Fortunately, if you attest that any core reporting measure is not clinically relevant to your practice, you can delete it from your list.
- For clinical quality metrics, you must select six of 44 dimensions of care for reporting purposes, including three core measures and three alternate measures
- Physicians who work only with hospitalized patients and do not have an outpatient practice—for example, internal medicine hospitalists and ObGyn laborists—are, currently, ineligible
- If you bill Medicare with point-of-service codes 21 and 23 for more than 90% of your patients, you are ineligible for this program
- You will be paid within 46 days of attesting to meaningful use of the EHR. Payments will be made to your billing entity’s taxpayer identification number.
Then, there are the penalties
What government program doesn’t have hidden penalties? Physicians who do not demonstrate meaningful use of a certified EHR by 2014 will be hit with a 1% reduction in their Medicare fees every following year from 2015 to 2017—and, potentially, after that. The penalty reduction may increase to 2%, annually, if less than 75% of US physicians adopt an EHR.
A transforming event in health care. Maybe.
EHRs generally improve the coordination of health care. At times, however, they can be burden-some—to clinicians and to patients. Furthermore, development of a national grid of interoperable medical records, with oversight by government agencies, subtly changes the relationship between the patient and her physician and increases the power and authority of large health systems, insurers, and government agencies to shape the future of health care.
The prediction among health care experts who are optimists is that HITECH will stimulate rapid adoption and interoperability of EHRs in the United States. In turn, such development of a nationwide system of health records will improve the quality and efficiency of care. They view the HITECH Act, and its consequences, as truly revolutionary.
The pessimists among us have quipped that, if you and your life partner decided to have children because your main goal was to be eligible for the IRS child tax credit, then you will really like HITECH.
The reality? It’s likely found midway between those two extremes of anticipation.
Regardless: Whether you’re optimistic or pessimistic about HITECH, you must decide whether you will participate; optimally, you need to make that decision this year. The accompanying sidebar, “A ‘meaningful use’ how-to-guide”, walks you through the steps of the program in detail.
#1 START THE LEARNING PROCESS
To see all the information that will be used for the EHR incentive program, start here: http://www.cms.gov/EHRIncentivePrograms/01_Overview.asp
#2 CHOOSE
Because the incentive is offered through two programs, choose the one that’s right for you
Medicare
Pros Meaningful use criteria are set and will not change over time.
Cons If you already receive e-prescribing incentives, you cannot also receive
Medicare EHR program incentives.
Medicaid
Pros There is no penalty if you choose not to participate. For this program, you must
demonstrate that you have adopted, implemented, or upgraded to certified
EHR technology in the first year, and become a meaningful user for at least
90 days in the second year. If you already qualify as a meaningful user of a
certified EHR, you will have to show meaningful use for 90 days in the first year,
and for the whole year in succeeding years. If you are receiving e-prescribing
incentives for Medicare you can also receive EHR incentives for Medicaid.
Cons Not all states are participating. As of February 1, 2011, this program is an option
if you practice in Alaska, California, Iowa, Kentucky, Louisiana, Oklahoma,
Michigan, Mississippi, Missouri, North Carolina, North Dakota, South Carolina,
Tennessee, and Texas. Other states may decide to participate at a later date.
In addition, each state will be allowed to develop more meaningful use criteria than
are applied through the Medicare program, if they choose to.
#3 REGISTER
It all starts at: https://ehrincentives.cms.gov. Click “Continue” until you reach the login screen, where you enter your National Plan and Provider Enumeration System (NPPES) Web server account user ID and password (you must have an active National Provider Identifier [NPI] number to do this).
(If you do not have an account, click on the link to the NPPES Web site to establish one.)
After logging in, click on the “Registration” tab to begin the online registration process, which includes selecting the Medicare or Medicaid incentive program. (Online registration allows you to complete the process at one session or to come back at a later time to finish registration or to modify your information.)
You do not have to be using a certified EHR to begin the registration process. You must be using one to receive the incentive payment, however.
#4 ATTEST
To receive the incentive payment for a given year, you must “attest” that you meet the criteria. All the criteria are listed on the Center for Medicare and Medicaid Services (CMS) Web site at: http://www.cms.gov/EHRIncentivePrograms/30_Meaningful_Use.asp.
To attest for the Medicare incentive payment, you must again log in to the registration site (listed above) and click on the “Attestation” tab. This tab will not be available until April 4, 2011, at the end of the first 90-day period. You will be asked to confirm each of the listed criteria by entering “Yes,” “No,” or “Exclusion (when allowed),” as applicable to each.
To attest for the Medicaid program, you must contact each participating state. The best way to do this is to search the Web, using the search parameter: “[state name] EHR incentive program”. For example, searching this way for the Alaska program brings up the Web site: http://ak.arraincentive.com. Some states have set up online attestation questionnaires; others have indicated that they will contact providers who have registered nationally.
#5 REPORT QUALITY MEASURES
Your work isn’t done when you’ve completed the attestation step. For the Medicare program, you must also report six clinical quality measures abstracted from the EHR. These measures are submitted by the certified vendor, but you must make certain you have reported them in your EHR record.—Melanie Witt, RN, CPC, COBGC, MA
Ms. Witt is an independent coding and documentation consultant and former program manager, department of coding and nomenclature, American Congress of Obstetricians and Gynecologists.