Physician practices around the country are asking us: "Should I wait for the government to finalize its definitions of 'meaningful use' and 'certified EHR technology' before I purchase electronic health record (EHR) software?"
Our answer: No.
We believe the chances of not qualifying for stimulus funds are next to zero, so long as you make smart decisions based on existing working definitions of meaningful use and certified electronic health record software. We know enough today to make the right purchase and implementation decisions.
There is another philosophy behind our answer: the stimulus opportunity is making too many practices lose sight of the real benefits of an EHR transformation. Focusing solely on government subsidies distracts practices from setting the right goals for the EHR project (e.g. quality of care, efficiency in the office). Without well-aligned goals, implementations fail.
Certified EHR Technology and Meaningful Use are Nearly Finalized
Update 1/7/09: Final interim rulings on meaningful use and certified EHR technology have been released.
The Health Information Technology for Economic and Clinical Health Act (HITECH Act), signed into law as part of the American Recovery and Reinvestment Act of 2009 (ARRA), created compelling financial incentives for physicians and hospitals who adopt electronic health records over the next five years.
Since the passage of the HITECH Act, Health & Human Services, along with various government health IT committees and groups, have been drafting definitions for meaningful use and certified EHR technology. The plan is to finalize these definitions by the end of 2009 or early 2010 (Interim final definitions have been released). But as you'll see below, their recommendations have been made public and submitted for final review to the Office of the National Coordinator of Health IT (ONC). In all likelihood, these public recommendations are what the ONC's office will use.
If you do the proper research and follow the recommendations that have been made public, it's nearly certain that you will qualify for ARRA incentives. Delaying an EHR software purchase not only defers the cost savings of using the software but also puts you at a disadvantage as EHR vendors become busier and busier in the coming year. Those that wait may find that their software vendor of choice is overwhelmed with other customers.
EHR Benefits Greater Than Stimulus Incentives
ARRA incentives begin in 2011 (assuming 2011 is your first year of being a meaningful user) and decrease over the next four years. Below, we put these incentives in the context of other return on investment (ROI) that you could realize from a successful EHR implementation. The takeaway is that ARRA incentives are significant, but they are just one piece of the EHR value proposition.
|Source: Electronic Health Records: A Guide for Clinicians and Administrators, Jerome Carter, MD, FACP|
The five-year savings of a full EHR implementation ($151,620) far outweigh the ARRA incentives ($44,000) over the same time period.
The first year (2011), is the only year ARRA incentives will exceed other EHR implementation benefits. That's due to the initial implementation costs of EHR software. In each subsequent year, the operational returns of a full EHR implementation will trump any stimulus incentives.
What does this mean for your practice?
You're not buying an EHR to to receive the ARRA incentives. You're buying an EHR to help you manage your practice more effectively, reduce costs and improve patient care. These are the goals that should drive your decision making.
The potential ARRA incentives for adopting an EHR are substantial. Over five years, the savings may be up to $44,000 for Medicare providers and up to $63,750 for Medicaid providers. But the benefits of choosing the right EHR for your practice are greater over a longer period of time. If you can choose an EHR that is right for you and is also eligible for ARRA incentives, then all the better.
Let's move on to what eligible professional, certified EHR technology and meaningful use mean in the context of the HITECH Act so you can better understand how to select your EHR software.
Eligible Professional Defined
This is the most straightforward section of the HITECH Act – defining who an eligible professional is.
Under Medicare, an eligible professional is a:
- Doctor of Medicine and Osteopathy
- Doctor of Dental Surgery or Dental Medicine
- Doctor of Podiatric Medicine
- Doctor of Optometry
Under Medicaid, an eligible professional is a:
- Certified Nurse Mid-Wife
- Nurse practitioner
- Physician Assistant (Rural Health Care Clinic/FQHC)
You cannot "double dip." You can only qualify under one program – either Medicare or Medicaid. The ARRA incentives will be payed out as Medicare or Medicaid reimbursements.
In 2006, the Certification Commission for Healthcare Information Technology (CCHIT) became the first group designated a Recognized Certification Body by Health and Human Services. CCHIT is not a government entity, but a non-profit, third party that certifies EHR software based on a number of stringent standards.
Right now, CCHIT's certification criteria for EHR software is the closest guide for what may be deemed the final certification standards criteria used by the United States government. Therefore, we believe that most any EHR with recent CCHIT Certification (i.e. 2007 or later) will qualify under the ARRA program.
However, in August 2009, the federal Health IT Policy Committee recommended that multiple entities be recognized as EHR certifying bodies in the interest of objectivity. In that August meeting, the committee discussed the possibility of up to a dozen certifying bodies in addition to CCHIT. It appears that CCHIT will eventually have some company as we move into 2010.
Defining Certified EHR Technology
On October 7, CCHIT announced two new levels of certification for EHR technology in 2011 and 2012: a) one designed to be comprehensive and exceed the federal standards; and, b) one designed to meet the federal standards for receiving ARRA incentives.
Here is CCHIT's EHR software criteria for meeting the less stringent ARRA standards level (which are also covered by the comprehensive certification level):
|Computer physician order entry||Capture orders for medications, laboratory, procedures, diagnostic imaging, immunizations, and referrals|
|Problem list||Maintain an up-to-date problem list of current and active diagnosis based on ICD-9 or SNOMED|
|Drug decision support||Perform drug-drug, drug-allergy and drug-formulary checks|
|E-prescribing||Generate and transmit permissible prescriptions electronically|
|Medication list||Maintain an active medication list|
|Medication allergy list||Maintain an active medication allergy list|
|Demographics||Record demographics including date of birth, insurance type, gender|
|Lab tests results||Incorporate lab-test results into EHR as structured data|
|Advance directives||Record advance directives|
|Vital signs||Record vital signs such as height, weight, blood and Body Mass Index|
|Patient lists||Generate lists of patients by specific condition to use for quality improvement, reduction of disparities, and outreach|
|Patient reminders||Send reminders to patients per patient preference for preventive/follow up care|
|Clinical decision rule||Have the ability to implement at least one clinical decision rule relevant to the specialty it is intended for, or at least one high clinical priority|
|Progress notes||Document a progress note for each encounter|
|Insurance eligibility||Check insurance eligibility from public and private payers where possible and report the percentage of patient encounters with insurance|
|Electronic claims submission||Submit claims electronically to public and private payers and report the percentage of claims submitted in this manner|
|Patient copy of health information||Provide patients with electronic copy of their health information|
|Patient access to health information||Provide patients with timely electronic access to their health information|
|Exchange clinical information||Exchange key clinical information (medication list, allergies) among providers of care and patient authorized entities electronically|
|Medication reconciliation||Perform medication reconciliation at relevant encounters and at each transition of care|
|Electronic syndromic surveillance||Provide electronic syndromic surveillance data to public health agencies and actual transmission according to applicable law and practice|
|Immunization registeries||Submit electronic data to immunization registries where required and accepted|
If your EHR software has these features, you're in good shape for getting reimbursed by the government for your software purchase. At the same time, keep in mind that not all specialties require all of these features. If the features do not apply to your specialty, they would not be a requirement.
Defining Meaningful Use
Becoming a "meaningful user" of EHR technology is another step in meeting the ARRA incentive standards.
This definition has caused big debates in the healthcare community over exactly what the government means. But as in the case of certification, enough information exists to effectively guide your purchase.
The Health IT Policy Committee, a federal advisory committee that provides recommendations to the National Coordinator for Health IT, released its final recommendation of the definition of "meaningful use" in August. These recommendations have been forwarded to the final decision makers – the Center for Medicare and Medicaid Services and the Office of the National Coordinator for Health IT.
Here are the Health IT Policy Committee's final recommendations for defining "meaningful use:"
- Provide access to comprehensive patient health data for patient's health care team
- Use evidence-based order sets and CPOE
- Apply clinical decision support at the point of care
- Generate lists of patients who need care and use them to reach out to patients (e.g. reminders, care instructions, etc.)
- Report to patient registeries for quality improvement, public reporting, etc.
- Provide patients and families with timely access to data, knowledge, and tools to make information decisions and manage their health
- Exchange meaningful clinical information among professional health care team
- Communicate with public health agencies
- Ensure privacy and security protections for confidential information through operating policies, procedures, and technologies and compliance with applicable law
- Provide transparency of data sharing to patient
We recommend that you follow CCHIT's ARRA certification criteria; use an EHR in a meaningful manner according to the recommendations above; and most importantly, choose the EHR software that is the best fit for your practice, regardless of ARRA incentives.
More than likely, the EHR you choose will qualify for incentives.