Once critical access hospitals become meaningful users of electronic health record systems, the money they will receive from the EHR Incentive Program will be calculated differently than it is for other hospitals.
All hospitals must calculate their “Medicare share” of patients as part of the reimbursement formula. Hospitals in the Medicare and Medicaid incentive programs also receive an initial amount based on their total number of patients; that amount is then divided by a transition factor, which decreases as the years pass as a means of encouraging hospitals to adopt EHR technology sooner.
For critical access hospitals — which must be certified under the Social Security Act and are loosely defined as the lone facilities providing 24-hour emergency care to rural areas — there is no initial amount. Instead, these facilities are reimbursed based on the “reasonable cost” of acquiring a certified EHR system, as well as the cost of “associated” software and hardware “necessary to administer” that EHR system. (The rationale here is that critical access hospitals often need to take out a loan to cover IT investments, and lenders need to know that EHR Incentive Program funds will be enough to pay back the loans.)
The quotation marks are necessary, for, as the blog Rural Health IT points out, those terms — fundamental to the reimbursement process for critical access hospitals — have yet to be clearly defined. Do network upgrades count as associated costs? What about vendor support for the EHR system itself?
Ultimately, clarification needs to come from the Centers for Medicare & Medicaid Services. Rural Health IT called for more information on EHR expenses for critical access hospitals back in January, shortly after the meaningful use proposed rule came out.
It is now November. The meaningful use final rule came out four months ago. It’s about time critical access hospitals know what they need to do.