The highly anticipated time has finally arrived: On April 18, the Centers for Medicare and Medicaid Services launched the attestation program for reporting stage 1 milestones of "meaningful use."
Under the American Recovery and Reinvestment Act of 2009 (ARRA), this will allow providers who have implemented a certified electronic health record to cash in on the Medicare incentives promised for so long. Finally, that $44,000 seems within reach!
Dr. Neil Skolnik and Dr. Chris Notte
To claim the incentive dollars, practices should navigate to the CMS Web site and begin reporting. The site provides detailed instructions, tutorials, and step-by-step screenshots on what to expect throughout the process.
Providers are required to report on 15 core measures, 5 out of 10 additional measures from a menu of options, and 6 clinical quality measures. Each step differs in what information must be provided, and records need to be maintained in case of audit.
The ARRA incentive program is administered at the state level, and therefore the timeline for reimbursement varies based on practice location. Those skeptical about ever seeing the money should be reassured that many have already begun realizing the financial rewards of their EHR: The CMS reports it has already disbursed $65 million since the beginning of 2011 to providers in certain states.
If you find yourself fortunate enough to be among that group, consider yourself lucky. But before taking a much-needed rest on your proverbial laurels, remember what’s looming just around the corner: stage 2.
The wrangling already has begun over the stage 2 requirements. Not surprisingly, there are many who are concerned about the timing of implementation. They argue that it is unrealistic to expect physicians to begin thinking about stage 2 when many have not yet begun to use an EHR in a significant way. If the original timeline is maintained, physicians will need to collect stage 2 data in 2012 to receive bonuses in 2013. But many providers have stated that they will not be able to even consider stage 1 reporting until 2012 at the earliest.
As long as the process is started by next year, practices will still be able to maximize the incentives – but there is no question that the sooner an EHR is adopted, the better the chance of financial reward.
Conversion to electronic records does not occur overnight. It is time consuming to choose the right EHR, and once selected, the transition to actual "meaningful use" can take several months or more. In addition, even in the best of situations, unforeseen roadblocks can significantly slow down the process. Eventually, failure to meet meaningful use will result in reimbursement penalties, and the advent of stage 2 criteria is a reminder that the clock is ticking.
The content of the stage 2 criteria is another concern, with experts disagreeing on what should actually be included. To make things worse, other recent health initiatives have significantly complicated this process.
On March 31, the Department of Health and Human Services released the proposed rule for accountable care organizations (ACOs).
As described, an ACO will be a group of providers that assume responsibility for a defined population of Medicare patients, with the goal of increasing quality of care and decreasing delivery costs. If successful, the providers will share in the cost savings.
While ACOs sound like a good idea on the surface, they will come with a new and completely different set of reporting requirements. Certified EHRs that have been designed around "meaningful use" may not have the capabilities necessary for ACOs, especially when it comes to provider communications and transition of care. This may mean significant software revisions and system upgrades that are both time consuming and expensive.
Many are calling for an alignment of the stage 2 requirements with those of ACOs, as accountable care organizations represent a model that will endure long after "meaningful use" has come and gone. Dr. Farzad Mostashari, who just succeeded Dr. David Blumenthal as the National Coordinator for Health Information Technology, stated recently that he would like to see meaningful use as a "jump-start on what you’re going to need to do to be successful as an ACO." This is probably a best-case scenario for stage 2.
Over the next few months, there will be tremendous attention paid to how health care reform will shape the landscape of electronic health records. As care providers and EHR vendors lobby for delaying the implementation of stage 2, patients and consumer advocacy groups will continue to call for ever-advancing technology focused on better care at lower costs.