After working for more than a year to develop its Meaningful Use and Certification rules, the Centers for Medicare and Medicaid Services and the Office of the National Coordinator for Health Information Technology (ONC) are focused on ensuring healthcare providers know how to enroll in the soon-to-be-launched incentive program.
In a “free training” session held by CMS on the final rules, officials from that agency and ONC covered eligibility issues, the relationship between HITECH and other government incentive programs and how the states and federal government will harmonize the Medicare and Medicaid portions of the program.
Beyond actually doing the Meaningful Use work, providers must adhere to the following administrative requirements. In January 2011, all providers must register via the EHR Incentive Program Web site; be enrolled in Medicare FFS, MA, or Medicaid (FFS or managed care); have a National Provider Identifier (NPI); use certified EHR technology to demonstrate Meaningful Use (Medicaid providers may adopt, implement, or upgrade in their first year) and all Medicare providers and Medicaid eligible hospitals must be enrolled in PECOS.
States will connect to the EHR Incentive Program Web site to verify provider eligibility and prevent duplicate payments; and ask providers for additional information in order to “make accurate and timely payments” (such as patient volume, licensure, A/I/U or Meaningful Use, and Certified EHR Technology).
Explaining some changes that occurred as the Meaningful Use NPRM morphed into its recently released final form, Elizabeth Holland from the Office of E-Health Standards and Services (OESS) under CMS, explained one particular area of concern to many providers which has been adjusted.
Specifically, many providers complained in their comment letters about the burden of having to manually discern the denominator for the electronically related numerators CMS wanted to collect. For example, if CMS wanted to know the number of CPOE orders versus the total number of orders placed, that would require a manual count. As a result, Holland said CMS split its requirements into two areas — some which will still require a manual count, and some which will not. The latter would concern the percentage of certain tasks which are performed only in electronic records — for example, how many times patient demographics were taken for all the EHRs kept in a facility.
The issue of eligible providers who practice at multiple locations was also addressed. Jessica Kahn, technical director for HIT at CMS, said an EP who works at multiple locations, but does not have certified EHR technology available at all of those, must have 50 percent of their total patient encounters at locations where certified EHR technology is available; and base all their Meaningful Use measures only on encounters that occurred at locations where certified EHR technology is available.
With many programs in the same area, CMS stated its goals are to coordinate clinical quality measure (CQM) development and reporting with implementation of the Patient Protection and Affordable Care Act; and align Medicare Physician Quality Reporting Initiative (PQRI) and Reporting Hospital Quality Data for Annual Payment Update (RHQDAPU) reporting. The agency is also focused on aligning Children’s Health Insurance Program Reauthorization Act (CHIPRA) and HITECH CQMs “where possible.”
Other programs CMS is looking to harmonize include the, Medicare EHR Demonstration; Medicare Care Management Performance Demonstration; and Electronic Prescribing Incentive Program. Providers may enroll in the former three and also enroll in the Meaningful Use incentive program, while for the latter, they cannot if also enrolled in the Medicare portion of HITECH.
While attestation will suffice for the 2011 reporting period, in 2012 EPs, eligible hospitals, and critical access hospitals (CAHs) seeking to demonstrate Meaningful Use will be required to electronically submit aggregate CQM numerator, denominator, and exclusion data to CMS or the states.
EHR Incentive Program Timeline
- January 2011 –Registration for the EHR Incentive Programs begins
- January 2011 –For Medicaid providers, States may launch their programs if they so choose
- April 2011 –Attestation for the Medicare EHR Incentive Program begins
- May 2011 –EHR incentive payments begin
- November 30, 2011 –Last day for eligible hospitals and CAHs to register and attest to receive an incentive payment for FFY 2011
- February 29, 2012 –Last day for EPs to register and attest to receive an incentive payment for CY 2011
- 2015 –Medicare payment adjustments begin for EPs and eligible hospitals that are not meaningful users of EHR technology
- 2016 –Last year to receive a Medicare EHR incentive payment; Last year to initiate participation in Medicaid EHR Incentive Program
- 2021 –Last year to receive Medicaid EHR incentive payment