Friday, August 6, 2010

Incentive Payments to Qualified Users of EHR: What Is the Latest Information?

Dear ICANotes User,
Here is the latest information about the incentive payments to qualified users of Electronic Health Record systems.  We will keep you informed as new information becomes available. Please feel free to ask any questions you may have.

Background

The Federal Government is eager to promote the use of EHRs. It believes that their use will improve the quality and decrease the expense of medical care. Toward that end it made incentive payments to users of EHRs part of the American Recovery and Reinvestment Act of 2009. (HITECH is the part of ARRA describing the incentives.)

How Much Money? Eligible users of EHRs will receive as much as:

$18,000 in 2011
$12,000 in 2012
$ 8,000 in 2013
$ 4,000 in 2014
$ 2,000 in 2015
$ 0 in 2016

Total: $44,000

This incentive payment is calculated as 75% of Medicare or Medicaid payments. So, to receive the full $18,000 incentive payment in 2011 the clinician would have had to have received at least $24,000 in Medicare charges. ( 75% of $24,000 is $18,000.) Medicaid has a slightly different payment schedule.

Besides incentives for eligible users (the carrot), there are penalties for Medicare and Medicaid providers who do not use EHRs. In 2015 "payment adjustments" will be imposed on eligible providers who are not meaningful users of EHRs.

Who is Eligible?


Only clinicians who are Medicare or Medicaid providers are eligible.

Medicare: A Medicare Eligible Provider is defined as a doctor of medicine or osteopathy, doctor of dental surgery or dental medicine, doctor of podiatry, doctor of optometry or a chiropractor who is not hospital-based.

NOTE: A Medicare Eligible Provider is considered hospital-based if 90% or more of the EP's services are performed in a hospital inpatient or emergency room setting.

Medicaid: A Medicaid EP is defined as a physician, nurse practitioner, certified nurse-midwife, dentist, or physician assistant who furnish services in a Federally Qualified Health Center or Rural Health Clinic that is led by a physician assistant. To qualify for an EHR incentive payment, a Medicaid EP must not be hospital-based and must meet one of the following criteria:

- Have a minimum 30% Medicaid patient volume*
- Have a minimum 20% Medicaid patient volume, and is a pediatrician*
- Practice predominantly in a Federally Qualified Health Center or Rural Health Center and have a minimum 30% patient volume attributable to needy individuals
 
NOTE: A Medicaid EP is considered hospital-based if 90% or more of the EP's services are performed in a hospital inpatient or emergency room setting.

* Children's Health Insurance Program (CHIP) patients do not count towards the Medicaid patient volume criteria.

For more information about eligibility click here.

When Do Payments Start?

For eligible clinicians who can demonstrate meaningful use the payments will start as early as May of 2011.

What is Meaningful Use?

The most important part of Meaningful Use is that the eligible clinician has been using a Certified EHR system. ICANotes will be a Certified EHR in the near future. For more information regarding the status of certification see below.

Also, the clinician wanting to demonstrate Meaningful Use will have to show that the Certified EHR was used for at least 90 consecutive days in 2011 (which is whyeligible providers can't apply until April 2011 and payments can begin as early as May 2011.)

Also, use of E-Prescribing (which is available thru ICANotes) must be demonstrated for a certain percentage of patients.

Finally, as noted above, a Medicaid Provider who wants to be reimbursed through that program must demonstrate a certain percentage of Medicaid patients.

How Will Clinicians Demonstrate Meaningful Use?

For the first year, 2011, all that will be required is the clinician's attestation that the meaningful use criteria have been met.

What is the Status of Certification for ICANotes?

ICANotes is preparing itself for the certification process, which has not yet started for any behavioral health software. Recently the standards ICANotes and other behavioral health software will have to meet were released. As this is written we are waiting for the release of information about how the standards will be tested. Also, the government is currently considering the credentials of the agencies that will administer the certifying tests.

It is currently expected that testing can start by November. ICANotes expects to apply for the test and achieve certification by the end of 2010.

What sort of Standards Will ICANotes have to Meet?

As a relatively mature EHR ICANotes will have no trouble meeting the criteria for certification. Here are some examples of the test criteria:

Maintain an active medication list. More than 80% of patients have at least one entry recorded as structured data. ICANotes already maintains an active medication list.

Maintain an active medication allergy list. More than 80% of patients have at least one entry recorded as structured data. ICANotes already maintains an active medication allergy list.

Record smoking status for patients 13 and older. More than 50% if patients age 13 or older have smoking status recorded as structured data. ICANotes already records smoking status in the medical history (under Health and Behavior.) The data will have to also be stored in separate fields (as structured data) but this is an easy modification to make.

Record patient demographics (sex, race, ethnicity, date of birth, preferred language, and in the case of hospitals, date and preliminary cause of death in the event of mortality). More than 50% of patients’ demographic data must be recorded as structured data. ICANotes already collects extensive demographic data, all as structured data. A field for preferred language will soon be added.

There are 25 standards of this sort.

We will keep you informed as new information becomes available.
 
 
 

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