The American Recovery & Reinvestment Act of 2009 (ARRA) authorized Medicare to distribute $19 billion in incentive payments to eligible professionals (physicians and hospitals) who are successful in meeting the requirements of "Meaningful Use" of "certified EHR technology" (an Electronic Health Record).  Starting in 2015, providers are expected to have adopted and be actively utilizing an EHR in compliance with the "Meaningful Use" definition or they will be subject to financial penalties under Medicare.

Based on the "Meaningful Use" assessments that The Huntzinger Management Group (HMG) has completed for several providers and a review of multiple studies on Meaningful Use Readiness, HMG believes that better understanding of the key components of the HITECH Stimulus Package (Meaningful Use Guidelines, Definitions, Incentives, and Timelines) is needed to dispel any misinformation or misinterpretation of the package.  We have provided this article for your consideration and review.  To learn more about the key components of Meaningful Use requirements and other facts, please read on.

Introduction: Dollars and Timing

Dollars

The American Recovery & Reinvestment Act of 2009 (ARRA) authorized a total of 147.7 billion of available funds.  As seen in the chart below, $19 billion is headed to eligible healthcare professionals (physicians and hospitals) who are successful in meeting the requirements of "Meaningful Use" of "certified EHR technology" beginning at the end of 2010 and gradually phasing down. 

To be eligible for the incentive payments, physicians and hospitals must use the technology in a meaningful manner.  This includes exchanging electronic health information to improve the quality of care and submitting clinical quality and other measurements, as recently submitted by the Secretary of Health & Human Services (HHS) in January 2010 (See Appendix). 

Timing

Although the final version of the Meaningful Use Matrix was published August 2009, the comprehensive recommendations of Meaningful Use were just released in early January 2010.  A 30-day comment period begins in mid-January with final approval expected in June 2010.

Key Meaningful Use Objectives by Year

As seen in the graph below, 2011 is about the "capture" of information.  By 2013, the guidelines are looking for the "processes and support" that will improve care and the "achievement of improved care" in 2015 and beyond. 

2011

• Use computerized physician order entry for all order types, including medications.
• Incorporate laboratory tests into EHRs and share results electronically with public health agencies.
• Generate lists of patients by specific condition to use for quality improvement.
• Provide clinical summaries for patients after each encounter.
• Exchange key clinical information among health professionals (problems, medications, allergies, test results, etc.).
• Generate and transmit prescriptions electronically (physicians).

2013

• Manage chronic conditions using patient lists and decision support tools.
• Use bar coding for medication administration.
• Offer secure patient-physician messaging capability.
• Record patient preferences in EHR.
• Evidence-based clinical content in practice.

2015

• Achieve minimal levels of performance on quality, safety and efficiency measures.
• Give patients access to self-management tools.
• Access comprehensive patient data from all available sources.
• Conduct automated real-time surveillance on occurrences such as adverse events, disease outbreaks and bioterrorism.
• Incorporate clinical dashboards into EHR.
  
  
  

Meaningful Use Incentives and Formulas: Hospitals and Physicians

Hospitals

The Recovery Act establishes financial incentives beginning in October 2010 for eligible hospitals and critical access hospitals (CAHs) that are Meaningful EHR Users.  Hospitals can receive incentives over a four-year period when they can demonstrate the following:

• Utilize a functional EHR certified by the Certification Commission for Healthcare Information Technology (CCHIT).
  
  
• Utilize Electronic exchange of standardized patient data with clinical and administrative organizations using the Healthcare Information Technology Standards Panel's (HITSP) interoperability specifications and integrating the Healthcare Enterprise's (IHE) frameworks.
  
  
• Utilize clinical decision support (CDS) tools and providing clinicians with clinical knowledge and intelligently-filtered patient information to enhance patient care.
  
  
• Ability to support process and care measurements that drive improvements in patient safety, quality outcomes, and cost reductions.
  
  

Hospitals can receive incentives based upon the following calculation:

1. Start with base amount = $2 million
   
   
2. Add discharge related amount = $200/ for each discharge day over 1,150 and up to a maximum 23,000 annually
   
   
3. Calculate Medicare share = Parts A & C inpatient days/total inpatient days minus charity care charges
   
   
4. Apply transition factor = Decrements 25%/year (100%, 75%, 50%, 25%)
   

Hospital Formula = [[(base amount + discharge related amount) x Medicare share] x transition factor]

Physicians

In January 2011, eligible professionals (EPs) can receive Recovery Act funds over a five-year period when they can demonstrate the following:

• Utilize an EHR certified by the Certification Commission for Healthcare Information Technology (CCHIT).
  
  
• Ability to electronically exchange standardized patient summary data with clinical and administrative organizations.
  
  
• Utilize the practice of electronic prescribing.
  
  
• Report quality and patient safety data.
  
  

Physicians can receive up to $44,000 (five-year total) based up on the following:

• Medicare Maximum (early adopters 2011-2012)

               Year 1               -               $18,000
               Year 2               -               $12,000
               Year 3               -               $8,000
               Year 4               -               $4,000
               Year 5               -               $2,000
               ___________________________
               TOTAL               -               $44,000

• Potential 10% increase if in EP practices in an HPSA
  
  
• Cap - 75% allowed charges provided by EP during the year
  
  
  

Medicaid

Certain classes of Medicaid professionals and hospitals are eligible for incentive payments to encourage the adoption and use of certified EHR technology.  To be eligible for incentive payments not associated with the initial adoption/implementation/upgrade of EHR technology, the provider must demonstrate Meaningful Use of the EHR technology through a means approved by the state and acceptable to the secretary.   Eligible professionals must meet minimum Medicaid patient volume percentages and must waive rights to duplicate Medicare EHR incentive payments.   Incentive payments are available for no more than a six-year period, and EPs may not receive an incentive under both Medicare and Medicaid in a given year. 

Summary

The Huntzinger Management Group certainly hopes you have benefited in some way from this summary.  If you are interested in learning more about HMG's Meaningful Use Assessment and what we can do for your organization, please contact us at 678-249-5146 or bkitts@huntzingergroup.com, and one of the principals of our firm will be happy to work directly with you.

For general information about The Huntzinger Management Group and our services, we invite you to visit http://www.huntzingergroup.com/

APPENDIX:  Meaningful Use & Acronym Definitions

Meaningful Use Definition

In early January 2010, ONCHIT released the regulations that define "Meaningful Use."  The incentive rule contains specifics regarding percentages of orders, payment schedules and measures.

Stage 1 specifications take effect in 2011 and fall into four (4) major categories: Vocabulary, Content Exchange, Transport and Privacy & Security.

The following is a high-level summary of the key Meaningful Use requirements recently released by ONCHIT in January 2010:

• CPOE (Computerized Physician Order Entry)
• Physicians:
• CPOE for orders involving medications, laboratory, radiology and referrals
• 80% of total orders must be entered directly by clinician
• Hospitals:
• CPOE for orders involving medications, laboratory, radiology, blood bank, PT, OT, RT, rehab, dialysis, consults, discharge and transfer
• 10% of all orders entered via CPOE
• Clinical Checking of Orders
• Real-time screening (drug-to-drug interactions, etc.), formulary check, track user responses
• Problem List
• Longitudinal current and active diagnoses coded (ICD-9-CM or SNOMED CT)
• 80% of unique patients must have at least one (1) coded problem/diagnosis
• e-Prescribing
• 75% of non-controlled substance prescriptions electronically (physicians only)
• Active Medication List
• 80% of unique patients must have at least one (1) coded entry
• Medication Allergy List
• Track longitudinal allergy history
• 80% of unique patients must have at least one (1) coded entry
  
• Demographics
• Physicians:
• Preferred language, insurance type, gender, ethnicity and Date of Birth (DOB)
• Hospitals:
• Same as physicians plus Cause of Death, if applicable
• 80% of patients must have demographics recorded as structured data
• Vital Signs
• Height, weight, BP, BMI, growth charts for patients 2-20 years old, temperature, pulse
• 80% of patients 2 and over must have BP and BMI entered
• Children 2-20 must have a growth chart
• Smoking Status
• Current smoker, former smoker, never smoked
• 80% of patients must be recorded
• Structured Lab Results
• Display results, translate LOINC codes, allow maintenance based on new results
• 50% of all results must be recorded as structured data delivered in positive/negative format
• Patient Lists
• Allow users to select, sort, retrieve and output patient lists based on demographics, medications, and conditions
• Report Quality Measures to CMS and States
• Calculate, display and submit quality measure results
• Patient Reminders
• Reminders based upon patient preferences, demographics, conditions and medication list (physicians only)
• Five (5) Clinical Decision Support Rules
• Beyond drug screening, based upon demographics:
• Diagnoses
• Lab Results
• Medication List
• Real-time alerts and suggestions based upon medical evidence
• Track response to alerts
• Eligibility
• Allow user to record and display based upon eligibility from payer
• 80% of all claims must be submitted electronically
• Electronic Claims
• 80% of all claims must be submitted electronically
• Electronic Copy of Health Information to Patients
• Physicians:
• Allow users to create an electronic copy of test results, problem list, medication list, medication allergy list, immunizations and procedures
• Hospitals:
• Same as physicians and Discharge Summary
• Must be able to provide electronic copy within 48 hours of request
• Electronic Copy of Discharge Information (hospitals only)
• 80% of discharged patients who request electronic discharge information
• Timely Patient Access to Health Information (physicians only)
• Within 96 hours of availability provide diagnostic results, problem list, medication list, medication allergy list, immunizations and procedures
• 10% of unique id patients
• Clinical Summary of Each Visit (physicians only)
• Provide diagnostic results, medication list, procedures, problem list and immunizations
• 80% of all office visits
• Information Exchange
• Enable the sending and receiving of:
• Physicians:
• Diagnostic test results, problem list, medication list, medication allergy list, immunizations and procedures
• Hospitals:
• Same as physicians and Discharge Summary
• Must conduct at least one (1) test of exchanging information
• Medication Reconciliation
• Compare and merge two (2) or more medication lists into a single list to display in real-time
• 80% of all encounters and care transitions
• Submit Data to Immunization Registries
• Must conduct at least one (1) test of submitting information
• Submit Lab Results to Public Health Agencies (hospitals only)
• Must conduct at least one (1) test of submitting information
• Submit Syndrome Surveillance Data to Public Health Agencies
• Must conduct at least one (1) test of submitting information
• Protect Electronic Patient Information
• Track unique identifiers of users
• Emergency access for authorized users
• Session timeout
• Encryption where preferred
• Encryption mandatory when exchanging information
• Maintain audit logs
• Provide integrity check for recipient of electronically transmitted information
• Verify user identities and access privileges
• Record PHI disclosures
• Conduct security risk analysis
• Implement security updates
  
  
  

•·        Acronyms Definitions

ONC
Office of the National Coordinator for Health Information Technology

• Support the adoption of health information technology & the promotion of nationwide health information exchange to improve health care
  

ONCHIT
Office of the National Coordinator for Health Information Technology

• Controls HIT policy and Standards Committees
• Responsible for creating a nationwide health information technology infrastructure aimed at improving health care quality and care coordination

HIPAA & OCR
Office for Civil Rights

• Together protect fundamental rights of nondiscrimination and health information privacy
  

CCHIT
Certification Commission for Health Information Technology

• Organization recognized as certification body for electronic health records
  
  

HITECH
Health Information Technology for Economic and Clinical Health Act

Eligible Professional is defined in the following ways:

Medicare
A physician as defined in section 181(r) of the Social Security Act*, which includes the following five types of professionals:

• Doctor of medicine or osteopathy
• Doctor of dental surgery or medicine
• Doctor of podiatric medicine
• Doctor of optometry
• Chiropractor
  
  
  

Medicaid

• Physicians
• Dentists
• Certified nurse-midwives
• Nurse practitioners
• Physician assistants who are practicing in Federally Qualified Health Centers (FQHCs) or Rural Health Clinics (RHCs) led by a physician assistant.
  
  
  

 Covered Entity

• Health care provider that conducts certain transactions in electronic form
• Health care clearinghouse
• Health plan
  
  
  
  

*An entity that is one or more of these types of entities is referred to as a "covered entity" in the Administrative Simplification regulations.

http://www.cms.hhs.gov/HIPAAGenInfo/Downloads/CoveredEntitycharts.pdf