CMS and ONC Proposed Rules
During the last week of
December 2009, the Centers for Medicare and
Medicaid Services (CMS) and the Office of
the National Coordinator for Health
Information Technology (ONC) announced
publication of two important documents
outlining proposed rules governing
Electronic Health Record (EHR) incentives
under the American Reinvestment and Recover
Act of 2009 (ARRA).
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.
Sage has
also maintained CCHIT certification for Sage
Intergy EHR since the certifying body’s
inception in 2006. In fact,
Sage guarantees
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, MD
Solutions, Inc. and Sage 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 check back soon, or
contact MD Solutions 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.
