Q. Where did the phrase “meaningful use” first appear?
A. In 2009, the American Recovery and Reinvestment Act first introduced us to the phrase “meaningful use.” This legislation authorized the Centers for Medicare & Medicaid Services to provide a financial incentive to physicians who are “meaningful users” of electronic health record technology.
Q. What are the fundamentals of meaningful use?
A. ARRA defined three elements of meaningful use. They required use of a certified EHR
1. in a meaningful manner (e.g., e-prescribing);2. for electronic exchange of health information with the objective of improving the quality of health care; and3. to submit clinical quality and other measures.
The CMS final rule on the topic published July 13, 2010, states: “meaningful use means providers need to show they’re using certified EHR technology in ways that can be measured significantly in quality and in quantity.”
Q. How will these requirements be implemented?
A. The meaningful use requirements will be implemented in three stages, each one adding new requirements and increasing accountability for some established requirements. Currently, eligible physicians are being held to Stage 1 requirements. Stage 2 requirements have been proposed but are not finalized.
Q. Is there a financial incentive to be a meaningful user of EHR?
A. Yes. The Health Information Technology bonus program began in 2011. Separate programs exist for Medicare and Medicaid, and the programs will continue through 2016. However, to qualify for an incentive payment, physician participation must begin no later than 2014.
Q. How does a physician qualify for the Medicare HIT bonus?
A. Physicians qualify for the incentive bonus payment by demonstrating that they meet the meaningful use requirements. The Medicare incentive program requires successful demonstration of meaningful use each consecutive year of participation.
Q. Are bonus payments made to individual physicians?
A. Yes and no. Bonus payments are made for each eligible professional; this means that each eligible provider in a group may qualify for the bonus. However, the bonus payments are made to the holder of the tax ID number of the group.
Q. What is the maximum incentive payment for the bonus programs?
A. The maximum incentive payment in the Medicare program is $44,000 and $63,750 for the Medicaid incentive program. Physicians may not participate in both the Medicare and Medicaid programs concurrently, and must choose one to participate in. However, physicians may make a one-time switch between programs.
Q. Will I be penalized if I do not adopt EHR and meet meaningful use requirements?
A. Yes. To avoid being penalized by CMS, you must attest to meaningful use by October 3, 2014. The penalties (reduction to your Medicare fee schedule) will be a reduction of 1 percent in 2015, 2 percent in 2016, 3 percent in 2017 and up to 5 percent beyond 2017.
Q. What steps should I take to achieve meaningful use?
A. Your first step is to partner with a certified EHR software vendor. The vendor of a certified system provides assurance that the EHR technology is capable of meeting meaningful use requirements. At the present time, there are approximately 1,300 Certified Health IT Products; however the number of certified programs changes frequently. For a current list visit: http://oncchpl.force.com/ehrcert/CHPLHome.
Q. What are the general requirements for Stage 1 meaningful use?
A. For Stage 1, eligible professionals (such as ophthalmologists) must report all 15 of the Core Set Objectives and Measures in sufficient number to meet or exceed specific threshold requirements. In addition, eligible professionals must report five of 10 Menu Set Objectives and Measures. At least one of the five measures must address public health. Lastly, you are required to report six Clinical Quality Measures.
Further details on these measures can be found at: http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms.
Q. If I have EHR and want to participate in the Medicare bonus program, how do I start the process to report meaningful use?
A. In order to receive your incentive bonus, eligible professionals will need to register in the Medicare EHR Incentive Program. You may register at any time. Registration does not hold you accountable to attestation, but you cannot attest to meaningful use if you are not registered. You can learn more about the registration process at the following CMS link: http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/RegistrationandAttestation.html.
Q. If I have met the requirements for meaningful use, Stage 1, how do I inform CMS?
A. After you have satisfied the requirements for Stage 1 meaningful use, you can attest to it on the CMS website. The attestation process requires providers to enter numerators and denominators for the various measure ratios and CQMs, as well as applicable exclusions, and to legally attest that meaningful use was successfully achieved. Once your data is submitted, you will see a summary of the data and whether or not it was successful.
Q. Am I required to have met meaningful use for the entire year?
Q. When can we expect to be held accountable for Stage 2 and Stage 3 requirements?
A. The proposed Stage 2 requirements were finalized on August 23, 2012. CMS pushed back the start date for Stage 2 compliance to January 1, 2014. There is only sketchy information about Stage 3 at this time. Physicians will be held to the requirements for each stage for two successive years.
Q. How much bonus money has been paid to physicians for the Medicare EHR incentive program?
A. According to CMS, as of May 2012, $994,883,305 has been paid to a total of 58,530 Medicare eligible professionals under the EHR Incentive Program. REVIEW
Ms. McCune is vice president of the Corcoran Consulting Group. Contact her at DMcCune@corcoranccg.com.