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.
meaningful use of certified EHR
Certified EHRs Expected to Transmit Data for Medicare’s New Hospital Inpatient Value-Based Purchasing Program
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
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.
EHR Certification Organizations and Certified EHRs
Just to recap where we are today, the U.S. Health & Human Services Department (HHS) Office of National Coordinator for Health Information Technology (ONC) has authorized three organizations to perform complete EHR and/or EHR module testing and certification under the Temporary Certification Program Rules. Certification means that the EHR or EHR module has the capabilities necessary to support the efforts of eligible hospitals and eligible professionals in meeting the Meaningful Use requirements under Final Rule issued by Centers for Medicare and Medicaid Services (CMS) for Meaningful Use. The three ONC-Authorized Testing & Certification Bodies (ATCBs) to date are Certification Commission for Health Information Technology (CCHIT), Drummond Group, Inc. (Drummond), and InfoGuard Laboratories, Inc. (InfoGuard). For additional information about the ONC process for achieving ATCB status, as well as more information about Standards & Certification generally, see the ONC webpage.
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.”
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