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With apologies to Will Smith fans (Fresh Prince era):
Here´s what eligible providers need to know about getting incentive dollars from CMS for the meaningful use of electronic health records in under 3 minutes. The American College of Medical Informatimusicology presents the Meaningful Yoose Rap, written and performed by Dr. HITECH, aka Ross D. Martin, MD, MHA. Directed by Ishu Krishna.
In part 1, we discussed some of the nuances of registering for Meaningful Use (MU) reporting and why most practices would be better off waiting until 2012 – such as still being able to qualify for E-Prescribing incentives. In part 2, we give you an action plan for getting your practice ready for MU.
How is the MU Reporting Actually Done?
For 2011, practices could merely report they are using EHR in a Meaningful Use without actually sending anything to CMS – this is known as attestation. For 2012, attestation alone is insufficient. CMS will require practices to report on their meaningful use criteria, which for most practices will be a total of 20 (all 15 Core Set and 5 out of the 10 Menu Set items). Some items in the Core Set only need to have functionality enabled (such as Exchanging Critical Information) or performed at least once (Security Risk Analysis). Others will become a daily part of a practice’s workflow (such as Smoking Status or Demographics) and must meet a certain threshold (such as 50% of the number of unique patients seen for the year), unless they are not appropriate for a physician in a particular specialty. For example, an ophthalmology practice does not routinely check vital signs so would report a denominator of zero for that criterion. For a list of the Core and Menu Set objectives see EHR Incentive Programs
Many certified EHR systems will have a means to upload the report files to CMS, either directly or using report-generating software such as Crystal Reports, while other practices may use a third party solution such as registries, the same ones that were helping physicians report PQRI. But while Stage 1 may consist of simply requiring a practice to report on a specific criterion, Stage 2 may contain additional requirements and higher thresholds.
An example of this would be providing a Clinical Summary Report for a patient: In Stage 1, you can document the patient’s preferred format but do not necessarily need to supply it to them in that format, whereas in Stage 2, you might have to comply with that request. And this can make the reporting process that much more onerous.
Advice from a Practice Ready for MU
Sandra Regenye, Director of Billing for Horizon Eye Care in NJ, has these recommendations for getting a start on Meaningful Use:
Getting Ready for the Reporting Process
For this year, the first year of Meaningful Use, practices are only required to attest to the fact that they are meeting the MU requirements. Attestation means you are collecting the data in some fashion, even if you are only doing it manually, as on a spreadsheet. For 2012, practices will need to actually collect and submit the data to CMS. The attestation process officially began on April 18, 2011. CMS offers webinars and updates with specific details. Ms. Regenye says these have not been real clear, “but they are getting better.” She recommends that all practices register with Medicare now, even if they don’t have an EMR system yet.
Like many things in life, you can either choose to do something or wait until something happens to you. Many physicians are taking the latter approach when it comes to electronic medical records implementation and the Meaningful Use (MU) incentives from CMS. Their feeling is that it would be safer to wait until EMR systems are perfected (which they never will be), to wait until the government certifies a particular EMR system (which they never will do), and until the MU requirements are 100% unambiguous (dream on). These things may never come to pass. And after 2012, the MU incentives will start to decrease and then reimbursement penalties will kick in.
Meaningful Use: What’s the Point?
In his 2004 State of the Union address, President George W. Bush outlined his plan for the adoption of electronic health records that could be accessed by all citizens in the United States. The Department of Health and Human Services (HHS) then created a 10-year map to implement that plan, although there was no specific funding set. Then in 2009, as part of the American Recovery and Reinvestment Act of 2009, the HITECH Act (Health Information Technology in Economic and Clinical Health) allocated almost $30 billion to push the adoption of EHR through the use of financial incentives. Subsequently, rules were created that required those providers seeking incentives to prove they were using certified electronic health records technology according to a set of guidelines of quality healthcare, or in a ‘meaningful use’ manner.
Non-MU Incentives Aren’t Too Shabby Either (or Why Waiting Until 2012 May Be More Profitable)
In the case of our practice, we had transitioned our old practice management (EPM) system to a new one with an integrated EMR a few years ago, but felt it prudent to wait a bit before we attempted to implement the EMR module. That came about at the end of 2008, so now that we have about 2 ½ years of ‘live’ experience with EMR, we are turning our attention to the MU incentives. But we haven’t been idly sitting by. Using software we developed in-house, we have been qualifying for both PQRI (Physician Quality Reporting Initiative) and E-Rx (E-Prescribing) incentives since their inception, in 2007 and 2009 respectively. Those have resulted in as much as a 4% bonus of our annual Medicare fees.
Although Stage 1 of Meaningful Use officially begins 2011 – with Stages 2 and 3 slated for 2013 (for the time being) and 2015, respectively – we decided that we would wait until 2012 before seeking the Meaningful Use (MU) incentives. The Office of the National Coordinator on Healthcare IT (ONC) announced that practices can qualify for the full MU incentives starting either in 2011 or 2012. They also ruled that practices can also get PQRI incentives concurrently with the MU incentives. So why would we wait another year? ONC also ruled that MU would disqualify ERx incentives, so this would give us another year of E-Prescribing bonuses plus another year to get our practice ready for MU. This means, however, that we have only one year to prepare for Stage 2 in 2013 instead of two, but this mostly builds on the work that needs to be done for Stage 1. (And, did I mention this means more money?)
Some Practices are Ahead of the Curve
Horizon Eye Care is an eight-doctor ophthalmology practice in Margate, New Jersey. Like our practice, they use an integrated EMR/EPM system from NextGen, but they have been using the EMR module for the past 10 years. According to Sandra Regenye, Director of Billing, they were ready to qualify for MU this year, but also decided to wait until 2012, since there was no decrease in the total incentives for waiting. And in addition to being able to collect ERx incentives for 2011 (which are excluded under MU), this is allowing their practice to perform simulations to test run the reporting process.
Ms. Regenye points out that it is the practice that must be a meaningful user of EMR, not the EMR system itself. “If you are not using your EMR in an appropriate manner, then you are not a ‘meaningful user.’ Even the best, certified EMR system cannot magically qualify you for MU incentives. There is no ‘plug-and-play’ for meaningful use. “
In part 2, we’ll map out your Meaningful Use incentives action plan.
On American Medical News, a report on a meeting of the AMA National Advocacy Conference found CMS Administrator Donald Berwick, MD, answering some tough questions, including the effect that some reimbursement cuts have had on certain specialties and challenges to EMR adoption.
Also on the agenda was David Blumenthal, MD, the outgoing national health information technology chief (ONCHIT), who states that “physicians who fail to invest in EMRs will see their practices decline in value relative to colleagues who do invest” and that “they also will face more difficulty recruiting young physicians and attracting patients who will expect such technology.”
“Certified” is the $44,000 buzzword prefixing electronic health records (EHR) software. To qualify for Health Information Technology for Economic and Clincal Health (HITECH) Act incentive payments, you must use an EHR that is certified by the government. Additionally, you must use a system – or systems – that offer 100% of the functional and security capabilities required to meet “Meaningful Use” criteria.
Many EHR vendors are promoting their products as “certified,” but the claim can be misleading. There are three ways they could lead you astray:
Alternative Certifications
Before the HITECH Act, two organizations certified medical software:
In an effort to stand out from the other 300+ EHR systems on the market, vendors widely promote their CCHIT or KLAS credentials. They may even tack the word “certified” onto their CCHIT or KLAS approved product. This muddies the water for providers. They have to distinguish between CCHIT, KLAS and certification from an ONC-Authorized Testing and Certification Body (ONC-ATCB). While CCHIT and KLAS are meaningful credentials, they’re not the certifications that qualify for incentive funds.
This is especially confusing because CCHIT is now one of six organizations approved to certify EHRs for the HITECH Act. So, if an EHR vendor claims they have CCHIT certification, you’ll need to clarify which one. Is it ONC-ATCB certification, or one of CCHIT’s independent credentials?
Complete EHR vs EHR Module
Software vendors can receive ONC-ATCB certification for a complete EHR or an EHR module. This means a product doesn’t need to meet all criteria for Meaningful Use – instead, it can be partially certified if one or more functions meet a subset of requirements. For example, a vendor could certify their e-prescribing application or their patient portal.
This under-publicized detail could cost you thousands of dollars; by itself, a certified EHR module won’t make you eligible for incentive payments. You must use two or more modular EHRs that, combined, meet 100% of the ONC criteria. So while vendors can officially promote a module as having ONC-ATCB certification, it may fall short of making you eligible.
Guaranteed Incentive Payments
Be mindful of guaranteed incentive payments. It is reasonable for a vendor to guarantee they’ll meet certification criteria. In fact, you might make it a requirement in your purchase decision.
However, guaranteeing incentive payments is altogether different. Technology alone won’t make you eligible. EHRs are just a means to an end. Ultimately, you are responsible for achieving Meaningful Use status. So be wary of this type of guarantee. Read the fine print and find out how you are reimbursed if you don’t qualify for incentive payments. Does the vendor reimburse you the full amount of lost incentive payments? Or do you just get reimbursed for the cost of the software? You shouldn’t purchase a system based on this guarantee alone.
Five Key Questions to Ask Vendors
To help you avoid thse pitfalls, we put together a list of 5 questions to ask vendors. Answering these will put you in a good position to become eligible for incentive payments.
This article was written by Houston Neal of Software Advice, a free online resource that presents reviews and comparisons of electronic medical record software. The original article can be viewed at Playing Games for ONC Certification.
That feels like it should be said with a German accent. But seriously, the date for registration for Medicare’s EHR incentive payment program begins on January 3, 2011. According to a report on MassDevice.com, the CMS and the ONCHIT (Office of the National Coordinator for Health Information Technology) have announced key milestones for implementation of the incentive program’s first year:
Jot these dates down, or bookmark that page. In addition, we will be keeping you up-to-date with these milestones in the coming months.
Please post any comments on this topic below.
According to a report in Health Data Management magazine, InfoGard Laboratories has been selected by ONCHIT (Office of the National Coordinator for Health Information Technology) as the latest entity for certifying EHR (electronic health records) systems. Based in San Luis Obispo, California, InfoGard, a federally accredited IT security testing laboratory since 1995, joins current certifiers CCHIT and the Drummond Group.
The Certification Commission for Health Information Technology (CCHIT), one of the two entities approved for certifying electronic health records (EHR) systems, has just announced the first wave of EHR/EMR products (33 for now) officially achieving Stage 1 certification.
The ONC-ATCB 2011/2012 certification program tests and certifies that [a particular] EHR technology is capable of meeting the 2011/2012 criteria approved by the Secretary of Health and Human Services (HHS). The certifications include Complete EHRs, which meet all of the 2011/2012 criteria for either eligible provider or hospital technology and EHR Modules, which meet one or more – but not all – of the criteria. [This certification] does not represent an endorsement of the certified EHR technology by the U.S. Department of Health and Human Services nor does it guarantee the receipt of incentive payments.
The Office of the National Coordinator for Information Technology (ONCHIT) has announced the first two companies that have been authorized to test and certify EHR (electronic health records) systems, according to a report by the American Academy of Family Practice.
CCHIT (The Certification Commission for Health Information Technology), one of the entities, is no big surprise to anyone who has been following this topic. The other entity, the Drummond Group Inc., may be less familiar to many. The Austin, Texas, based firm says it has been “working diligently for many months to meet the stringent criteria set forth by the ONC[HIT] to become certified as an ATCB (authorized testing and certification body).”
For those critics who complained that CCHIT was going to monopolize the certification process, this may come as welcome news. But there are still some small EMR vendors who fear they will be locked out of the market.
Recently I wrote about a Harvard study that found evidence that physicians that use electronic medical records systems (EMRs) are less likely to be involved in a malpractice lawsuit. But regardless of whether your charts are better documented and therefore make you less of a target for a claim, does using EMR make you practice medicine better?
According to the Huffington Post Investigative Fund, there have been several cases of EMRs gone amok. In most cases there was no harm to patients. But they quote Dr. Jeffrey Shuren of the FDA as attributing six deaths and 200 injuries to poorly implemented CPOE (computerized physician order entry). Many critics of the government’s EMR implementation plan point to these cases as examples of not enough regulation and oversight.
On the other hand, the ONC (Office of the National Coordinator [for Health Information Technology]) spokesman says the they are working closely with a number of organizations including the FDA to improve safety. Critics say that the ONC has too friendly a relationship with the EMR industry, and feel that the FDA needs to be given more authority to collect and analyze errors caused by EMR systems.
