These proposed rules mark a substantive step toward the final definition of “meaningful use” of Electronic Health Records (EHR) systems by healthcare providers and toward an initial set of standards that must be met by certified EHR technology. While not yet finalized (a 60-day public comment period follows the announcement), the proposed rules give providers and technology vendors alike sufficient guidance to begin finalizing their EHR strategies.
CMS Notice of Proposed Rulemaking (NPRM)
This document defines the proposed criteria for meaningful use that Eligible Professionals (EPs) must achieve in order to be eligible for incentive payments under the HITECH provisions of the ARRA. In the NPRM, CMS identifies three proposed stages of meaningful use criteria:
- Stage 1, focuses on the electronic capture and tracking of codified health information, use of data for care coordination purposes, and on reporting of clinical quality measures and health information to CMS. EP’s must complete 25 measures in order to be deemed a “meaningful” EHR user and to qualify for 2011 incentive payments
- Stages 2 and 3, to be finalized at a later date, expand on the requirements to include disease and medication management, quality measurement and sharing of data with public health agencies
ONC Interim Final Rule (IFR)
This document from the ONC outlines initial standards, implementation specifications, and certification criteria applicable to EHR technology. ONC plans to release an additional NPRM specific to the certification of EHR systems.
The IFR describes an initial set of standards that ensures accurate and secure health information exchange across different EHR systems such as:
- Standard formats for clinical summaries and prescriptions
- Standard terms to describe clinical problems, procedures, lab tests, medications and allergies
- Standards for the reliable and secure transportation of the above information
The standards will rely on those already established and promoted by leading standards bodies such as HL7, Integrating the Healthcare Enterprise (IHE) and National Institute of Standards and Technology (NIST). Sage has been an early adopter of these standards, within the architecture of Sage Intergy EHR, and is widely recognized as a leader in the IHE community.
What does this mean to you?
While the details concerning payment to practices are contained in the proposed CMS rule and subject to change after the 60-day public comment period, here are some important highlights.
- There are two CMS incentive programs – Medicare and Medicaid
- Eligible Providers (EPs) may only participate in one CMS incentive program, although EPs will have one opportunity to switch programs
- Amount and timing of incentive payments will vary depending on when the provider elects to participate and which program they participate in (Medicare or Medicaid). The programs are structured to provide the greatest financial benefit to providers and practices participating from the beginning and for the full duration of the program.
- In general, the maximum amount of total incentive payments that an EP can receive is up to $44,000 under the Medicare program and up to $63,750 under the Medicaid program.
- To earn incentives for a given payment year, an eligible provider must demonstrate meaningful use during a designated “reporting period”.
- For 2011 (the first payment year), Medicare providers need to demonstrate meaningful use for a minimum of 90 consecutive days. Under the proposed rule, the reporting period for the 2011 payment year could begin as early as July 2010 or as late as September 2011.
- In subsequent years, demonstration of meaningful use will be required for the full payment year.
What now?
If your practice is not currently utilizing an EHR or you don’t believe your current EHR will meet certification requirements, you should begin actively searching now. It typically takes several months to implement a new system after completing the selection and purchase.
You’ll want to look for a vendor that has maintained current certification with CCHIT and complies (or plans to comply) with the 25 proposed measures listed under stage 1 of the NPRM. Most importantly (and as a basis for complying with the requirements), the vendor’s EHR system must utilize structured data documentation and allow for interoperable exchange of data, along with having other key functionality such as:
- Electronic order entry (CPOE)
- Codified electronic lab results
- ePrescribing, including interactions and formulary checking, and medication management
- Electronic insurance claims and eligibility verification
What is Sage doing to help?
We take meaningful use and certification seriously. Sage Intergy EHR was developed to easily capture codified, clinical details and, more importantly, to utilize that data for detailed reporting and to drive preventative medicine and chronic disease management.
We’ve also maintained CCHIT certification for Sage Intergy EHR since the certifying body’s inception in 2006. In fact, we guarantee that Sage Intergy EHR will remain compliant with certification criteria set forth by the ONC and will modify Sage Intergy EHR as necessary. These modifications will be made available to active customers in good standing under their support agreement.
At the same time, we are dedicated to our partnership with you – helping your practice formulate a plan to qualify for the incentives through meaningful use of Sage Intergy EHR.
For more information on Sage Intergy EHR:
Next Steps
There are some major announcements still to come. Within the next 90 days the federal government is expected to announce the final “meaningful use” definition along with EHR standards and certification criteria.
Please stay tuned, or contact your Sage account representative for more information. We are committed to providing informational and actionable tools to help you understand these announcements and how they relate to your practice.
Additional resources:
Frequently Asked Questions
Eligible Provider “Meaningful Use” Criteria – Healthcare IT News
US Department of Health and Human Services News Release
CMS Incentive Fact Sheet - Medicare
CMS Incentive Fact Sheet - Medicaid
CMS Meaningful Use Fact Sheet
CMS, ONC deliver meaningful use package – Healthcare IT News
ARRA Information for Your Practice
