Incentives to Accelerate EHR Adoption

Incentives to Accelerate EHR Adoption The passage of the American Recovery and Reinvestment Act (ARRA) of 2009 provides incentives for eligible professionals (EPs) to adopt and use electronic health records (EHRs) in their daily practice. The program as defined in the HITECH Act of the ARRA legislation requires that providers prove they are meaningful users of a certified EHR. Providers have until October 1, 2012 to get started and earn the maximum Medicare incentives Overview EPs must be office-based providers to be eligible for the incentives. Providers can qualify under either the Medicare or Medicaid provision but cannot collect from both programs. Providers in the Medicare program can earn the maximum incentives as long as they begin by October 1, 2012. Providers in the Medicaid program must start by 2016 to earn the maximum Medicaid incentive. Under the Medicare provision, an EP is a physician as defined in the Social Security Act section 1861 to include a doctor of medicine or osteopathy, a doctor of dental surgery or of dental medicine, a doctor of podiatric medicine, a doctor of optometry and a chiropractor. The Medicaid HIT Incentive program expands the definition to also include a certified nurse mid-wife, a nurse practitioner and a physician assistant practicing in an FQHC or RHC that is led by a physician assistant Medicare Program Beginning in 2011, the Medicare EHR incentive programs provide incentive payments up to $44,000 over five years to eligible professionals that are meaningful users of certified EHRs. The structure of the maximum incentives is shown in Table 1 below. Additionally, office-based physicians can qualify for a one-time, early adopter incentive of $3,000 if they qualify for the program in 2011 or 2012. Incentives are calculated as 75% of the provider s Medicare Part B allowed charges based on claims submitted to Medicare during the incentive payment year up to a certain maximum. And, physicians practicing in CMS-designated Physician Shortage Areas will earn an additional 10% bonus. The Medicare program will be administered by CMS under the direction of the Secretary of the Department of Health and Human Services (HHS). Page 1

Table 1: Medicare Incentive Timeline (Amounts shown are the maximum available to providers.) Meaningful EHR User 2011 2012 2013 2014 2015 2016 Total 2011 $18,000 $12,000 $8,000 $4,000 $2,000 $44,000 2012 $18,000 $12,000 $8,000 $4,000 $2,000 $44,000 2013 $15,000 $12,000 $8,000 $4,000 $39,000 2014 $12,000 $8,000 $4,000 $24,000 Medicare penalties begin in 2015 Penalties For office-based physicians who do not adopt EHR technology by 2015, Medicare payments will be reduced by: 1% in 2015 2% in 2016 3% in 2017 In 2018 and beyond, the HHS Secretary may decrease one additional percent per year (maximum of 5%) contingent upon the levels of overall EHR adoption in the market. Medicaid Program Beginning in 2011, the Medicaid program provides incentive payments up to $63,750 over six years calculated as 85% of EHR net average allowable cost not exceeding $25,000 in the first year, followed by 85% of annual costs not exceeding $10,000 over the next five years shown in table 2. EPs must show efforts to adopt, implement or upgrade certified EHR technology in the first year and for meaningful use for up to another five years. To be eligible under this provision, more than 30% of their patient encounters must be attributable to Medicaid or 20% for pediatricians. Patient encounters will be determined by the encounters attributable to Medicaid (or needy individuals in an FQHC or RHC) over any continuous 90-day period within the most recent calendar year prior to the reporting year. The States will administer the Medicaid program and can determine when their programs will begin. Table 2: Medicaid Incentive Timeline (Amounts shown are the maximum available to providers.) 30% Provider 20% Pediatrician Year 1 $21,250 $14,167 Year 2 $8,500 $5,667 Year 3 $8,500 $5,667 Year 4 $8,500 $5,667 Year 5 $8,500 $5,666 Year 6 (up to 2021) $8,500 $5,666 TOTAL $63,750 $42,500 Page 2

Meaningful Use EPs will be eligible for the incentive payments if they can prove they are using a certified EHR in a meaningful manner. The Stage 1 Meaningful Use (MU) criteria were published in the Final Rule issued on July 28, 2010. The criteria are defined through a set of objectives and related measures. Each EP must meet all 15 required Core Objectives (Table 3.) In addition to the 15 required Core objectives, each eligible professional must select five of ten optional Menu Objectives (Table 4.) Over time, EPs will be required to meet Stage 2 and Stage 3 criteria that will be released in future rule making. Table 3: Meaningful Use Core Objectives Providers must meet all 15 Core objectives Objective Use CPOE for medication orders directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local and professional guidelines Implement drug-drug and drug-allergy interaction checks Generate and transmit permissible prescriptions electronically (erx) Record demographics: preferred language gender race ethnicity date of birth Maintain an up-to-date problem list of current and active diagnoses Maintain active medication list Maintain active medication allergy list Record and chart changes in vital signs: Height Weight Blood pressure Calculate and display BMI Plot and display growth charts for children 2-20 years, including BMI Record smoking status for patients 13 years old or older Implement one clinical decision support rule relevant to specialty or high clinical priority along with the ability to track compliance that rule Report ambulatory quality measures to CMS or the States* Measure More than 30% of unique patients with at least one medication in their medication list seen by the EP have at least one medication order entered using CPOE The EP has enabled this functionality for the entire EHR reporting period More than 40% of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technology More than 50% of all unique patients seen by the EP have demographics recorded as structured data More than 80% of all unique patients seen by the EP have at least one entry or an indication that no problems are known for the patient recorded as structured data More than 80% of all unique patients seen by the EP have at least one entry (or an indication that the patient is not currently prescribed any medication) recorded as structured data More than 80% of all unique patients seen by the EP have at least one entry (or an indication that the patient has no known medication allergies) recorded as structured data For more than 50% of all unique patients age 2 and over seen by the EP - height, weight and blood pressure are recorded as structured data More than 50% of all unique patients 13 years old or older seen by the EP have smoking status recorded as structured data Implement one clinical decision support rule For 2011, provide aggregate numerator, denominator, and exclusions through attestation as discussed the final rule For 2012, electronically submit the clinical quality Page 3

Objective Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, medication allergies), upon request Provide clinical summaries for patients for each office visit Capability to exchange key clinical information (for example, problem list, medication list, medication allergies, diagnostic test results), among providers of care and patient authorized entities electronically Protect electronic health information created or maintained by the certified EHR technology through the implementation of appropriate technical capabilities Measure measures as discussed in the final rule More than 50% of all patients of the EP request an electronic copy of their health information are provided it within 3 business days Clinical summaries provided to patients for more than 50% of all office visits within 3 business days Performed at least one test of certified EHR technology's capacity to electronically exchange key clinical information Conduct or review a security risk analysis and implement security updates as necessary and correct identified security deficiencies as part of its risk management process *EPs will be required to report on a total of 6 quality measures, 3 core measures plus 3 from a list of 38 Clinical Quality Measures that are not designated by specialty. The definition of each of the quality measures can be found in the the electronic specifications for the measures on the CMS website. Table 4: Meaningful Use Menu Objectives Providers must choose 5 of 10 menu objectives Objectives Use CPOE for medication orders directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local and professional guidelines Implement drug-formulary checks Incorporate clinical lab-test results into certified EHR technology as structured data Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research or outreach Send reminders to patients per patient preference for preventive/ follow up care Provide patients with timely electronic access to their health information (including lab results, problem list, medication lists, medication allergies) within four business days of the information being available to the EP Use certified EHR technology to identify patientspecific education resources and provide those resources to the patient if appropriate Measures More than 30% of unique patients with at least one medication in their medication list seen by the EP have at least one medication order entered using CPOE The EP has enabled this functionality and has access to at least one internal or external drug formulary for the entire EHR reporting period More than 40% of all clinical lab tests results ordered by the EP or by an authorized provider of the eligible hospital or CAH for patients admitted to its inpatient or emergency department (POS 21 or 23) during the EHR reporting period whose results are either in a positive/negative or numerical format are incorporated in certified EHR technology as structured data Generate at least one report listing patients of the EP with a specific condition More than 20% of all unique patients 65 years or older or 5 years old or younger were sent an appropriate reminder during the EHR reporting period More than 10% of all unique patients seen by the EP are provided timely (available to the patient within four business days of being updated in the certified EHR technology) electronic access to their health information subject to the EP s discretion to withhold certain information More than 10% of all unique patients seen by the EP are provided patient-specific education resources Page 4

Objectives The EP who receives a patient from another setting of care or provider of care or believes an encounter is relevant should perform medication reconciliation The EP who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care should provide summary of care record for each transition of care or referral Capability to submit electronic data to immunization registries or Immunization Information Systems and actual submission in accordance with applicable law and practice* Capability to submit electronic syndromic surveillance data to public health agencies and actual submission in accordance with applicable law and practice* Measures The EP performs medication reconciliation for more than 50% of transitions of care in which the patient is transitioned into the care of the EP The EP who transitions or refers their patient to another setting of care or provider of care provides a summary of care record for more than 50% of transitions of care and referrals Performed at least one test of certified EHR technology's capacity to submit electronic data to immunization registries and follow up submission if the test is successful (unless none of the immunization registries to which the EP submits such information have the capacity to receive the information electronically) Performed at least one test of certified EHR technology's capacity to provide electronic syndromic surveillance data to public health agencies and followup submission if the test is successful (unless none of the public health agencies to which an EP submits such information have the capacity to receive the information electronically) *EPs will be required to choose one of these two objectives focused on population health. Exclusions Some MU objectives are not applicable to every provider s clinical practice and would not have any eligible patients or actions for the measure denominator. EPs will be allowed to be excluded from those requirements. Acceptable exclusions are listed in Table 5. Table 5: Meaningful Use Exclusions Exclusions are available for objectives that do not apply to a provider s practice Objective Incorporate discrete clinical lab results into EHR Send reminders to patients per patient preference Provide patient with electronic access to health information Perform medication reconciliation on transition Provide summary care record on transition Submit data to immunization registries Submit surveillance data Incorporate discrete clinical lab results into EHR Exclusion Any EP who orders no lab tests whose results are either in positive/negative or numeric format during the EHR reporting period Any EP who has no patients 65 years old or older or 5 years old or younger with records maintained using certified EHR technology Any EP that neither orders nor creates any of the information listed at 45 CFR 170.304(g) in the July 13, 2010 Final Rule during the EHR reporting period Any EP who was not the recipient of any transitions of care during the EHR reporting period Any EP who neither transfers a patient to another setting nor refers a patient to another provider during the EHR reporting period Any EP who administers no immunizations during the EHR reporting period or where no immunization registry has the capacity to receive the information electronically Any EP who does not collect any reportable syndromic information on their patients during the EHR reporting period or does not submit such information to any public health agency that has the capacity to receive the information electronically Any EP who orders no lab tests whose results are either in positive/negative or numeric format during the EHR reporting period Page 5

Registration and Reporting Provider registration for the EHR incentive program opened in January 2011. Registration and the attestation reporting process for both the Medicare and Medicaid programs occurs on the CMS website using the Medicare & Medicaid EHR Incentive Program Registration & Attestation System. In the first meaningful use reporting year, Medicare providers will need to prove meaningful use of required measures over any continuous 90-day period. In the subsequent years, the reporting period will be based on the full calendar year. Medicare providers will need to begin their 90-day reporting period no later than October 1, 2012 to be eligible for the maximum incentive payment. Incentives will be paid to providers in single, consolidated annual payments. Medicaid providers only need to report that they are adopting, implementing, or upgrading for their first payment year. However, in their second payment year or first year of demonstrating meaningful use they have to prove meaningful use of required measures over any continuous 90-day period. It is in the third payment year or second year of demonstrating meaningful use that Medicaid EPs must report for a 12-month EHR period. Visit the Official Web Site for the Medicare and Medicaid EHR Incentive Programs for more information. Certification EHRs are certified once a vendor passes the certification process proving the solution has the required functionality to enable an EP to achieve meaningful use. Authorized testing and certification bodies have been named by the Office of the National Coordinator of Health IT and must use standard test procedures to certify that an EHR solution meets the required standards. Providers must use an EHR solution that has been certified by one of these bodies under the guidelines of the HHS Certification program. The Path to Meaningful Use using Epocrates EHR Epocrates EHR offers a path to meaningful use at a comfortable pace Epocrates is focused on providing an electronic health record system that will achieve the required ONC Certification and will be vigilant in complying with the Meaningful Use criteria as it evolves over time. Epocrates is committed to completing the initial certification process by the end of 2011 enabling providers to demonstrate the 90 continuous days of meaningful use in 2012 and be eligible for the full government incentives. The core functionality required to meet many of the requirements is currently available. Epocrates EHR will also be seamlessly updated with additional functionality throughout 2011. This will allow providers and staff to learn the features and functions of Epocrates EHR in manageable pieces, mastering one section of the EHR before moving on to another. And, with Epocrates EHR web-based SaaS architecture, providers can take advantage of the new capabilities as soon as they are available. With Epocrates EHR capabilities and updates, your practice can be well on its way to achieving MU and its associated incentives in 2012. Page 6