ARRA Incentives--Meaningful Use
When Congress passed the Stimulus Bill, formally known as the American Recovery and Reinvestment Act (ARRA), certain parts of which are also known as the HITECH act, they allocated over $30 billion to incentives for meaningful use of certified EHRs (EMRs). On July 13, 2010, HHS delivered its final rule that defines how this will work. You can download a nicely bookmarked copy of the rule from this location. Here are highlights:
Incentives begin in 2011 or 2012 (your choice) . Eligible providers can select either the Medicare or Medicaid incentive, but not both. Payments are spread out over 4 years.
- Medicare Incentives to Physicians - Maximum amount of $44,000 between 2011 and 2015.
- Medicaid Incentives to Pediatricians as well as Uninsured, FQHC, Rural and Low-Income Providers/Eligible Professionals - Maximum amount of $63,750 between 2010 and 2015.
So the key questions are:
- What determines "Meaningful Use"?
- Who is an Eligible Provider (EP)?
- Which EHR systems are certified?
- Will VersaForm be certified?
Eligible Provider "Meaningful Use" Criteria
The following criteria apply to activity during the reporting period. Requirements for hospitals are omitted from this list
- Record patient demographics (sex, race, ethnicity, date of birth, and preferred language). More than 50% of patients’ demographic data must be recorded as structured data
- Record vital signs and chart changes (height, weight, blood pressure, body mass index, growth charts for children). More than 50% of patients 2 years of age or older must have height, weight and blood pressure recorded as structured data.
- Maintain up-to-date problem list of current and active diagnoses. More than 80% of patients must have at least one entry recorded as structured data.
- Maintain an active medication list. More than 80% of patients have at least one entry recorded as structured data.
- Maintain an active medication allergy list. More than 80% of patients have at least one entry recorded as structured data.
- Record smoking status for patients 13 and older. More than 50% of patients age 13 or older have smoking status recorded as structured data.
- For professionals, provide patients with clinical summaries for each office visit. Clinical summaries should be provided for more than 50% of all visits within 3 business days.
- Upon request, provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication list, and medication allergies. More than 50% of requesting patients must receive an electronic copy within 3 business days.
- Generate and transmit permissible prescriptions electronically. More than 40% must be transmitted electronically using certified EHR technology.
- Computerized Provider Order Entry for Medication Orders. More than 30% of patients with at least one medication in their medication list must have at least one medication ordered through CPOE.
- Implement drug-drug and drug-allergy interaction checks. Functionality must be enabled for these checks for the entire reporting period.
- Implement capability to electronically exchange key clinical information among providers and patient-authorized entities. Must perform at least one test of the EHR’s capacity to electronically exchange information.
- Implement one clinical decision support rule and track compliance with that rule. One rule must be implemented.
- Implement systems to protect privacy and security of patient data in the EHR. Must conduct or review a security risk analysis, implement security updates as necessary and correct identified security deficiencies.
- Report clinical quality measures to CMS or states.
- For 2011, provide aggregate numerator and denominator through attestation.
- For 2012, electronically submit measures.
Meaningful Use - Menu Set
Meet 5 of these 10, include one population/public health measure.
- Implement drug formulary checks. Drug formulary check system must be implemented and access at least one internal or external drug formulary during the reporting period.
- Incorporate clinical laboratory test results into EHRs as structured data. More than 40% of clinical laboratory test results which are in positive/negative or numerical format and are incorporated into EHRs as structured data.
- Generate lists of patients by specific conditions for use for quality improvement, reduction of disparities, research or outreach. Must generate one listing of patients with a specific condition.
- Use EHR technology to identify patient-specific education resources and provide those to the patient as appropriate. More than 10% of patients are provided patient specific education resources.
- Perform Medication reconciliation between care settings. Medication reconciliation must be performed for more than 50% of transitions of care.
- Provide summary of care record for patients referred or transitioned to another provider or setting. Summary of care record must be provided for more than 50% of patient transitions or referrals.
- Submission of electronic immunization data to immunization registries or immunization information systems.
- Must perform at least one test of data submission and follow-up submission (where registries can accept electronic submissions)
- Submission of electronic syndromic surveillance data to public health agencies.
- Must perform at least one test of data submission and follow-up submission (where public health agencies can accept electronic data)
- Send reminders to patients (per patient preference) for preventative and followup care. More than 20% of patients aged 65 or older or age 5 or younger must be sent appropriate reminders.
- Provide patients with timely electronic access to their health information (including laboratory results, problem list, medication list, medication allergies). More than 10% of patients must be provided with electronic access to information within 4 days of its being updated in the EHR.
Who is an Eligible Provider?
Medicare: A Medicare EP is defined as a doctor of medicine or osteopathy, doctor of dental surgery or dental medicine, doctor of podiatry, doctor of optometry or a chiropractor who is not hospital-based.
NOTE: A Medicare EP is considered hospital-based if 90% or more of the EP's services are performed in a hospital inpatient or emergency room setting
Medicaid: A Medicaid EP is defined as a physician, nurse practitioner, certified nurse-midwife, dentist, or physician assistant who furnish services in a Federally Qualified Health Center or Rural Health Clinic that is led by a physician assistant. To qualify for an EHR incentive payment, a Medicaid EP must not be hospital-based and must meet one of the following criteria:
- Have a minimum 30% Medicaid patient volume*
- Have a minimum 20% Medicaid patient volume, and is a pediatrician*
- Practice predominantly in a Federally Qualified Health Center or Rural Health Center and have a minimum 30% patient volume attributable to needy individuals
NOTE: A Medicaid EP is considered hospital-based if 90% or more of the EP's services are performed in a hospital inpatient or emergency room setting.
* Children's Health Insurance Program (CHIP) patients do not count towards the Medicaid patient volume criteria.
Which EHR Systems are Certified?
None. To repeat: at present, no EHR systems are yet certified. Previous certifications, such as CCHIT certifications obtained in previous years are not valid for ARRA incentive payments. The reason is that certification for ARRA must follow closely the Meaningful Use requirements above--the intent is to assure providers that the system can give them the ability to satisfy the Meaningful Use requirements.
As of this writing (Sept. 7, 2010), two organizations have become certifying bodies--CCHIT (Chicago, IL) and the Drummond Group Inc. (Austin, TX). No EHR systems have been certified yet..
Will VersaForm be Certified?
Of course.
More Information?
See this site.
Comments?
The formal comment period on the rule is closed.
Comments or questions to VersaForm are always welcome.
