>Debate over "Meaningful
Use"
While there has been
continuing speculation over many aspects of the
EHR stimulus plan program, the definition of
"meaningful use" has been the recent focus of
much discussion and drafting. On June 16,
the Office of the National Coordinator (ONC),
issued a tentative definition of "meaningful
use." After a short comment period, the National
Coordinator of Health IT (David Blumenthal) sent
his committee back to work crafting another set
of guidelines. As a result, new guidelines
were issued on July 16. Although many
experts do not believe these guidelines are now
in completely final form, no more major changes
are expected. The final definition should
therefore be released by the end of the year.
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>Stimulus Package
Review
Of the $137 billion
allocated to healthcare by Congress
in support of President Obama's American Recovery
and Reinvestment Act, $19 billion is
set aside for healthcare IT
and Electronic Health Records (EHR)
software implementation. The President's vision supporting
this subsidy is to "wield technology's wonders
to raise healthcare's quality and lower
its cost." The administrative task of addressing
the "devil in the details" of this vision
is now under way.
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>Physician Incentives
For being
a "meaningful EHR user" of a "certified EHR
software", "eligible professionals" (EPs) can
claim stimulus money with payments beginning in
January 2011. Maximum total payments will
be $44,000 payable over five years, but those
payments are to be reduced if 75% of Medicare
allowables payable to EPs does not exceed
$18,000 in the first year stimulus payments are
to be received. That is, total stimulus
payments in any given year cannot exceed 75% of
Medicare receipts. Since year 2 stimulus
payments drop
to $12,000 and fall further to $8,000 in
year 3, the "75% of Medicare allowables"
threshold drops accordingly in those years.
Also, hospital-based physicians substantially furnishing services in
a hospital setting are not eligible
for EHR stimulus payments. Last, eligible professionals
who first make "meaningful use"
of qualified EHR software in 2015 or
thereafter will also not qualify for
stimulus payments, and those EPs
will commence incurring Medicare payment
reductions in 2015 if they are
not meaningful EHR users by that time.
More rules clarifications are coming -
CMS expects to release a detailed proposed
rule covering many more relevant specifics of this
program in late 2009.
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>Deciphering the
"Meaningful
Use" Matrix
ONC
issued its "meaningful use" definition in the
form of a complex matrix. The matrix
includes five major Health Outcomes Policy
Priorities. They
are:
1. Improve Quality,
Safety, Efficiency, and Reduce Health
Disparities.
2. Engage
Patients and Families.
3.
Improve Care
Coordination.
4. Improve
Population and Public
Health.
5. Ensure Adequate Privacy and Security Protections
for Personal Health Information.
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>Five Year Plan for
Five Priorities
Each of
the five initiatives above has been broken down
into a five-year plan, with different objectives
and measures scheduled to take effect in 2011,
2013, and 2015. There are very specific
functions that an EHR system must be able to
perform in order to meet the federal standard in
each category, and that functionality increases
in each of the three-year periods. Note
that the Improving Quality, Safety, Efficiency,
and Reducing Health Disparities initiative has
the greatest number of immediate objectives for
implementation in 2011. The complete
matrix and its requirements can be found
at:
http://healthit.hhs.gov/portal/server.pt/gateway/PTARGS_0_10741_876940_0_0_18/Meaningful%20Use%20Matrix%2007162009.pdf
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>Is Your Practice Behind
Schedule?
The ONC has pushed back
the deadline for implementing a certified EHR
software system (and still receive all stimulus
funding) until the end of 2011. Therefore,
if your practice's EHR system is in place before
the 2012 year begins, you can still receive the
full stimulus incentive. In the Priorities
Matrix then, 2011 would be the year to meet
"year one" objectives, 2013 would be "year
three," and 2015 would be "year five." If your
practice has not implemented a certified EHR
system by 2015, you will be subject to federal
penalties.
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>How will EHR Software be
Certified?
The ONC has been working
on guidelines for certifying EHR software
systems, and has so far decided that the basic
criteria will revolve around a software system's
ability to support "meaningful use", while also
supporting security and privacy
capabilities. Once specific qualifications
are established, ONC is recommending that the
National Institute of Standards and Technology
(NIST) perform the certification.
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>What Role will CCHIT Play in
Certification?
The Certification
Commission for Healthcare Information Technology
(CCHIT) has to date been the main body granting
private "certification" of Electronic Health
Records software. At this point, CCHIT
seems likely to play a role in certifying EHR
software systems under the new government
guidelines, which appear to be somewhat less
rigorous than CCHIT's existing
qualifications. CCHIT is certainly making
an effort to put itself in that position.
It currently appears that CCHIT will end up
playing some role as a certifying agency, with
it being likely that NIST will also directly
certify EHR software systems in some
manner. More on exactly how the
certification process will work should be
forthcoming soon.
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