Meaningful Use - Physicians/Hospitals

Overview

The American Recovery and Reinvestment Act of 2009 (Recovery Act) authorizes the Centers for Medicare & Medicaid Services (CMS) to provide reimbursement incentives for eligible professionals and hospitals who are successful in becoming "meaningful users" of certified electronic health record (EHR) technology. The Medicare EHR incentive program will provide incentive payments to eligible professionals (EPs), eligible hospitals, and critical access hospitals (CAHs) that are meaningful users of certified EHR technology. By implementing the financial incentives for "meaningful use," providers will reap benefits not only financially, but also for their practice. Examples include a reduction in errors, availability of records and data, reminders and alerts, clinical decision support, and ePrescribing automation.

Rule Development

On December 30, 2009, CMS announced a notice of proposed rulemaking (NPRM) to implement provisions of the Recovery Act that provide incentive payments for the meaningful use of certified EHR technology. The proposed rule outlines provisions governing the EHR incentive programs, including defining the central concept of "meaningful use" of EHR technology. CMS' goal is for the definition of meaningful use to be consistent with applicable provisions of Medicare and Medicaid law while continually advancing the contributions certified EHR technology can make to improving health care quality, efficiency, and patient safety. To accomplish this, CMS' proposed rule would phase in more robust criteria for demonstrating meaningful use in three stages.

Definition by Congress

Congress defines three main components of Meaningful Use in the Recovery Act that are required to qualify for incentive payments. The requirements illustrate that providers need to show that they are using certified EHR technology in ways that can be measured significantly, both in quality and in quantity. The three main components are as follows:

1. Use of certified EHR technology in a meaningful manner (for example, electronic prescribing)

2. That the certified EHR technology is connected in a manner that provides for the electronic exchange of health information to improve the quality of care

3. That, in using certified EHR technology, the provider submits information on clinical quality measures and other measures selected by the Secretary.(ONC)

Purpose of Meaningful Use

• Ensure reform of health care and improved healthcare quality
• Encourages widespread EHR adoption
• Promotes innovation
• Avoids imposing excessive or unnecessary burdens on healthcare providers
• Recognize HITECH Act for providers to begin using certified EHR technology.
• Leading ultimately to patient-centered, evidence-based, prevention-oriented, efficient, and equitable health

Final CMS and ONC Rules

The final ruling for CMS defines the minimum requirements that providers must meet through their use of certified EHR technology in order to qualify for payments. After receiving more than 2,000 comments on the CMS proposed rule, the final rule addresses concerns while retaining the intent and structure of the incentive programs.

• Specifies initial criteria the eligible professionals (EPs), eligible hospitals, and critical access hospitals (CAHs) must meet to demonstrate meaningful use.
• Includes both "core" criteria that providers are required to meet, while allowing the provider a choice among a "menu set" of additional criteria. This gives the provider flexibility in the way they implement their EHR technology.
• Outlines a phased approach to implement the requirements for demonstrating meaningful use. This initially establishes criteria for meaningful use based on the available technological capabilities and providers' experience. CMS will continue to establish graduated criteria for demonstrating meaningful use through future rulemaking that will be consistent with the anticipated developments in technology and providers' capabilities.

According to the final rule's economic analysis, incentive payments under Medicare and Medicaid EHR programs for 2011 through 2019 will range from $9.7 billion to $27.4 billion. This could be as much as $44,000 through Medicare and $63,750 through Medicaid per clinician.

The final ONC rule also identifies the standards and certification criteria for the certification of EHR technology. This will reassure eligible professionals and hospitals that the systems they adopt are capable of performing the required functions and will allow them to qualify for incentive payments.

• Sets initial standards, implementation specifications, and certification criteria for EHR technology under the incentive program.
• Coordinates the standards required of EHR systems with Meaningful Use requirements for Eligible professionals and hospitals.
• With these standards in place, providers can be assured that the certified EHR technology they adopt is capable of performing the required functions as defined by meaningful use.

Who qualifies as an Eligible Provider (EP)

Medicare

Doctor of Medicine (MD), Doctor of Osteopathy (DO), Doctor of Podiatric Medicine (DPM), Doctor of Optometry, Doctor of Oral Surgery, Doctor of Dental Medicine

Medicaid

Doctor of Medicine (MD), Doctor of Osteopathy (DO), Doctor of PodiatricMedicine (DPM), Doctor of Optometry, Doctor of Oral Surgery, Doctor of Dental Medicine, Physician Assistant, Nurse Practitioner, Clinical Nurse Specialist, Certified Registered Nurse Anesthetist (and Anesthesiologist Assistant), Certified Nurse Midwife, Clinical Social Worker, Clinical Psychologist, Registered Dietician, Nutrition Professional, Audiologists, Physical Therapist, Occupational Therapist, Qualified Speech-Language Therapist.

Timetable for Implementation

According to the HITECH Act, payments for Medicare providers may begin no sooner than October 1, 2010 for eligible hospitals and January 1, 2011 for EPs. The final rule also aligned the Medicare and Medicaid program start dates. The implementation timetable is as follows:

• July 1, 2010: ONC began accepting applications from entities that seek approval as an ONC-Authorized Testing and Certification Body (ONC-ATCB)
• Fall 2010: ONC projects that certified EHR software will be available for purchase
• October 1, 2010: Reporting year begins for eligible hospitals and CAHs.
• January 1, 2011: Reporting year begins for eligible professionals.
• January 3, 2011:Registration by both EPs and eligible hospitals with CMS for the EHR incentive program begins. Registration begins online at http://www.cms.gov/EHRIncentivePrograms/20_RegistrationandAttestation.asp, where you can find a link to start the registration process, as well as user guides.
• April 2011: Attestations may be made for the Medicare program for both EPs and eligible hospitals.
• May 2011: Medicare EHR incentive payments begin.
• July 3, 2011: Last day for eligible hospitals to begin their 90-day reporting period to demonstrate meaningful use.
• October 1, 2011: Last day for eligible professionals to begin their 90-day reporting period for 2011 for the Medicare EHR Incentive Program.
• December 31, 2011: Reporting year ends for eligible professionals.
• February 29, 2012: Last day for eligible professionals to register and attest to receive an Incentive Payment for 2011.
• States will be initiating their incentive programs on a rolling basis, subject to CMS approval of the State Medicaid HIT plan, which details how each State will implement and oversee its incentives.

Implementation Stage Focus

1. Stage 1: Focuses on electronically capturing health information in a coded format; using that information to track key clinical conditions and communicating that information for care coordination purposes (whether that information is structured or unstructured, but in structured format whenever feasible); consistent with other provisions of Medicare and Medicaid law, implementing clinical decision support tools to facilitate disease and medication management; and reporting clinical quality measures and public health information.

2. Stage 2: Consistent with other provisions of Medicare and Medicaid law, expand upon the Stage 1 criteria to encourage the use of health IT for continuous quality improvement at the point of care, and the exchange of information in the most structured format possible, such as the electronic transmission of orders entered using computerized provider order entry (CPOE) and the electronic transmission of diagnostic test results (such as blood tests, microbiology, urinalysis, pathology tests, radiology, cardiac imaging, nuclear medicine tests, pulmonary function tests, and other such data needed to diagnose and treat disease). Additionally we may consider applying the criteria more broadly to both the inpatient and outpatient hospital settings.

3. Stage 3: Focus on promoting improvements in quality, safety and efficiency, focusing on decision support for national high priority conditions, patient access to self management tools, access to comprehensive patient data, and improving population health.

Meaningful Use Criteria

The criteria for meaningful use is staged in three stages over the course of the next five years.

Stage 1 (2011 and 2012) sets the baseline for electronic data capture and information sharing. It focuses on electronically capturing health information and using that information to track key clinical conditions and communicating that information for care coordination purposes. It must be consistent with other provisions of Medicare and Medicaid law, assist in implementing clinical decision support tools to facilitate disease and medication management, and report clinical quality measures and public health information.

Stage 2 (expected to be implemented in 2013) and State 3 (expected to be implemented in 2015) will continue to expand on the baseline established by Stage 1 and is to be developed in future rule making. It will focus on promoting improvements in quality, safety, and efficiency, focusing on decision support for national high priority conditions, patient access to self management tools, access to comprehensive patient data, and improving population health.

Stage 1 Requirements for Meaningful Use (2011 and 2012)

Meaningful use includes both a core set and a menu set of objective, specific to EPs, EHs, and CAHs. The objective is to improve quality, safety, efficiency, and reducing health disparities.

• For Eligible Professionals (EPs), there are 25 total meaningful use objectives. To qualify, 20 out of 25 objectives must be met.
• 15 are required core objectives, and the remaining 5 objectives may be chosen from a menu set of 10 objectives.
• For Eligible Hospitals (EHs) and CAHs, there are 24 total meaningful use objectives. To qualify, 19 out of 24 must be met.
• 14 are required core objectives, and the remaining 5 objectives may be chosen from a menu set of 10 objectives.

Stages 2 and 3 requirements will be defined further in future rulemaking.

Meaningful Use Terminology:

Meaningful use includes both a core set and a menu set of objective, specific to EPs, EHs, and CAHs. The objective is to improve quality, safety, efficiency, and reducing health disparities.

• Adopted: Acquired and installed certified EHR technology and can show evidence of installation.
• Implemented: Beginning to use certified EHR technology, such as providing staff training or data entry of patient demographic information into EHR.
• Upgraded: Expanded the existing technology to meet certification requirements
• Eligible Professionals (EP): These differ between the Medicare and Medicaid incentive programs.
• Medicare EP's: includes a Doctor of Medicine (MD), Doctor of Osteopathy (DO), Doctor of Podiatric Medicine (DPM), Doctor of Optometry, Doctor of Oral Surgery, or Doctor of Dental Medicine.
• Medicaid EP's: includes a Doctor of Medicine (MD), Doctor of Osteopathy (DO), Doctor of Podiatric Medicine (DPM), Doctor of Optometry, Doctor of Oral Surgery, Doctor of Dental Medicine, Physician Assistant, Nurse Practitioner, Clinical Nurse Specialist, Certified Registered Nurse Anesthetist (and Anesthesiologist Assistant), Certified Nurse Midwife, Clinical Social Worker, Clinical Psychologist, Registered Dietician, Nutrition Professional, Audiologists, Physical Therapist, Occupational Therapist, or Qualified Speech-Language Therapist.

To Learn more about Meaningful Use and Incentive Programs go to:

Azalea Health Innovations will propose the best Electronic Medical Records system for your practice including implementation, training, support, and guidance for stimulus reimbursements.