If you've been following our series of articles on ARRA EHR incentive funding for private practice pediatricians, you'll probably want to learn more about what is required in order to prove “Meaningful Use” of a Certified EHR. This topic is a key piece of the equation for physicians hoping to get their share of the stimulus money. Even for those who aren't, there is a good chance that issues surrounding this discussion will help shape the way we use Health Information Technology to facilitate patient care in the future.
If your practice is considering taking advantage of the ARRA EHR incentives, there are three questions you must address. First, are you eligible? Once you have determined your eligibility, you'll want to know whether you need a Certified EHR. Finally, if you are eligible for funding and you plan to adopt, update or implement a Certified EHR product within the timetable for ARRA funding. You must also must prove you are a Meaningful User of your Electronic Health Record technology. This article will provide some general information about the proposed criteria for proving Meaningful Use and the changes in these criteria that are applicable to private practice pediatricians.
Meaningful Use - A Staged Plan
The objective of the Meaningful Use initiative is to ensure that EHR technology improves the quality of patient care. The program began in 2011 and ends in 2021. There has been much debate over how to measure the quality of patient care. The result is a set of criteria that the Centers for Medicaid & Medicare Services (CMS) says is attainable now. The Final Rule on Meaningful Use was published in the Federal Register on July 28, 2010 and focuses on criteria for the first stage of the program. The Final Rule on Stage 2 was published in the Federal Register September 4, 2012 and will begin in 2014. Standards for Stage 3 are being explored.
The Meaningful Use criteria is organized into 15 "core set" criteria, all of which are required, and 10 "menu set'' criteria, of which 5 are required. A total of 20 criteria must be met in order for a provider to be deemed a meaningful EHR user. The criteria outlined in the Final Rule can be read in the Federal Register Document online. Because the criteria is intended to be used by a wide array of medical offices, the Final Rule and criteria list are quite lengthy. PCC has reviewed the Final Rule and pulled together a shorter list of Meaningful Use Criteria for Pediatricians interested in this program that may help your practice make a decision about participation in this program.
What Does This Mean For Pediatricians?
Pediatric providers will need to display Meaningful Use of a Certified EHR system using criteria established by CMS. Your practice can meet some of the Meaningful Use criteria by simply producing reports from your EHR system. If this sounds too good to be true, that's because, in some cases, it is. Certification and Meaningful Use criteria were developed each with the other in mind, but at this stage, it isn't a perfect fit.
A certified EHR and vendor may not be be able to provide all of the reports you need to prove Meaningful Use. Many systems charge for custom reports. Be wary of additional vendor fees for Meaningful Use reporting and other special reporting your practice might need to meet state requirements that don't apply to physicians participating under the medicare program.
Some Meaningful Use measures are not simple, reportable numbers from your EHR. For example, the performance of security and risk analysis is a task that will take some time to complete and will need to be updated regularly.
Meeting some of these requirements will necessitate significant changes to the processes your practice currently use. Take a look at the requirement to provide clinical summaries for 50% of your patients or the requirement of providing a timely response (within 3 business days) for specific communications, including a request for a copy of medical records. These criteria will present both technical and process challenges for many offices. Review the criteria and capabilities of your Certified EHR carefully to determine if the technology cost and the cost of your time to implement, maintain, and report on new initiatives is worth the incentive being provided.
Assess your risk. How confident are you that your practice will meet all of this criteria? What about special state criteria that pediatricians and other providers qualifying for Medicaid incentives may be required to meet? There is no incentive for meeting the criteria partially. If you miss one benchmark, you will not receive your ARRA funds.
If you're thinking about taking advantage of the ARRA EHR Incentive Program, we encourage you to stay informed on Meaningful Use. To learn more, visit our ARRA funding resources.
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