Taking Steps Now to Determine Your HITECH Preparedness
The American Recovery and Reinvestment Act of 2009 (ARRA) was signed into law in February 2009 by President Obama.
The Stimulus or the Recovery Act, as the ARRA is also known as, was intended to promote investment and consumer spending and create jobs during the recession.
Provisions of the Recovery Act include improving affordable health care, modernizing the United States' infrastructure, furthering energy independence and relieving education costs, among other provisions.
The Health Information Technology for Economic and Clinical Health Act or HITECH Act, is a section of the Recovery Act that allocates $19 billion for Health Information Technology (HIT) - which includes incentives for eligible professionals for the adoption and meaningful use of certified Electronic Health Record (EHR) technology.
HITECH created three alternative incentive programs for EHR, including incentives for Medicare, Medicaid, and Medicare Advantage Organization.
The Medicare incentive program offers eligible professionals incentive payments - eligible professionals are identified as doctors of medicine or osteopathy, doctors of dental surgery or medicine, doctors of podiatric medicine, doctors of optometry and chiropractors, who demonstrate the meaningful use of certified EHR technology.
Hospital-based eligible professionals, however, do not qualify for incentive payments.
Provisions for Medicare Incentive Medicare incentives for eligible professionals are based on an amount not to exceed 75% of approximated allowed costs for covered services, subject to maximum yearly payment limits that vary by year and are based on the year in which incentive payments are first made.
A summary of the maximum payments available to eligible professionals is shown below.
Maximum Medicare Payments Available to Eligible Professionals If First Payment Year is 2011 2011 - $18,000 2012 - $12,000 2013 - $8,000 2014 - $4,000 2015 - $2,000 2016 - $0 2017 - $0 Total* - $44,000 If First Payment Year is 2012 2012 - $18,000 2013 - $12,000 2014 - $8,000 2015 - $4,000 2016 - $2,000 2017 - $0 Total* - $44,000 If First Payment Year is 2013 2013 - $15,000 2014 - $12,000 2015 - $8,000 2016 - $4,000 2017 - $0 Total* - $39,000 If First Payment Year is 2014 2014 - $12,000 2015 - $8,000 2016 - $4,000 2017 - $0 Total* - $24,000 Years After 2014 2015 - $0 2016 - $0 2017 - $0 Total* - $0 *Excludes 10% bonus payments to health professional shortage area eligible professionals.
Mandated under HITECH, adjustment provisions serve to decrease payments to eligible professionals in years after 2014 at a rate of 1% per year, subject to a maximum cutback of payments of 5% under the authority of the U.
S.
Secretary of Health and Human Services.
Provisions for Medicaid Incentive Even though eligible hospitals can collect both Medicare and Medicaid incentive payments, eligible professionals must choose one of the two programs.
Medicaid program incentives are available to physicians, nurse practitioners, certified nurse mid-wives, physician assistants working in a federally qualified health center or rural health clinic, and dentists - hospital-based professionals are excluded from the program.
Eligible professionals must meet minimum Medicaid patient volume percentages to qualify for the program incentive, with payments based on estimated allowed charges and capped at 85% of $25,000 in the first year and 85% of $10,000 in subsequent years.
Meaningful Use of Certified EHR Technology The Centers for Medicare and Medicaid Services (CMS) was mandated by Congress to define meaningful use of certified EHR technology and propose an outline of requirements and deadlines for implementation.
Published on January 13, 2010 in the Federal Register, the proposed rule includes Stage 1 criteria - initial meaningful use criteria - that will be gradually updated in the future.
Stage 1 criteria focuses on electronically capturing health information in coded format, using captured information to track key clinical conditions and communicating captured information for care coordination.
Implementing clinical decision support tools to facilitate disease and medication management is also a main focus, as well as reporting clinical quality measures and public health information.
CMS Stage 1 Criteria: Meaningful Use Objectives for Eligible Professionals by Health Outcomes Policy Priority - 1.
Improve quality, safety, efficiency, and reduce health disparities a.
Use computerized provider order entry (CPOE) b.
Record demographics, such as preferred language, insurance type, gender, race, ethnicity, date of birth c.
Record and chart changes in vital signs, such as height, weight, blood pressure, body mass index, and growth d.
Generate list of patients by specific conditions to use for quality improvement, reduction of disparities, research and outreach e.
Implement drug-drug, drug-allergy, drug-formulary checks f.
Maintain an up-to-date problem list of current and active diagnoses g.
Maintain active medication list h.
Maintain active medication allergy list i.
Generate and transmit permissible prescriptions electronically j.
Record smoking status for patients 13 years old and older k.
Incorporate clinical lab test results into EHR as structured data l.
Check insurance eligibility electronically from public and private payers m.
Submit claims electronically to public and private payers n.
Report ambulatory quality measures to CMS or, in the case of Medicaid eligible professionals, the states o.
Implement five clinical decision support rules relevant to specialty or high clinical priority, including for diagnostic test ordering, along with the ability to track compliance with those rules p.
Send reminders to patients per patient preference for preventive/follow-up care 2.
Engage patients and families in their health care a.
Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, and allergies) upon request b.
Provide patients with timely electronic access to their health information (including diagnostic test results, problem list, medication lists, and allergies) within 96 hours of the information being available to the eligible professional c.
Provide clinical summaries to patients for each office visit 3.
Improve care coordination a.
Capability to exchange key clinical information among providers of care and patient-authorized entities electronically b.
Perform medication reconciliation at relevant encounters and each transition of care c.
Provide summary care record for each transition of care referral 4.
Improve population and public health a.
Capability to submit electronic data to immunization registries and actual submission where required and accepted b.
Capability to provide electronic syndromic surveillance data to public health agencies and actual transmission according to applicable law and practice 5.
Ensure adequate privacy and security protections for personal health information a.
Protect electronic health information created or maintained by EHR technology through the implementation of appropriate technical capabilities The Centers for Medicare and Medicaid Services expect to release the proposed Stage 2 criteria by the end of 2011 and the proposed Stage 3 criteria by the end of 2013.
CMS predicts that Stage 3 criteria will define goals that will be attainable by the end of the incentive programs.
Payment years will decide which criteria will be used to judge whether an eligible professional is a meaningful user of certified EHR technology.
A summary of the three stages of meaningful use by payment year is shown below.
Staged Meaningful Use Criteria by Payment Year If First Payment Year is 2011 2011 - Stage 1 If First Payment Year is 2012 2011 - Stage 1 2012 - Stage 1 If First Payment Year is 2013 2011 - Stage 2 2012 - Stage 1 2013 - Stage 1 If First Payment Year is 2014 2011 - Stage 2 2012 - Stage 2 2013 - Stage 2 2014 - Stage 1 Years After 2014 2011 - Stage 3 2012 - Stage 3 2013 - Stage 3 2014 - Stage 3 2015 - Stage 3 As indicated above, eligible professionals are encouraged to adopt meaningful use criteria as soon as possible, as late attainment will require compliance with more complex Stage 2 and/or Stage 3 criteria and possible reduction in reimbursement for those who are not meaningful users by 2015.
Documenting Meaningful Use of Certified EHR Technology Eligible professionals are required to report meaningful use of certified EHR technology in the first payment year, during any continuous 90-day period within a calendar year, and the entire calendar year for the second, third, fourth, fifth, and sixth payment years.
In order to qualify for payments in 2011, eligible professionals must attest to satisfaction of the preceding Stage 1 objectives during the reporting period, via a secured mechanism in a manner specified by CMS, for Medicare eligible professionals or the state of Medicaid eligible professionals.
Medicaid eligible professionals must also meet the state's additional CMS-approved criteria for meaningful use by way of a secure mechanism approved by CMS.
The EHR reporting period must be determined and the eligible professional must provide the result of each applicable measure, for all patients seen during the EHR reporting period for which a selected measure is applicable.
Additionally, the eligible professional must attest that certified EHR technology was used during the reporting period.
If a Medicaid eligible professional has adopted, implemented, or upgraded certified EHR technology, the provider must demonstrate meaningful use in the second payment year.
For payment years in 2012 and after, eligible professionals must attest to all items attested to in 2011 except that "report ambulatory quality measures to CMS or, in the case of Medicaid EPs, the states.
" Eligible professionals should also electronically submit to CMS or the state for Medicaid EPs, clinical quality information in the approach specified by CMS.
Certification Criteria A qualified Electronic Health Record is one that includes certain basic requirements to identify the patient and provide medical history, supports physician order entry, has the capacity to furnish clinical decision support, captures and queries information as it relates to quality of care, and exchanges and integrates such information.
Only a qualified EHR that has been tested and certified, in accordance with the certification program created by the national coordinator, is acceptable to become certified EHR technology.
Certified EHR technology may be either a Complete EHR, which is a single system that has been developed to meet all applicable certification criteria adopted, or a group of EHR Modules that when combined, form an EHR capable of being certified.
Certification standards for certified EHR technology are divided into four separate categories - Transport Standards, Content Exchange Standards, Vocabulary Standards and Privacy and Security Standards.
Transport Standards constitute a universal and secure communication protocol among systems.
Content Exchange Standards are used to share prescription information and clinical summaries, which have been adopted from a multitude of sources and existing standards.
Vocabulary Standards establish uniform nomenclatures and codes used to describe clinical procedures, medications, allergies and other issues.
Privacy and Security Standards set encryption and tracking requirements that certified EHR technology must meet, in addition to HIPAA's requirements for securing electronic health information.
The meaningful use objectives for eligible professionals and eligible hospitals in Stage 1, carry with it specific certification criteria to reinforce the achievement of the objectives.
The ability to achieve the certification criteria is integral in a Complete EHR or EHR Module.
How to Determine Your Meaningful Use Preparedness In order to define the standard for achieving meaningful use, a thorough technical and cultural analysis must be performed.
If an EHR is already in position, one must evaluate the currently implemented EHR system.
EHRs that have already been certified by the Certification Committee for Healthcare Information Technology (CCHIT) - which presently serves as a recognized U.
S.
certification authority for EHR technology - likely embrace many of the clinically oriented capabilities necessary for certified EHRs under the Recovery Act.
These previously CCHIT-certified EHRs are not expected to meet ARRA certification criteria, however, will be tested and certified as EHR Modules rather than Complete EHRs.
Resources, like independent readiness assessment audits and scorecards, are available to assist with readiness assessment.
These resources help define the methodology and strategy used in designing and implementing the EHR system, creating performance evaluation tools, sustaining a satisfactory level of performance, and addressing resource utilization and workflow challenges.
Why Transition Now? Both the provider and patient benefit from early transition to achieving meaningful use of certified EHR technology.
Providers will receive larger incentive payments, as available incentive payments decrease when Stage 1 criteria are adopted post-2012 and the complexity of the meaningful use definition will heighten as Stage 2 and Stage 3 criteria are implemented.
Patients will benefit by receiving better quality and more efficient patient care and possible lower provider insurance premiums as malpractice suits reduce or diminish.
The Stimulus or the Recovery Act, as the ARRA is also known as, was intended to promote investment and consumer spending and create jobs during the recession.
Provisions of the Recovery Act include improving affordable health care, modernizing the United States' infrastructure, furthering energy independence and relieving education costs, among other provisions.
The Health Information Technology for Economic and Clinical Health Act or HITECH Act, is a section of the Recovery Act that allocates $19 billion for Health Information Technology (HIT) - which includes incentives for eligible professionals for the adoption and meaningful use of certified Electronic Health Record (EHR) technology.
HITECH created three alternative incentive programs for EHR, including incentives for Medicare, Medicaid, and Medicare Advantage Organization.
The Medicare incentive program offers eligible professionals incentive payments - eligible professionals are identified as doctors of medicine or osteopathy, doctors of dental surgery or medicine, doctors of podiatric medicine, doctors of optometry and chiropractors, who demonstrate the meaningful use of certified EHR technology.
Hospital-based eligible professionals, however, do not qualify for incentive payments.
Provisions for Medicare Incentive Medicare incentives for eligible professionals are based on an amount not to exceed 75% of approximated allowed costs for covered services, subject to maximum yearly payment limits that vary by year and are based on the year in which incentive payments are first made.
A summary of the maximum payments available to eligible professionals is shown below.
Maximum Medicare Payments Available to Eligible Professionals If First Payment Year is 2011 2011 - $18,000 2012 - $12,000 2013 - $8,000 2014 - $4,000 2015 - $2,000 2016 - $0 2017 - $0 Total* - $44,000 If First Payment Year is 2012 2012 - $18,000 2013 - $12,000 2014 - $8,000 2015 - $4,000 2016 - $2,000 2017 - $0 Total* - $44,000 If First Payment Year is 2013 2013 - $15,000 2014 - $12,000 2015 - $8,000 2016 - $4,000 2017 - $0 Total* - $39,000 If First Payment Year is 2014 2014 - $12,000 2015 - $8,000 2016 - $4,000 2017 - $0 Total* - $24,000 Years After 2014 2015 - $0 2016 - $0 2017 - $0 Total* - $0 *Excludes 10% bonus payments to health professional shortage area eligible professionals.
Mandated under HITECH, adjustment provisions serve to decrease payments to eligible professionals in years after 2014 at a rate of 1% per year, subject to a maximum cutback of payments of 5% under the authority of the U.
S.
Secretary of Health and Human Services.
Provisions for Medicaid Incentive Even though eligible hospitals can collect both Medicare and Medicaid incentive payments, eligible professionals must choose one of the two programs.
Medicaid program incentives are available to physicians, nurse practitioners, certified nurse mid-wives, physician assistants working in a federally qualified health center or rural health clinic, and dentists - hospital-based professionals are excluded from the program.
Eligible professionals must meet minimum Medicaid patient volume percentages to qualify for the program incentive, with payments based on estimated allowed charges and capped at 85% of $25,000 in the first year and 85% of $10,000 in subsequent years.
Meaningful Use of Certified EHR Technology The Centers for Medicare and Medicaid Services (CMS) was mandated by Congress to define meaningful use of certified EHR technology and propose an outline of requirements and deadlines for implementation.
Published on January 13, 2010 in the Federal Register, the proposed rule includes Stage 1 criteria - initial meaningful use criteria - that will be gradually updated in the future.
Stage 1 criteria focuses on electronically capturing health information in coded format, using captured information to track key clinical conditions and communicating captured information for care coordination.
Implementing clinical decision support tools to facilitate disease and medication management is also a main focus, as well as reporting clinical quality measures and public health information.
CMS Stage 1 Criteria: Meaningful Use Objectives for Eligible Professionals by Health Outcomes Policy Priority - 1.
Improve quality, safety, efficiency, and reduce health disparities a.
Use computerized provider order entry (CPOE) b.
Record demographics, such as preferred language, insurance type, gender, race, ethnicity, date of birth c.
Record and chart changes in vital signs, such as height, weight, blood pressure, body mass index, and growth d.
Generate list of patients by specific conditions to use for quality improvement, reduction of disparities, research and outreach e.
Implement drug-drug, drug-allergy, drug-formulary checks f.
Maintain an up-to-date problem list of current and active diagnoses g.
Maintain active medication list h.
Maintain active medication allergy list i.
Generate and transmit permissible prescriptions electronically j.
Record smoking status for patients 13 years old and older k.
Incorporate clinical lab test results into EHR as structured data l.
Check insurance eligibility electronically from public and private payers m.
Submit claims electronically to public and private payers n.
Report ambulatory quality measures to CMS or, in the case of Medicaid eligible professionals, the states o.
Implement five clinical decision support rules relevant to specialty or high clinical priority, including for diagnostic test ordering, along with the ability to track compliance with those rules p.
Send reminders to patients per patient preference for preventive/follow-up care 2.
Engage patients and families in their health care a.
Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, and allergies) upon request b.
Provide patients with timely electronic access to their health information (including diagnostic test results, problem list, medication lists, and allergies) within 96 hours of the information being available to the eligible professional c.
Provide clinical summaries to patients for each office visit 3.
Improve care coordination a.
Capability to exchange key clinical information among providers of care and patient-authorized entities electronically b.
Perform medication reconciliation at relevant encounters and each transition of care c.
Provide summary care record for each transition of care referral 4.
Improve population and public health a.
Capability to submit electronic data to immunization registries and actual submission where required and accepted b.
Capability to provide electronic syndromic surveillance data to public health agencies and actual transmission according to applicable law and practice 5.
Ensure adequate privacy and security protections for personal health information a.
Protect electronic health information created or maintained by EHR technology through the implementation of appropriate technical capabilities The Centers for Medicare and Medicaid Services expect to release the proposed Stage 2 criteria by the end of 2011 and the proposed Stage 3 criteria by the end of 2013.
CMS predicts that Stage 3 criteria will define goals that will be attainable by the end of the incentive programs.
Payment years will decide which criteria will be used to judge whether an eligible professional is a meaningful user of certified EHR technology.
A summary of the three stages of meaningful use by payment year is shown below.
Staged Meaningful Use Criteria by Payment Year If First Payment Year is 2011 2011 - Stage 1 If First Payment Year is 2012 2011 - Stage 1 2012 - Stage 1 If First Payment Year is 2013 2011 - Stage 2 2012 - Stage 1 2013 - Stage 1 If First Payment Year is 2014 2011 - Stage 2 2012 - Stage 2 2013 - Stage 2 2014 - Stage 1 Years After 2014 2011 - Stage 3 2012 - Stage 3 2013 - Stage 3 2014 - Stage 3 2015 - Stage 3 As indicated above, eligible professionals are encouraged to adopt meaningful use criteria as soon as possible, as late attainment will require compliance with more complex Stage 2 and/or Stage 3 criteria and possible reduction in reimbursement for those who are not meaningful users by 2015.
Documenting Meaningful Use of Certified EHR Technology Eligible professionals are required to report meaningful use of certified EHR technology in the first payment year, during any continuous 90-day period within a calendar year, and the entire calendar year for the second, third, fourth, fifth, and sixth payment years.
In order to qualify for payments in 2011, eligible professionals must attest to satisfaction of the preceding Stage 1 objectives during the reporting period, via a secured mechanism in a manner specified by CMS, for Medicare eligible professionals or the state of Medicaid eligible professionals.
Medicaid eligible professionals must also meet the state's additional CMS-approved criteria for meaningful use by way of a secure mechanism approved by CMS.
The EHR reporting period must be determined and the eligible professional must provide the result of each applicable measure, for all patients seen during the EHR reporting period for which a selected measure is applicable.
Additionally, the eligible professional must attest that certified EHR technology was used during the reporting period.
If a Medicaid eligible professional has adopted, implemented, or upgraded certified EHR technology, the provider must demonstrate meaningful use in the second payment year.
For payment years in 2012 and after, eligible professionals must attest to all items attested to in 2011 except that "report ambulatory quality measures to CMS or, in the case of Medicaid EPs, the states.
" Eligible professionals should also electronically submit to CMS or the state for Medicaid EPs, clinical quality information in the approach specified by CMS.
Certification Criteria A qualified Electronic Health Record is one that includes certain basic requirements to identify the patient and provide medical history, supports physician order entry, has the capacity to furnish clinical decision support, captures and queries information as it relates to quality of care, and exchanges and integrates such information.
Only a qualified EHR that has been tested and certified, in accordance with the certification program created by the national coordinator, is acceptable to become certified EHR technology.
Certified EHR technology may be either a Complete EHR, which is a single system that has been developed to meet all applicable certification criteria adopted, or a group of EHR Modules that when combined, form an EHR capable of being certified.
Certification standards for certified EHR technology are divided into four separate categories - Transport Standards, Content Exchange Standards, Vocabulary Standards and Privacy and Security Standards.
Transport Standards constitute a universal and secure communication protocol among systems.
Content Exchange Standards are used to share prescription information and clinical summaries, which have been adopted from a multitude of sources and existing standards.
Vocabulary Standards establish uniform nomenclatures and codes used to describe clinical procedures, medications, allergies and other issues.
Privacy and Security Standards set encryption and tracking requirements that certified EHR technology must meet, in addition to HIPAA's requirements for securing electronic health information.
The meaningful use objectives for eligible professionals and eligible hospitals in Stage 1, carry with it specific certification criteria to reinforce the achievement of the objectives.
The ability to achieve the certification criteria is integral in a Complete EHR or EHR Module.
How to Determine Your Meaningful Use Preparedness In order to define the standard for achieving meaningful use, a thorough technical and cultural analysis must be performed.
If an EHR is already in position, one must evaluate the currently implemented EHR system.
EHRs that have already been certified by the Certification Committee for Healthcare Information Technology (CCHIT) - which presently serves as a recognized U.
S.
certification authority for EHR technology - likely embrace many of the clinically oriented capabilities necessary for certified EHRs under the Recovery Act.
These previously CCHIT-certified EHRs are not expected to meet ARRA certification criteria, however, will be tested and certified as EHR Modules rather than Complete EHRs.
Resources, like independent readiness assessment audits and scorecards, are available to assist with readiness assessment.
These resources help define the methodology and strategy used in designing and implementing the EHR system, creating performance evaluation tools, sustaining a satisfactory level of performance, and addressing resource utilization and workflow challenges.
Why Transition Now? Both the provider and patient benefit from early transition to achieving meaningful use of certified EHR technology.
Providers will receive larger incentive payments, as available incentive payments decrease when Stage 1 criteria are adopted post-2012 and the complexity of the meaningful use definition will heighten as Stage 2 and Stage 3 criteria are implemented.
Patients will benefit by receiving better quality and more efficient patient care and possible lower provider insurance premiums as malpractice suits reduce or diminish.
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