As many in the anesthesia community have known for quite some time, it is very difficult for the vast majority of anesthesiologists to meet the requirements for meaningful use under the Medicare EHR Incentive Program and thus, receive an incentive payment of up to $44,000. Some of the Program’s meaningful use criteria simply are not applicable to anesthesia. ASA provides a rundown of the “… many hurdles you face when attempting to become a meaningful user of electronic health records.”2
It’s important to note a few key comments from the ASA Newsletter article “The Meaningful Use Hurdle” written by Grant Couch, Federal Affairs Associate for ASA.
1. “… only 422 anesthesiologists in the entire country have received incentives through the EHR Incentive Program as of June 19, 2012.3 Roughly, this is less than 1 percent of physicians who identify their specialty as anesthesiology.”1
2. “…most anesthesiologists are eligible [professionals] and could be subject to eventual payment reductions that could total 5 percent annually.”2
3. “…anesthesiologists do not have a meaningful set of criteria to participate in the incentives.”2
In its Final Rules on Stage 2, CMS acknowledged anesthesiologists’ difficulty in satisfying the meaningful use criteria by establishing a hardship exception, which would exempt an anesthesiologist from the payment penalty, where achieving meaningful use would result in a hardship for them. Otherwise, the payment penalty would apply to many anesthesiologists, beginning in 2015. In the Final Rules, CMS pointed, in part to, “…lack of face-to-face interactions and need to follow up with patients…” as justifications for the hardship exception. CMS went on to note that “…anesthesiologists do interact with patients, but not in a manner that is conducive to collecting the information needed for many aspects of meaningful use.” 5
If you have not done so, make meaningful use of your time by reading the full ASA article “The Meaningful Use Hurdle” and reviewing the Medicare EHR Incentive Program’s meaningful use criteria for Stage 1 to better understand what it takes to qualify.
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To demonstrate meaningful use and qualify for a Medicare EHR Incentive Program incentive payment, eligible professionals must meet 20 of the 25 meaningful use objectives and report on 6 clinical quality measures.
The 15 core objectives are:
The menu set objectives are:
*When selecting 5 menu objectives (from the 10 listed above), at least one must come from the Public Health list, which are items 1 and 2 on the list above.
In addition to meeting the core and menu objectives, eligible professionals are also required to report on 6 total clinical quality measures, as follows: 3 required core measures (or 3 alternate core measures); and 3 additional measures (selected from a set of 38).
The 3 required core measures** are:
**If the eligible professional’s EHR data indicates a zero for the denominator of one or more of the core clinical quality measures, then they must choose one or more alternate core clinical quality measures from the alternate core measures list.
The 3 alternate core measures are:
The additional clinical quality measures are:
Still looking for more information? Review ASA’s analysis of the applicability and achievability of the Stage 1 requirements for surgical anesthesiologists, available as a PDF download at http://www.asahq.org/~/media/For%20Members/Advocacy/Electronic%20Health%20Records/ASA%20Analysis%20and%20Recommends%20for%20MU%20Requirements.ashx
1 This percentage is derived by taking the 422 anesthesiologists that have received the inventive and divided by the 43,359 physicians that identify their specialty as anesthesiology. Physician Characteristics and Distribution in the US. American Medical Association. 2012.
2 American Society of Anesthesiologists Newsletter. September 2012. Volume 76. Number 9, at pp. 44-45. See online version at: http://viewer.zmags.com/publication/153a4063#/153a4063/46
3 “CMS Medicare and Medicaid EHR Incentive Program, electronic health record products used for attestation” (Updated June 19, 2012 and accessed via data.go on June 28, 2012).
4 Letter from Jerry A. Cohen, M.D. to Marilyn Tavenner, Administrator and Chief Operating Officer – Centers for Medicare and Medicaid Services. May 7, 2012. http://www.asahq.org/~/media/For%20Members/Advocacy/Electronic%20Health%20Records/ASA%20Stage%202%20letter%205%207%2012.ashx
5 77 Federal Register, 53968, at p. 54099 (September 4, 2012). http://www.gpo.gov/fdsys/pkg/FR-2012-09-04/html/2012-21050.htm
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