Michael D. Paquin, FHIMSS

www.mdpgrp.com

In this segment on Electronic Healthcare records, being sponsored by Physicians Office Resource, we will look at:

Meaningful Use Rules Now Official

Breaking News, January, 2010

It is time to make your opinion heard!

Agencies of the Department of Health and Human Services on Jan. 13 officially published two rules covering the meaningful use of electronic health records provisions of the HITECH Act within the American Recovery and Reinvestment Act.

Publication of the rules starts the clock for the public comment period, with both rules having a March 15 deadline for comment. The proposed rule from the Centers for Medicare and Medicaid Services defines 'meaningful use' of electronic health records to qualify for Medicare and Medicaid incentive payments. It lays out a series of measures to collect and report data to government agencies. The rule is 169 pages long in a PDF format.

An interim final rule from the Office of the National Coordinator for Health Information Technology sets initial standards, implementation specifications and certification criteria for EHR technology. The rule is 33 pages long in a PDF format. A forthcoming rule will establish an EHR certification program.

The rules are available at gpoaccess.gov/fr/index.html.

What is the AARA?

The American Recovery and Reinvestment Act of 2009 (ARRA) authorizes the Centers for Medicare & Medicaid Services (CMS) to provide financial incentives for physicians/eligible professionals as well as hospitals that become “meaningful users” of certified electronic health records (EHR). A CMS fact sheet and additional specifics are available at: www.cms.hhs.gov/Recovery/11_HealthIT.asp. For a direct copy of this legislation, go to www.hhs.gov/recovery/overview/index.html.

In summary, this is what you will need to receive funds:

1) Eligibility/Payment - Determine if you are a Medicaid or Medicare eligible provider you can only qualify as one.

Medicaid - If more than 30% (20% for pediatricians) of patient mix is Medicaid, qualify for up to $63,750 per provider. This may cover 85% of the “average allowable cost” to purchase, implement or upgrade a certified EHR including implementation, training and annual maintenance charges.

Medicare - If more than $24,000 in allowable Medicare charges, you may qualify for the maximum of $18,000 in 2011 and up to $44,000 per provider (2011-2016) 

Otherwise, you may qualify for 75% of allowable Medicare charges. 

2) Certification - Obtain or verify that your EHR is HHS certified with needed capabilities according to ARRA defined by CMS

3) Meaningful use - Use required EHR capabilities capturing needed information to create/send reports for CMS

4) Timelines - Meet 2011-2016 Medicare and 2011-2021 for Medicaid timelines including interim criteria checkpoints in 2013 and 2015

5) Assistance - If you are in a practice with less than 10 providers or supporting Medicaid populations, starting early 2010 obtain an additional $5,000 per provider in consulting assistance from regional extension centers.

Certification

EHR products certified prior to 2009 meet some, yet not all requirements for funding under ARRA. In October 2009, the Certification Commission for Health Information Technology (CCHIT) began offering 2 new EHR product certifications: CCHIT Certified^® 2011 Comprehensive and Preliminary ARRA 2011. According to CCHIT, comprehensive certification meets or exceeds ARRA 2011 certification requirements and provides maximal assurance of comprehensive, integrated EHR capabilities. Preliminary ARRA certification is limited to certifying security, privacy, interoperability and modular functional requirements.

Once CMS publishes its final rule in spring 2010, CCHIT plans to also offer a site certification option intended for organizations using self-developed or non-certified EHRs. See www.cchit.org for specifics. CCHIT provides three paths to meet EHR certification criteria needed for ARRA funding: 1) purchase a comprehensive certified package from one vendor, 2) purchase certified components from different vendors and 3) build your own EHR or use a non-certified product and certify it individually on site for a fee.

Meaningful use

Overall, EHR meaningful use will support national goals to: • Improve quality, safety and efficiency and reduce disparities

• Engage patients in their care

• Increase coordination of care

• Improve the health status of the population

• Ensure privacy and security

Care Goals include:

Access - Provide access to comprehensive patient health data for patient’s health care team

CPOE - Use evidence-based order sets and CPOE

CDS - Apply clinical decision support at the point of care

Care reminders/outreach - Generate lists of patients who need care and use them to reach out to patients (e.g., reminders, instructions)

Quality Reporting - Report to patient registries for quality improvement, public reporting, etc.

Engaging Consumers - Provide patients/families with access to data, knowledge and tools to make informed decisions/manage their health

Care Coordination - Exchange meaningful clinical information among professional team and communicate with public health agencies. Provide transparency of data sharing to patient.

Privacy/Security - Ensure privacy & security protections for confidential information through operating policies, procedures, technologies and compliance with applicable law

The Health Information Technology (HIT) Policy Committee approved their EHR meaningful use definition in July 2009.

According to the legislation, meaningful use includes: electronic prescribing, the electronic exchange of health information to improve the quality of healthcare, and reporting on clinical quality and other measures. The meaningful use definition will evolve over time as objectives and measures for 2013 and 2015 build on those of 2011. Beyond 2011, the criteria required to obtain payment is more subject to change.