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Briefing: Getting meaningful use money in five (not so easy) steps

Obtaining financial incentives for demonstrating the meaningful use of EHR technology is no easy task. This guide outlines the five steps that are key to getting the job done.

Last year's Health Information Technology for Economic and Clinical Health (HITECH) Act set forth a process that...

requires American health care providers to demonstrate the meaningful use of electronic health record (EHR) technology. Hospitals and eligible professionals (EPs) who fail to do so by 2015 face penalties in the form of reduced Medicare and Medicaid reimbursements. Those who can demonstrate meaningful use before 2015, however, are eligible for financial incentives, with more money going to those who either get there faster or offer services to underserved populations.

This guide outlines the five (not so easy) steps necessary for demonstrating the meaningful use of EHR technology and collecting those federal incentives. It is part of SearchHealthIT.com's Briefings series, which is designed to give IT leaders strategic guidance and advice that addresses the management and decision-making aspects of timely topics.

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Step 1: Determine meaningful use eligibility

Not everyone qualifies for meaningful use. For example, only EPs within certain specialties are eligible, and among those who aren't are physicians who provide more than 90% of their services in a hospital setting. In addition, EPs have to decide whether to participate in the Medicare or the Medicaid EHR incentive program. The latter program, on the one hand, offers larger financial incentives (a maximum of $63,750 versus $44,000 for the Medicare program) and has a more appealing timeline (it gives providers until 2016 to implement EHR technology and still receive the maximum amount). On the other hand, fewer providers will qualify as Medicaid EPs. In addition, the federal Centers for Medicare & Medicaid Services (CMS) administers the Medicare program, but the Medicaid program is the responsibility of the individual states, and many are struggling to have planning and implementation policies approved on time.

The question for hospitals, meanwhile, is whether to participate in the Medicare, Medicaid or critical access hospital reimbursement program, which have different eligibility criteria and reporting requirements. Depending on the services they provide, certain hospitals will qualify for both the Medicare and Medicaid programs.

Learn more in "How do I qualify for the EHR Incentive Program?" Also:

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Step 2: Implement a certified EHR system

Having determined it qualifies for meaningful use, the hospital's or EP's next task is to make sure it is using an EHR system that has been certified by an Authorized Testing and Certification Body (ATCB) that in turn has been authorized by the Office of the National Coordinator for Health Information Technology (ONC). The certification process ensures that the EHR software includes the features needed to meet each meaningful use criterion. The list of certified products includes both complete EHR systems and EHR modules; in addition, products are classified as serving either hospitals or ambulatory care providers. The ONC is maintaining a complete Certified Health IT Product List that combines the lists from all the ATCBs. To date, the ONC has authorized the Certification Commission for Health Information Technology, Drummond Group Inc. and InfoGard Laboratories, though only CCHIT and Drummond have gone through the process of certifying EHR systems.

Learn more in "A buyer's guide for choosing an EHR system." Also:

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Step 3: Demonstrate meaningful use

Once they have a certified EHR system in place, hospitals and EPs have to demonstrate that they are meeting the ONC's meaningful use criteria, which cover such medical technology areas as clinical decision support, computerized physician order entry, or CPOE, and e-prescribing. There are 15 mandatory core measures for EPs and 14 for hospitals. There also are 10 "menu options", from which providers must select five.

Meaningful use must be demonstrated for a continuous, 90-day period during an organization's first payment year. Under meaningful use, a hospital's payment year is defined as a fiscal year, and an EP's payment year is defined as a calendar year. Hospitals, then, could have begun demonstrating meaningful use on Oct. 1, 2010, the first day of the 2011 federal fiscal year, while EPs can begin on Jan. 1, 2011.

To receive the maximum reimbursement, EPs should aim for either 2011 or 2012 as their first payment year -- that is, a year in which they demonstrate meaningful use for 90 days. For hospitals to reap the greatest reward, the first payment year should be no later than the 2013 fiscal year.

Learn more in "Criteria for meaningful use of EHR." Also:

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Step 4: Submit reports to HHS

Having demonstrated meaningful use for 90 consecutive days, health care organizations must prove they did so to the ONC, in the form of reports. Under the meaningful use final rule, organizations must "use an attestation methodology to submit summary information … on … quality measures as a condition of demonstrating meaningful use of certified EHR technology." Separate quality measures have been developed for hospitals and EPs.

In 2011, submitting reports electronically is not required, but using a certified EHR system "to capture the data elements and calculate the results for certain clinical quality measures" is. In 2012, electronic submission will be required, provided the ONC has developed the systems necessary to accept and read electronic submissions. (If it hasn't, an announcement will be posted in the Federal Register, and paper reports will be accepted in 2012.)

Learn more in "Hospital quality measures required by meaningful use and "Clinical quality measures required by meaningful use ." Also:

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Step 5: Collect meaningful use incentives

Once reports have been submitted, the waiting game begins. The ONC hasn't indicated how long it expects the process of analyzing reports to take, although the allocation of Medicaid meaningful use incentives is contingent on the development of the National Level Repository, which CMS will use to track who is eligible for the Medicaid program.

EPs will receive different amounts of money depending on how quickly they have adopted EHR technology and, as stated, whether they have qualified for the Medicare or the Medicaid incentives. These factors apply to hospitals as well; in addition, hospital incentives will vary depending on how many patients the facility discharges per payment year.

To continue receiving incentives, health care providers must continue to demonstrate meaningful use -- and from the second year onward, must do so for the entire year, not just 90 days. (Then again, once a health care provider has gone to the trouble to implement the technology necessary to achieve meaningful use, it's unlikely it would suddenly uninstall everything.)

Learn more in "Getting money from the EHR Incentive Program." Also:

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Let us know what you think about the FAQ; email Brian Eastwood, Site Editor.

This was last published in November 2010

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