are Your Leaving Money on the Table?

This Issue:

• How can your practice qualify for ‘Stimulus Bill’ financial incentives?
• ePrescribing(eRx) & PQRI – what bonuses can you expect for each?
• How do you make a claim?
• Find out about PQRI Toolset, a tool that can help you claim bonus payments

(Note: MPT has a financial interest in Protodrone LLC, creator of PQRI Toolset)

Podcast: Download (Duration: 10:42 — 4.3MB)

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The Centers for Medicare and Medicaid Services (CMS) announced today a proposed outline for Meaningful Use criteria, in accordance with EMR implementation provisions under the Health Information Technology for Clinical and Economic Health (HITECH) Act, part of the American Recovery and Reinvestment Act (ARRA) of 2009. These specify some of the guidelines by which physicians can receive incentives of up to $44,000 per provider, over 5 years, beginning as early as 2011.

Stage 1 criteria (the first of 3 total) would cover 25 meaningful use objectives (and 23 for hospitals). These are listed under modules known as Health Outcomes Policy Priorities such as Improving quality and patient safety (use of drug-allergy interaction checks, use of ePrescribing, maintaining active medication list, etc.), Engaging patients and their families in their health care (e.g., provide patients with a copy of their health information), Improving care coordination (e.g., exchanging key clinical information among authorized entities), Improving population and public health (e.g., capability to submit data to immunization registries), and Ensuring adequate privacy and security for personal health information (through the use of appropriate EMR technology).

The implementation of Stage 1 meaningful use standards would begin in 2011. Stage 2 (which would essentially expand upon certain aspects of Stage 1) and Stage 3 (which would deal with achieving improvements in conditions of a national high-priority nature and population health outcomes) would follow later.

While this certainly doesn’t clear things up completely for the individual physician, every piece of information that trickles down from Washington is eventually analyzed and translated for all parties which have a vested interest in the process. Hopefully, resources such as this can help doctors stay informed and as up-to-date as possible.

If you have any comments or questions, please post them here. If we don’t know the answer we’ll certainly try to find someone who does.

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If you talk to anyone who is involved in the electronic medical records (EMR) industry, one of the biggest points of discussion is what is known as “Meaningful Use of EMR.” What started as a well-intentioned (by some) effort to establish standards for EMR software systems has morphed into political jockeying by corporations, consumer watchdogs, and others.

The US Dept of Health and Human Services (HHS) outlined these criteria for Meaningful Use of EMR:
1)    Improve quality, safety, efficiency, and reduce health disparities
2)    Engage patients and families
3)    Improve care coordination
4)    Improve population and public health
5)    Ensure adequate privacy and security protections for personal health information

And although each of these has defined goals followed by specific objectives and measures for the years 2011, 2013, and 2015, these still sound a bit ambiguous. Many industry experts, however, expect these to be more fine-tuned as the dates approach, but medical practices will have to stay informed to keep ahead of the curve.

Financial Incentives

As part of the ARRA (American Recovery and Reinvestment Act of 2009), financial incentives will be given to those physicians whose practices demonstrate “meaningful use” beginning January, 2011.

The incentive payment, according to CMS, is equal to 75% of Medicare-allowable charges for covered services in a given year, and maxes out as follows:

• Year 1 – $15,000
• Year 2 – $12,000
• Year 3 – $8,000
• Year 4 – $4,000
• Year 5 – $2,000

For those practices who are early adopters of the technology and hit the threshold for meaningful use in 2011 or 2012, the first year payment would be $18,000. Note that this only applies to Medicare; there are additional incentives for healthcare providers who have a certain threshold of Medicaid patients and/or who practice in a rural area. The threshold for office-based pediatricians is lower, and so they would be more likely to qualify for those additional funds.

[table courtesy of SoftwareAdvice.com]

Even considering the fact that EMR implementation may cost anywhere from $10,000 to $50,000 per provider, these incentives would certainly make that investment more palatable.

Those practices that procrastinate, however, will be penalized with cuts in Medicare and Medicaid payments:

• 2015 – 1%
• 2016 – 2%
• 2017 – 3%
• 2020 – 5% (maximum reduction)

So, how do you know if you qualify? According to the health IT blog NetDoc, to be a “meaningful EHR user”, a physician must satisfy three criteria:

1. Must use “certified EHR [EMR] technology”
2. Must demonstrate that the certified EHR technology is connected in such a way that it provides for the electronic exchange of health  information to improve the quality of health care, such as promoting the coordination of care (using HL7 or XML standards)
3. Must submit information on clinical quality measures specified by HHS (such as PQRI)

Some physicians have told me that because there isn’t a final definition of what is considered “certified EHR technology” they are just going to wait. Big mistake. Most health care IT experts working on and advising on this issue feel fairly strongly that the Office of the National Coordinator for Health Information Technology (ONCHIT) will set CCHIT (Certification Commission for Health Information Technology) criteria as the standard for EMR certification.

CCHIT is a non-profit organization funded by various corporations and groups such as the American College of Physicians and the American Academy of Family Physicians, and was recognized by the US Dept of Health and Human Services (HHS) as a certifying body in 2006.

Some critics, however, charge that CCHIT is a shill for the Healthcare Information and Management Systems Society (HIMSS), the healthcare industry’s membership organization focused on healthcare IT. Although made up of both corporate and individual members, these critics feel that their goal is to corner the market for certain major EMR players. Nevertheless, unless or until there is an alternative, most EMR vendors are using CCHIT certification as the benchmark.

In addition to the EMR certification criteria, the ONCHIT is expected to adopt an initial set of standards and implementation specifications by the end of the year 2009.

Timeline

So, is too late to implement EMR in your practice and still qualify for the financial incentives? Well, that depends on the size of your practice, type of specialty, and how motivated your doctors and staff are to go paperless. Just don’t expect to run down to Office Depot, buy an EMR program and launch it the next day (although there is talk about WalMart getting into the EMR business, but we’ll leave that story for another day…)

According to MBA HealthGroup, these are some reasonable time frames to expect for EMR Implementation:

• Stage 1 – up to 6 months – researching vendors, getting buy-in, setting up an EMR committee, checking out demos, and making a final decision on the EMR system
• Stage 2 – up to 5 months –  time it will take to actually ‘go live’. In the meantime, adapting workflow to EMR system you chose, ordering hardware, and standardizing processes
• Stage 3 – between 6 and 12 months – amount of time it will likely take to achieve “meaningful use”, which includes ePrescribing, documenting electronically, and ability to report certain items (which are still being determined)

[timeline courtesy of MBA HealthBlog]

Smaller groups and solo doctors may be able to purchase a more basic, “out-of-the-box” EMR system and more quickly adapt their workflow to the system, rather than vice versa in the case of larger medical practices. But, the one thing you can count on with EMR implementation is that you can’t count on anything – that is why some sort of timeline is important [see EMR Implementation Rollout].

What this boils down to is that those practices that have already started implementing EMR will have a good shot at getting those higher financial incentives. On the other hand, physicians who have been wishing that the whole idea of EMR was just a fleeting fad may not only miss out on these incentives but may also face cuts in their reimbursement.

Questions? Comments? Post them below

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Much of the new regulatory information coming out of Washington is getting increasingly more difficult to translate into English. I was recently asked whether a medical practice could use Google’s free email service GMail instead of spending money on a mail server and its associated server software. After checking with our own head of IT, I discovered it is a bit more complicated than just picking where you want to store your emails.

Buried deep within the HITECH (Health Information Technology for Clinical and Health) Act’s Sub-Title D is the language on privacy directly related to HIPAA (Health Insurance Portability and Accountability Act). Since most of us (health care providers) are considered “covered entities”, we must ensure that not only our employees and staff abide by these rules but our “associates” do as well.

If we started using GMail for our practice’s communication, there would be patient information located on Google’s mail servers and Google would, in fact, be considered one of our associates. This would require entering into a Business Associate Contract with Google, Inc. What do you think the chances are of Google, or a similar technology firm, signing a confidentiality agreement with perhaps thousands of medical practices across the country? I thought so.

Digital Business Law Group has an analysis of the language found in HITECH’s Sub-Title D – Privacy section that makes it a bit easier to comprehend.

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A recent article in the AMA news discussed some of the continued ambiguities of the “Meaningful Use” prerequisites handed down by the Health IT Policy Committee. Nevertheless, it does give everyone an idea of where they are headed. Generally speaking, meaningful users are defined as healthcare-providers who are using E-Prescribing, that their EMR technology is connected in such a way that there is an electronic exchange of health information, and that clinical quality measures are submitted to the government via electronic means.

For practices that fail to have meaningful use by the end of the set timelines, not only would there not be incentives, there would actually be penalties in the form of reductions in Medicare reimbursements – unless the practice could demonstrate some type of financial hardship that would prevent adoption of EMR.

If you don’t think the financial incentives are worthwhile, thing again. SoftwareAdvice.com has a nice explanation of what medical practices have to gain by getting the ball rolling and not waiting until the perfect EMR solution falls out of the sky and hits them in the heads (note: it ain’t gonna happen).

To give you an idea of the timeline we are talking about, here is a graphic from a committee report (courtesy of Digitized Medicine). So, what are you waiting for?

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