Eligible Professionals (EPs), Eligible Hospitals (EHs) and Critical Access Hospitals (CAHs) who make a meaningful use of a certified electronic health record(EHR) are eligible for financial incentives under the Health Information Technology for Economic and Clinical Health Act of 2009 (HITECH Act). EPs , EHs and CAHs will be able to attest to meeting the “meaningful use” criteria through a special on-line portal beginning April 18, 2011. The Centers for Medicare and Medicaid (CMS) has posted a sneak preview of the attestation system with screenshots of the meaningful use screens that providers will complete in order to attest to meaningful use. More information about how to register and attest is available on the CMS official website for the Medicare and Medicaid EHR Incentive Programs.
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CMS Posts Helpful EHR Incentive Program Registration Guides
CMS has posted very helpful Electronic Health Record (EHR) Registration User Guides, one for Eligible Hospitals and one for Eligible Professionals. The Guides provide an excellent overview of the path to receiving EHR Incentives available under the Health Information Technology for Economic and Clinical Health (HITECH) Act. As I pointed out in my previous post, CMS is encouraging Eligible Hospitals and Eligible Professionals to go ahead and register in advance of making an attestation to meaningful use of a certified EHR. CMS has set up the system so that registrants do not have to fear that registration alone could somehow subject them to penalties later for failing to follow through with implementing and making an meaningful use of an EHR. This is evident by reviewing the way in which the registration system is broken down into four parts or “tabs”: Registration, Attestation, Status and Account Management.Registration Tab. Here is where hospitals and physicians (as well as other practitioners eligible for incentives under State Medicaid programs) can register for the EHR Incentive Program. Registrants also will access this Tab to take one of the following actions: Continue an Incomplete Registration, Modify an Existing Registration, Resubmit a registration that was previously deemed ineligible, Reactivate a Registration, Switch Incentive Programs (Medicare/Medicaid), Switch Medicaid State, and Cancel Participation in the EHR Incentive Program.
Attestation Tab. Under this Tab is where registrants can submit their Attestation of meaningful use when ready. This Tab also provides options and instructions for Registrants wanting to: Continue an Incomplete Attestation, Modify an Existing Attestation, or Discontinue an Attestation.
Status Tab. Here, registrants can view the status of Registration, Attestation and their EHR Incentive Payment.
Account Management Tab. Here, registrants can Update Account Information, Request Access to Organizations, or Remove Access to Organizations.
CMS Posts Updated and New EHR Incentive FAQs
On September 27, 2010, CMS updated its answers and posted a few new ones to frequently asked questions (FAQs) about the electronic health record (EHR) incentives available under the HITECH Act’s Meaningful Use (“MU”) Final Rule. Here is a sampling of answers addressed in the FAQs:
- Registration for Medicare MU incentives is to be available on-line in January 2011 with more information to come near end of 2010.
- All EHR products must be certified through the ONC Authorzied Testing and Certification Body (ATCB) in order to meet MU.
- Providers, not vendors, must demonstrate MU of certified EHRs.
- Payment of Medicare MU incentives is expected to begin in May 2011.
- There is no funding to reimburse a provider for EHR implementation costs that exceed the established MU incentive payment caps.
- Ambulatory Surgery Centers are not eligible for the EHR incentives.
- There is no funding under the HITECH Act for nursing home EHRs.
- Eligible Professionals (EPs) may assign their incentive payments to their employer or an entity with whom the EP has a contractual arrangement.
- EPs cannot receive an incentive payment under both the Medicare MU program and the MIPPA E-Prescribing Incentive Program in the same year.
- EPs can receive both the Medicaid MU Program incentive and the MIPPA E-Prescribing Incentive Program payment for the same year.
- An EP in a hospital-based ambulatory care clinic may be eligible to receive the Medicare MU Incentives if such EP is not providing 90% of his or her services in the hospital ED or inpatient care setting.
- EPs eligible for both the Medicare MU incentive and Medicaid MU incentive payment in the same year must choose one.
- Once an EP receives an MU incentive payment under either Medicare or Medicaid, that EP can switch between the programs only once before 2015.
- The reporting period for EPs is 90 consecutive days during the first calendar year that the EP qualifies and a full calendar year thereafter.
- Medicare payment adjustments begin in 2015 for both EPs and hospitals who do not demonstrate MU.
- CMS will publish the names, addresses and business phone numbers of all EPs and hospitals receiving EHR incentive payments.
- The meaning of numerators and denominators in the measures required to establish MU is briefly summarized in this FAQ.
- Patients admitted through the Emergency Department (ED) will be included in the MU measures respecting inpatients.
As of today’s date, there were 103 FAQs related to EHR incentives. To read all the FAQs about EHR incentives, go to the CMS FAQs webpage and enter the search terms “EHR incentives.”
Commercial Payors Implementing EHR Meaningful Use Criteria in P4P Programs
Update: On August 9, 2010, Humana, Inc. and athenahealth, Inc. announced their collaboration to provide physicians access to a practice management/EHR software system combined with a rewards program related to quality measures. For more information, click here.
On August 5, 2010, four major commercial health insurance payors participated in the Health Industry Forum in Washington, D.C., to discuss private industry collaboration with the United States Health & Human Services Department (HHS) to support providers in the adoption of certified electronic health records (EHRs). Leading the Forum’s panel discussion was David Blumenthal, M.D., Chief of the Office of National Coordinator of HIT. All four payors will include the Meaningful Use criteria in their pay for performance (P4P) programs.
CMS Holds Training Teleconference on EHR Final Rules
On Thursday, July 22, 2010, the Centers for Medicare and Medicaid Services (CMS) held a publicly available teleconference to give an overview of the 800+ page Final Rule on Meaningful Use (MU) under the HITECH Act, as well as an overview of the Final and Proposed Rules on Temporary & Permanent Certification Program and the Final Rule on the Standards and Certification Criteria for electronic health records (EHRs). CMS is making an “encore recording” of the 90-minute teleconference available until 11:00 pm, Saturday, July 24, 2010. Call toll-free, 1-800-642-1689 and enter the conference ID 87841621 to hear the encore recording. CMS will post an audio recording link to the teleconference on its EHR Incentive Programs website sometime in August 2010. The slides accompanying the audio are available on that same website, here (scroll to Downloads and click on the links for the July 22, 2010 Training materials).
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