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Starting in 2011 the American Recovery & Reinvestment Act (ARRA) will begin to pay out reimbursements for those who have implemented a “qualifying” EHR. The reimbursements will apply only to those who have implemented their EHR by 2014, but the earlier you act the more you will benefit. About 70% of the payments come in the first two years, and the amount you will receive decreases the longer you wait. As well as if you do not adopt and EHR by 2015 you will be penalized through percentage decreases in Medicare reimbursement rates. (See charts below for details) |
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Reimbursement Schedule under Medicare
| Year |
2011 |
2012 |
2013 |
2014 |
2015 |
2016+ |
| 2011 |
$18,000 |
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| 2012 |
$12,000 |
$18,000 |
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| 2013 |
$4,000 |
$12,000 |
$15,000 |
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| 2014 |
$2,000 |
$4,000 |
$12,000 |
$12,000 |
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| 2015 |
$0 |
$2,000 |
$4,000 |
$4,000 |
$0 |
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| 2016 |
$0 |
$0 |
$2,000 |
$2,000 |
$0 |
$0 |
| 2017+ |
$0 |
$0 |
$0 |
$0 |
$0 |
$0 |
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Penalties under Medicare
| Year |
% Withheld |
| 2016 |
1% |
| 2017 |
2% |
| 2018 |
3% |
| 2019 |
3-4% |
| 2020+ |
4-5% |
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EHR Qualifications
In order for an EHR to be qualified it must meet the following standards:
"(13) QUALIFIED ELECTRONIC HEALTH RECORD.-The term qualified electronic health record means an electronic record of health-related information on an individual that-
"(A) Includes patient demographic and clinical health info, such as medical history and problem lists; and
"(B) Has the capacity -
"(i) to provide clinical decision support;
"(ii) to support physician order entry;
"(iii) to capture and query information relevant to health care quality; and
"(iv) to exchange electronic health information with, and integrate such information from other sources.
In addition to these you also have to be able to prove "meaningful" use of the EHR. This is to be determined by the Secretary of Heath and Human Services, and the current qualifications are:
1. Using certified EHR technology that includes electronic prescribing
2. Using EHR technology that allows electronic exchange of health information.
3. Eligible professionals must submit information for the period
These qualifications are very vague and are currently being reviewed. There should be a rough outline released in September 2009, and the final decision will be made by December 31st 2009. Also the term "certified" is up in the air at this point, as there has not been a decision made as to who the certifying body will be.
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Stimulus readiness at InPracSysTM
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Notable industry events:
-In a new NEJM article, Dr. Blumenthal (ONCHIT) observes that some certified EHRs (of the type that physicians would have to use to qualify for government incentives) are neither user-friendly, nor designed to meet [the federal] HITECH [Act]s ambitious goal of improving quality and efficiency in the health care system. Tightening the certification process is a critical early challenge for ONCHIT.
-Mark Leavitt, the former chief medical officer at the health information group, who now runs the certification commission, said he expects that his organization will be "the body or one of several certifying bodies that are recognized" by the government, in part because it is currently the only certification group for health information technology.
-The Office of the National Coordinator for Health Information Technology, has released to Congress an operating plan for implementing provisions of the HITECH Act within the American Recovery and Reinvestment Act.
This plan lays out steps for:
°Defining “meaningful use” of an EHR
°Adoption of initial standards, implementation specifications and certification criteria
°Updating the federal health IT strategic plan
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Meaningful Use
Please see our meaningful use matrix for details on :
Meaningful Use Matrix |
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Certifications
Standards Rulemaking: Recovery Act §3004 (B) (1) - No later than December 31, 2009, HHS shall adopt and publish an initial set of standards, implementation specifications, and certification criteria. The rulemaking for this initial set of standards, implementation specifications, and certification criteria may be issued on an interim, final basis. Fully competitive contract awards will be utilized to support the impact analysis.
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Milestones
| Milestone |
Start |
End |
| Receive input from Federal and private-sector stakeholders to inform path forward |
05/18/2009 |
08/30/2009 |
| Review impact on other projects |
09/01/2009 |
09/30/2009 |
| Adjust operating plan, as needed |
10/01/2009 |
10/15/2009 |
| Submit for clearance |
10/15/2009 |
12/15/2009 |
| Publish revised plan on HHS Website |
12/15/2009 |
12/31/2009 |
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Special Features
