The federal government’s “meaningful use” program for electronic health records is now in full swing with more than $400 million in incentives already awarded to physicians (eligible providers or EPs) and hospitals through the Medicare and Medicaid programs.
Despite extensive media coverage about the program, many physicians and healthcare executives remain uncertain about the details of the program. The situation is particularly confusing for ambulatory surgery centers (ASCs), which the government has placed in a separate category from hospitals and making them currently ineligible to qualify for the incentive payments.
Here are the key points surgeons need to know about meaningful use:
• ASCs do not currently qualify as “eligible hospitals” and thus can’t collect stimulus payments as organizations;
• Surgeons are eligible professionals (EPs) and can count their ASC cases toward earning their own meaningful use awards;
• For EPs to qualify for MU incentives they need to use an EHR certified for meaningful use;
• In 2015, the incentives turn into penalties, with physicians who are not meaningful users of EHRs facing Medicare penalties.
The meaningful use incentive program was officially launched on Jan. 1, 2011 and will continue through 2015. Individual physicians can potentially receive up to $44,000 in incentive payments available from Medicare and up to $66,000 from Medicaid during this period. Physicians must choose which program to participate in; they can’t get payments from both.
Under current CMS rules, 50 percent of a physician’s patient encounters during the EHR reporting period must be at one or more practices that are equipped with meaningful use certified system. This allows EPs to participate in the program even if they work at multiple locations with varying levels of meaningful use adoption.
The meaningful use program is just one part of a series of “carrots and sticks” the Center for Medicare and Medicaid Services (CMS) is using to promote EHR usage. For example, new e-prescribing requirements took effect July 1. Physicians who did not report at least 10 electronic prescriptions on Medicare claims during the first six months of 2011 will experience a 1 percent pay cut in 2012 that grows to 2 percent in 2014.
The sticks get bigger. In 2015 physicians who are not meaningful EHR users will begin receiving reduced Medicare reimbursement with cuts increasing each year.
To take advantage of the awards and avoid the penalties, ASC executives can take these four steps.
No. 1: Check EHR for ONC-ATCB Certification
Qualifying for meaningful use starts with implementing a certified EHR. This means the EHR has been tested by an organization designated ONC-ATCB (Office of National Coordinator, Authorized Testing and Certification Body). There are more than 350 certified EHRs across two categories: in-patient (hospital) and ambulatory (physician practices). While ASCs are ineligible for in-patient incentives, surgeons who practice at surgery centers can count those cases in qualifying for their physician payments. This means ASC executives will want to purchase an ambulatory EHR.
There are two categories of ONC-ATCB certification: full and modular. A fully certified EHR enables a practice to earn meaningful use payments without any other software system. An EHR with modular certification is only approved for certain tasks, and a medical group will need to purchase at least one and possibly two or three different modular systems to qualify for meaningful use payments.
The full list of all certified EHRs is available at the official ONC website: http://onc-chpl.force.com/ehrcert .
No. 2: Select an EHR Designed for Surgical Practices
Surgeons working in a busy ASC will face a number of new data collection requirements when qualifying for meaningful use. The data collection issue is less burdensome to primary care physicians, who generally see 15–20 patients per day, many of which are follow-up visits. In contrast, most surgeons working in an ASC will be seeing many first-time patients each day. Thus, collecting the needed information from patients in a timely manner becomes critical.
For example, the meaningful use requirements require providers to collect vital signs on patient visits.
Since ASC medical staff may not have been routinely collecting this information, this may require a workflow change. While vital signs can be collected by nurses or medical assistants, the surgeon will need to document his evaluation of the patient. Thus, surgeons should look for an EHR system that can speed up the data entry process through dictation or click minimization.
No. 3: Ask Patients to Self-Report Demographics
Another meaningful use standard requires practices to collect patient demographics as structured data, including preferred language, gender, race, ethnicity, and date of birth. This is also likely to be a new data collection task for many ASCs.
Patients are used to self-reporting this information in many business situations; it makes sense to have them do this in the waiting room. Many medical offices are finding it makes sense to provide check-in kiosks or tablets to patients.
If your ASC serves many elderly patients, you may want to consider staying with a paper solution. One option is to collect the needed demographic with “bubble-in” or scantron forms that can be fed into optical mark readers, which will then load the data to your EHR system. Before purchasing the forms or optical scanners, check with your EHR to ensure full compatibility.
No. 4: Use a Patient Portal for Clinical Summaries
Under the meaningful use rules, the physician’s office must provide clinical summaries to patients within three business days of the visit. For a busy surgical center, it can be difficult to complete and print out the summary in time to hand it to the patient before she leaves the office. Printing and mailing the summary later (within three days) is an option, but costly and time consuming.
One cost-effective alternative is to install a patient portal, a web-based application that allows patients to interact with their providers. Many, but not all, certified EHRs come with patient portals.
When the practice has installed a patient portal, staff can quickly upload the clinical summary to the web site to be viewed by the patient. Note that the current meaningful use standards do not require that patients read or download this clinical summary; it just needs to be “provided,” generally interpreted as sent electronically.
If you haven’t yet made a decision on an EHR purchase, or if you have a choice of patient portal solutions that work with your EHR, have the vendor demonstrate this process. If it takes six clicks of the mouse to send or upload the patient summary and you see 50 patients a day, that can add an extra 30 minutes of work each day for you or your staff. A more automated solution, allowing easy selection and quick uploading, will make it easier to meet the meaningful use requirements.
Under current rules, acute care hospitals must have EHR systems in place, meeting meaningful use criteria, by the end of 2014 to avoid CMS penalties. While ASCs do not currently face this requirement, it is likely CMS will implement such a rule in the future.
The selection and implementation of an EHR should be viewed in terms of a sound business investment that will generate a positive ROI and improve patient care. While the clock is ticking, there is still plenty of time to plan for EHR implementation in a careful manner. Executives who wait until the last minute may find themselves rushed into hasty decisions and without time for effective training.