Workflow

Economic Stimulus – Electronic Health Record Incentives

WorkflowEHR has obtained ONC-ATCB 2011/2012 Certification

We are excited to announce that workflowEHR has been certified under Meaningful Use Stage One, which is a requirement for eligible professionals to receive incentive payments under the American Recovery and Reinvestment Act.
View the press release.

This Complete EHR is 2011/2012 compliant and has been certified by an ONC-ATCB in accordance with the applicable certification criteria adopted by the Secretary of Health and Human Services. This certification does not represent an endorsement by the U.S. Department of Health and Human Services or guarantee the receipt of incentive payments.

• Vendor Name: Workflow.com, LLC
• Date Certified: 10/13/2010
• Product Version: 2.5
• Certification ID Number: 10132010-2067-1
• Clinical Quality Measures Certified: NQF 0013, NQF‐0421/PQRI128, NQF0041/PQRI110,NQF0024, NQF0028, NQF0038, NQF0031/PQRI112, NQF0032, NQF0043/PQRI111
• The additional software workflowEHR relied upon to demonstrate compliance includes: spreadsheet software and email software

So, what does all this mean for you? In this section, we have provided a general summary of the EHR Incentive Program. Note that it is not intended to grant rights or impose obligations. We encourage readers to review the specific statutes and regulations for a full and accurate statement of their contents. The full ARRA legislation is available at http://www.thomas.gov/home/approp/app09.html#h1.

American Recovery and Reinvestment Act of 2009

The American Recovery and Reinvestment Act (ARRA), signed by President Obama on February 17, 2009, aims to stimulate the economy through investments in infrastructure, unemployment benefits, transportation, education, and healthcare. The Health Information Technology for Economic and Clinical Health Act (HITECH Act) was signed into law as part of ARRA. The bill encourages investment in healthcare technology, including achieving widespread adoption and use of EHR technologies within hospitals, physician practices, community health organizations, public health settings, and others.

According to ARRA, eligible professionals will receive incentive payments for demonstrating meaningful use of certified EHR technology during the reporting period for each payment year.

Two incentive programs are available: one provides payments totaling up to $44,000 for Medicare Providers and the other up to $63,750 for Medicaid Providers. Both programs will disperse funds over a pre-determined time period (five years with Medicare and six years with Medicaid) and will be available beginning in 2011. Note that providers may only elect to receive incentive payments from one of the programs in a given year. Additionally, providers may only switch from one program to the other once during the life of the EHR incentive program.

Who is an Eligible Professional?

Click here to view the CMS Flow Chart for Eligible Professionals

Medicare

Under the Medicare EHR Incentive Program, Eligible Professionals (EPs) must be one of the following:

• Doctors of Medicine or Osteopathy
• Doctors of Dental Surgery or Dental Medicine
• Doctors of Podiatric Medicine
• Doctors of Optometry
• Chiropractors

NOTE: Medicare EPs may not be hospital-based. A Medicare EP is considered hospital-based if 90% or more of the EP’s services are performed in a hospital inpatient or emergency room setting.

Eligible Professionals in the Medicare Advantage (MA) Program must:

• Furnish, on average, at least 20 hours/week of patient care services and be employed by a qualifying MA Organization (MAO), OR
• Furnish, on average, at least 20 hours/week of patient care services and be employed by, or be a partner of, an entity that through contract with a qualifying MAO furnishes at least 80% of the entity’s Medicare patient care services to enrollees of the MAO, AND
• 80% of professional services must be provided to enrollees of the MAO

Medicaid

Under the Medicaid EHR incentive program, EPs include the following:

• Physicians (Pediatricians have special eligibility and payment rules)
• Nurse Practitioners (NPs)
• Certified Nurse-Midwives (CNMs)
• Dentists
• Physician Assistants (PAs) who provide services in a Federally Qualified Health Center (FQHC) or rural health clinic (RHC) that is led by a PA

Medicaid EPs must also meet patient volume criteria, defined as follows:

• A non-hospital-based EP who has at least 30% of his/her patient volume attributable to individuals who are receiving medical assistance through Medicaid.
• A non-hospital-based Pediatrician who has at least 20% of his/her patient volume attributable to individuals who are receiving medical assistance through Medicaid.
• An EP who practices predominately in a Federally-Qualified Health Center (FQHC) or Rural Health Clinic (RHC) and has at least 30 percent of his/her patient volume attributable to needy individuals.

NOTE: Medicaid EPs may not be hospital-based. A Medicaid EP is considered hospital-based if 90% or more of the EP’s services are performed in a hospital inpatient or emergency room setting.

What is Meaningful Use?

Ultimately, the goal of Meaningful Use is to help improve health, increase safety, and reduce healthcare costs in the US through the use of an EHR.

On July 13, 2010, the Centers for Medicare and Medicaid Services (CMS) released the definition of Meaningful Use, including the objectives and measures that providers must report on and submit in order to qualify for incentive payments. The final rule definitively outlines all the specifics of Stage 1 Meaningful Use (there will be three stages, rolled out consecutively) and clinical quality measure reporting required to receive the incentive payments in 2011 and 2012. Subsequent rules will govern later phases. This approach will allow CMS to phase in additional and more rigorous requirements for EHR performance and clinical quality measures over a period of a few years.

Meaningful Use objectives and measures are divided into Core and Menu sets. In Stage 1 (2011-2012), 13 objectives from the Core set must be met. Additionally, providers must meet five out of 10 from the Menu set.

The chart below provides a basic summary of the MU objectives:

* Source: Blumenthal, David, and Marilyn Tavenner. “The ‘Meaningful Use’ Regulation for Electronic Health Records” The New England Journal of Medicine, (8/52010): 501-504

What is a Certified Electronic Health Record?

On July 13, 2010, the Office of the National Coordinator (ONC) released the final rule for the Certification Criteria of EHR technology. This final rule established the required capabilities, related standards, and implementation specifications that Certified EHR technology must include to support the achievement of Meaningful Use Stage 1.

Certification of EHR technology provides assurance to buyers that an EHR system offers the necessary technological capability, functionality, and security to meet Meaningful Use criteria. Use of a Certified EHR technology is a requirement for EPs to receive incentive payments under Medicare and Medicaid incentive programs.

In order to be officially recognized as a Certified EHR, existing EHR technology needs to be certified by an ONC Authorized Testing and Certification Body (ATCB). The ONC has created a temporary certification program for ATCBs, which defines the processes that organizations will need to follow in order to be authorized by the ONC to test and certify EHR technology for 2011-2012.

For a complete list of EHRs that have been tested and certified by an ONC-ATCB, visit the ONC’s Certified Health IT Product List website – http://onc-chpl.force.com/ehrcert

WorkflowEHR has obtained the ONC-ATCB 2011/2012 Certification

This Complete EHR is 2011/2012 compliant and has been certified by an ONC-ATCB in accordance with the applicable certification criteria adopted by the Secretary of Health and Human Services. This certification does not represent an endorsement by the U.S. Department of Health and Human Services or guarantee the receipt of incentive payments.

• Vendor Name: Workflow.com, LLC
• Date Certified: 10/13/2010
• Product Version: 2.5
• Certification ID Number: 10132010-2067-1
• Clinical Quality Measures Certified: NQF 0013, NQF‐0421/PQRI128, NQF0041/PQRI110,NQF0024, NQF0028, NQF0038, NQF0031/PQRI112, NQF0032, NQF0043/PQRI111
• The additional software workflowEHR relied upon to demonstrate compliance includes: spreadsheet software and email software

EHR Medicare Incentive Program Overview

• EPs can qualify for incentives totaling up to $44,000 over a five year time period (equal to 75% of an EP’s Medicare physician fee schedule allowed charges).
• EPs must participate for five consecutive years to receive the maximum incentive amount.
• EPs can expect to receive one lump sum payment each year.
• The incentive amount will decrease for professionals who demonstrate meaningful use after 2012.
• If an EP does not demonstrate meaningful use by 2015, he/she will begin to incur penalties.
• No incentive payments will be made after 2016.

To maximize the incentive payments, EPs should begin implementing certified EHR technology as soon as possible and demonstrate meaningful use beginning in 2011-2012. The table below provides a basic overview of the incentive payment schedule:

*Represents the first year in which an EP demonstrates meaningful use of a certified EHR

ARRA also includes additional incentives for EPs who predominantly furnish services in an area that is designated as a geographic health professional shortage area (HPSA). These incentives will equal up to a 10% increase in incentive payments each payment year.

Beginning in 2015, Medicare reimbursements will be reduced on the following schedule for eligible professionals who cannot demonstrate meaningful use of certified EHR technology:

• 2015 = 1% reduction
• 2016 = 2% reduction
• 2017 and each subsequent year = 3% reduction

EHR Medicaid Incentive Program Overview

• EPs can receive up to $63,750 (85% of their net average allowable costs) over a six year time period for certified EHR technology (plus necessary support services including maintenance and training).
• During the first payment year, EPs can receive up to $21,250 by:
  • Purchasing and implementing Certified EHR technology or upgrading to Certified EHR technology
  • Demonstrating that he/she is engaged in efforts to adopt, implement, or upgrade Certified EHR technology
  • Demonstrating that an investment in the adoption and use of certified EHR technology was made prior to beginning of the funding period
• During subsequent payment years, EPs can receive up to $8,500 to pay for the cost of the operation, maintenance, and use of certified EHR technology.
• EPs do not have to participate in consecutive years to receive the full incentive amount (i.e. EPs can receive all six payments over a 10 year period).
• EPs can expect to receive one lump sum payment each year.
• Incentives will be reduced by one-third for eligible Pediatricians who only meet the 20% patient volume calculation. Therefore, incentives in the first payment year will be $14,167 and $5,667 in subsequent year, for a total of $42,500 over the six-year period.
• Medicaid EPs are not subject to payment reductions.
• 2021 is the final year for Medicaid EHR incentive payments.

The table below provides a basic overview of the incentive payment schedule:

*Represents the first year in which an EP demonstrates meaningful use of a certified EHR.

The EHR Medicaid Incentive Program is voluntary for each state. Therefore, if a state decides not to participate in the incentive program, EPs in that state will be unable to receive incentive payments through Medicaid (however, they can participate in the Medicare program if eligible). State Medicaid agencies may begin participating in the EHR Incentive Program between 2011 and 2016. Medicaid EPs can switch to another state’s Medicaid program, but it must be at the beginning of the year.

Are there any Limitations?

Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) authorized an incentive program for eligible professionals utilizing ePrescribing. Medicare EPs seeking incentives under ARRA will no longer be eligible for MIPPA incentives (Medicaid EPs may still receive incentives from both programs).

Both Medicare and Medicaid EPs may also participate in the Medicare Physician Quality Reporting Initiative (PQRI) and Medicare Electronic Health Record Demonstration (EHR Demo) Programs while simultaneously participating in the EHR Incentive Program.

Helpful Links

• Medicare and Medicaid EHR Incentive Programs: http://www.cms.gov/EHRIncentivePrograms/
• Office of the National Coordinator Standards and Certification Criteria: http://healthit.hhs.gov/standardsandcertification

Sources

• The American Recovery and Reinvestment Act of 2009
• HIMSS Legislative Overview and Policy/ Industry Ramifications, February 2009
• http://www.cms.gov/EHRIncentivePrograms/30_Certification.asp#TopOfPage
• http://www.hhs.gov/news/press/2010pres/07/20100713a.html
• http://www.modernhealthcare.com/article/20100713/NEWS/307139973
• http://govhealthit.com/newsitem.aspx?nid=74328
• Blumenthal, David, and Marilyn Tavenner. “The ‘Meaningful Use’ Regulation for Electronic Health Records” The New England Journal of Medicine, (8/52010): 501-504