Getting your ARRA/HITECH Act EHR incentive payments

Issue: September/October 2010

ByJeff Grant

Jeff Grant

Ophthalmologists can, and will, receive payments if all requirements are met.

The Final Rules for Meaningful Use, recently released by the Centers for Medicare and Medicaid Services and the Office of the National Coordinator for Health Information Technology, include much more flexibility than most experts imagined they would. There are no specialty-specific requirements.

Contrary to what you might have heard, ophthalmologists can, and will, receive EHR incentive payments.

It is important to point out that most of the requirements for becoming a “meaningful user” will be borne by the EHR software vendor. Since you are required to use a certified EHR technology, the top-tier EHR vendors are working feverishly to become certified. That will become possible in the coming weeks because, on August 30, 2010, the ONC announced the first two Authorized Testing & Certification Bodies (ONC-ATCB):

Certification Commission for Health Information Technology (CCHIT), Chicago, Ill.
Drummond Group, Inc., Austin, Texas

This means that both entities will be able to begin certifying software vendors very shortly, and we might have the first “HHS Stage 1” Certified EHR’s by the end of September!

There are only 15 Final Rules for Meaningful Use (MU) core measures that must be met to be eligible for the incentive payments. First, here are the five easiest ones. Chances are that your normal clinical documentation already meets these requirements:

Maintain a problem list for more than 80% of all unique patients seen by the eligible professional (EP).
Maintain an active medication list for more than 80% of all unique patients seen by the EP.
Maintain an active medication allergy list for more than 80% of all unique patients seen by the EP.
Record demographics (preferred language, gender, race and ethnicity, and date of birth) for more than 50% of all unique patients.
Maintain privacy and security (HIPAA) compliance.
Other items on the list might require some minor modifications to your normal documentation:
Record vital signs (height, weight, blood pressure), calculate BMI and display/print growth charts for more than 50% of all unique patients age 2 years and older seen by the EP. Any EP who believes that all three vital signs have no relevance to their scope of practice is exempt from this requirement.
Use Computer Physician Order Entry for 30% of your medication orders. You’re probably already recording most orders, and the Final Rule only requires that medications be recorded as an order. EPs who write fewer than 100 prescriptions during the EHR reporting period are exempt.
Record smoking status for more than 50% of all unique patients 13 years old or older seen by the EP. (You merely need to indicate one of three choices).
Generate and transmit permissible prescriptions electronically for 40% of all permissible prescriptions. Any EP who writes fewer than 100 prescriptions during the reporting period is exempt.
Provide clinical summaries to patients for more than 50% of all office visits within three business days. Although you probably aren’t doing this now, the clinical summary is something that your EHR software will have to generate.

Meeting the requirements of the other “Core Set” measures is certainly not an insurmountable hurdle:

Implement drug-drug and drug-allergy checks.
Implement one clinical decision support rule. For example, if the patient has a diagnosis of glaucoma, the decision support system could present tests that might be pertinent, preferred practice patterns (the practice’s own or those published by AAO), medications that are available, etc. All of this would include supporting documentation.
Have the capability to exchange key clinical information (e.g., problem list, medication list, medication allergies, and diagnostic test results) among providers of care and patient-authorized entities electronically.
Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, and medication allergies) for at least 50% of patients who request it within three business days. Any EP who has no such requests during the EHR reporting period is exempt from this requirement.
Report clinical quality measures. This is the requirement that will give practices the most fits, especially those who have not participated in the Physician Quality Reporting Initiative (PQRI). The requirements will be familiar to those already doing PQRI. CMS/ONC is making this pretty easy in the beginning, merely requiring attestation of data generated by your EHR software in 2011. By 2012, though, your EHR software vendor will have to be ready to submit the data electronically.

In addition to the 15 items above, there are also 10 MU “Menu Set Measures,” of which you can pick the five you feel would be most advantageous (with the caveat that you must pick one of two “public health” measures). Just as with the Core Set, the Menu Set offers more than enough flexibility for nearly any practice to pick measures they are comfortable with.

In summary, the changes required of you will be nominal, much of the work will be done by your Certified EHR Software, and you do have quite a bit of flexibility in the first couple of years (during Stage 1). There is certainly enough compensation available to make it worth your time and effort ($44,000 per NPI from Medicare). Rather than gnash your teeth over the Final Rules for MU not being ophthalmology-friendly, focus on the once-in-a-lifetime opportunity presented by the incentive, and the fundamental improvement in practice efficiency and patient care that a top-tier EHR application allows you to enjoy.

Jeff Grant is a Medical Practice Management Consultant with HCMA Inc. He can be reached at 307-765-2241; e-mail: jeff@hcma-consulting.com.