The Health Information for Economic and Clinical Health Act (HITECH) portion of the American Recovery & Reinvestment Act of 2009 (ARRA) provides incentives and regulations for the use of electronic health records (EHR) by all Medicare enrolled practitioners, whether a single physician or a multiple site clinic group.
The HITECH act has three objectives:
- Use of certified EHR in a “meaning manner”,
- Use of certified EHR technology for electronic exchange of health information to improve quality of healthcare, and
- Use of certified EHR technology to submit clinical quality measures (CQM) and other such measures selected by the Secretary (of Health and Human Services).
CMS stated the criteria for meaningful use is based on a series of specific objectives, each of which is tied to a measure that allows Eligible Professionals (EPs) and hospitals to demonstrate that they are meaningful users of certified EHR technology.
The use of EHR will be rolled out in stages over the next five years. For Stage 1, which began January 1, 2011, there are 25 objectives/measures for EPs. The objectives/measures have been divided into a core set and menu set. EPs and eligible hospitals must meet all objectives/ measures in the core set (15 for EPs and 14 for eligible hospitals). Where it is impossible for an EP or eligible hospital to meet a specific measure, an exclusion was defined in the final rule. If an exclusion applies to an EP or eligible hospital, then such professional or hospital does not have to meet that objective/ measure in order to be determined a meaningful EHR user. For example, if an EP has two exceptions (one for a core objective/measure and one for a menu objective/measure), the EP would need to meet the remaining 14 objectives/measures in the core set and four of the remaining nine objectives/measures in the menu set.
What are the 25 objectives/measures? Here’s a partial list:
- CPOE (Computerized Physician Order Entry) – 30% of patients seen with meds have at least one med ordered by CPOE
- eRx – >40% permissible scripts are sent electronically
- Capability to report ambulatory clinical quality measures (CQM) to CMS & State – 3 required measures, 3 elective measures
- Implement 1 clinical decision support rule
- Provide patients with an electronic copy of their health information upon request
- Provide clinical summaries for patients for each office visit
- Drug/Drug and Drug/Allergy interaction checks capability
- Record patient demographics – at least 5 specific items
- Maintain up-to-date problem list of current diagnoses per patient
- Maintain active medication list
- Maintain active medication allergy list
- Record and chart changes in vital signs
- Record smoking status for patients age 13 and up
- Demonstrate ability to exchange key clinical information among providers electronically – at least one test during 2011
- Protect electronic health information –system security capabilities
Clinical Quality Measures to Report
What are the CQM’s mentioned that must be reported to CMS and State agencies? The three required measures are:
- Hypertension/Blood Pressure Measurement
- Preventive Care & Screening for Tobacco Use Assessment and
- Cessation Intervention and Adult Weight Screening and Followup.
The three alternative measures are:
- Weight Assessment & Counseling for Children/Adolescents
- Influenza Immunization for patients age 50 and up and
- Childhood Immunization status.
This provides clinics with an understanding of what CMS wishes to target in the national population over the next 20 years.
The implementation of EHR will be spread over a five year period beginning January 1, 2011. Both the Medicare and State Medicaid (Medi-Cal) programs will provide incentives to practitioners to become compliant with EHR requirements. Under the Medicare program eligible professionals include doctors, dentists, podiatrists and chiropractors.
The Medicaid programs add nurse practitioners, certified nurse-midwives and physician assistants (if working in an FQHC or RHC) to the eligibility list.
What are the incentives? The Medicaid programs offer slightly more money and are less restrictive in their requirements. Medicare offers $44,000 maximum over a 5 year period, with an additional 10% available if the eligible professional works in a HPSA (Health Professional Shortage Area) designated service area. Medi-Cal offers $ 63,750 maximum over 6 years. These payouts will be made on a “per practitioner” basis, tied to the personal NPI identifier for each provider. Clinic and physician groups can utilize these funds to upgrade or change the site’s practice management system (hardware & software) to include all required components of an EHR.
CMS objective is to obtain widespread adoption of electronic information exchange… to facilitate the exchange of patient information among multiple sites and practitioners.
An Interesting Situation
If a physician practices strictly in a clinic setting and is compensated for patient care by that clinic, how does the clinic get reimbursed for the physician’s incentive payment? Consideration should be given by clinic management to negotiating a handover of the funds from the physician, especially if the physician utilizes the resources and practice management system of the clinic.
Obtaining widespread adoption of electronic information exchange. CMS’ objective is to obtain widespread adoption of electronic information exchange (HIE) within clinic and physician group practices in order to facilitate the exchange of patient information among multiple sites and practitioners. They believe the results will be a more standardized approach to recording patient information and a reduction in clinical redundancies and errors. The time to adopt EHR is now while financial incentives exist to assist in this transition.