By the Greenway Medical Staff
Stated meaningful use goals of the HITECH
Act within The American Recovery and
Reinvestment Act of 2009 (ARRA) mirror those
of physician practices: early detection,
prevention, and management of chronic
diseases, for example.
Additional incentives seek to improve the
coordination of care and information among
hospitals, laboratories, and physician
offices; improve healthcare quality, reduce
medical errors, reduce health disparities,
and advance the delivery of patient-centered
medical care.
Getting there, specifically in terms of
qualifying for up to $44,000 through
Medicare and up to $63,750 through Medicaid
pathways, paid per eligible professional
within a practice of any size, is a matter
of finding the pathway that best suits your
practice, specialty and patient volume.
Now that the Centers for Medicare and
Medicaid Services (CMS) and the Office of
the National Coordinator for Health
Information Technology (ONC) are just a few
months away from releasing final meaningful
use criteria, with CMS covering physicians
and ONC overseeing the functionality of
electronic health records, it's still safe
to consider the requirements as a meaningful
use checklist for your practice and your
existing or desired EHR.
The initial criteria established up to two
dozen functionality standards each for
providers and EHRs because overall,
meaningful use is a two-part consideration.
On one hand, certified EHRs must have the
necessary functionality to support
meaningful use. On the other, practices must
show they are using the functionality in a
meaningful way within proposed criteria to
qualify for the appropriate incentives.
(That checklist of functionality, details on
eligibility within the Medicare and Medicaid
pathways and details of new certification
criteria for EHR systems to be eligible to
report meaningful use, can be found by
clicking
here.)
With the public comment phase of the
original proposals having come to a close
March 15, expect final regulations to
subtract or limit some of the functionality
criteria. By regulatory definition, and
again based on public comment, do not expect
any expansion of the CMS or ONC list of
functionality requirements.
There's still plenty of time to qualify.
Incentive funds for Medicaid providers are
available as early as October 2010 and funds
for Medicare providers are available as soon
as January 2011. Providers are free to begin
the process when they are ready. However, ARRA funds are only available through 2015.
Within the Medicare pathway, the initial
criteria states that eligible professionals
must only achieve meaningful use reporting
for 90 continuous days to qualify in the
first year. Therefore the provider can begin
reporting meaningful use as late as October
of 2011 and still qualify for the largest
amount of initial funding. (Medicaid
incentives can be subject to individual
state plans in regards to timetables and is
well worth checking.)
Also, on April 15 of this year, language
from the original legislation was changed
and signed into law which expands
eligibility to eligible providers working in
hospital-based outpatient settings.
Originally, hospital-based outpatient
practitioners were excluded from incentives.
(Hospital-based inpatient and ED
practitioners remain ineligible.)
The following care providers are currently
eligible to receive Medicare stimulus
funds; Doctor of Medicine or Osteopathy,
Doctor of Dental Surgery or Dental Medicine,
Doctor of Podiatric, Doctor of Optometry and
Chiropractor (focus on Spinal Subluxation).
The Medicaid eligible professional
definition includes the following;
Physician, Dentist,
Certified Nurse Mid-wife, Nurse
Practitioner, Physician Assistant (Rural
Health Clinic/FQHC.
Overall, meaningful use criteria is a
two-part consideration. On one hand, your
certified EHR must have the necessary
functionality to support meaningful use. On
the other, practices must show they are
using the functionality in a meaningful way
within proposed criteria to qualify for the
appropriate incentives.
The overall meaningful use criteria is
proposed in three phases over time, with
only phase one required in the first
meaningful use year. Phase one emphasizes
the ability of providers to collect data in
electronic form, share key information with
other providers and patients, and report
quality measures through CPOE, for example.
Phases two and three of meaningful use
coming after 2011 expand functionality to
include disease management criteria and
information exchange with government and
public health agencies, when formulary
checks, encounter progress notes, and
automated lab results come into play. For
example, an interoperable EHR should link
clinical devices such as ECG or spirometry,
or merge automated lab results into flow
sheets on a system that maintains the values
and integrity of the data for later
retrieval.
The demystification comes into play when
practices selecting an EHR find that 1) EHR
software providers have been developing
functionality and interoperability that
adheres to previously known meaningful use
criteria, and 2) that current certification
has also been shaped to meaningful use
standards.
Throughout your selection process, keep in
mind that the CMS and ONC proposals do state
that meaningful use is, "based on currently
available technological capabilities and
providers' practice experience," and that,
"the standards adopted in the rules are
consistent with current industry standards."
Also keep in mind your "meaningful use" EHR
must be certified to qualify. The ONC is
also scheduled to publish final requirements
for certification bodies this summer.
Systems currently certified by CCHIT, such
as Greenway's PrimeSuite, are poised
to qualify, because the certification was
aligned with federal reporting criteria used
as a basis for meaningful use. Other
organizations are expected to also become
certification bodies in the future.
And finally, it's important to realize that
the stimulus EHR adoption incentives are
grounded in law, not just regulation,
meaning the funds will not go away.
