Q: What
is ARRA or “the stimulus” and what does
it mean for medical practices?
A: The HITECH
provisions of the American Recovery and
Reinvestment Act of 2009 (ARRA), also
known as the “economic stimulus plan”,
provide significant financial incentives
to assist physicians in the purchase,
implementation and meaningful use of a
certified electronic health records
(EHR) system.
Q: Who
is eligible to receive stimulus dollars
under ARRA/HITECH?
A: The ARRA
outlines two separate EHR incentive
programs— a Medicare program and a
Medicaid program. Each has its own set
of eligibility requirements under the
proposed rules.
Under the
Medicare
program,
it has been proposed that an eligible
professional (EP) is “a doctor of
medicine or osteopathy, a doctor of
dental surgery or dental medicine, a
doctor of podiatric medicine,
a doctor of optometry, or a
chiropractor, who is legally authorized
to practice under state law.” A
qualifying EP must demonstrate
meaningful use of an EHR as defined by
CMS during the specified reporting
period.
Under the
Medicaid
program,
it has been proposed that EPs include
“physicians, dentists, certified
nurse-midwives, nurse practitioners, and
physician assistants who are practicing
in Federally Qualified Health Centers
(FQHCs) or Rural Health Clinics (RHCs)
led by a physician assistant.” A
qualifying EP must demonstrate
meaningful use through a means
determined by the State and meet
Medicaid volume percentages—20% for
pediatricians, 30% for others.
EPs may not receive
incentives from both Medicare and
Medicaid. EPs must choose to participate
in either the Medicare or Medicaid
program. They will have one opportunity
through the course of the stimulus
funding to switch to the other program.
Q: So,
what is meant by “meaningful use” and is
there a definition?
A: Meaningful use
is a central concept under ARRA/HITECH.
Purchasing EHR does not, on its own,
qualify you to receive stimulus dollars.
A provider must actually make
“meaningful use” of this technology, as
defined by CMS. The proposed rule
announced on December 30 is the closest
the federal government has come to
defining the term. It consists three
stages, the first beginning in 2011 and
consisting of 25 measures. At the
conclusion of a 60 day public comment
period, the final definition will be
released.
Q: What
is meant by “certified” and is Sage
certified?
A: Sage has
maintained (and continues to maintain)
current certification with the
Certification Committee for Health
Information Technology (CCHIT) since its
inception in 2006. Alongside the CMS
announcement, the ONC announced an
initial set of standards, implementation
specifications, and certification
criteria for EHR systems. CCHIT is
expected to incorporate these
requirements into its certification and
to be one of the certification bodies
officially recognized by the ONC (though
probably not the only one). Sage is
committed to meeting all certification
standards required by the ONC.
Q: As a
physician, how will I receive payment
from the federal government and how will
they calculate my payment?
A: Providers will
receive incentives in the form of
additional reimbursement from Medicare
or Medicaid.
Under the
Medicare
program,
payments will be calculated by
multiplying the allowable charges by 75%
and paying reimbursement bonuses up to
the capped amount for the year. So, in
order to earn the maximum incentive in
2011 ($18,000), you will need to submit
claims with allowable charges of $24,000
or more. Qualified eligible providers
who do not meet this threshold will
receive an amount less than the $18,000
maximum, in proportion to submitted
allowable charges.
Under the
Medicaid
program,
an EP may receive “up to 85 percent of
the net average allowable costs for
certified EHR technology, including
support and training (determined on the
basis of studies that the Secretary will
undertake)” and will receive up to
$25,000 in the first year, and up to an
additional $10,000 in subsequent
reporting years up to the maximum.
Q: Does
ARRA require my practice to adopt EHR
and participate in the CMS program?
Aside from missing out on the
incentives, are there any penalties
specified if I choose not participate or
to adopt EHR?
A: While neither
ARRA nor the latest announcement from
CMS “require” adoption of EHR, providers
who fail to demonstrate meaningful use
in the 2014 timeframe face reduction of
Medicare payments by 1% a year starting
in 2015 and continuing through 2017,
with the option to lower fees to 95% of
the regular fee schedule. So, in order
to gain a full picture of the impact of
this decision, medical practices will
need to assess the total cost of these
penalties over time in addition to the
loss of the incentives. There are no
penalties associated with the Medicaid
program.
Q: My
practice does not see Medicare or
Medicaid patients. What are the
incentives for my practice to adopt EHR
and demonstrate meaningful use?
A. There are no
specific provisions under ARRA to
incentivize providers other than through
Medicare/Medicaid reimbursement.
However, the door is open for HHS to
offer additional incentives after 2011
based on adoption levels. Also, industry
experts predict that private insurers
will follow suit and begin to offer
incentives and/or penalties based on
certain meaningful use criteria,
including reporting of quality measures.
Q: Will Sage
guarantee that our practice will receive
stimulus dollars by using Sage products?
A: We guarantee
that Sage Intergy EHR will remain
compliant with all certification
criteria set forth by the ONC and will
modify Sage Intergy EHR as necessary.
Sage will make these modifications
available to active customers in good
standing under the terms of the current
Support Services Agreement. At the same
time, Sage is committed to partnering
with customers planning to qualify for
the incentives through meaningful use of
Sage Intergy EHR.
