Electronic Medical Records Evaluation, Selection & Implementation Process Presented by: Sherri L. Boston, MBA, COE, OCS Session Objectives Provide an overview of the Electronic Health Records (EHR) provisions in the Economic Stimulus Package. Explain the EMR evaluation, selection and implementation process. Review the tools available to assist the practice and staff during the EMR review and implementation process. Economic Stimulus Package President Obama signed H.R. 1, the American Recovery and Reinvestment Act of 2009 (ARRA) into law on 2/17/09. Health Information Technology for Economic and Clinical Health Act (HITECH) part of ARRA; encourages adoption of electronic health records (EHRs) through incentive payments. EHR provisions in HITECH: $19.2 billion available to encourage adoption of EHR. Qualified providers and hospitals earn incentive benefits beginning in 2011 by demonstrating meaningful use of EHR systems. Penalties for non-compliance begin in 2015. On 1/13/10 the Centers for Medicare & Medicaid Services (CMS) and the Office of National Coordinator of Health Information Technology (ONC) published two coordinated sets of regulations for EHR incentives. 1
ONC and CMS Regulations ONC Interim Final Rule Certified EHR Technology Outlines requirements to be certified: Standards Implementation Specifications Certification Criteria Does not change HIPAA requirements CMS Proposed Rule Meaningful Use Outlines criteria for demonstrating meaningful use of certified technology Provides proposed calculation and payment of incentives HHS will accept comments on these regulations through March 15, 2010. Certified EHR Technology Definitions: Qualified EHR: An electronic record of health-related information on an individual that: 1. Includes patient demographics and clinical health information. 2. Has the capacity to: Provide clinical decision support. Support MD order entry. Capture and query information relevant to health care quality. Exchange electronic health information with, and integrate such information from, other sources. Certified EHR Technology: Meets requirements of qualified EHR and has been tested and certified by ONC program, meeting all certification criteria. Meaningful Use Requirements: HITECH Act requires that eligible professionals must be meaningful EHR user of certified EHR technology and meet three requirements: 1. Demonstrate use of certified EHR technology in a meaningful manner. 2. Demonstrate that such certified EHR technology is connected in a manner that provides for electronic exchange of health information, in accordance with laws and standards, to promote quality health care. 3. Using certified EHR technology, submit information on clinical quality measure and other such measures, as required. 2
Phased Roll-Out of Meaningful Use Criteria CMS proposed rule sets forth three stages for demonstrating meaningful use. Stage 1: Criteria focus on electronically recording patient data to facilitate coordination of care, implementation of clinical decision support, and reporting clinical quality measures. Stages 2 & 3: Criteria not yet defined; will focus on interoperability of EHR technology, increase in efficiency, and improvement in population health. Phased roll-out allows for incrementally improving and expanding the adoption and implementation of EHR technology. Stages of Meaningful Use Stage of Meaningful Use Criteria by Payment Year 2011 2012 2013 2014 2015 2011 Stage 1 Stage 1 Stage 2 Stage 2 Stage 3 2012 Stage 1 Stage 1 Stage 2 Stage 3 2013 Stage 1 Stage 2 Stage 3 2014 Stage 1 Stage 3 2015 Stage 3 Only the Stage 1 criteria are currently proposed and include 25 objectives and functionality measures for eligible professionals. CMS is expected to provide guidance on Stage 2 & 3 measures beginning in 2013. EMR Incentive Payments Proposed rule calls for Part B Medicare carriers to make payments once meaningful use is demonstrated for the applicable reporting period. Incentive payment is to equal 75% of the physician s allowable Medicare charges for up to five years; subject to a maximum amount per physician. Annual cap may be higher for professionals in designated health professional shortage area. Payment ceiling declines each year; penalizing late adopters. To qualify for the full incentive benefit of $44,000, physicians must have EHR in place by 2011 or 2012. 3
EMR Incentive Payments Maximum Annual Payment by Year Implemented 2011 2012 2013 2014 2015 2011 $18,000 2012 $12,000 $18,000 2013 $8,000 $12,000 $15,000 2014 $4,000 $8,000 $12,000 $12,000 2015 $2,000 $4,000 $8,000 $8,000 $0 2016 $2,000 $4,000 $4,000 $0 Total $44,000 $44,000 $39,000 $24,000 $0 Payment Adjustments Beginning in 2015 Penalties for non-compliance begin in 2015. Medicare reimbursement reduced by 1%, 2%, and 3% in 2015, 2016, and 2017 and each subsequent calendar year. HITECH Act authorizes CMS to further reduce reimbursement in 2018 if less than 75% of eligible professionals are EHR users. Proposed rule has an exemption for professionals due to a significant hardship; however, no definition of significant hardship has been provided by CMS. EMR Evaluation, Selection, and Implementation Process 4
Define clear vision of project Identify project team and include representatives from management, clinical, and physician teams Define scope of project and develop work plan outlining details of the process. Complete a self-assessment of your EMR readiness Review articles and publications related to EMR Evaluate risks/benefits of EMR implementation Make decision to go forward or delay selection and implementation process Sample Self-Assessment 5
Article: Financial Impact of an EMR System Collect data from practices currently using EMR, schedule site visits Determine practice design requirements for EMR utilization Number of users Hardware needs Networking and connectivity Interface options with existing EPM Interface capability with diagnostic equipment Select 4 5 EMR vendors; send RFPs Sample Request For Proposal 6
Identify 10 15 priority needs for EMR Complete a comparison of the EMR vendor RFPs Perform a cost benefit analysis Compare practice needs and costs with results of RFP Determine top 2 3 vendors, schedule onsite demonstrations Utilize EMR Project Team to make EMR selection Evaluate financing options Negotiate and sign hardware/software contracts Sample Cost Benefit Analysis Identify implementation team Set realistic timeline for training & implementation Review and redesign every work process Evaluate hardware needs; purchase Arrange for networking/connectivity Assess and determine method of phase in to EMR with final goal of paperless Customize office visit templates Determine which old patient information is to be scanned into the new system; begin the scanning process 7
Designate Training Team Develop training plan (preliminary training/vendor training) Arrange basic computer skill training for staff needing assistance Schedule preliminary training for staff and physicians Schedule vendor on-site training Implement vendor training plan for both staff and physicians (include hands-on training) Training Phase Modify patient schedule before going live Select day of week to launch EMR Make certain vendor trainers are present Assemble staff early to review processes Debrief at the end of the first day; adjust processes as needed Conduct regular meetings to address EMR concerns and needs Provide periodic quality review of charts Celebrate! Training Phase Implementation Phase EMR evaluation, selection, and implementation is a long, difficult process; however it is one with many positive implications for the practice. Consider the following: Examine practice needs and resources carefully before deciding to proceed with EMR implementation. Make certain there is strong leadership from both administration and physicians Set realistic time goals for the project Training Phase Implementation Phase 8
Utilize a team to maximize efforts in planning and implementation Plan Train Implement Reevaluate Redesign Retrain Implement! It s an ongoing process Celebrate accomplishments! Most practices with EMR would NEVER want to return to paper charts. If EMR is right for the practice, the arduous process is worth it! Both the challenges and opportunities can be yours! Training Phase Implementation Phase Thank You! 9