Electronic Health Records: What it Means for Today s Radiologist By: Anne Reynolds

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1 Electronic Health Records: What it Means for Today s Radiologist By: Anne Reynolds Introduction Program Overview In February of 2009, President Obama signed the American Recovery and Reinvestment Act of 2009 (ARRA), commonly known as the stimulus act, to help create jobs and promote investment during the recession. Of the $787 billion dollars allocated for this act, the Healthcare industry received $147.7 billion with the creation of the Health Information Technology for Economic and Clinical Health Act (HITECH). Subtitle D of this act provided $30 billion dollars (an increase of the initial budget of $19 billion dollars) directly for Health Information Technology and supports programs such as Medicare and Medicaid to incentivize the Meaningful Use of certified Electronic Health Record technology. For those of us who instantly jumped on board with the Physician Quality Reporting System (PQRS, formerly PQRI) incentive system, the EHR incentive program might be met with a certain degree of skepticism. For many providers participating in PQRS, bonus checks, at least in the program s infancy, seemed to be as mythical as Bigfoot or the Loch Ness Monster. Regardless, the program does give eligible providers and hospitals the opportunity for a sizeable financial reward for helping to push the goal of healthcare reform through the use of technology. Just like PQRS, eventually there will come a time where all eligible physicians and hospitals are required to demonstrate Meaningful Use. As previously mentioned, the Health Information Technology for Economic and Clinical Health Act was created under the ARRA for the purpose of advancing healthcare through the use of technology. Under this act, both Medicare and Medicaid have received funding to incentivize hospitals and providers to adopt strategies and practices that demonstrate the Meaningful Use of certified electronic records. The fundamental core components for both programs are simple: Providers demonstrating Meaningful Use of Certified Electronic Health Record Technology. It should be noted that eligibility requirements differ between the Medicare and Medicaid programs. For the purpose of this article, eligibility and requirements will be focused on the Medicare program as it is more applicable to radiologists. Medicare s Electronic Health Record Incentive Program - Three Small Bytes The first byte: Provider Perhaps the most confusing to radiologists is the question Am I eligible to participate? When CMS released its final rules for stage 1 of Meaningful Use in July 2010, the rules all changed and many providers found themselves eligible for participation. The final rules clarified outpatient setting to include Place of Service 22, meaning physicians who read exams at hospital based outpatient centers qualify. The ACR anticipates 1

2 85-90% of all radiologists nationwide are eligible to participate in this program. Radiologists are considered eligible providers if: They are a Doctor of Medicine or Osteopathy They are enrolled in PECOS They furnish at least 10% of services in an outpatient setting. Outpatient is technically defined as POS 11, 20, 22, 24, and 49 (office, urgent care facility, outpatient hospital, ambulatory surgery center, and independent clinic respectively). In practice, anything that is not considered Inpatient or Emergency is considered Outpatient. If services are rendered at multiple locations, at least 50% of all services must include Meaningful Use of certified EHR technology The second byte: Meaningful Use While the term Meaningful Use can sound overwhelming, as if it was deeply rooted in ancient Greek philosophy, it is really nothing more than CMS s way of ensuring that providers utilize healthcare technology to leverage better outcomes for the patients. CMS will quantify or establish Meaningful Use in three stages. The first stage began on January 1, 2011 and has a focus on data capture and sharing. Stage two, which is still in the process of being defined, will focus on advance clinical processes, such as decision support and clinical decision making. Stage two is slated to roll out in The third and final phase will focus on quality patient outcomes. The implementation date for this is yet to be determined. CMS has only released the requirements for stage 1 of the program at the time of this white paper. For eligible providers, there are a total of 25 Meaningful Use objectives. To qualify for an incentive payment, only 20 of the 25 measures need to be met. Fifteen of these objectives are considered core objectives. It is estimated that radiologists will be excluded from 5 of these and must meet all non-excluded measures. There are ten menu set measures, of which radiologists are eligible for 6 exclusions, and must meet 5 of the ten measures. Finally, there are 44 Clinical Quality Measures. Radiologists must report 6 of the 44 measures (3 core and 3 non-core). 2

3 15 Core Objectives: Meaningful Use Measures Most Radiologists will be excluded from: Computerized Physician Order Entry (CPOE) Record and chart changes in vital signs E-Prescribing (erx) Remaining Measures (must meet all non excluded measures) Provide patients with an electronic copy of their health information upon request Provide clinical summaries for patients Drug-drug and drug-allergy interaction checks Record demographics Maintain active medication allergy lists Record smoking status for patients 13 years or older Maintain an up to date problem list of current and active diagnoses Maintain active medication allergy Implement one clinical decision support rule Electronically exchange key clinical information amount patient authorized providers Report ambulatory clinical quality measures to CMS/states Conduct annual Security Risk Analysis, HIPPA 45 CFR (a)(1) 10 Menu Objectives: MU measures that most Rads will be excluded from: Medication reconciliation Summary of care record for each transition of care/referrals Capability to submit electronic data to immunization registries/systems Remaining Measures must select all but 5 Provide patients access to their health information via electronic portal Generate lists of patients by specific conditions Drug-formulary checks Incorporate clinical lab test results as structured data Send reminders to patients for preventative/follow up care Use of certified EHR to identify patient-specific education resources Capability to provide electronic syndromic surveillance data 3

4 The last byte: Certified Electronic Health Record Technology technology must be capable of capturing 100% of the measures in order to be certified. physicians must utilize EHR technologies that have been certified. The certification ensures that the technology can handle all of the requirements necessary for demonstrating Meaningful Use. This technology can be one product, or a collection of certified modular products. Certifications have been announced by CMS and the office of the National Coordinator for Health Information Technology (ONCHIT). A list of certified products can be found on their website: In addition to this list, it is expected that more vendors will complete the certification process. Similar to when the government announced rebates for energy efficient appliances and home heating elements, vendors were inspired to modify their already existing products to meet government standards and therefore capture customers in search of products that qualify for the financial incentive. Three authorized testing entities have been named to complete the certifications: Certification Commission for Healthcare Information Technology, Drummond Group INC, and Info Gard Laboratories. It should be noted that while Radiologists are eligible for exclusions from some Meaningful Use measures, the It is not relevant who purchased the technology. For example, physicians working in large hospitals might utilize the hospitals Electronic Health Record. Although they did not pay for this with their own funds, they are utilizing the technology for the purpose of enhanced patient care. Incentives and Penalties Considering the looming cuts to reimbursement that physicians deal with every day Congress is in session, the opportunity for additional revenue should not be taken lightly. Under Medicare s incentive program, eligible providers who enroll by 2012 can receive a maximum amount of $44,000 over a five year span. This number decreases to $39,000 if enrollment is delayed until 2013 and $24,000 if enrollment is delayed until Medicare recognizes that providers might be required to purchase new technologies or spend cash to upgrade existing products. For this reason, the payment schedule is front loaded with higher reimbursement dollars during the initial years of the program. See the figure on the next page for the reimbursement schedule. 4

5 s Payment in 2011 receive First Payment in 2012 Payment in 2013 payment in 2014 Payment in 2015 for 2011 per provider for 2012 for 2013 for 2014 for 2015 for 2016 $18, $12,000 $18, $8,000 $12,000 $15, $4,000 $8,000 $12,000 $12,000 - $2,000 $4,000 $8,000 $8,000 - $2,000 $4,000 $4,000 - Total Amount $44,000 $44,000 $39,000 $24,000 5 Payments to physicians are set at 75% of billed charges, but then capped at the amounts in the figure above. While most radiologists will not have difficulties reaching this billed charge threshold, physicians will only receive the maximum bonus amount if they bill in excess of $24,000 to Medicare. For example, a physician who is a meaningful user of certified EHR technology in 2011 and bills $10,000 to Medicare, this physician will receive $7,500, or 75% of billed charges. In addition to the financial incentives within the EHR program, physicians should consider the fact that in 2015, they will be subject to a financial penalty of up to 5% total Medicare Reimbursement for NOT participating in Meaningful Use of certified EHR technology. Similar to the PQRS program, the thought process of if we have to do it anyway, we might as well get paid for it now comes into play. As if the additional threat of decreased reimbursement were not enough, experts report that major commercial payors are exploring Meaningful Use requirements and sanctions. It is also possible that in the future, Medical Boards and licensure renewals will be contingent on the physicians participation in Meaningful Use. Recommendations for Integration in your Radiology Practice Radiologists should start preparing for Meaningful Use by looking at the technologies that already exist within their own departments. Experts suggest that many measures required for demonstrating Meaningful Use can already be achieved with the products that are already in use. Radiologists should encourage their current vendors to certify for these measures. After taking inventory of the measures that can be met through

6 existing technology, radiologists should then seek to acquire or create certified solutions for the remaining required measures. Getting Enrolled Registration for the Electronic Health Record Incentive Program began on January 3, Providers can enroll online via CMS s website. Radiologists will log into the registration website with the same user name and password created when they registered for their NPI. Once logged in, the provider will select which incentive program in which they wish to enroll (Medicare or Medicaid) and enter their personal information including full name, business address, the provider s social security number, national provider identifier (NPI) and a valid address. Providers are not required to have certified technologies at the time of enrollment; however, a certification number will be required before incentive payments are issued. Following completion of the online registration, radiologists will then complete a written attestation in April of Attestation involves sending information on which meaningful measures each provider met and the data for each measure. You must attest for 90 days during your first year of meeting Meaningful Use by October 1, 2011 in order to receive EHR bonus payments in At the current time, CMS has only defined stage 1 of the Electronic Health Record incentive program. While the goals for this program have been outlined for the future, the methodologies and requirements for demonstration have not. It is critical that radiologists begin facilitating discussions with their hospital administrators and IT officials. Since it is likely that radiologists will be leveraging the hospital s EHR to demonstrate Meaningful Use, it is key that they be included in the strategies for the growth and evolution of this program. As the largest radiology-only billing company in the United States, ADVOCATE recognizes the importance this incentive program has on radiologists practices. We are working with each provider on an individual basis to determine their eligibility for participation and facilitating the online enrollment from the program s start. As the layers of the Electronic Health Record incentive program are revealed, it is critical that your billing company is prepared to provide you with the latest information available, and is aware of any new requirements for demonstrating and communicating Meaningful Use of EHR technology. Medicaid Incentive Program Summary The Medicaid incentive program is voluntarily offered by states and territories as early as 2011 depending on the state. providers can receive up to $63,750 over six years with successful demonstration of Meaningful Use of certified Electronic Health Record technology. In order for providers to be eligible for the Medicaid program, they must have a minimum of 30% Medicaid volume. This will exclude the majority of radiologists from participation; however in the event that a provider meets eligibility requirements for both the Medicare and Medicaid program, the provider must select only one program for participation. Contact your respective client manager to help you determine if you are indeed eligible for participation with both programs, and for guidance on which EHR incentive program is most appropriate for your practice. 6

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