Meaningful Use: Latest Updates on Qualifying for ARRA (American Recovery and Reinvestment Act) Incentives

>The American Recovery and Reinvestment Act of 2009 (Stimulus Bill) included a subsection called HiTECH which provides funds to incentivize hospitals and doctors to purchase and implement an electronic medical record.

>To determine whether a provider or hospital has implemented such a system, and thus qualified to receive the incentive, the government created a concept called Meaningful Use.

Not included in the Recovery Act were behavioral health providers, including alcohol and substance abuse and mental health services as well as other non-physical healthcare providers. To rectify this omission, Congress introduced two bills (HR 5040 and S3709) aimed at specifically making these providers eligible for Medicaid incentives. However, each eligible nurse or doctor working in behavioral healthcare organizations is eligible for incentive payments.

>Not all doctors and nurses are eligible and if they work for more than one org, only ONE of those orgs can “access” their incentive payment.

What are the Incentives (Medicare)?

> The Medicare EHR Incentive Program will provide incentive payments to eligible professionals, eligible hospitals, and CAHs (critical access hospitals) that demonstrate meaningful use of certified EHR technology.

• Participation can begin as early as 2011.
• Eligible professionals can receive up to $44,000 over five years under the Medicare EHR Incentive Program. ($8800/year for software) To get the maximum incentive payment, Medicare eligible professionals must begin participation by 2012.
• Incentive payments for eligible hospitals may begin as early as 2011 and are based on a number of factors, beginning with a $2 million base payment.
• Important! For 2015 and later, Medicare eligible professionals, eligible hospitals, and CAHs that do not successfully demonstrate meaningful use will have a payment adjustment in their Medicare reimbursement.

What are the Incentives (Medicaid)
> The Medicaid EHR Incentive Program will provide incentive payments to eligible professionals, and eligible hospitals as they adopt, implement, upgrade, or demonstrate meaningful use of certified EHR technology in their first year of participation and demonstrate meaningful use for up to five remaining participation years.

• The Medicaid EHR Incentive Program is voluntarily offered by individual states and territories and may begin as early as 2011, depending on the state. Eligible professionals can receive up to $63,750 over the six years that they choose to participate in the program. ($10,625/year for software) (They can start ANY TIME up to 2015.)
• (N/A: Eligible hospital incentive payments may begin as early as 2011, depending on when the state begins its program. The last year a Medicaid eligible hospital may begin the program is 2016. Hospital payments are based on a number of factors, beginning with a $2 million base payment.)
• There are no payment adjustments under the Medicaid EHR Incentive Program.

Who is Eligible?

Eligibility for Individual Providers – Eligible Professionals

The incentive payments for EPs are based on individual providers.

If you are part of a practice, each EP may qualify for an incentive payment if each EP successfully demonstrates meaningful use of certified EHR technology.

Each EP is only eligible for one incentive payment per year, regardless of how many practices or locations at which he or she provide services.

Hospital-based EPs are not eligible for incentive payments. An EP is considered hospital-based if 90% or more of his or her services are performed in a hospital inpatient or emergency room setting.

Medicare: 
Doctor of medicine or osteopathy
Doctor of dental surgery or dental medicine
Doctor of podiatry
Doctor of optometry
Chiropractor

Medicaid:
Physicians
Nurse practitioner
Certified nurse-midwife
Dentist
Physician assistant who furnishes services in a Federally Qualified Health Center or Rural Health Clinic that is led by a physician assistant

EP 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

So, What Do I Have to Do?

Exclusions

Meaningful Use Core Measures: 1-15¹

Meaningful Use Menu Set Measures: 1-10¹

Eligible Professional – Patient Requirements

Any eligible professional demonstrating meaningful use must have at least 50% of their of their patient encounters during the EHR reporting period at a practice/location or practices/locations equipped with certified EHR technology capable of meeting all of the meaningful use objectives. Therefore, States should collect information on meaningful users’ practice locations in order to validate this requirement in an audit.

Patient volume: Eligible professionals may choose one (or more) clinical sites of practice in order to calculate their patient volume. This calculation does not need to be across all of an eligible professional’s sites of practice. However, at least one of the locations where the eligible professional is adopting or meaningfully using certified EHR technology should be included in the patient volume. In other words, if an eligible professional practices in two locations, one with certified EHR technology and one without, the eligible professional should include the patient volume at least at the site that includes the certified EHR technology. When making an individual patient volume calculation (i.e., not using the group/clinic proxy option), a professional may calculate across all practice sites, or just at the one site.

Resources

> Certifiers:
Drummond Group
CCHIT: http://wwwstage.cchit.org/get_certified/cchit-certified-2011
There are more…

> Overseers:
Office of the National Coordinator – Health IT: http://healthit.hhs.gov/
Centers for Medicaid and Medicare Services: http://www.cms.gov/EHRIncentivePrograms/
NIST (for vendors): http://healthcare.nist.gov/use_testing/finalized_requirements.html
“Path to Payment”:
http://www.cms.gov/EHRIncentivePrograms/10_PathtoPayment.asp#TopOfPage

> Regional Extension Centers:

> Registration & Attestation:
Eligible professionals must register here: https://ehrincentives.cms.gov/hitech/login.action
State level info: http://www.cms.gov/EHRIncentivePrograms/40_MedicaidStateInfo.asp
National Medicaid Attestation Sites: http://www.cms.gov/apps/files/medicaid-HIT-sites/

All Core Measures, How measured, reported, exclusions:
http://www.cms.gov/EHRIncentivePrograms/Downloads/EP-MU-TOC-Core-and-MenuSet-Objectives.pdf