The foundation of the Medicare & Medicaid EHR Incentive Program is to improve quality of care. Facilitating documentation, enhancing provider communication and focusing on indicators that produce better outcomes necessitate an electronic solution for most providers. To achieve this, CMS has created significant and attractive financial incentives: a maximum payment of $44,000 per eligible professional (MD, DO, DMD, DDS, DPM, DC, OD) for Medicare, or up to $63,750 per EP for Medicaid. This means that a group with three EPs, could qualify for three distinct payments which are paid over a five-year period.
The Eligibility Process
Eligibility is straightforward. The EP must:
- Select an electronic health record system from the list of Certified EHR Technology.
- Decide for which incentives to apply. The Medicaid incentive payment is based on a volume of at least 30% Medicaid patients, while the requirement for the Medicare payment is contained in the volume requirements for the core and other measures.
- Register with CMS and receive an ID number.
- Complete an attestation each year. Keep in mind that a distinct attestation must be completed for each EP based on his/her use of the system.
However, the hand that giveth, also taketh away, so it’s important to understand the requirements that constitute ‘Meaningful Use’ and the attestation process that validates an EP’s eligibility for payment. This is the point at which some of the clients we’re coaching through the attestation process throw up their hands and say, “Maybe I don’t really need the money.”
The obvious goal of this program is to ensure providers use the system to its maximum capabilities to deliver quality care. It’s not unusual for a physician to make the investment in an EHR and then fail to devote the time to understand and adapt to the system. The result is a system that fails to deliver the efficiencies promised by the vendor.
The Attestation Process
An attestation is the means by which CMS ensures the system is implemented and used for key processes. The attestation is also what triggers the payment. For the first year, the EP is required to demonstrate compliance with 15 core measures during any 90-consecutive-day period. Some of the criteria are relatively simple, such as recording smoking status and maintaining an active allergy and medication list. Others can be somewhat taxing, like providing a clinical summary to patients for 50% of all office visits within three business days. But for the most part, the measures are do-able once the provider overcomes any psychological barriers to the system and realizes that the criteria will result in better care. These criteria include ordering medications electronically and allowing the system to check for drug interactions.
This process also requires meeting five Meaningful Use measures which include at least one public health criterion. Some examples are the capability to submit electronic immunization and syndromic surveillance data, as well as incorporating clinical lab test results into the system as structured data. This means that simply scanning in or importing the lab report isn’t sufficient. Providers need to key the actual values in a numeric or positive/negative format so the data can be analyzed and aggregated.
The burden for subsequent years is demonstrated use of the system for all required measures for the entire year, and not just one quarter. Obviously, it is expected that once a provider enjoys the benefits of an EHR, he or she will be more apt to continue the trend.
In summary, the Medicare and Medicaid EHR Incentive Program removes some of the obstacles to implementing this important technology by defraying a portion of the costs and by creating measurable goals that enhance patient wellness and facilitate practice efficiency. And if you haven’t started the ‘Meaningful Use’ process, the ship has not yet sailed on the incentive program. EPs have the balance of 2012 to secure an EHR and begin using it to qualify for the maximum payment. The Medicare incentive payments for 2013 and 2014 are $39,000 and $24,000, respectively.