Ready or not…

By Brad Rourke, CPA

The Health and Human Services (HHS) plan that allows for providers to receive financial incentives of up to $44,000 for use of certified EHR technology is marching on. Ready or not, here comes Stage 2.

If a provider does not jump on board with “meaningfully using” certified technology by 2014, not only will incentive entitlements become unavailable, but providers’ wallets will also be hit by way of reduced Medicare reimbursements. Those providers’ reimbursements will be reduced by one percent in 2015, and potentially reduced by five percent through 2019. That could add up to a tidy sum.

ELECTRONIC EXCHANGE

Furthermore, providers who chose not to use certified technology that supports electronic exchange of patient information may not be high on the referral lists of providers who do. For instance, certain primary care providers may choose to refer their patients to optometrists for an eye exam only if they can electronically refer and can count on receiving the eye exam test results back electronically.

The receipt of exam results in certified format can efficiently be amalgamated into the referring physician’s own records. Faxed results of an eye examination, on the other hand, may be deemed too cumbersome to administrate by the referring primary care provider. He or she may, therefore, limit referrals to optometrists who exchange clinical information electronically.

Most important, the objectives of meaningfully using certified technology are praiseworthy. They include:

■ improving the quality, safety, and efficiency of healthcare;

■ engaging patients and families;

■ and improving coordination of care for purposes of better clinical outcomes.

The overriding objectives of meaningful use of EHR technology are to improve the health of all Americans and to improve the efficiency of healthcare delivery. The evergrowing cost of Medicare, for which we will all be eligible at the age of 65, is not sustainable in our current healthcare delivery context. Our healthcare system desperately needs to meet these necessary objectives.

THE TIMELINE

The onset of Stage 2 criteria is effective in 2014. You might be saying, “Stage 2? I don’t even know what Stage 1 is.”

If that’s you, fear not. Health and Human Services is bending over backward to accommodate providers and EHR vendors from the inordinately challenging timeline that the program legislation originally set out.

In fact, both providers and EHR vendors can consider themselves fortunate because the onset of Stage 2 was originally set for 2013. In addition, Health and Human Services has further accommodated providers and EHR vendors by relaxing the initial implementation period for both Stages 1 and 2. That initial implementation requirement has been reduced from one year to 90 days for both stages. In other words, providers are only required to demonstrate meaningful use of certified technology for 90 days for each of Stages 1 and 2.

Each stage covers a period of two years, so the first year in each stage requires meaningful use of 90 days, and the second year in each stage requires meaningful use for the 365 days.

EHR ACCOMMODATIONS

That being said, for 2014 only, there is one final accommodation for both providers and EHR vendors: All providers, regardless of their Stage of meaningful use, are only required to demonstrate meaningful use for a three-month period in calendar year 2014. So, if 2013 is a provider’s first year of Stage 1, of which 90 days of meaningful use is required, in 2014 all that is required is another 90 days, not 365.

Why is Health and Human Services permitting a 90-day reporting period in 2014 regardless of a provider’s stage? It’s so that all providers can upgrade to 2014 Certified EHR Technology and have adequate time to implement their new certified EHR systems or perform upgrades.

BEGINNING AT STAGE 1

Regardless of the fact that Stage 2 is imminent, all providers choosing to participate in the EHR incentive program begin with Stage 1 criteria. Each stage must be satisfied over the duration of two years. During the first year, the meaningful use requirement is 90 days; during the second year of the stage, it is a full 365 days- except for the 2014 caveat which requires only 90 days regardless of stage. After providers comply with two years of Stage 1, they are then required to advance to Stage 2 criteria.

Stage 1 consists of 15 core criteria, all of which must be met, along with a menu set of 10 criteria. From the 10 menu criteria, five must be satisfied, which in addition to the 15 core criteria is a total of 20 criteria to be met.

CONTROVERSIAL COMPONENT

A controversial component of Stage 2 requires that patients use health information technology in order for providers to achieve meaningful use. Yes, your patients control your ability to meet meaningful use. The Centers for Medicare & Medicaid Services (CMS) believes providers are in the best position to encourage the use of health information technology by patients to further their own health care. To this end, Stage 2 criteria requires that at least five percent of patients you see to go online and view or download or transmit their health information to a third party.

The criteria include requirements such as e-prescribing, documenting patient vital signs, and providing patients with clinic summaries. A complete list of Stage 1 criteria can be found at cms.gov.

STAGE 2 CRITERIA

To demonstrate Stage 2 meaningful use, providers must satisfy 17 core criteria and choose three additional criteria from a menu list of six—for a total of 20 criteria. Most Stage 1 criteria have been included in the 17 core Stage 2 criteria, though the bar for those criteria is raised in Stage 2. For instance, Stage 1 requires providers to send 40 percent of their prescriptions to pharmacies electronically; this criterion is increased to 50 percent in Stage 2.

In Stage 2, an entirely new criterion has been introduced within one of the mandatory 17 core criteria. Providers must now communicate relevant health information to at least five percent of patients seen using secure electronic messaging. As a corollary to this, certified EHR vendors must provide secure messaging functionality in order to retain their certified technology status.

JUST DO IT

From our experience, providers are never perfectly ready for meaningful use of certified technology. EHR vendors are doing their utmost to provide the required functionality in as usable condition as possible given the HHS time constraints.

Providers as well are doing their utmost to understand and meet the criteria, in order to provide the world’s best healthcare to patients. We have found that providers who achieve meaningful use do not find the criteria overly burdensome or onerous. Providers, when it comes to ready or not, are in fact much more ready than they think. EB