Say it once, they hear you. Say it twice, they understand you. Say it three times, they take action. Maybe you're aware of the philosophy that you have to communicate a message at least three times - and perhaps in different ways - in order to create an actionable response. That's precisely what the government is doing regarding meaningful use of electronic health records (EHR), and each time they communicate, they get more specific. So, although I've talked in broader terms about meaningful use, I'm following the government's lead and breaking down what they're saying (the how and the when) to create an actionable response from you - before it's too late to cash in on $44,000. Doctors of chiropractic, start your engines.
Leader of the Pack
The Health and Human Services (HHS) Office of the National Coordinator for Health Information Technology's HIT Policy Committee is in charge of defining the parameters of EHRs qualifying for stimulus plan dollars - up to $44,000, depending on when you adopt the technology. The HIT organization recently sent me a communication that outlines the latest draft of requirements. I don't have the space to inform you of every one of them, but I want to take this opportunity to drill it down. Because the regulations are well-defined, complying should not be difficult. Here's a quick summary:
Stipulations one and three are pretty straightforward, but truly, what the heck is meaningful use? What's meaningful to you might not be meaningful to me and vice versa. But we don't get to define that; the government does. The fact is, if you have the right software partner - one who is aware of the guidelines, automatically and continuously updating your software, and showing you how to use the technology - you should have little concern. Put the responsibility squarely on the shoulders of your vendor. If broad enough, they will shoulder the burden for you.
Another important announcement from the HIT Policy Committee (in August) indicated that the only current certifying body shall be the CCHIT, which will verify whether your EHR meets the standards required by the HIT Policy Committee for the $44,000 incentive payments. Additionally, they will likely blend some of the rules of meaningful use and reporting into certification approval so your EHR can properly assist you in achieving meaningful use.
The Green Flag
Here's an eye opener: If you don't have a meaningfully used qualified EHR in place during the next several months (by the end of first quarter of next year), you may miss up to $18,000 - the first year's eligible payments for 2011. But that's just the first year. Over the following four (through 2015), the HIT Policy Committee will continue to increase its requirements every two years. If you get on board in early 2010, not only will you be eligible for stimulus funds, but you also will have to meet fewer requirements than those who adopt the technology later.
For example, in 2013, the qualifying criteria will likely be doubled from what they were in 2011; by 2015, tripled. Scary? Maybe. But not really for those who are prepared. In the first two years of eligibility (2011 and 2012), a chiropractic physician can receive up to $30,000. It makes sense not only to start your engines, but also to step on the gas and go.
Three-Way Tie for First Place
Although you may not have guessed it, the HIT Policy Committee developed its guidelines for three-way benefit: payers, doctors and patients. Now ultimately, it's the patients who will benefit most from your adopting - and meaningfully using - a qualified EHR, but the benefits for you are obvious, too. Your office will run more efficiently, records will be quicker to access, information will be easier to gather and report; and, then there's the whole matter of the $44,000 incentive.
According to several estimates, the average cost for one medical doctor to introduce an electronic health record system plus hardware is $40,000 to $60,000. The cost for one doctor of chiropractic to purchase true EHR software is $12,000 (plus any hardware you may require). Take that however you'd like, but the fact of the matter is, in our profession, we are poised to not only get fully reimbursed for adopting, but also to have a little pocket change left over for all the hardware and training you would ever need.
You know there is a caveat, however. The longer you wait, the less money you'll get, based on the incentive schedule of payments (which I presented in a previous article). And, if you don't adopt at all, you'll get financially penalized - in the form of lesser Medicare claims reimbursement. Ouch.
What's Under the Hood?
Here's a look at a few of the elements that make up the HIT Policy Committee's upcoming requirements for your EHR. In order to qualify, you must do the following:
- provide access to patient-specific education resources before 2011;
- provide patients with an electronic copy of their health information before 2011;
- incorporate lab-test results into your EHR before 2011;
- send preference-based reminders to patients for preventative/follow-up care before 2011;
- record clinical documentation in your EHR in 2013;
- use evidence-based order sets in 2013; and
- provide clinical decision support at point of care (reminders, alerts, etc.) in 2013.
Many of you may already be taking measures to meet these criteria. If you're not, it's not too late, but you'll want to get off the starting blocks quickly.
Drive With Purpose
Let's go back to the concept of meaningful use. When you're looking at an EHR system, don't buy it just to qualify for stimulus money. Make sure it's interoperable, easy to use and allows you to report on predetermined measures as well as demonstrate meaningful use. Although meaningful use has different definitions from person to person, the HIT Policy Committee's definition is becoming clearer. However, there is still some fine-tuning, and we should expect to see results published by December of this year.
Winning the Race
At this point, it's a race against the clock. Although you don't have to be the first one to reach the checkered flag (adoption, installation, implementation, understanding and meaningful use of a qualified EHR), you do have to reach it without hesitation if you want to qualify for the bigger payouts in the first two years of government incentive payments.
Should that sound overwhelming, take the pressure off. Keeping your software up-to-date in accordance with government guidelines (this includes criteria on federally defined meaningful use) means keeping reimbursements coming over the years. Otherwise, you might qualify for stimulus plan dollars now, but fail to do so through 2015. Some DCs won't qualify at all because their EHR vendor does not have the capacity or infrastructure to meet all of the criteria for development of a true EHR. This becomes even more problematic, as other entities such as Medicare and insurers will likely require the same government certification in the coming years in order to participate in their panels of providers or to participate in reimbursement programs.
I've previously asked, "Why wait?" when it comes to adopting technology. Now, it's not a question of why; that's established - because the federal government is driving the technology (the "what") in order to comply with changing regulations and to achieve cost savings across all avenues of health care. The "when" is also in place - by early 2010, in order to qualify for the first available annual payments totaling up to $44,000 for each doctor (the "where") in your office. The "how" is by choosing the right EHR and support structure to assist you in being the clinic of the future rather than the clinic of the past - to call on experts and partners to help you meet the criteria smoothly, efficiently and effectively. "Who?" That's you.
See you at the finish line.
