Health Information Technology

Health IT Policy Committee Recommends Delay for Stage 2 Meaningful Use

Kathie McDonald-McClure Electronic Health Records, Eligible Professional Incentives, Health Information Technology, HITECH Law, Hospital EHR Stimulus, Meaningful Use, Physician EMR Stimulus , , , , , , ,

UPDATE: On July 6, 2011, Farzad Mostashari, M.D., ONC Chief, backed the ONC Policy Committee’s recommendation to delay implementing Stage 2 meaningful use criteria.

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On June 16, 2011, Paul Tang, M.D. , as Vice Chair of the Health IT Policy Committee for the  Office of National Coordinator (ONC), wrote a letter to Farzad Mostashari, M.D., the ONC National Coordinator, requesting a delay in implementing Stage 2 of the meaningful use criteria that eligible healthcare providers must meet in order to obtain the monetary incentives for adoption of electronic health records (EHRs).  The monetary incentives were established pursuant to the Health Information Technology for Economic and Clinical Health Act of 2009 (HITECH Act), which was part of the American Recovery and Reinvestment Act of 2009 (ARRA).  Dr. Tang states in the letter:

The HITPC has heard from both the vendor community and the provider community that the current schedule for compliance with stage 2 meaningful use objectives in 2013 poses a nearly insurmountable timing challenge for those who attest to meaningful use in 2011. With the anticipated release of the final rule for stage 2 in June, 2012, it would require EHR vendors to design, develop, and release new functionality, and for eligible hospitals to upgrade, implement and begin using the new functionality by the beginning of the reporting year in October of 2012. After careful consideration of the trade-offs between the urgency with which new functionality is needed and the ability to safely deliver and to effectively use the new functionality, the HITPC recommends that—only for those who begin to attest to MU in 2011—an extra year be provided to phase in the stage 2 expectations (ie., Stage 2 for those who attest in 2011 would begin in 2014).

The Committee asserts that the delay would only affect providers who implement Stage 1 in 2011.  This assumes that providers who wait until 2012 to implement Stage 1 would not have been ready to implement Stage 2 until 2014 anyway.  The letter also sets forth the proposals for stengthening Stage 1 criteria in Stage 2.  The Committee voted 12 to 5 in favor of the recommendations in the letter.  To read the entire 14-page letter, click here.

CMS Proposed Rule on Accountable Care Organizations is linked to Meaningful Use Measures

Kathie McDonald-McClure EHR Certification Standards, Electronic Health Records, Health care reform, Health Information Technology, HITECH Law, Meaningful Use , , , , ,

What do the Physician Quality Reporting Incentives Program (PQRI) and Hospital Inpatient Value Based Purchasing (VBP) Program have in common with the recently released proposed regulation for establishing an Accountable Care Organization (ACO)? Answer: The meaningful use measures established by the Centers for Medicare and Medicare Services (CMS) for qualifying for incentives under the Health Information  Technology for Economic and Clinical Health Act of 2009 (HITECH).  Of course! 

On April 7, 2011, CMS published the Proposed Rule on Medicare Shared Savings Program: Accountable Care Organizations in the Federal Register. The Proposed Rule sets forth the requirements that an ACO must meet in order to qualify for the cost savings that will be available to qualifying providers.  Among the requirements, CMS incorporates the EHR meaningful use incentives, stating:

[T]he ACO should have a process in place (or clear path to develop such a process) to electronically exchange summary of care information when patients transition to another provider or setting of care, both within and outside the ACO, consistent with meaningful use requirements under the EHR Incentive program.

Now Medicare providers have another reason to get on board sooner rather than later with the implementation of a certified electronic health record (EHR). 

Stay tuned to the HITECH Law Blog for a post that will have a more in-depth review of how the ACO requirements may impact providers in regard to the implementation and use of certified EHRs, including a review of the overlapping measures for PQRI, Hospital VBP Programs, HITECH EHR incentives and ACOs.  In the meantime, to read more about the HITECH meaningful use measures utilized in the CMS Hospital VPB Program, see the article, “Certified EHRs Expected to Transmit Data for Medicare’s New Hospital Inpatient Value-Based Purchasing Program,” posted to the HITECH Law Blog on February 8, 2011.

CMS Posts Sneak Preview of Meaningful Use Attestation, Which Opens April 18, 2011

Kathie McDonald-McClure Electronic Health Records, Health Information Technology, HITECH Law, Hospital EHR Stimulus, Meaningful Use, Physician EMR Stimulus , , , , ,

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.

Certified EHRs Expected to Transmit Data for Medicare’s New Hospital Inpatient Value-Based Purchasing Program

Kathie McDonald-McClure EHR Certification Standards, Electronic Health Records, Health care reform, Health Information Technology, HITECH Law, Meaningful Use , , , , , ,

On January 13, 2011, the Centers for Medicare and Medicaid Services (CMS) released its Proposed Rule on the Medicare Hospital Inpatient Value-Based Purchasing (VBP) Program. The VPB Program is being established per the directive of the Patient Protection and Affordable Access to Care Act of 2010 (PPACA). CMS is to begin making incentive payments under the VBP Program for discharges on or after October 1, 2012.

Seven years before PPACA required CMS to establish the VBP Incentive Program, the Medicare Prescription Drug, Improvement, and Modernization Act of 2003 (MMA) gave CMS authority to establish the Hospital Inpatient Quality Reporting (IQR) Program. The clinical quality measures that CMS has adopted for the IQR Program will feed into the measures for the VBP Program.

The IQR Program measures were generally based on recommendations from the National Quality Forum (NQF), a voluntary consensus standard-setting organization with a diverse representation of consumer, purchaser, provider, academic, clinical, and other health care stakeholder organizations. The IQR measures began as a set of 10 quality indicators that have since expanded to 45 clinical quality measures for the FY 2011 IQR program payment determination. The FY 2011 IQR hospital measures focus on four topics: 1) Acute Myocardial Infarction (AMI); 2) Heart Failure (HF); 3) Pneumonia (PN); and 4) Surgical Care Improvement Project (SCIP).

So how does this relate to the Health Information Technology for Economic and Clinical Health Act (HITECH Act) and a hospital’s “meaningful use” of a “certified EHR“? Ahhh, there is a method to the madness. As the CMS VBP Proposed Rule points out, the Hospital IQR program and the Hospital VBP Program have “important areas of overlap and synergy with regard to the reporting of quality measures under the HITECH Act.”

CMS notes in the Proposed Rule that the certification standards for EHRs under the HITECH Act are directed at enabling EHR submission of quality measures. CMS is striving “to align the [VPB] measures with the adoption of meaningful use standards for health information technology (HIT), so the collection of performance information is part of care delivery.” As a result, CMS anticipates that hospitals will use their certified EHRs for the reporting of clinical quality measures under both the Hospital IQR program and the subsequent Hospital VBP Program.

The proposed initial measures for the FY 2013 Hospital VBP Program include 18 measures. Of these 18 measures, 17 measures will focus on the four clinical process of care topics set forth for the 2011 IQR Program (AMI, HF, PN, and SCIP), and will add Healthcare-Associated Infections (HAI). The 18th measure will include a measure from the Hospital Consumer Assessment of Healthcare Providers and Systems Survey (HCAHPS) that will fall under a patient experience of care domain.

The proposed performance period is to begin July 1, 2011 and will continue through March 31, 2012 for the FY 2013 payment determination. This is already less than five months away! Another reason for Eligible Hospitals under the HITECH Act to focus on implementation of a certified EHR. Did I hear someone ask how the VBP incentive payments will be funded? Answer: By a reduction of the Fiscal Year 2013 base operating DRG payments for each discharge of 1%. “What one hand giveth, the other hand taketh away.” (Unknown)

For more information about the IQR Program, visit QualityNet.  For additional details about the VBP Program, see the Proposed Rule.  CMS will accept comments on the VBP Proposed Rule until March 8, 2011.  CMS expects to issue a final rule in 2012.

CMS Posts Helpful EHR Incentive Program Registration Guides

Kathie McDonald-McClure Electronic Health Records, Health Information Technology, HITECH Law, Hospital EHR Stimulus, Physician EMR Stimulus , , , , , , , ,
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.
 
The Hospital Guide can be accessed here and the Eligible Professional Guide can be accessed here.