The Office of the National Coordinator (ONC), established and funded by the American Recovery and Reinvestment Act (ARRA) HITECH Act, is in place to set initial standards, implementation specifications and certification criteria for EHR technology under the CMS EHR Incentive Program. The ONC coordinates the standards required of EHR systems with the meaningful use objectives for eligible professionals (EPs) and hospitals. With the ONC standards in place, providers can be assured that the certified EHR technology they adopt is capable of performing the required functions to comply with CMS' meaningful use objectives. To help standardize the meaningful use functionality that will be required from EMRs, the ONC established Approved Testing and Certification Bodies (ATCBs), such as CCHIT, to test and certify that an EMR functionality will allow providers to meet current meaningful use requirements.
While there are over 400 EMRs to choose from in the industry, not every vendor has the resources or desire to certify its software through an ONC-ATCB. Providers interested in implementing EMR for the first time, and providers already using an EMR, should check with their current vendor to verify that their EMR is (or will be) certified in time to secure incentive reimbursement dollars in 2011 or 2012 to ensure the provider will be eligible for maximum reimbursement throughout the life of the CMS EHR Incentive Program.
The first 2 years of the CMS EHR Incentive Program focus on a set of core and menu set requirements providers need to meet, called Stage 1 Meaningful Use. Stage 1 is intended to focus on the electronic capture of health info and use of that info to track key clinical conditions, communicate data for improved care coordination and report clinical quality measures and public health information. Providers should also secure commitment from their vendor that the EMR will be certified throughout all the stages of meaningful use, including Stages 2 and 3, which run through 2015.
For the Medicare program, providers are eligible to receive reimbursement of up to 75% of their maximum Medicare Part B allowable charges, annually, not to exceed the program maximum payout amounts by year. Providers practicing in a federally designated "Health Professional Shortage Area" are eligible for a 10% additional incentive bonus.
Please see the chart below to determine maximum Medicare annual reimbursements and the payout schedule.
For the Medicaid program, providers having over 30% of total patient visits dedicated to Medicaid are eligible to receive reimbursement of up to 85% of their net allowable charges for EMR purchase, implementation, training, support etc. required for the provider to adopt, implement or use EMR. Pediatricians who may not have 30% of their patient visits dedicated to Medicaid may still participate if at least 20% of their visits are Medicaid, although Pediatricians that opt for this relaxed percentage will only be eligible to receive 66% of the maximum reimbursement each payment year.
In the first desired payment year, Medicaid incentive program providers only need to prove adoption, implementation or use of a certified EMR in order to secure reimbursement. Future payment years may require that Medicaid program participants adhere to a full year of the same meaningful use requirements that the Medicare program mandates. Providers should verify the requirements with their state Medicaid organization. Finally, providers participating in multiple state Medicaid programs must select a single state from which to secure reimbursement.
Please see the chart below to determine maximum Medicaid annual reimbursements and the payout schedule.
First, you must select a CMS EHR Incentive Program, either Medicaid or Medicare. You should select the program for which you will receive the largest incentive. You cannot participate in both. The Medicare reimbursement program is federally managed so that it is consistent across all states and requires a single registration through the CMS EHR website. The Medicaid program is administered by the individual states so registration is slightly different in that providers will need to register through the CMS website, select the single state from which they seek reimbursement and then register with the selected state Medicaid organization.
Providers may register for the Medicare program now through the CMS EHR Incentive Program Registration and Attestation page. Pay close attention to the information that will be required for registration. Gather all the required info and complete the registration. The website will verify eligibility and inform the provider whether the registration was successful. As the Medicaid incentive programs are established by each state, providers will need to check with their state Medicaid organization to verify if and when their state program will be open for registration and well as requirements and reimbursement payment timelines. Click here to access the CMS list of Medicaid programs and their current status. Providers should verify if there will be any additional requirements to register for their state Medicaid program, as each state may have requirements that differ from the Medicare registration. Additionally, Medicaid programs will require a two part registration. First, providers will need to register with the CMS for an EHR Incentive Program through the CMS EHR Incentive Program Registration and Attestation page. Once registration is successfully completed through the CMS website, providers will be directed to follow up with their state Medicaid organization to complete the second part of their registration.
Once you've registered for the appropriate program, eligible providers interested in securing incentive program reimbursement will need to prove (attest to) the use of an EMR certified by an ONC-ATCB. Proving the use of a certified system, will require providers to simply access the ONC Certified Health IT Products List website and use the site search for their EMR. Providers will then use the website to generate a code, called the CHPL Code, which the provider will enter into their online CMS program registration application. Providers may register for an incentive program even if they are not currently using a certified EMR; simply leave the CHPL Code field in the application blank. Providers may access their CMS EHR Incentive Program registration at any time to update the field when they are working with a certified EMR and ready to begin the attestation phase to request reimbursement.
While an EMR needs to be ONC-ATCB certified to verify that it features the required functionality to help providers meet meaningful use, it is up to the individual provider to use the EMR in a meaningful way. EMR is simply a tool to help providers achieve meaningful use. Eligible providers and staff must make the commitment to ensure that the EMR is used in the required meaningfully way, consistently. A strong EMR implementation plan can help overcome the challenges of provider adoption and promote ongoing meaningful use. Successful implementation of your certified EMR software will involve more than just installing the software and training on how to use the wealth of standard features. Implementation to ensure achievement of meaningful use will require specific training in meaningful use functionality and the monitoring of users to ensure they are doing what will be required for incentive program attestation and the delivery of reimbursement.
Keep in mind that the larger payouts in the early years of the programs are meant to encourage the early adoption and meaningful use of EMR. In order to secure maximum reimbursement from the incentive program, don't wait to select your EMR vendor. Many vendors are experiencing backlogs with an influx of new clients eager to take advantage of the incentives. Selecting an EMR vendor early will allow for the required time to successfully manage the implementation project, ensure training in meaningful use features and allow time for providers to monitor their success with meaningfully using EMR.
Please note that providers must use the certified version of their EMR for 90 days consecutively in the first year in which an incentive payment is desired. In order to secure the maximum incentive across the life of the Medicare program, providers may complete their 90 days of consecutive meaningful use in either 2011 or 2012.