Like many things in life, you can either choose to do something or wait until something happens to you. Many physicians are taking the latter approach when it comes to electronic medical records implementation and the Meaningful Use (MU) incentives from CMS. Their feeling is that it would be safer to wait until EMR systems are perfected (which they never will be), to wait until the government certifies a particular EMR system (which they never will do), and until the MU requirements are 100% unambiguous (dream on). These things may never come to pass. And after 2012, the MU incentives will start to decrease and then reimbursement penalties will kick in.
Meaningful Use: What’s the Point?
In his 2004 State of the Union address, President George W. Bush outlined his plan for the adoption of electronic health records that could be accessed by all citizens in the United States. The Department of Health and Human Services (HHS) then created a 10-year map to implement that plan, although there was no specific funding set. Then in 2009, as part of the American Recovery and Reinvestment Act of 2009, the HITECH Act (Health Information Technology in Economic and Clinical Health) allocated almost $30 billion to push the adoption of EHR through the use of financial incentives. Subsequently, rules were created that required those providers seeking incentives to prove they were using certified electronic health records technology according to a set of guidelines of quality healthcare, or in a ‘meaningful use’ manner.
Non-MU Incentives Aren’t Too Shabby Either (or Why Waiting Until 2012 May Be More Profitable)
In the case of our practice, we had transitioned our old practice management (EPM) system to a new one with an integrated EMR a few years ago, but felt it prudent to wait a bit before we attempted to implement the EMR module. That came about at the end of 2008, so now that we have about 2 ½ years of ‘live’ experience with EMR, we are turning our attention to the MU incentives. But we haven’t been idly sitting by. Using software we developed in-house, we have been qualifying for both PQRI (Physician Quality Reporting Initiative) and E-Rx (E-Prescribing) incentives since their inception, in 2007 and 2009 respectively. Those have resulted in as much as a 4% bonus of our annual Medicare fees.
Although Stage 1 of Meaningful Use officially begins 2011 – with Stages 2 and 3 slated for 2013 (for the time being) and 2015, respectively – we decided that we would wait until 2012 before seeking the Meaningful Use (MU) incentives. The Office of the National Coordinator on Healthcare IT (ONC) announced that practices can qualify for the full MU incentives starting either in 2011 or 2012. They also ruled that practices can also get PQRI incentives concurrently with the MU incentives. So why would we wait another year? ONC also ruled that MU would disqualify ERx incentives, so this would give us another year of E-Prescribing bonuses plus another year to get our practice ready for MU. This means, however, that we have only one year to prepare for Stage 2 in 2013 instead of two, but this mostly builds on the work that needs to be done for Stage 1. (And, did I mention this means more money?)
Some Practices are Ahead of the Curve
Horizon Eye Care is an eight-doctor ophthalmology practice in Margate, New Jersey. Like our practice, they use an integrated EMR/EPM system from NextGen, but they have been using the EMR module for the past 10 years. According to Sandra Regenye, Director of Billing, they were ready to qualify for MU this year, but also decided to wait until 2012, since there was no decrease in the total incentives for waiting. And in addition to being able to collect ERx incentives for 2011 (which are excluded under MU), this is allowing their practice to perform simulations to test run the reporting process.
Ms. Regenye points out that it is the practice that must be a meaningful user of EMR, not the EMR system itself. “If you are not using your EMR in an appropriate manner, then you are not a ‘meaningful user.’ Even the best, certified EMR system cannot magically qualify you for MU incentives. There is no ‘plug-and-play’ for meaningful use. ”
In part 2, we’ll map out your Meaningful Use incentives action plan.