Manage My Practice

As managers, providers and employees, we always have to be looking ahead at how the technology on our horizon will affect how our organizations administer health care. In the spirit of looking forward to the future, we present “2.0 Tuesday”, a feature on Manage My Practice about how technology is impacting our practices, and our patient and population outcomes.

We hope you enjoy looking ahead with us, and share your ideas, reactions and comments below!

• Natural Language Processing Advances Allow for Improved Insight into Public Health

Writing for KevinMD, Jaan Sidorov, author of the Disease Management Care Blog highlights several examples of how Natural Language Processing- the idea of teaching computer programs to understand the relationship between words in human speech (teaching them to not just hear us, but understand us- like Watson understood the clues on Jeopardy) is being be applied to the Electronic Health Record to predict and prepare for public health trends, as well as to correct mistakes present in the electronic record due to human error. Recent developments like the CDC’s Biosense program allow public health officials at local, state and federal levels to monitor big picture trends in public health by the words and diagnoses reported in medical documentation- keeping an ear on health trends, by “listening” to data about reported health incidents.

• 10 Best Practices for Implementing Telemedicine in Hospitals

Sabrina Rodak at Becker Orthopedic, Spine and Pain Management has put together a fantastic list of the steps and assessments involved in implementing a telemedicine program in a hospital setting. Although written with Orthopods in mind, the questions that need to be answered, and the steps that need to be taken to develop a strong, lasting program are similar across many different programs and specialties. With so much excitement in the field, it is very nice to see someone talk about the process of taking these technologies from drawing board excitement to nuts-and-bolts execution.

(via FierceHealthIT)

• San Diego Health System Seeks to Develop Single App to Access Any EMR

Presenting at a Toronto Mobile Healthcare Summit Last Week, Dr. Benjamin Kanter, CIO of Palomar Pomerado Health presented the two-hospital system’s plans to develop their own native mobile application to view as many different Electronic Medical Records as possible from a single mobile interface. In other words, this fairly small health system, who has only devoted three employees to the project, is taking on one of the biggest, and toughest challenges in HIT by simply saying “We can do it ourselves!”, and from some of the reactions from the conference attendees who saw the presentation, they are off to quite a strong start. The first version of the program should launch for Android in March, and the system already has a deal in place with vendor Cerner to access their systems. Stay tuned!

(via ITWorldCanada)

Be sure to check back soon for another 2.0 Tuesday!

Mary Pat: Where does the name of your company, Lutrum, come from?

Ed Garay: When I was developing a name for this company, I didn’t want to be like every other healthcare IT services company with health, md, medical, etc. as part of their name. I wanted it to represent something deeper about what we do and who we are as an IT organization. Although we are IT specialists, I realized that one of the things that I am always working with my team on is to listen and understand our clients needs. Which lead me to creating the name, Lutrum. Lutrum is a slight variant of the Latin word Lutra. Lutra means otter in English. And the otter symbolizes empathy.

Mary Pat: What led up to you starting your own business?

Ed Garay: In late 2000, I worked as an IT Director for an organization that continued to downsize. I came to a career crossroad. With starting to support under 100 systems, and the network running in tip-top shape, there was really no need for me to be there full-time in the long run. So, do I look for another job that cant possibly be as fulfilling as where I was, or do I take a leap of faith and start up my own business and share my knowledge with the masses? Through the feedback of mentors and other resources that knew me personally and professionally, I was highly motivated to take the leap of faith and have never looked back. My business career has evolved over the years and has naturally lead me to Lutrum.

Mary Pat: What are Managed IT Services?

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One of the most exciting trends in modern healthcare can be found at the intersection of two larger societal changes: the shifting demographics of an aging Baby-Boomer population, and the fast adoption of smart mobile devices and mobile application platforms. As robust, secure and intuitive mHealth applications are adopted, patients are more empowered to monitor and share their health data outside of a traditional medical office or hospital setting. As healthcare delivery system already short on providers becomes even more taxed, mHealth applications will allow the system as a whole (patients, caregivers, loved ones, and payers) to navigate health decisions in a more efficient and informed way.

This quote from the Deloitte Center for Health Solutions 2010 Survey of Health Care Consumers says it all:

Boomers view tech-enabled health products as a way to foster control and ongoing independence for themselves, especially in light of the rise in incidence in chronic disease with aging, and their desire to reduce costs. Nearly 56% of boomers show a high willingness to use in-home health monitoring devices in tandem with care of their primary physician.

What are the advantages of pushing home health medical data from the source to the care provider?

• Minimum lag time between data collection and the clinicians ability to review it.
• Reduction in errors associated with human intervention in data entry.
• Intuitive and simple interfaces promote active patient involvement and caregiver communication in healthcare management.
• Secure sharing of PHI (Protected Health Information) with patient, family members, and approved internal and external stakeholders in health.

Here are just a few of the companies and products available now (or in the near future) that might change your mind about where and how health data is captured and shared. Each of these products automates the capture of health data and the transfer of the data in a usable format to an Electronic Health Record.

Near Field Communications

NFC (Near Field Communications) is a wireless technology that allows for quick transfer of data between two sensors that are fairly close (an inch or two) together. The secure transfer allows for seamless data tracking inside caregivers workflow. For example: medical supplies, drugs, injectables and fluids can be fitted with low cost sensors that are swiped past a patients sensor to indicate they will be administered to the patient, and then again past the providers sensor to indicate a finished procedure, capturing time of administration, dosage, and patient information without slowing down the care to enter this critical data by writing them down, typing them in, or just resolving to remember them for later entry.

Gentag makes the data sensors and applications that manufacturers can use to send data via cell phone to the hospital or physician for seamless inclusion in the electronic medical record (EMR). Monitoring of blood pressure, fever, weight management and urinalysis are just a few of the ways Gentag has improved data capture in healthcare.

iMPak Health makes a cholesterol monitor the size of a credit card that accepts a small blood sample to process for triglyceride levels. The data is uploaded wirelessly to a cell phone that transmits it to a health provider.

Smart Fabrics and Wearable Monitors

Researchers at the Universidad Carlos III de Madrid in Spain developed a fascinating concept for an Intelligent T-Shirt that uses sensors woven into a washable fabric to create a hospital garment that does more than preserve the patients modesty. The sensors in the fabric can detect and record temperature, bioelectric impulses (for ECG monitoring), as well as the patients location, current resting position, and level of physical activity.

Copenhagen Institute of Interaction Design graduate Pedro Nakazato Andrade has designed a dynamic cast called Bones that collects muscle activity data around a fracture area by using electromyographic (EMG) sensors to report the patients progress to physicians automatically. This could reduce the need for follow-up visits and imaging, or change the specifics of rehabilitation.

The Basis Band is a wristwatch-type accessory that monitors heart rate by directing light into the skin to image blood flow. It also uses a heat sensor for skin temperature changes, an accelerometer for recording movement and activity, and sensors for galvanic skin response. The band also gives customers access to a free, web-based health dashboard to oversee the data the device collects and transmits.

There are still some considerable hurdles to full adoption of mobile home health monitoring. Very few patients use only one medical device, so not only do monitoring devices need to work with networked EHR technologies, they have to be integrated with each other to present a comprehensive picture of health to providers and Health Information Exchanges (HIEs). Also, as patients navigate the system of generalists, specialists, and emergency care providers, the possibility of encountering multiple software and hardware platforms will require flexible, integrated solutions that can run on any device. As with any networked application of sensitive data, security and availability are major factors in a success deployment. Unless patients can count on the privacy of their data, and providers can count on the uptime of their software, healthcare systems wont be able to realize the full benefit of mHealth installations. On top of that, more monitoring of patient health means that there will be even more data to be collected on each patient, and on the population as a whole. While more data means more opportunity for large scale research and analysis for the public benefit, it also means more data has to be secured and protected as a part of the health record, requiring even more security and storage resources. And finally, the Food and Drug Administration will have a large say in the future of mHealth application development through industry regulation. Device makers and application developers will certainly have to work within a governmental framework which will have a large say in the time-to-market of many possible products.

With all that being said, the opportunity to meet the demographic challenges of an already stressed healthcare system with mobile home health monitoring and Electronic Health Records will be one of the major themes of the future of both the heath and technology industries.

At Manage My Practice, we have always been fascinated by the opportunities created when innovation and technical advancements are applied to the Healthcare system. The intersection of technology and medical practice has always been one of the most exciting spaces in research and development because the challenges of the Human Body are some of the most daunting and emotionally charged of our endeavors. Curing diseases, diagnosing symptoms and improving and saving lives are among our most noble callings, so naturally they inspire some of our brightest thinkers and industry leaders.

As managers, providers and employees, we always have to be looking ahead at how the technology on our horizon will affect how our organizations administer health care. In the spirit of looking forward to the future, we present “2.0 Tuesday”, a weekly feature on Manage My Practice about how technology is impacting our practices, and our patient and group outcomes.

We hope you enjoy looking ahead with us, and share your ideas, reactions and comments below!

• Steve Jobs thought iCloud had the potential to store Medical Data

Apple’s recently announced iCloud service let’s you store pictures, movies, music, and documents in Apple’s “cloud”, or Internet storage system, and retrieve them with your iPhones, iPods, iPads, and Mac computers. Dr. Iltifat Husain, writing for the IMedicalApps blog notes that in the new biography of the Apple founder, Jobs mentioned that he thought even personal medical data would one day be stored in Apple’s iCloud. Cloud storage is all the rage right now in a lot of different areas of technology, but Jobs saying that medical data would be stored on the consumer end next to vacation photos and favorite songs represents a very bold vision of the future of patient data.

• Researchers using Social Media to study attitudes about Public Health

A team led by Marcel Salath, PhD at Pennsylvania State University published a study last month in PLoS Computational Biology that used “tweets” gathered from the social network Twitter to analyze how the public felt about the H1N1 influenza vaccine in 2009. Although Social Media research has limitations, Christine S. Moyer, writing for the American Medical Association’s Amednews.com notes that the results were similar to traditional phone surveys conducted by the Centers for Disease Control, and provides some other examples of how Social Media has been used to understand public health trends.

• Interesting EHR/EMR data from the Soliant Health Blog

Medical staffing specialist Soliant Health had very eye-opening list of statistics about EHR/EMR implementations on their blog last week. My personal favorite: Hospitals using EHR/EMR systems have a 3 to 4% lower mortality rate than those that dont. Very interesting numbers.

• HealthWorks Collective predicts changes in healthcare communications after ACA

Healthworks Collective‘s Susan Gosselin makes some predictions about how the communications between and among providers and patients are going to be changed by the Affordable Care Act (or Healthcare Reform)- and what both groups will demand from a changing system. Great stuff!

• Oregon to help disabled voters cast ballots using iPads

In today’s local and congressional elections, five counties in the state of Oregon are going to be equipping local officials with iPads preloaded with special touch-interface software to accompany people with physical or visual impairments, or who would otherwise have a hard time making it to the polls. The 9 to 5 Mac blog is reporting that the pilot program features hardware donated by Apple, and could soon spread statewide by the next election.

Be sure to check back next week for another 2.0 Tuesday!

Some of worst horror stories in healthcare operations right now have to do with the failure of Electronic Health Record, (or EHR) installations. The high rate of EHR failures is being compounded by the pressure to attest in 2011 and start recouping some money against the EHR purchase and implementation.

To help organizations adopt EHRs smoothly and successfully, billing and management specialist Kris Jones, owner of Healthcare Management Services, is providing her clients with an innovative EHR program that she calls “Crawl. Walk. Run. Fly.” Kris told me “I found my clients so resistant to EHR, so paralyzed by the horror stories of money spent and productivity lost that I couldn’t help them move forward like we both knew they should.”

So Kris created the program that she thinks of as “Baby Steps” to make the process much more manageable and less intimidating. She brings the practice team on board a step at a time, removing the fear of the unknown and the greatest fear of all – change! Because Kris supplies the practice management software as well as the EMR, it is feasible for for her to let the practice take as much time as it needs to move through each stage.

Step 1. Crawl

The practice uses the EHR as a repository for medical record images. Staff makes first contact with the software.

Step 2. Walk

The practice adds e-prescribing and the staff enters data into the EHR for the problem list, the medication list and vitals. The software begins a functional role in patient interactions.

Step 3. Run

The physicians start with partial, then move to a full progress note. Physicians make first contact with the software.

Step 4. Fly

The practice achieves Meaningful Use with full implementation of the EHR.

What Kris has developed for her clients is the antithesis of the experience most practices have with the purchase of an EHR. It gives her clients the continual support and incremental change they need to preserve their workflow while slowly integrating the new software. This “slow and steady” approach has allowed her clients to be able to get their feet wet in the Electronic Health Record before being assured that the water’s fine and taking a full dip.

Click here to see the special free offer Kris and her team have put together for Manage My Practice readers.

Kris Jones-Bartley founded Healthcare Management Systems in 1985. Over the last 25 years, Kris built HCMS in to a multi-faceted practice management company with clients nationwide. Kris has personally managed every phase of a medical practice, from start-up to retirement, and including the recovery of practices on the brink of insolvency. Critical thinking, candor and eye-for-detail, make Kris a valuable partner in the business of medicine. HCMS is focused on specialty Revenue Cycle Management deployed in conjunction with E.H.R. capability.

HealthCareManagementSystems Experience. Expertise. Integrity. Determination. Results. Value.

Today, PhysiciansPractice sponsored a webinar with CMS’s Robert Anthony on the topic of “Meaningful Use Stage 1.” Robert Anthony is a Health Insurance Specialist in the Office of E-Health Standards and Services (OESS) at the Centers for Medicare & Medicaid Services (CMS), where he focuses on the EHR Incentive Programs. Robert had a very pleasant voice to listen to, and he gets my vote for the best CMS Employee Speaker that I’ve heard!

I was not familiar with the OESS before, so I looked it up and found out what they do: Provide the overall leadership for and coordinate the implementation of Title IV of the HITECHAct. (Title IV = Medicare and Medicaid Health Information Technology)

Robert briefly reviewed what has happened to date with the EHR Incentive Program and the terms of the Medicare and Medicaid programs. The three main differences in the two programs are:

1. The types of providers that are eligible for each program – information here.
2. The volume of each type of patient needed to participate: no volume needed to participate in the Medicare program and 30% Medicaid patients for all eligible practitioners except pediatricians who only need 20% Medicaid patients.
3. The tasks in year one in which the certified EHR is adopted. For Medicaid the practice only needs to attest that they have adopted, implemented or upgraded an EHR. In year one for Medicare the practice needs to attest to meaningful use for 90 days, which means data is collected and input into the attestation system.

The majority of the webinar was devoted to FAQs (my favorite part of any CMS-related education session!)

FAQs

Q: Can entities participate in the Medicare EHR Demonstration Project, and the Medicare or Medicaid EHR Incentive programs too?

A: Yes. The demonstration projects are about to be sunsetted (completed.)

Q: What information must be provided to patients to meet the requirement for a clinical summary at the end of each visit?

A: If system is certified, it will automatically provide the appropriate information for the clinical summary, which includes the patient’s problem list, medication list, medication allergy list, and diagnostic test results.

Robert suggested looking at the answer online at the CMS FAQ which I posted below:

In our final rule, we defined “clinical summary” as: an after-visit summary that provides a patient with relevant and actionable information and instructions containing, but not limited to, the patient name, provider’s office contact information, date and location of visit, an updated medication list, updated vitals, reason(s) for visit, procedures and other instructions based on clinical discussions that took place during the office visit, any updates to a problem list, immunizations or medications administered during visit, summary of topics covered/considered during visit, time and location of next appointment/testing if scheduled, or a recommended appointment time if not scheduled, list of other appointments and tests that the patient needs to schedule with contact information, recommended patient decision aids, laboratory and other diagnostic test orders, test/laboratory results (if received before 24 hours after visit), and symptoms.

The EP must include all of the above that can be populated into the clinical summary by certified EHR technology. If the EP’s certified EHR technology cannot populate all of the above fields, then at a minimum the EP must provide in a clinical summary the data elements for which all EHR technology is certified for the purposes of this program (according to 170.304(h)):

• Problem List
• Diagnostic Test Results
• Medication List
• Medication Allergy List

Q: How and when are incentive payments made?

A: After the online attestation is made (attestation thresholds must be attained), provider information is verified, then in 6 to 8 weeks a payment is generated. Payments are made in whatever way the entity typically gets CMS payments.

Q: What if patients do not routinely receive prescriptions during an office visit? How can the threshold be met? (Referring to computerized provider order entry (CPOE) for medication orders.)

A: For attestation, practices need to do this for 30% or more of all unique patients with at least one medication in their medication list. Note that patients with no medications in their medication list are excluded, so CMS believes this core initiative is realistic.

Q: For the Medicaid program, do you count the patient visit or the number of services (e.g. patient visit plus two tests equals three patient ticks) during the visit?

A: This question needs follow-up and if you send an email to editor@physicianspractice.com, they will be sent to CMS for the answer. Here is additional information from the CMS FAQ:

When calculating Medicaid patient volume or needy patient volume for the Medicaid EHR Incentive Program, are eligible professionals (EPs) required to use visits, or unique patients?

There are multiple definitions of encounter in terms of how it applies to the various requirements for patient volume.Generally stated, a patient encounter is any one day where Medicaid paid for all or part of the service or Medicaid paid the co-pays, cost-sharing, or premiums for the service.The requirements differ for EPs and hospitals.In general, the same concept applies to needy individuals.Please contact your State Medicaid agency for more information on which types of encounters qualify as Medicaid/needy individual patient volume.

Q: We are a new practice and plan on getting an EMR in the next 3 months. Can you walk me through the time lines?

A: If you haven’t chosen an EMR yet, your first year in either program will probably be 2012. In the first year of Medicare participation, you will need to use the EMR meaningfully for 90 days during calendar year 2012, and you have up to 60 days after the close of the calendar year to attest to your use. In the first year of Medicaid participation, you will need to adopt (acquire, install), implement (commence utilization of EHR such as train, data entry), or upgrade (expand) a certified EHR and attest to your activity at any time during the calendar year.

Q: What validation or oversight will CMS provide for the attestation process?

A: Before any payment is made, checks of provider eligibility and information will be done. Keep in mind that attestation is a legal process. Random audits will be put in place in the near future.

Q: Should a practice register if we don’t know which program we are going to use?

A: You can register at any time, and you can change from one program to the other prior to attesting, so you can register for one program and change before you begin the attestation.

Q: If your first year of attestation is in 2012, can you get the full 44K over the course of the program?

A: Yes.

Q: Can you verify if Physician Assistants are eligible for one of the programs?

A: Physician Assistants (PAs) are only eligible under the Medicaid program and must be the lead provider for a Federally Qualified Health Center (FQHC) or Rural Health Clinic (RHC) to qualify.

Q: Does a radiology practice have to provide a clinical summary for patients?

A: No practice type is excluded from clinical summary mandate. CMS has not heard of any practice type having a problem with this so far. Remember, to achieve meaningful use, you must provide clinical summaries to patients for more than 50 percent of office visits within three business days. Exclusion: Any EP who has no office visits during the period of EHR reporting.

Q: Is the problem list supposed to be related to the chief compliant of the office visit?

A: Not necessarily. Practices are required to maintain an up-to-date problem list of current and active diagnoses based on ICD-9-CM or SNOMED CT (Systematized Nomenclature of Medicine – Clinical Terms) codes. To comply, at least 80 percent of all unique patients seen by eligible providers must have at least one entry (or an indication of none) recorded as structured data.

Q: What if questions were not able to be answered during the webinar?

A: Please e-mail Physicians Practice and well get your answers from CMS. This could take several days, so please be patient. We will post your answers and all post-webinar questions at http://www.physicianspractice.com and notify you via e-mail as well.

Resources

A great list of additional resources were provided by Robert Anthony and Physicians Practice:

Resources from CMS

• EHR Incentive Programs website
• ONC website
• FAQs
• Listserv
• Meaningful Use Specification Sheets
• EHR Information Center
• Registration & Attestation User Guides
• EHR Hotline: 888-734-6433 / -6563 (TTY)

Resources from PhysiciansPractice.com

• Topic Resource Centers
  • EHR
  • Meaningful Use
• Tools
  • Are You Ready? Quiz
  • Pricing Worksheet
  • Preparation Checklist
  • Meaningful Use Stage 1 Crib Sheet
• You can also listen to an archived video of today’s webinar here.

Other Posts I have written on this topic:

Step by Step Directions for Getting the EHR Incentive Money: My Notes From Last Weeks CMS Call

CMS Holds National Provider Calls for the Medicare EHR Incentive Program and EHR Attestation Q & A

Digging Into the Details of Certified EMR & Tips For Buying an EMR

How Do You Get That Stimulus Money for Using an Electronic Medical Record? (You Register!)

How My Practice Knew We Were Ready for EMR

10 Ways to Get More Out of Your PM, EMR or Any Medical Software

First the facts on what has taken place so far in the 2011 EHR Incentive Programs.

• As of June 30th, the total of Medicare EHR Incentive Program payments is over $94 million.
• As of June 30th, over $166 million has been paid in Medicaid EHR incentives since the program began in January. In May and June, four states launched Medicaid EHRIncentive Programs – Indiana, Ohio, Pennsylvania, and Washington, bringing the total states with Medicaid EHR Incentive Programs to 21. More states will launch in July.
• There are 68,001 active registrations of eligible professionals and eligible hospitals for the Medicare and Medicaid EHR Incentive Programs.

If your group hasn’t received a check and hasn’t registered for the Medicare or Medicaid Incentive Program, then this blog post is for you! For anyone who is really just beginning their EHR journey, today’s presentation clarified previous information given by CMS, as well as giving listeners new information about the programs.

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Most managers long for the end of paper charts and the day when all of our data is at our fingertips. Lost charts waste so much time and effort in the practice that an EMR seems destined to offer major improvements in efficiency. But getting converted from paper charts to EMR can be a rocky road, with one of the biggest obstacles being scanning current patient paper charts.

There is no single accepted best practice for scanning charts into an EMR, as a conversion game plan must be specific to each individual practice and coordinated with the new record’s training and go-live.

Every group has to decide which date range and type of charts to scan prior to go live, and additionally which data points will need to be preloaded (or sometimes called “back-loaded”).

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Note: See my latest post on registering and attesting for the EHR Incentive Program here.

CMS has announced two national calls for attestation.

Tue May 3, 2-3:30pm ET (for Eligible Hospitals)

Thu May 5, 1:30-3pm ET (for Eligible Professionals)

CMS is holding conference calls for eligible professionals (EPs), eligible hospitals, and critical access hospitals (CAHs) participating in the Medicare Electronic Health Record (EHR) Incentive Program to provide information on the attestation process. Mark your calendars for one of the calls below.

What the Calls Will Cover

Instructions on How to Register for a Call
To register for these calls, take the following steps:

Prior to each call, presentation materials will be available in the Upcoming Events section of the Spotlight Page on the CMS EHR website.

Registration closes when all available space has been filled, or 24 hours before each call; no exceptions will be made, so please register early.

How will I attest for the Medicare and Medicaid Incentive Programs?

Medicare eligible professionals, eligible hospitals and critical access hospitals will have to demonstrate meaningful use through CMS’ web-based Registration and Attestation System. In the Medicare & Medicaid EHR Incentive Program Registration and Attestation System, providers will fill in numerators and denominators for the meaningful use objectives and clinical quality measures, indicate if they qualify for exclusions to specific objectives, and legally attest that they have successfully demonstrated meaningful use. A complete EHR system will provide a report of the numerators, denominators and other information. Then you will need to enter that data into our online Attestation System. Providers will qualify for a Medicare EHR incentive payment upon completing a successful online submission through the Attestation Systemimmediately after you submit your results you will see a summary of your attestation, and whether or not it was successful. The Attestation System for the Medicare EHR Incentive Program will open on April 18, 2011.

For the Medicaid EHR Incentive Program, providers will follow a similar process using their state’s Attestation System. Check here to see states’ scheduled launch dates for their Medicaid EHR Incentive Programs.

Do you have questions about the EHR Incentive Programs? Do you want to find out if you are eligible, how much of an incentive payment you can earn, and learn more details about the program and what you need to do to qualify?

• Visit the Path to Payment page for a program overview
• Visit the Meaningful Use page

When can I attest?

To attest for the Medicare EHR Incentive Program in your first year of participation, you will need to have met meaningful use for a consecutive 90-day reporting period. If your initial attestation fails, you can select a different 90-day reporting period that may partially overlap with a previously reported 90-day period. To attest for the Medicare EHR Incentive Program in subsequent years, you will need to have met meaningful use for a full year. Please note the reporting period for eligible professionals must fall within the calendar year, while the reporting period for eligible hospitals and critical access hospitals must fall during the Federal fiscal year.

April 18, 2011, is the earliest an eligible professional, eligible hospital or critical access hospital can attest that they have demonstrated meaningful use of certified EHR technology under the Medicare EHR Incentive Program.

Under the Medicaid EHR Incentive Program, providers can attest that they have adopted, implemented or upgraded certified EHR technology in their first year of participation to receive an incentive payment.Medicaid EHR Incentive Program participants should check with their state to find out when they can begin participation.

What can I do now to prepare for attestation?

Visit the Registration page and get registered for the EHR Incentive Programs right now. If you haven’t previously registered, you can complete the registration and attestation process at the same time.

Also, review the Attestation User Guides, which provide step-by-step instructions for login and completing attestation. You can find separate Attestation User Guides for eligible professionals and eligible hospitals in the Resources section below.

Finally, you can enter your information in our Meaningful Use Attestation Calculator prior to submitting your attestation to see if you would be able to meet all of the necessary measures to successfully demonstrate meaningful use and qualify for an EHR incentive payment.

What will I need to login to the Attestation System?

If you are an eligible professional, you’ll need:

• Your Type 1 National Provider Identifier (NPI)
• The same user ID and password you used to register

If you are working on behalf of an eligible hospital or critical access hospital, you’ll need:

• An active National Provider Identifier (NPI)
• The same user ID and password you used to register
• An EHR Certification Number from Office of the National Coordinator
• If you did not register the facility, you’ll need an Identity and Access Management system (I&A) Web user account (User ID/Password) and be associated to the organization NPI, if you’re a user working on behalf of an eligible hospital or critical access hospital. Create a login in the I&A System if you’re working on behalf of an eligible hospital or Critical Access Hospital and don’t have an I&A web user account.

What is the CMS EHR Certification Number?

During attestation, CMS requires each eligible professional, eligible hospital and critical access hospital to provide a CMS EHR Certification ID or Number that identifies the certified EHR technology being used to demonstrate meaningful use. This unique CMS EHR Certification ID or Number can be obtained by entering the certified EHR technology product information at the Certified Health IT Product List (CHPL) on the ONC website here.

NOTE: The ONC CHPL Product Number issued to your vendor for each certified technology is different than the CMS EHR Certification ID. Only a CMS EHR Certification ID obtained through the CHPL will be accepted at attestation.

Eligible professionals, eligible hospitals and critical access hospitals can obtain a CMS EHR Certification ID or Number by following these steps:

1. Go to the ONC CHPL website.
2. Select your practice type by selecting the Ambulatory or Inpatient buttons.
3. Search for EHR Products by browsing all products, searching by product name or searching by criteria met.
4. Add product(s) to your cart to determine if your product(s) meet 100% of the CMS required criteria.
5. Request a CMS EHR Certification ID for CMS attestation.NOTE: The “Get CMS EHR Certification ID” button will not be activated until the products in your cart meet 100% of the CMS required criteria. If the EHR product(s) do not meet 100% of the CMS required criteria to demonstrate Meaningful Use, a CMS EHR Certification ID will not be issued.
6. The CMS EHR Certification ID contains 15 alphanumeric characters.

I’m an Eligible Professional (EP). Can I designate a third party to register and/or attest on my behalf?

In April 2011, CMS implemented functionality that allows an EP to designate a third party to register and attest on his or her behalf. To do so, users working on behalf of an EP must have an Identity and Access Management System (I&A) web user account (User ID/Password), and be associated to the EP’s NPI. If you are working on behalf of an EP(s), and do not have an I&A web user account, please visit I&A Security Check to create one. States will not necessarily offer the same functionality for attestation in the Medicaid EHR Incentive Program. Check with your State to see what functionality will be offered.

When will I get paid?

Incentive payments for the Medicare EHR Incentive Program will be made approximately four to six weeks after an eligible professional, eligible hospital or critical access hospital meets the program requirements and successfully attests they have demonstrated meaningful use of certified EHR technology. CMS expects that Medicare incentive payments will begin in May 2011. Payments will be held for eligible professionals until the eligible professional meets the $24,000 threshold in allowed charges.

Eligible hospitals and critical access hospitals attesting in April 2011 could receive their initial payments as early as May 2011. Final payment will be determined at the time of settling the hospital Medicare cost report.

Medicaid incentives will be paid by the states and are expected also to begin in 2011. States are required to issue incentive payments within 45 days of providers successfully attesting to having adopted, implemented or upgraded certified EHR technology during their first year of participation in the Medicaid EHR Incentive Program. Launch date for the Medicaid EHR Incentive Program varies by state, so the earliest date attestation can begin also varies by state. Several states have disbursed incentive payments as early as April 2011.

How will I get paid?

Payments to Medicare providers will be made to the taxpayer identification number (TIN) you selected at the time you registered for the Medicare EHR Incentive Program.

CMS will deposit payment in the first bank account on file. It will appear on your bank statement as “EHR Incentive Payment”

If you receive payments for Medicare services via electronic funds transfer, you will receive Medicare EHR Incentive Program payment the same way. If you currently receive Medicare payments by paper check, you will also receive your first Medicare EHR Incentive Program payment by paper check.

IMPORTANT: Medicare Administrative Contractors (MACs), carriers and fiscal intermediaries will not be making these payments. CMS has contracted with a Payment File Development Contractor to make these payments.

Have questions about your EHR incentive payment?

DON’T: Call your MAC/carrier/fiscal intermediary with questions

DO: Call the EHR Information Center

1-888-734-6433. TTY users should call 1-888-734-6563

Hours of Operation: 7:30 a.m. 6:30 p.m. (Central Time) Monday through Friday, except federal holidays

Why the payment amount may be less than you thought: The Medicare & Medicaid EHR Incentive Program Registration and Attestation System contains a Status tab at the top which will contain the amount of the incentive payment, the amount of tax or nontax offsets applied, and the remittance advice reason code containing the reason for any reduction.

For those receiving paper checks, there will be a tear-off pay stub which identifies offsets made to the incentive payment.

Where you can find more information about the offsets: For more information about tax offsets, call the Internal Revenue Service (IRS) at 1-800-829-3903.

For more information about non tax offsets, call the Department of the Treasury, Financial Management Service (FMS) at 1-800-304-3107.

Will CMS conduct audits?

Any provider attesting to receive an EHR incentive payment for either the Medicare EHR Incentive Program or the Medicaid EHR Incentive Program potentially may be subject to an audit. Here’s what you need to know to make sure you’re prepared:

Overview of the CMS EHR Incentive Programs Audits

• All providers attesting to receive an EHR incentive payment for either Medicare or Medicaid EHR Incentive Programs should retain ALL relevant supporting documentation (in either paper or electronic format used in the completion of the Attestation Module responses). Documentation to support the attestation should be retained for six years post-attestation. Documentation to support payment calculations (such as cost report data) should continue to follow the current documentation retention processes.
• CMS, and its contractors, will perform audits on Medicare and dually-eligible (Medicare and Medicaid) providers.
• States, and their contractors, will perform audits on Medicaid providers.
• CMS and states will also manage appeals processes.

Preparing for an Audit

• To ensure you are prepared for a potential audit, save the supporting electronic or paper documentation that support your attestation. Also save the documentation to support your Clinical Quality Measures (CQMs). Hospitals should also maintain documentation to support their payment calculations.
• Upon audit, the documentation will be used to validate that the provided accurately attested and submitted CQMs, as well as to verify that the incentive payment was accurate.

Details of the Audits

• There are numerous pre-payment edit checks built into the EHR Incentive Programs’ systems to detect inaccuracies in eligibility, reporting and payment.
• Post-payment audits will also be completed during the course of the EHR Incentive Programs.
• If, based on an audit, a provider is found to not be eligible for an EHR incentive payment, the payment will be recouped.
• CMS will be implementing an appeals process for eligible professionals, eligible hospitals and critical access hospitals that participate in the Medicare EHR Incentive Program. More information about this process will be posted to the CMS Web site soon.
• States will implement appeals processes for the Medicaid EHR Incentive Program. For more information about these appeals, please contact your State Medicaid Agency.

Where can I find user guides and other resources?

Below are step-by-step Attestation User Guides to help you attest for the Medicare EHR Incentive Program. You can also use our Attestation Worksheet, Meaningful Use Attestation Calculator, and educational webinar to help you prepare for and complete the attestation process:

• Attestation User Guide for Eligible Hospitals
• Attestation User Guide for Medicare Eligible Professionals
• Meaningful Use Attestation Calculator (version 1)
• Electronic Specifications for clinical quality measures (CQM)

The Electronic Health Record (EHR) Information Center is open to assist the EHR Provider Community with inquiries.

1-888-734-6433. TTY users should call 1-888-734-6563.

EHR Information Center Hours of Operation: 7:30 a.m. 6:30 p.m. (Central Time) Monday through Friday, except federal holidays.

Should I consider ePrescribing in 2011 if I’m not ready to install an EMR? 

• In 2012 eligible professionals who are not successful eprescribers, based on claims submitted between January 1, 2011 June 30, 2011, may be subject to a “payment adjustment” (read payment cut) in their Medicare Part B Physician Fee Schedule (PFS) for covered professional services.
• Those that dont eprescribe as a part of 10 Medicare patient encounters by June 30, 2011 will only receive 99% of their Medicare payment for all encounters in 2012.
• Those that don’t ePrescribe as a part of 25 encounters by December 31, 2011, will only receive 98.5% of their Medicare payments for all encounters in 2013 and only 98% of their Medicare payments for encounters during 2014 and going forward.
• The payment adjustment does not apply if <10% of an eligible professionals (or group practices) allowed charges for the January 1, 2011 through June 30, 2011 reporting period are comprised of codes in the denominator of the 2011 eRx measure.

The DENOMINATOR is the visit code that is eligible for an eprescribing code (see list below.)

Patient visit during the reporting period (CPT or HCPCS): 90801, 90802, 90804, 90805, 90806, 90807, 90808, 90809, 90862, 92002, 92004, 92012, 92014, 96150, 96151, 96152, 99201, 99202, 99203, 99204, 99205, 99211, 99212, 99213, 99214, 99215, 99304, 99305, 99306, 99307, 99308, 99309, 99310, 99315, 99316, 99324, 99325, 99326, 99327, 99328, 99334, 99335, 99336, 99337, 99341, 99342, 99343, 99344, 99345, 99347, 99348, 99349, 99350, G0101, G0108, G0109

The NUMERATOR is a prescription generated and transmitted via a qualified eRx system and reported using a quality data code.

G8553: At least one prescription created during the encounter was generated and transmitted electronically using a qualified eRx system (reported via claims, a registry, or an EHR.)

Please note that earning an eRx incentive for 2011 will NOT necessarily exempt an eligible professional or group practice from the payment adjustment in 2012.

How to Avoid the 2012 Payment Adjustment

An eligible professional can avoid losing 1% in 2012 if (s)he:

• Is not a physician (MD, DO, or podiatrist), nurse practitioner, or physician assistant as of June 30, 2011 based on primary taxonomy code in NPPES,
• Does not have prescribing privileges. (S)he must report (G8644) at least one time on an eligible claim prior to June 30, 2011;
• Does not have at least 100 cases containing an encounter code in the measure denominator;
• Becomes a successful e-prescriber; and
• Reports the eRx measure for at least 10 unique eRx events for patients in the denominator of the measure.

Exemptions from the Medicare Payment Adjustment in 2012

• An (EP) eligible professional or selected group practice may request an exemption from the eRx Incentive Program and from the payment adjustment based upon a significant hardship.
• The qualifying circumstances are based upon two hardship codes that need reported on at least one claim prior to June 30, 2011 should one of the following situations apply:

G8642 - The eligible professional practices in a rural area without sufficient high speed internet access and requests a hardship exemption from the application of the payment adjustment under section 1848(a)(5)(A) of the Social Security Act.

G8643 - The eligible professional practices in an area without sufficient available pharmacies for electronic prescribing and requests a hardship exemption from the application of the payment adjustment under
section 1848(a)(5)(A) of the Social Security Act

To Recap:

1. Each Physician or practice that does not currently ePrescribe should consider whether or not ePrescribing is worthwhile. (Note: For group practices participating in eRx GPRO I or GPRO II during 2011, the group practice MUST become a successful e-prescriber. Depending on the groups size, the group practice must report the eRx measure for 75-2,500 unique eRx events for patients in the denominator of the measure. Check out the Group Practice Reporting Option here.)
2. In estimating the value of ePrescribing, the practice manager must consider on one hand the expense (which there is, even for free standalone eRx systems) surrounding the implementation of ePrescribing, and the potential income from the ePrescribing Incentive.
3. The practice must also determine if an EMR is in their future, and if so, if the installation will take place soon enough to report the 10 encounters with Medicare patients.
4. Individual eligible professionals (EPs) may choose to participate in either the PQRI, eRx, or both. PQRI and eRx are separate incentive programs.
5. If an eligible professional (EP) earns an incentive under the Medicare EHR Incentive Program, he or she cannot receive an incentive payment under the eRx Incentive Program in the same program year, and vice versa. However, if an EP earns an incentive under the Medicaid EHR Incentive Program, he or she can receive an incentive payment under the eRx Incentive Program in the same program year.
6. Eligible professionals must have adopted a “qualified” eRx system. There are two types of systems: a system for eRx only (stand-alone) or an electronic health record (EHR system) with eRx functionality. Regardless of the type of system used, to be considered “qualified” it must be based on ALL of the following capabilities:
   • Generating a complete active medication list incorporating electronic data received from applicable pharmacies and benefit managers (PBMs) if available.
   • Providing information related to lower cost, therapeutically appropriate alternatives (if any). Selecting medications, printing prescriptions, electronically transmitting prescriptions, and conducting all alerts.
   • Providing information on formulary or tiered formulary medications, patient eligibility, and authorization requirements received electronically from the patient’s drug plan, if available.

For a list of qualified registries and qualified EHR vendors and products, click here.

An excellent article, Choosing the Right E-prescribing Application: Should you buy a standalone app or an EHR-integrated module? was published in January 2011 by Physicians Practice here.

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