What we already know
Over the next 5 years physicians are receiving an unprecedented opportunity through the American Recovery and Reinvestment Act’s HITECH Act. Up-to-$44,000 dollars in incentive payments for each provider has been allocated by Medicare and is available for early adopters of electronic health records (EHR’s). In order to qualify for this incentive, providers must:
1) Adopt a certified EHR system.
2) Demonstrate that they are using a certified EHR in a meaningful way according to the final rules defined by CMS and the National Coordinator for Health Information Technology.
3) Must be a Medicare provider. Incentive payments are based on Medicare allowed charges (75%) submitted during the payment year not to exceed maximum thresholds.
In this article, Part 3 of a series, we will continue with an explanation of how incentives will be paid out over the next five years as well as drilldown through the 556 page document that outlines this program in order to help determine what your practice needs to do to participate. Next month, I will provide a final summary and commentary based on the latest and final government information.
Foundational concepts that need to be clarified
Chiropractors are eligible for participation in the incentive program, but it's not a requirement. There is no mandate for you to adopt an EHR system but Medicare has revealed that they are going to start lowering reimbursements starting in 2015 for those who haven't adopted a certified electronic health record. There is strong speculation that other third-party payers will adopt similar standards as Medicare, and several PPO networks are starting to develop policies that would require any provider on a PPO panel to be required to use a certified EHR or be eliminated from the panel.
The incentive program is technically not a reimbursement. Payment is going to be an incentive, based on your Medicare allowable charges submitted. Not all chiropractors have Medicare patients to qualify for the maximum incentives, but you can still qualify for 75% of your total annual allowed charges.
Incentive payments are for each individual provider. In a multi-doctor facility, each doctor could be eligible for incentive payments based on the allowed charges submitted by each provider individually. You will need to purchase an EHR system and meet the meaningful use requirements to receive these incentives.
As of the writing of this article, there is no certifying entity announced to certify EHR systems for HHS/ONC. These entities will be announced this summer but, until then, eligible providers should focus on finding a system that will meet the meaningful use criteria and a vendor that guarantees the product will meet certification standards.
2011 is year One
The government doesn't believe that it has given eligible providers enough time to adapt to these new requirements in 2010, so the meaningful use (MU) requirements have been slated to start in 2011. Starting January 1, 2011, is your first day to count towards the use of the certified EHR and your MU of that EHR.
In order to be eligible for the 2011 incentive payments, you need to show meaningful use of your EHR for 90 consecutive business days in 2011. If you show and report that you have meaningfully used all criteria with your certified EHR for 90 days in 2011, you will be eligible to receive as much as 75% of your annual Medicare allowed charges submitted for that year/(90 day timeframe times 4). The maximum you can receive for year 2011 (year one) is $18,000, which is 75% of $24,000 in Medicare allowed charges. You don't have to actually bill $24,000 in services to Medicare in order to be eligible.
Payment continues over next five years
Each year after 2011, the maximum incentive payments go down. Most chiropractors will be eligible for the maximum incentives.
Reporting meaningful use
In year one (2011), your office will need to show it used the EHR meaningfully by completing a detailed application and reporting on the 25 meaningful use items, including calculations of the percent of patients you performed these actions upon. In the years after 2011, you will be automatically reporting to Medicare electronically through your certified EHR system.
For the moment, the MU criteria currently published needs to be met in 2011 and 2012. This is considered Stage 1 of three stages. Additional MU criteria will be added in 2013 and again in 2015. The sooner you adopt and understand how to demonstrate meaningful use, the better prepared you will be for succeeding stages.
Decide on participation
1) Review what you're being asked to do to participate. Understand that all applicable MU criteria should be met in your first year of using your EHR system.
2) Even though incentive payments are based only upon Medicare patient allowed charges submitted, the meaningful use criteria applies to your entire set of patients, not just to Medicare patients.
3) Start talking to vendors; having a technology partner that is willing to guarantee their system will meet government EHR certification is critical. Make sure you leave enough time for the adaption process of your new EHR system.
Ready for adoption
The time to adopt an EHR system is now. If for no other reason, do it while the federal government is rewarding you to help reduce your costs. Once you start seeing the improvements to your practice, patient care, and the benefits to your bottom line, you’ll wonder why you needed an incentive in the first place.
Dr. Steven J. Kraus is Founder and Chairman of Future Health¯the nation’s #1 provider of chiropractic-specific EHR/practice management software. He has more than 22 years’ experience in practice management and is an acknowledged expert in Heath IT, including EHR and the up-to-$44,000 ARRA government incentive. Dr. Kraus serves on numerous committees and frequently travels to Washington, D.C., to represent chiropractic physicians in healthcare discussions and policymaking. To see a no-obligation Future Health software demo, call Toll Free 1-888-434-7347.