CMS Proposes Definition of ‘Meaningful Use’
HITECH — Health Information Technology for Economic and Clinical Health Act —was created to stimulate the adoption of electronic health records by making funds available to enhance infrastructure at a state level and actually set up systems at a facility level. Part of the overall American Recovery and Reinvestment Act of 2009, one of the stipulations for receiving the federal dollars was using health information technology in a meaningful manner to enhance efficiency, establish quality controls and safeguard patients.
Jennifer McAnally, HIT program manager for QSource, readily recognizes the advantages to her clients who use the stimulus dollars to replace outdated paper systems with electronic ones. QSource, which has held the Quality Improvement Organization (QIO) contract for the state of Tennessee for more than three decades, is also a nonprofit healthcare consulting firm with an expertise in quality and safety.
“Health information technology is a tool just like a stethoscope is a tool,” McAnally pointed out. “Health information technology is really about making sure the doctor has the right information at the right time for the right patient. It’s making sure a doctor has a continuity of care picture for that patient, which is a moving picture rather than a snapshot.”
While there has been some movement in healthcare … albeit slow … to utilize the available technology, McAnally said many of the efforts are still siloed. “It’s very difficult to get information from one care setting to another.” However, she continued, part of the stimulus package allows for the creation of state health exchanges to ultimately ensure an easier flow of information not only between cities and counties but also nationwide.
Currently, there are numerous Web sites in Tennessee with important information such as the controlled substance or pediatric immunization data. However, McAnally said NetTN (
www.tennk12.net) would ultimately become the repository for “all things HIT” in Tennessee. NetTN has partnered with Tennessee eHealth Network (
www.tennesseeanytime.org/ehealth) to further facilitate the smooth flow of information. Additionally, there are health information exchanges already in place in East Tennessee (CareSpark) and in Memphis (Midsouth eHealth Alliance). Although Nashville does not yet have an exchange, one is in the works.
McAnally was quick to say that Tennessee is in a much better position than many states. “All the counties in Tennessee have broadband access. We actually take that for granted in Tennessee,” she noted, adding many states aren’t nearly as far along in terms of infrastructure and eHealth initiatives.
Up until now, there have been several major issues in adopting HIT at a facility or regional level. Cost, utilization and dealing with vendor-specific proprietary software have all created headaches and acted as a barrier to widespread adoption. The cost of purchasing and implementing a system has been significantly mitigated with the HITECH funding incentives. Recent certification requirements have begun to address some of the interface issues. “About three years ago, you started to see the market change,” noted McAnally. “More demands were put on vendors to make systems that are more interoperable.” As for utilization … there is still a steep learning curve to get providers and staff to change the way they complete daily tasks.
To help shore up the healthcare industry’s resolve to get on board the technology train, the federal government has not only created incentives to become a meaningful user of EHR between now and 2014, but the bonus plan converts to penalties in the form of reduced reimbursements in the year 2015. The penalty is a 1 percent payment reduction in 2015, 2 percent in 2016, and 3 percent in 2017. Furthermore, for those who wait until 2015 or later to adopt EHRs, there will not be any incentive money available to offset the cost of implementation.
For those who are ready to move forward, there are two stimulus options to consider. The first is the Medicare incentive. A non-hospital provider is paid 75 percent of what is billed to Medicare up to $18,000 in the first two years of the program. Therefore, McAnally explained, a provider who bills $10,000 annually in Medicare would be eligible to receive $7,500 in incentive dollars with a demonstration of meaningful use. To receive the maximum payout of $18,000 for the first year of use, which is only offered in 2011 and 2012, a provider would need to bill at least $24,000 annually to Medicare.
By keeping up that Medicare billing level and demonstrating meaningful use beginning in either 2011 or 2012, the provider should be able to draw down the maximum incentive of $44,000. If, however, meaningful use isn’t demonstrated until 2013, then the maximum draw becomes $39,000. In the final year of eligibility, 2014, the incentive drops to a maximum of $24,000 for the program.
The second option is the Medicaid incentive … or TennCare in Tennessee. It is based on the percentage of patient encounters that fall into this reimbursement category annually. McAnally said non-hospital family providers and specialists must have 30 percent of their patient volume be TennCare. For pediatricians, it need only be 20 percent. The plus of choosing this option, if qualified, is that it includes approximately $20,000 additional incentive dollars. “Most people are going to pick Medicaid if they qualify,” she said. “You can switch from year-to-year between Medicare and Medicaid, but you can never realize more than the maximum $63,750.”
For either option, first year of eligibility is defined as any continuous 90-day period of EHR reporting. After the first year, the assumption is that the system is up and running; therefore the EHR reporting period must be the entire year. To receive incentive funds the first year they are available, the system must be operational by Oct. 1, 2011 at the latest. To have the opportunity to receive the maximum five-year incentive payments, Oct. 1, 2012 is the last day to launch a certified EHR.
Although there must be at least 90 days of “meaningful use” in the first year, McAnally said the criteria for stage one compliance is fairly basic data capture. She said in this stage a provider would have to purchase certified technology, have the ability to e-prescribe, be able to accomplish computer physician order entry (CPOE) and be able to report clinical data.
“In stage two and three, they are definitely going to raise the threshold,” she said. Although specifics have not been published, CMS has been clear that in subsequent stages systems would be required to have the ability to transmit captured data across care settings and have viable population management features in place to ensure patient safety, quality of care and decision-making founded in evidence-based guidelines.
As for barriers to full implementation, McAnally said she believes the shear volume of providers lining up to purchase systems has the potential to be problematic for vendors, as well as from a credentialing standpoint. Additionally, she said, “There’s a real dearth of qualified health information technology professionals. There are just not a lot of curriculums that are developed around health information technology. That’s going to be an issue … just finding someone to install and implement (a system).”
Another concern is the overwhelming nature of the rule and educational curve to get providers up to speed on expectations and incentives. To that end, QSource has bid to become a Regional Extension Center (REC). The goal of these centers is to become a one-stop resource for all things HITECH. An announcement of REC bid winners is expected sometime this spring.