With the final rule for meaningful use for an electronic health record (EHR) released in mid-July, how to meet those requirements may seem as clear as mud. Whether your practice has already installed an electronic medical record (EMR) system, about to install one, still mulling over the various systems or dragging your feet hoping the legislation goes away, ensuring that your system meets the requirements of meaningful use is imperative. Although this can seem daunting, several sources of help are available to ensure that your system meets the requirements to qualify for incentive payments and avoid penalties.
“While the final objectives have been determined, it can still leave healthcare providers scratching their heads as to how these will impact their operations, how will they measure each objective and how will they prove they are meeting the objectives,” said Becky Englehardt, a healthcare consultant with Horne, PLLC in Nashville. “With the final decision on meaningful use set, it is imperative that physicians evaluate the EHR system they have already purchased or are considering purchasing to ensure that it meets all the requirements of a qualified user and receive incentive payments.”
Under the final rule for meaningful use for Stage I incentives in 2011 and 2012, most requirements are unchanged from the draft released in January, but some thresholds were reduced and significant flexibility added to make the transition to EHRs more feasible for many providers. The requirements are basically the same as those proposed in January, but now only 15 core requirements are mandatory for eligible providers. Another five requirements must be selected from a menu of 10 additional requirements. At least one of the selected menu requirements must relate to public health. Many of the targets for the percentage of patients that must meet the requirements also have been lowered.
To qualify for incentives, eligible providers must be using certified systems. To be certified, the systems must be capable of meeting all the final requirements and report on all the required measures, thereby increasing the requirements for vendor products.
Each requirement has an associated measure. Most measures are based on unique patients seen during a reporting period. Certified systems will be required to have the capability to report on all the required measures. The percentages indicated to meet a measure apply to all patients.
To receive the incentive in 2011, healthcare providers must verify that they have demonstrated meaningful use of certified electronic health records for 90 days. The format for this attestation of meaningful use will be available on the Center for Medicaid and Medicare Services website on EHR Incentive Programs. In 2012, quality data must be submitted electronically and coded according to the final standards from July 13.
“When you chose an EHR vendor, I recommend looking for a company with an excellent reputation that stays current with developments and that you know will be around in five years,” said Englehardt, who has a bachelor’s degree in nursing, a master’s degree in business and is a certified professional coder. “It is important in the selection process of an EHR system that physicians ask their vendor to prove to them that the system meets each objective and get it in writing. EHR vendors, for the most part, are working diligently to keep their systems up to speed with meaningful use requirements, even in the flurry of changes that have occurred. Some practices that already have an EHR system in operation may need to buy additional software to meet the latest requirements and produce the special reports required.”
“It is imperative that a practice understand the meaningful use criteria, whether they go to a seminar, webinar or hire a consultant. There is so much to meaningful use, you have to be pretty techno-savvy to do it. Even if a practice is at the point of filing attestation to get incentive payments, they should have someone evaluate their system and see that the paperwork is in order. The cost of this outside help depends on the size of the practice and the amount of assistance it requires.”
In an effort to help physicians and hospitals make this technology transition, the HITECH Act authorizes a Health Information Technology Extension Program, consisting of Health Information Technology Regional Extension RECs and a national Health Information Technology Research Center (HITRC). “These programs have help available, especially for primary care physicians,” said Englehardt. “Besides the incentive program, 60 RECs have been established across the country and have funds to help practices and hospitals choose an EHR system, educate and train their staff and evaluate their work flow process.”
According to a Health and Human Services fact sheet, RECs will support and serve healthcare providers to help them quickly become adept and meaningful users of EHRs. The goal of the program is to provide outreach and support services to at least 100,000 priority primary care providers within two years.
“Through the REC, a practice can get a professional to walk them through the selection process, educate the staff and even go through the attestation process,” said Englehardt. “REC grant money can help defer some of these costs, but it is not unlimited, so practices need to take advantage of it before it is gone.”
Initial funding for the first two years of the program is about $598 million with an additional $45 million available for years three and four. Federal support continues for four years, after which the program is expected to be self-sustaining. A total of $643 million is devoted to the Regional Extension Centers.
QSource operates Tennessee’s Regional Extension Center (tnREC). Assistance is available to all providers, but priority is given to community health centers and rural health clinics, individual and small group practices predominately focused on primary care and others who primarily serve the uninsured, underinsured or medically underserved populations. Services provided are progress toward the meaningful use of EHRs, assistance with group purchasing of EHRs, privacy and security training, office workflow redesign, onsite technical assistance, workforce development training, health information exchange (HIE) and interoperability. To apply for assistance through Tennessee’s REC, visit www.tnrec.org
“Regardless of whether a practice utilizes the REC resources or seeks the resources of an independent consultant,” said Englehardt, “I recommend practices get outside help to ensure their system meets meaningful use criteria.”