Meaningful Use: Qualify for EHR Incentive Programs

The Health Information Technology for Economic and Clinical Health Act (HITECH) allocates $19 billion in government funds to encourage the healthcare industry to adopt information technology in the way of electronic health records.

Integrating this technological advance will help medical practices prevent medical errors, cut unnecessary costs, limit paperwork and improve the quality of healthcare across the nation. Both the Medicare and Medicaid EHR Incentive Programs provide financial incentives to eligible professionals who are able to demonstrate meaningful use of certified EHR technology.

The American Recovery and Reinvestment Act of 2009 specifies three primary components of meaningful use:

  1. Use of a certified EHR in a meaningful manner, such as e-prescribing.
  2. Use of certified EHR technology for electronic exchange of health information to improve the quality of healthcare.
  3. The use of certified EHR technology to submit clinical quality measures (CQM) and other quantifiable markers.

Simply put, “meaningful use” means that medical professionals must show that they are using certified EHR technology in ways that can be significantly measured in quality and in quantity.

The meaningful use attestation process may seem complex at first glance, so we would like to help physicians and other healthcare professionals become more comfortable by taking a step-by-step approach to the certification process, making it easier and quicker to receive incentive payments.

For the Medicare EHR Incentive Program, eligible professionals include:

  • Doctors of medicine or osteopathy
  • Dentists
  • Podiatrists
  • Optometrists
  • Chiropractors

Eligible professionals under the Medicaid EHR Incentive Program include:

  • Physicians (primary doctors of medicine and doctors of osteopathy)
  • Nurse practitioners 
  • Certified nurse-midwives
  • Dentists
  • Physician assistants who furnish services in a Federally Qualified Health Center or Rural Health Clinic that are led by physician assistants.

Both the Medicare and Medicaid EHR Incentive Programs currently exclude clinical psychologists, clinical social workers, physical therapists, occupational therapists, dieticians, diabetes nurse educators and “hospital-based” physicians. The Centers for Medicare & Medicaid Services (CMS) defines hospital-based physicians as those who provide 90 percent or more of their services in a hospital inpatient or outpatient setting.

Those who wish to qualify for the Medicaid EHR Incentive Program must meet one of the following requirements:

  • A minimum of 30 percent Medicaid patient volume
    • For pediatricians, a minimum of 20 percent Medicaid patient volume
  • Practice predominately in a federally qualified health center or rural health center with a 30 percent minimum patient volume attributable to needy individuals.

Incentive payments for eligible professionals are based on individual practitioners and not the practice as a whole. Each eligible professional in a practice must demonstrate meaningful use of certified EHR technology to qualify for an incentive payment. The number of individual incentive payments will not exceed one per year, regardless of how many practices or locations at which the individual provides service.

Eligible professionals cannot participate in both the Medicare and Medicaid incentive programs. They must choose which program is more beneficial to them. Before 2015, an eligible professional may only switch programs once after the first incentive payment is made. If a provider chooses the Medicaid incentive program, they will also have to choose an individual state from which to receive payment, even if they provide care across state borders. Once a provider determines that they are eligible to receive incentive payments, the next step is registration.

Eligible professionals must first register for the program using the online CMS Registration and Attestation System. They may register before they have a certified EHR in place and even before they have an enrollment record in the Medicare Provider Enrollment, Chain and Ownership System (PECOS), which is required for all Medicare eligible professionals. To help the registration process go smoothly, it is important to have the following information available:

  • National Professional Identifier (NPI)
  • National Plan and Professional Enumeration System (NPPES) User ID and Password
  • Payee Tax Identification Number (if reassigning benefits)
  • Payee National Professional Identifier (NPI) (if reassigning benefits)

Not all states are ready to participate in the Medicaid EHR Incentive Program. Providers who choose to receive payments for the Medicaid EHR incentive program must be sure to check their state’s status on the CMS website. Providers will be unable to register until their state’s program has started.

Choosing a certified EHR technology is critical to qualifying for EHR incentive payments. Eligible professionals must choose an EHR technology that has been tested and certified by an Office of the National Coordinator (ONC) Authorized Testing and Certification Body (ATCB). If an eligible professional currently has an EHR in place, it is important to make sure the software has been tested and certified by an ONC-ATCB, specifically for the Medicare and Medicaid EHR Incentive Programs. A list of certified EHR products is available on the Office of the National Coordinator for Health Information Technology (ONC) website.

To demonstrate meaningful use, eligible professionals must use a certified EHR system to meet defined objectives and report clinical quality measures. 

To qualify for incentive payments, meaningful use requirements must be met in the following ways:

  • For the Medicare EHR Incentive Program, eligible professionals must successfully demonstrate meaningful use of certified EHR technology every year they participate in the program by meeting defined objectives and clinical quality measures.
  • For the Medicaid EHR Incentive Program, eligible professionals have the option of adopting, implementing, upgrading or demonstrating meaningful use of certified EHR technology in their first year of participation.

CMS defines “adoption” as acquiring and installing a certified EHR technology. “Implementation” is defined as beginning the use of a certified EHR technology, and “upgrading” is defined as expanding existing EHR technology to meet certification requirements. Finally, “demonstration” includes meeting defined objectives and clinical quality measures.

For Medicare, eligible professionals must successfully demonstrate meaningful use of certified EHR technology every year, starting the first year of participation. Those who wish to qualify for Medicaid have more options in Year One -- either adopting, implementing, upgrading or demonstrating meaningful use. After Year One, they too must demonstrate meaningful use every year. As mentioned before, demonstrating meaningful use requires meeting what CMS calls “Defined Objectives and Clinical Quality Measures” Defined objectives spell out the requirements for qualification. They are currently scheduled to be rolled out in 3 stages over five years.

To qualify for 2012 payments, eligible professionals must meet 15 of the Stage 1 Core objectives and 5 of the Menu Set objectives. Core objectives include, but are not limited to:

  • Implementing drug-drug and drug-allergy interaction checks
  • Maintaining up-to-date problem list of current and active diagnoses
  • Generating and transmitting permissible prescriptions electronically (eRx)
  • Maintaining active medication lists
  • Maintaining active medication allergy lists
  • Recording demographic information, including:
    • Preferred language
    • Gender
    • Race
    • Ethnicity
    • Date of Birth
  • Recording and charting changes in the following vital signs:
    • Height
    • Weight
    • Blood Pressure
    • Calculate and display body mass index (BMI)
    • Plot and display growth charts for children 2–20 years, including BMI
  • Providing patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, medication allergies) upon request
  • Providing clinical summaries for patients for each office visit
  • Exchanging key clinical information among providers of care and patient authorized entities electronically
  • Protecting electronic health information created or maintained by the certified EHR technology through the implementation of appropriate technical capabilities.

The remaining 5 objectives may be chosen from a list of 10 menu set objectives. These objectives include, but are not limited to:

  • Implementing formulary checks
  • Incorporating clinical lab-test results into EHR as structured data
  • Generating lists of patients by specific conditions for use in quality improvement, reduction of disparities, research, or outreach
  • Sending patient reminders per patient preference for preventative and/or follow-up care 
  • Providing patients with timely electronic access to their health information (including lab results, problem list, medication lists, and allergies) within 4 business days of the information being available to the eligible professional
  • Using certified EHR technology to identify patient-specific education resources and providing those resources to the patient if appropriate
  • Providing summary care records for each transition of care or referral
  • Capability to submit electronic data to immunization registries or immunization information systems and actual submission according to applicable law and practice
  • Capability to submit electronic syndromic surveillance data to public health agencies and actual submission according to applicable law and practice

In addition to meeting the objectives just outlined, eligible professionals will also need to report on six “Clinical Quality Measures” that measure healthcare processes, outcomes, patient perceptions and organizational systems associated with the ability to provide quality health care. There are three core measures and three additional measures that may be selected from a list of 38. If a particular patient population is not eligible to meet a measure’s inclusion requirements, providers must report on an alternate core measure for each core measure that their patient population does not meet. The list of core measures can be found on the CMS website.

Eligible professionals will need to return to the Web-based CMS Registration and Attestation System after meeting the meaningful use objectives and clinical quality measures for 90 days in order to legally attest that they have met the meaningful use criteria for the Medicare EHR Incentive Program. To attest for the Medicare EHR Incentive Program in subsequent years, providers will need to have met meaningful use for a full year. The reporting period for eligible professionals must fall within the calendar year. Again, in the first year of participation in the Medicaid EHR Incentive Program, eligible professionals have the option to adopt, implement, upgrade or demonstrate meaningful use of their certified EHR technology. Medicaid EHR Incentive Program participants should check with their state to find out when they can begin participation.

A certified EHR system will assist in the attestation process by providing eligible professionals with a report of the numerators, denominators and other information needed to successfully report on meaningful use objectives and clinical quality measures.

Eligible professionals must identify their certified EHR by providing the CMS EHR Certification ID. This unique ID can be found on the Certified Health IT Product List on the Office of the National Coordinator for Health Information Technology (ONC) website.

Immediately after reporting, providers will see a summary of their attestation and if it was accepted. If accepted, incentive payments should be distributed approximately four to eight weeks following submission.

Eligible professionals may also use third parties to register and attest on their behalf. If providers elect to go this route, they need to keep in mind that users working on their behalf must have an Identity and Access Management System (I&A), Web user account (User ID/Password), and be linked to the eligible professional’s National Provider I.D.

The maximum total Medicare incentive payment for eligible professionals is $44,000 over a five-year period. The incentive payment is equal to 75% of Medicare fee-for-service allowable charges for covered services provided by an eligible professional in a payment year.

To receive the maximum incentive payment, eligible professionals must begin their 90 reporting period by October 3, 2012. To receive any Medicare incentive payments, they must qualify and enroll by 2014. If a provider fails to demonstrate meaningful use by 2015, they will be subject to a reduction in Medicare payments (1 percent penalty in 2015, 2 percent penalty in 2016, 3 percent penalty in 2017, and up to a 5 percent penalty in 2018 and beyond).

Under Medicaid, the incentive payments work slightly differently. The maximum incentive payment is $63,750 per eligible professional, paid over 6 years. The first year payment is $21,250, and $8,500 per year for subsequent years. States have their own timelines for implementing programs, but eligible professionals must enroll by 2016 to receive the maximum amount of incentive payments, since the program is only scheduled to run through 2021.