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CMS Releases EHR Adoption Rules, Part 1

On Tuesday July 13, CMS released the final rule for adopting a certified electronic health record (EHR) system.

After listing about 60 acronyms and abbreviations (and it’s impossible to remember them when reading the subsequent text), what follows is approximately 800 pages of proposals, related comments, and final rulings.

All this is to spell out the meaning of meaningful use (which we first touched on in October ), how to be considered an EP (eligible professional) and when said EP can expect to first receive any kind of incentive payment – for the early adopters, the first “payment year” is calendar year (CY) 2011.

When you actually receive the payment could be the end of the following calendar year). Hospitals will typically be incentivized on a fiscal year (FY) basis.

We’ll attempt to digest this compelling tome, one 100-page piece at a time (or so). Keep in mind, though, that this is only what CMS considers “Stage 1” of the meaningful use criteria. Stage 2 criteria are expected by the end of 2011 and Stage 3 criteria by the end of 2013. The idea is to have an “initial graduated approach to arriving at the ultimate goal”: total enlightenment of EMR, I suppose.

As we previously mentioned, a meaningful user is one who:

  1. demonstrates use of certified EHR technology in a meaningful manner (e.g. ePrescribing)
  2. demonstrates that certified EHR technology is connected in a manner that provides for the electronic exchange of health information to improve the quality of health care such as promoting care coordination, and
  3. using its certified EHR technology, submits, in a form and manner specified by CMS, information on clinical quality measures and other measures

According to CMS: the maximum incentive payment that would apply for this Medicare EP not practicing in a health professional shortage area (HPSA) would be $18,000 in 2011.

Early adopters, those practices that start CY 2011, essentially have the first two years to get the Stage 1 criteria right, as the Stage 2 criteria are not required to be adopted until 2013. However, if a practice waits until CY 2012 to start, they must adopt Stage 2 criteria the following year (CY 2013) and hence don’t get an extra year of practice.

Stage 1 criteria are purposely a bit easy on EMR users. The Core Set include such things as:

  • Implement drug to drug and drug allergy interaction checks
  • E-Prescribing (EP only)
  • Record demographics
  • Maintain an up-to-date problem list
  • Maintain active medication list
  • Record and chart changes in vital signs
  • Record smoking status
  • Provide patients with an electronic copy of their health information (this one might be a bit tricky in practice)

There are also an additional set of 10 objectives from which the physician chooses 5 and three additional quality measures.

Buried in the language is the magic figure of 80%. This refers to the percentage of unique patients which must include the core set criteria, objectives and quality measures (with some exceptions). If a provider practices at multiple locations and not all of these locations have certified EHR technology, this is taken into account: the denominator would only be those unique patients seen at the locations with EHR. Further clarification specifies that for a unique patient encounter to “count”, there must be sufficient relevant information entered in the EHR/EMR system – simply saving a patient’s name and address in the system does not count as an EHR. This lowers the burden on the provider.

One of the exceptions to the 80% rule, for example, is the objective of CPOE (computerized physician order entry), the threshold for which is 30%. This means that at least 30% of unique patients who have at least one medication listed in their medication list need to have at least one medication entered using CPOE. It does not, however, necessarily mean that this order needs to be transmitted outside the practice, such as to a pharmacy. Again, this does lower the burden on the practicing physician.

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