The Medicare and Medicaid Electronic Health Record (EHR) Incentive Program will provide incentive payments to eligible professionals, eligible hospitals, and critical access hospitals (CAHs) as they adopt, implement, upgrade or demonstrate meaningful use of certified EHR technology. abeo’s objective is to provide useful information and compliant solutions for our clients. We will be complying with the CMS requirements and will not be registering each provider for the EHR programs until CMS has implemented the correct functionalities. As more information becomes available and/or guidelines change we will provide updates.
The American Society of Anesthesiologists (ASA) released an article on December 3, 2010 in regards to the program and participation of an anesthesiologist. The article states the following:
“In order to receive the incentive payments one needs to meaningfully use a “certified EHR.” Because anesthesiologists were not initially intended to be deemed “eligible professionals,” the meaningful use requirements do not necessarily reflect the practice of anesthesiology and thus it will be difficult for anesthesiologists to achieve meaningful use based on the current requirements. In addition, at this time there are very few, if any, certified Anesthesia Information Management Systems (AIMS) out there and it is unclear whether all vendors will seek certification as they are waiting for some guidance as well. There are also questions of whether an anesthesiologist would need to use a combination of a hospital’s EHR and an AIMS system to meet meaningful use or whether they could simply use an AIMS and be exempt from the other requirements.
ASA staff has brought this problem to the attention of both CMS and the Office of National Coordinator (ONC). Currently, they have their hands full with trying to implement the program for the majority of eligible professionals and anesthesiologists are not at the top of their priority list at the moment. ASA is hoping that CMS will come out with some guidance for anesthesiologists as to how they can achieve meaningful use and receive the incentive payments or, at the very least, have hospitals obtain credit for the use of AIMS while allowing anesthesiologists to avoid penalties. ASA staff has been and will continue to push them to do so.” 1
At this time because of the issues noted above in regards to the meaningful use requirements an anesthesiologist may not qualify for the incentive payment, however that does not mean that the anesthesiologist cannot go register for the program while waiting for CMS to make changes to the program. Many other companies have informed their clients that they are going to automatically register each provider for the EHR program now; however on February 7, 2011 CMS released the following update:
“At this time, there is no method available for a third-party to register multiple eligible professionals (EPs) for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. Beginning in May, CMS plans to implement functionality that will allow an EP to designate a third-party to register and attest on his or her behalf. We will release detailed information about that process when it is available.
Please be aware that, currently, EPs are NOT permitted to allow a practice manager or any other person to register in their place. Sharing your National Plan and Provider Enumeration System (NPPES) user ID and password with third-parties can place your information at risk. Until CMS implements new functionality in May, each EP should register himself or herself separately for the Medicare and Medicaid EHR Incentive Programs.” 2
The HITECH Act provides two incentive programs for Eligible Providers (EP), one through Medicare and the other through Medicaid. Neither program is available to CRNA’s or Anesthesia Assistants.
An eligible professional is defined as follows:
Eligible professionals under the Medicare EHR Incentive Program include:
– Doctor of medicine or osteopathy
– Doctor of dental surgery or dental medicine
– Doctor of podiatry
– Doctor of optometry
Eligible professionals under the Medicaid EHR Incentive Program include:
– Physicians (primary doctors of medicine and doctors of osteopathy)
– Nurse practitioner
– Certified nurse-midwife
– Physician assistant who furnishes services in a Federally Qualified Health Center or Rural Health Clinic that is led by a physician assistant
The criteria below will help you to determine potential eligibility through meaningful use (MU) or other requirements.
CMS Chart 1
• Must be a participating provider
• Bonus = 75% of total Medicare Allowed Professional Charges, up to annual cap
• Maximum incentive is $44,000 for EP’s
• Requires 90 days of meaningful use in the initial payment year and full use after
• Last year a provider may initiate program is 2014; Last year to register is 2016; Payment adjustments begin 2015
• Register with CMS and attest with CMS
• Payment reductions begin in 2015 for providers that do not demonstrate meaningful use
• Voluntary for states to implement – may not be an option in every state
• Must be a participating provider
• Flat bonus
• Does not require meaningful use in initial payment year, can receive bonus for
“adopting, implementing or upgrading”
• Last year a provider may initiate program is 2016; Last year to register is 2016
• Register with CMS, attest with state Medicaid agency
• Use certified technology
• Use in a meaningful way – see objectives below
• Document meaningful use
• Apply for incentives
• 15 Core Objectives (six exclusions available noted with *)
o Use computerized provider order entry*
o Report ambulatory clinical quality measures to CMS/States
o Implement one clinical decision support rule
o Provide patients with an electronic copy of their health information, upon request*
o Provide clinical summaries for patients for each office visit*
o Drug-Drug and drug-allergy interaction checks
o Record demographics
o Maintain an up-to-date problem list of current and active diagnoses
o Maintain active medication list
o Maintain active medication allergy list
o Record and chart changes in vital signs*
o Record smoking status for patients 13 years or older*
o Capability to exchange key clinical information among providers of care and patient-authorized entities electronically
o Protect electronic health information
• 10 Menu Objectives. Choose the five that most closely match practice.
(seven exclusions available noted with *)
o Drug-formulary checks
o Incorporate clinical lab test results as structured data*
o Generate lists of patients by specific conditions
o Send reminders to patients per patient preference for preventive/follow up care*
o Provider patients with timely electronic access to their health information*
o Use certified EHR technology to identify patient-specific education resources and provide to patient, if appropriate
o Medication reconciliation*
o Summary of care record for each transition of care/referrals*
o Capability to submit electronic data to immunization registries/systems+*
o Capability to provider electronic syndromic surveillance data to public health agencies+*
• +At least one public health objective must be selected
• Registration does not create an obligation to report but opens the opportunity to report at a later time
• Proxy registration / attestation may be available in April or May. Currently providers must enroll themselves
• Information needed:
o NPPES User ID and Password
o Payee Tax ID
o Payee NPI
o PECOS enrollment
• CMS opens on April 4, 2011. First incentive checks to be issued in May 2011.
• State Medicaid agencies control their own processes / timing
1 ASA Washington Alerts. “Electronic Health Records Update” ASA website, December 3, 2010. http://www.asahq.org
2 Centers for Medicare & Medicaid Services. “Registration and Attestation.” CMS website, last updated March 25, 2011. https://www.cms.gov/EHRIncentivePrograms/20_RegistrationandAttestation.asp
3 David Blumenthal, M.D., M.P.P., and Marilyn Tavenner, R.N., M.H.A. “The “Meaningful Use” Regulation for Electronic Health Records.” The New England Journal of Medicine. August 5, 2010.
4 CMS Chart 1 and CMS Chart 2 Centers for Medicare & Medicaid Services. “Eligibility – Incentive Payments For Implementing Electronic Health Records Programs.” CMS website, last updated April 8, 2011. http://www.cms.gov/EHRIncentivePrograms/15_Eligibility.asp#TopOfPage.
abeo Management Corporation (abeo) serves as a leading source of revenue cycle management and practice management with a specialization in anesthesia. The company leverages its people, processes, and software to serve independent practices, surgery centers, hospitals and healthcare systems with a scope of services that include billing, coding, transcription, practice management, and business consulting.