Before You Expend Resources and Take Risks for Meaningful Use, It’s Best to Know the Players and the Plays You Need to Make.
There are not that many pieces of ‘gear’, ‘players’ and ‘plays’ to learn, so take you time and get comfortable with them. You’ll be at this for several years.
EHR: Electronic Health Record. When the emphasis is on the access of all stakeholders to an electronic record, this term is preferred over Electronic Medical Record. It is used exclusively in discussing Meaningful Use. It is also used when referring to an EHR software product, as in “I am looking for a certified EHR.”
ARRA: American Recovery and Reinvestment Act – the ‘Stimulus’ Bill. ARRA includes the HITECH Act.
HITECH Act: The Health Information Technology for Economic and Clinical Health Act. It includes provisions for the Meaningful Use of EHR incentives. It also includes provisions that strengthen the requirements for reporting breach of security and privacy that were in the original HIPAA legislation.
Meaningful Use: The full term is ‘Meaningful Use of an EHR’ but it is often shortened to ‘Meanngful Use’. As stated in the HITECH Act, it is a standard for EHR software and their use in healthcare. The standards are implemented in stages with incentives associated with achieving each stage.
ONC: Office of the National Coordinator Health Information Technology. A position created to give national leadership to health information technology inititives in the second Bush administration. It received broad additional responsibility for implementing the provisions of the HITECH Act including Meaningful Use.
CMS: Center for Medicare and Medicaid Services. CMS administers the Meaningful Use Incentive program registation process. Registation can be made for hospitals and for eligible professionals. It also administers the national Medicare Meaningful Use Incentive Program. States administer their own Medicaid programs. CMS is also the source of definitive guidance on the rules for achieving Meaningful Use through its FAQs, published on its website.
HIT Policy Committee: Health Information Technology Policy Committee. The committee was created by ARRA as a Advisory Committee appointed by the Controller General of the United Stated from private citizens who applied to be members based on their subject matter expertise and leadership qualities. It developed how the Meaningful Use Criteria would be rolled out in Stages and the mechanism for certifying EHR products as capable of achieving Meaningful Use.
Stage 1 Meaningful Use Standards: These standards are the first stage of compliance with the standards for Meaningful Use of an EHR stated in the HITECH Act. They were developed by the HIT Policy Committee under the direction of the ONC.
Certified EHR: This is an EHR software product that has been certified by a designated testing center as being able to achieve Meaningful Use standards. These technical standards were formulated by the National Institute of Standards and Technology based on Stage 1 Meaningful Use Standards.
Meaningful Use Incentive: A monetary award to eligible professionals or hospitals for achieving Meaningful Use standards using a Certified EHR.
Medicare Incentive: The national Meaningful Use Incentive program administered by CMS that pays eligible professionals or hospitals on the basis of 75% of Medicare claims up to a fixed amount. The incentive can be reapplied for in the four following years for a total incentive of $44,000 per eligible healthcare professional. The hospital payments are determined in a different manner.
Medicaid Incentive: Each state obtains approval from CMS to administer a program that pays eligible professionals or hospitals an incentive by having 30% of paid claims paid by Medicaid. The incentive can be applied for for five additional years with reduced base amounts after the first year up to a total award of $63,750. Hospitals payments are determined in a different manner.
Medicare Eligible Professionals: Eligible professionals include physicians, including doctors of podiatry, optometry, chiropractic and dentistry.
Medicaid Eligible Professionals: This includes MDs and DOs, but not the additional doctors approved under Medicare. Nurse practitioners are eligible. So are Physicians assistants leading a Federally Qualified Health Center.
Reassigning the Incentive to an Entity Promoting the Adoption of Certified EHR Technology: Most healthcare providers who use a certified EHR will have it provided by an organization they work for. Therefore, the incentive should go to the organization which is ‘promoting the adoption’ of the technology. However, the incentive is the professional’s to assign. The assignment must be voluntary.
Registration: Registration with CMS is the starting point for both eligible professionals and and hospitals in applying for a Meaningful Use of EHR incentive. A physician can register as an eligible professional even if they work at a hospital as long as the percentage of their hospital work does not equal or exceed 90%. Registration is done only once. The key choice is whether to participate in the Medicare or the Medicaid Incentive program. This choice can be changed in following years. The incentive can either be assigned to the professional (if they provided their own certified EHR) or to the organization providing the certified EHR.
Attestation – Medicare: For those applying for the Medicare Incentive, attestation is to CMS, the party applying for the incentive attests to using an EHR that has achieved Stage 1 Meaningful Use standards.
Attestation – Medicaid: For those applying for the Medicaid Incentive, attestation is to the state Medicaid program. It includes demonstrating at least a 30% level of Medicaid participation in paid claims. It also includes demonstrating having adopted, upgraded to or implemented a certified EHR. Use standards follow in subsequent years.