It’s important to remember that there are two major organizations that are responsible for all the “rules” for Meaningful Use. One is the Centers for Medicare & Medicaid Services (CMS) who actually owns the rule. The second major organization is called the Office of the National Coordinator (ONC). The ONC owns the standards and the certification criteria. It is important to understand the different organizations and their roles so you know from where the different “rules” are generated.
Meaningful use is all part of the 2009 Economic Stimulus Package The goal is to migrate all providers into the meaningful use of electronic health records to record the care of our patients for two reasons. The first is patient safety. The second is to aggregate patient information to facilitate the access of current, complete and accurate health information across providers as patients start traversing the healthcare continuum.
Two Sources of Money
There are two ways to get paid for Meaningful Use: Medicare or Medicaid.
Medicare
The Medicare money totals about $44,000 per provider (over 5 years), depending on how and when you implement. To get the maximum incentive payment, Medicare eligible professionals must begin participation by 2012.This money will only be available once you prove you have not only implemented your certified EHR but are using it in a “meaningful way”. It pays you for “Meaningful Use” – -meaning that you are not paid until you can prove you are using many components of your electronic system to care for patients and able to report electronically. You will have to make your investment, install the system, utilize it, and then report your use according to specific mandated requirements. Payment is received only when you successfully report your usage.
Medicaid
Medicaid offers about $63,700 per provider (over 6 years) and covers more eligible providers (advance practice nurses). This program is funded by each State and as of April 6, 2011, 14 states offer this option. This program provides payments as providers adopt, implement, upgrade or demonstrate meaningful use of a certified EHR technology in their first year of participation and demonstrate meaningful use for up to five remaining participation years. In other words, you can actually use your Medicaid dollars to purchase your electronic medical record and to implement it.
So How Do You Get the Money?
The 25 Measures
First, remember that there are 25 measures. Of those 25, you must meet the requirements of 20 – 15 mandated ones and 5 of the 10 remaining measures for 90 consecutive days. You will also need to meet 6 of the clinical quality goals. You must meet the numerator and the denominator for these measures, which we will go into in another blog post in the near future.
Attestation
Second, if you implement this in 2011, you will do it by attestation. You will submit attestations to Medicare stating that you met both the numerator and the denominator requirement for each of the 20 measures that you are going to submit. Registration is now open and attestation may begin as early as April 18th. The last day to begin your 90 day attestation period is October 1, 2011. CMS expects to begin making Medicare HER incentive payments as soon as May 2011.
Your EHR Vendor
There are a few key points to keep in mind. When you are setting up your reports to review your data and ascertain your progress for attestation, be sure you are following your EHR vendor’s lead. Starting in 2013,the only way that Medicare will accept this data is via your EHR vendor. You will not be able to submit your own reports nor will you be able to do it by attestation so it will be critical to know how your vendor pulls your data.
90 Days of Continuous Meaningful Use
In order to get your money this year, you will need to do 90 days of continuous Meaningful Use. In my three physician practices, we will be turning that clock on May 1, 2011. Beginning May 1, we will start the process and then for the next 90 days we will need to attest that our physicians are meeting each of the 20 measures – consistently, every day, for every measure.
Restarting the Clock
If a physician fails to meet one of the measures you will have to restart the clock for that particular doctor, but you don’t have to restart the clock for the whole group. You also can start this process without a certified EHR — however you MUST have the certified product in use when you submit your data.
Currently, you have to register and attest each of your physicians individually (as opposed to by group), but you will be able to designate a third party to handle these administrative tasks in early May. Until this system is in place, however, each eligible professional will have to register for him or herself.
Next Steps…
- First, you need to decide if you’re going to pursue funds from Medicare or Medicaid.
- Second, pick your 20 measures, 15 of them of course are mandated,and the remaining 5 are your choice.
- Third, register your physicians/group online.
- Fourth, you are going to start the 90 day clock as soon as you run your own internal reports and know you are in compliance. You will need to make sure you are meeting the criteria and the specific numerator criteria for each of those measures. Once the 90 day clock is complete you report to Medicare through the attestation process and, believe it or not, they are telling us that within 90 days of your submission you will get your money.
Unlike E-Prescribing and Physician Quality Reporting Initiative (PQRI), you will not have to wait a whole year. For Incentive payments in 2011, please remember that you can do PQRI and Meaningful Use together. However, you cannot do E-Prescribing and Meaningful Use together.
Future Stages of Meaningful Use
There are actually three stages to Meaningful Use. This is only the first stage, and this is supposed to be the easiest stage. The Stage 2 proposed rule has just been submitted. If you delay your implementation of Meaningful Use until 2013 or later, you will have to go right to Stage 2, which will have more stringent requirements and higher targets. This is why it is so critical to implement Meaningful Use as soon as possible.
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