Overview
- What is the American Recovery and Reinvestment Act?
- What is HITECH?
- What is Meaningful Use?
- How much money is allocated to Medicare and Medicaid providers?
- What is a "certified EHR"?
- What does this mean to my practice?
- What does the term "Eligible Professional" mean?
- What is the Meaningful Use "Notice of Proposed Rule Making" document?
- What is the "Interim Final Rule" document?
- The rules aren't finalized. Will they change when they are finalized?
Dates & Deadlines
- When does the "Economic Stimulus" program start?
- For how long do I need to be a "meaningful user" to be eligible for incentive funds?
- When is the earliest that I can apply for incentive funds in 2011?
- Can I demonstrate Meaningful Use for any three months in 2011?
- Will I receive the same amount if I wait until 2012 or 2013
Meaningful Use Program Details
- How do I determine if I have selected the right product?
- If I have already implemented an EHR system, can I apply for incentive reimbursement?
- Must all providers under the same practice tax ID # use the EHR to qualify for the Medicare incentive?
- Do I have to use the EHR 100 percent of the time?
- What are the proposed stages?
- What will be required in Stage 1, Stage 2 and Stage 3?
- How do the Medicare and Medicaid definitions compare under Meaningful Use?
- Who is eligible under Medicare?
- Who is eligible under Medicaid?
Overview
What is the American Recovery and Reinvestment Act?
The American Recovery and Reinvestment Act (ARRA) of 2009, is an economic stimulus package enacted by the 111th United States Congress in February 2009. The Act followed other economic recovery legislation including the Economic Stimulus Act of 2008 and the Emergency Economic Stabilization Act of 2008, which created the Troubled Assets Relief Program (TARP).
What is HITECH?
HITECH is the Health Information Technology for Economic and Clinical Health act that was included in ARRA. HITECH established Electronic Health Records (EHR) incentive programs, which offer Medicare and Medicaid financial incentives for medical providers and hospitals that adopt and engage in Meaningful Use of certified EHR.
What is Meaningful Use?
The HITECH Act specifies four requirements for Meaningful Use: 1) use a certified EHR technology; 2) use that technology to perform e-prescription; 3) connect the certified EHR in a manner that provides for the electronic exchange of health information to improve the quality of care; and 4) use the technology to submit to the Centers for Medicare and Medicaid Services (CMS), information on clinical quality measures and other measures selected by CMS. CMS is proposing a phased, incremental approach of data submissions over five years.
How much money is allocated to Medicare and Medicaid providers?
The CMS estimates that the Medicare and Medicaid incentive programs will receive in total between $14.1 billion and $27.3 billion (net federal expenditures). However, the level of actual federal disbursements will hinge upon the number of providers who can achieve Meaningful Use.
What is a "certified EHR"?
Per wording within the HITECH-provision of the ARRA, a "certified EHR" is technology that meets specific standards outlined in the bill. The first release of standards was published in and Interim Final Rule by the Office of the National Coordinator (ONC) on December 20, 2009, subject to a public comment period that will run through March 13, 2010.
What does this mean to my practice?
This is a great opportunity to qualify for federal and state funding to automate your practice with an EHR system, and receive financial incentives for its use.
What does the term "Eligible Professional" mean?
An Eligible Professional (EP) is a user of an EHR who meets the four Meaningful Use requirements.
What is the Meaningful Use "Notice of Proposed Rule Making" document?
Referred to as the NPRM, this 556-page document defines eligibility requirements so providers may be eligible to receive incentive funds under the HITECH provisions of the ARRA.
What is the "Interim Final Rule" document?
This 139-page document, also called the IFR, matches the provider and hospital requirements stated in the NPRM to actual product requirements, the standards on which government certification of technology will be based.
The rules aren't finalized. Will they change when they are finalized?
Changes are possible based on public comment. Those changes will probably relate more to the way in which the criteria are implemented rather than the actual criteria.
Dates & Deadlines
When does the "Economic Stimulus" program start?
Medicare stimulus starts January 1, 2011 for EPs and October 1, 2010 for hospitals. Medicaid starts in 2010 on a state-by-state basis once the specific state has its program approved by the federal government.
For how long do I need to be a "meaningful user" to be eligible for incentive funds?
In the first payment year, 90 consecutive days of Meaningful Use must be demonstrated to receive incentive payment. In future years, Meaningful Use must be demonstrated for the entire year.
When is the earliest that I can apply for incentive funds in 2011?
The earliest date you can apply is April 1, 2011, but only after having collected 90 consecutive days of Meaningful Use data from January 1, 2011 through March 31, 2011.
Can I demonstrate Meaningful Use for any three months in 2011?
Your reporting period must be for 90 consecutive days starting January 1, 2011. The one limitation is that the 90-day continuous period cannot start after November 1, 2011, because that 90-day period would cross into the next year – 2012.
Will I receive the same amount if I wait until 2012 or 2013?
To get the maximum Medicare payments, eligible providers need to qualify in CY 2012 and hospitals in FY 2013. Both physicians and hospitals also need to meet Stage 3 criteria by 2015.
Meaningful Use Program Details
How do I determine if I have selected the right product?
Purchasing the right EHR product is an essential requirement for achieving Meaningful Use. First, the product must be certified as providing the capabilities and complying with the standards for Meaningful Use. The product must also provide the applications and features to meet the quality and efficiency goals (including but not limited to the proposed Stage 1 requirements).
If I have already implemented an EHR system, can I apply for incentive reimbursement?
If you have implemented an EHR system that meets the definition of Meaningful Use, you are eligible for incentive reimbursements.
Must all providers under the same practice tax ID # use the EHR to qualify for the Medicare incentive?
The Medicare incentive will be paid on a per physician basis, not on a practice basis. Any physician not using the EHR would not qualify as a meaningful user, but this would not affect other physicians in the practice using the EHR. Incentives will be specified per physician using their nation provider indicator (NPI).
Do I have to use the EHR 100 percent of the time?
Fifty percent (50%) or more of your patient encounters during the EHR reporting period must be at one or more practices or locations that are equipped with a certified EHR. This allows for EPs to participate in the program even if they work at multiple locations with varying levels of Meaningful Use adoption.
What are the proposed stages?
CMS proposes a phased, incremental approach of adoption to certified EHR technology using three stages. Specific objectives and measures are established for Stage 1 only, but CMS plans to establish State 2 and Stage 3 criteria through future rule making processes.
What will be required in Stage 1, Stage 2 and Stage 3?
Stage 1 Meaningful Use criteria focuses on: 1) capturing health information in a coded format; 2) using the information to track key clinical conditions; 3) communicating captured information for care coordination purposes; and 4) reporting of clinical quality measures and public health information. CMS officials recommend Stage 2 criteria be proposed by the end of 2011 and the Stage 3 definition be proposed by the end of 2013.
How do the Medicare and Medicaid definitions compare under Meaningful Use?
CMS has proposed that the Medicare meaningful use criteria serve as a minimum standard, or floor, for the Medicaid program. With the approval of CMS, states may change or add measures, as long as they promote the use of EHR technology and do not require additional functionality beyond that required of a certified EHR.
Who is eligible under Medicare?
A Medicare 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 legally authorized chiropractor.
Who is eligible under Medicaid?
Physicians, Dentists, Certified Nurse-Midwives, Nurse Practitioners, and Physician Assistants in Federal Qualified Health Centers (FQHC) or Rural Health Clinic (RHC) led by a Physician Assistant are considered an EP.
