All EHRs will need to be certified for the EHR Incentive Programs by an Office of the National Coordinator for Health Information Technology Authorized Testing and Certification Body (ONC-ATCB).
Currently, EHRs with functionality aligned with meaningful use criteria, such as SuiteMed IMS have been certified by the private Certification Commission for Health Information Technology (CCHIT). SuiteMed IMS is a CCHIT Certified® 2008 Ambulatory EHR and is on track to meet CCHIT 2011 certification requirements in 2010 and becoming qualified by Health and Human Services (HHS), which is the standard as outlined in the ARRA.
The Commission is in the process of applying to become a meaningful use certification entity as designated by ONC.
Why “meaningful use” requirements?
EHRs do not achieve these benefits merely by transferring information from paper form into digital form. EHRs can only deliver their benefits when the information and the EHR are standardized and “structured” in uniform ways, just as ATMs depend on uniformly structured data. Therefore, the “meaningful use” approach requires identification of standards for EHR systems. These are contained in the ONC Standards and Certification regulation announced on July 13, 2010.
EHRs cannot achieve their full potential if providers don’t use the functions that deliver the most benefit – for example, exchanging information, and entering orders through the computer so that the “decision support” functions and other automated processes are activated. Therefore, the “meaningful use” approach requires that providers meet specified objectives in the use of EHRs, in order to qualify for the incentive payments.
How will the CMS EHR incentive program registration process work?
Hospitals and eligible professionals can register for the program starting in January 2011. Once the programs begin, a link on the Registration web page of CMS will be available. Providers can use this central website to get information about the program and link to the programs’ online registration system.
How will providers demonstrate that they have achieved the “meaningful use” objectives required by the regulation?
For 2011, CMS will accept provider attestations for demonstration of all the meaningful use measures, including clinical quality measures. Starting in 2012, CMS will continue attestation for most of the meaningful use objectives but plans to initiate the electronic submission of the clinical quality measures. States will also support attestation initially and then subsequent electronic submission of clinical quality measures for Medicaid providers’ demonstration of meaningful use.
When will the Centers for Medicare & Medicaid Services (CMS) begin to pay Medicare and Medicaid electronic health record (EHR)?
CMS expects that Medicare incentive will begin to be paid in May 2011. Medicaid incentives will be paid by the States and will also begin in 2011 but the timing will vary by State. Under the Medicaid EHR Incentive Program, incentives can also be paid for the adoption, implementation, or upgrade of certified EHR technology.
Can multiple software applications be used to achieve Meaningful Use?
Meaningful Use can be achieved using any combination of systems. However, every application and module used to achieve meaningful use must be certified (or the combination of systems in use at the site must achieve site certification).
The Meaningful Use Rule identifies 15 Core Set required criteria and 10 Menu Set optional criteria (from which eligible professionals and hospitals must choose 5). Can they any 5 be choosen?
Any 5 can be selected. The Meaningful Use final rule notes “all EPs and hospitals must choose at least one of the population and public health measures to demonstrate as part of the menu set. This is the only limitation placed on which five objectives can be deferred from the menu set.”
Can a paper copy of the visit summary or discharge summary to the patient be provided?
EHRs and Hospital Information Systems must have the capability of producing a human readable summary AND a computable summary that adheres to the Standards Final Rule (CCR or CCD). The Standards Rule requires a CCR/CCD at a minimum plus optional human readable PDF, Text, DOC etc.
The EP could choose any of the listed means from the proposed rule of PHR, care portal (web site delivery), secure email, electronic media such as CD or USB or printed copy. If the EP chooses an electronic media, they would be required to provide the patient a paper copy upon request. Both forms electronic and paper can be produced by SuiteMed IMS EHR technology.
Do Rural Health Clinics qualify for Medicare incentives?
According to the CMS website, “An eligible hospital for Medicare incentive payments is a 'subsection (d) hospital' that is paid under the hospital inpatient prospective payment system.”
According to an Issue Brief released by the American Hospital Association “The payment incentives in the American Recovery and Reinvestment Act of 2009 (ARRA) are available to each hospital that is a meaningful user of a certified electronic health record (EHR); ARRA defines a hospital as a Medicare subsection (d) hospital, which is a general, acute care, short-term hospital.”
For a large medical practice with many physicians, is the ARRA reimbursement allowed per physician, or just for the medical group?
The reimbursement is permitted per “eligible professional,” as long as the eligible professional demonstrates “meaningful use of an EHR” and participates in Medicare. An eligible professional means physician, as defined in section 1861(r) of the Social Security Act –– this says “The term ‘physician’, when used in connection with the performance of any function or action, means (1) a doctor of medicine or osteopathy legally authorized to practice medicine and surgery by the State in which he or she performs such function or action". One important exception is if the physician is employed by a hospital; in that case, the hospital, not the physician, is eligible for the reimbursement.
Are radiologists eligible for stimulus funds?
According to the CMS incentive fact sheets, a Medicare Eligible Professional (EP) “is a doctor of medicine or osteopathy, a doctor of dental surgery or dental medicine, a doctor of podiatric medicine, a doctor of optometry, or a chiropractor, who is legally authorized to practice under state law.” Based on this definition, radiologists, whom are MDs, qualify for incentives.