Five Key Steps to Ensure Federal Reimbursement for EMR Installation on Nashville Medical News

Five Key Steps to Ensure Federal Reimbursement for EMR Installation

By: TOM TARVER

Amidst all the hoopla surrounding the federal program to reimburse providers for adopting electronic medical records (EMR) systems, a key point sometimes gets overlooked: the path to payment is far from straight and easy.

It's fairly well known that medical practices will have to demonstrate in 25 different categories that they are making "meaningful use" of their EMR systems in order to receive the federal stimulus money. These include meeting standards with graduated milestones in 2011, 2013 and 2015 for such uses as e-prescribing and electronic order entry.

It's also well known that a carrot and stick approach is being used. The payments —$44,000 per physician in most cases — are the carrot. The stick is a reduced Medicare reimbursement schedule if compliance is not achieved by 2015.

But somewhat overlooked are the project planning and management approaches that will be needed if a practice is to have the best chance of success.

Experience suggests five key best practices:

Create a comprehensive project plan.
Build a team with the right people.
Use the right procurement process.
Be mindful of significant time constraints.
Verify compliance.

Create a comprehensive project plan

Full reimbursement comes only after following a four- to five-year process, so a project plan is vital to staying on track. Here are key elements:

Documenting your practice's requirements for a system.
Creating a procurement process that allows you to identify vendor offerings that match up with your requirements and provides a systematic method for reviewing those offerings.
Building a budget not only for hardware and software costs, but for training expenses, potential staff costs and consultant fees, as well.
Identifying financing for upfront outlays to purchase and implement the system. Federal payments are in arrears.

Establishing a compliance process to make sure federal requirements are being met. (More about that below.)

Build a team with the right people

Depending on the size and complexity of the practices, you'll want your EMR team to include the IT leader for the practice, a representative of the medical records staff, the practice manager and at least one physician champion to ensure buy-in by the medical staff.

Using the services of a consulting partner might also be helpful. A consultant's experience in purchasing and implementing EMR systems and in managing complex IT projects can save time and money and assure compliance.

Use the right procurement process

Your procurement approach should start with careful consideration of your requirements and also allow you to be sure that:

Systems being considered match up with the requirements of your specialty. Cardiologists, for example, need a system capable of reading their specialized diagnostics.

The system matches your workflow. Do your doctors want to input using a laptop in the exam room or use voice-recognition software? Different systems have different capabilities.

The EMR system will communicate seamlessly with your practice management system. If they don't come from the same vendor, they need to be able to integrate.

The system meets federal requirements. No certification, no reimbursement.

Be mindful of significant time constraints

Practices without an EMR system need to start the process now. Systems can take 12 to 24 months to put in place; and to obtain full reimbursement, a system must finish meeting the first stage of federal requirements by the end of 2012.
Going through the procurement process could easily take six months. Implementing the system could take another six months — and perhaps longer if vendor backlogs start to build. It might take additional months to go through the process of rolling doctors onto the system. And then you need to allow six to nine months of testing before attempting to meet the first stage requirement — that the milestones are being met for 90 consecutive days.

Of course if a practice already has a system in place and is just upgrading, less time would be required.

Verify compliance

While the federal government will make payments, at least initially, based just on an attestation by the practice that requirements have been met, it is just about inevitable that audits will follow. To avoid a bad audit, it is critical that a practice put into place a rigorous process to verify compliance.

That can be done in-house, but practices might wish to consider third-party verification. Third parties bring established testing procedures to the table and experience in identifying common problem areas. In addition, some financial institutions have suggested that they would require third-party approval to issue purchase financing.

In summary

Like many government programs, the reimbursement requirements for EMR are complex. Practices that put together the right team and undertake thoughtful planning and implementation will be most likely to receive the maximum federal payment.

Tom Tarver is president of LBMC eHealth Solutions, which assists physician practices in managing the process of acquiring and installing EMRs and in verifying compliance with federal rules. Contact Tom at ttarver@lbmc.com.