In order to be eligible to receive payments, each provider will have to register with HHS. The registration will occur online starting January 1, 2011. When registering, each provider will have to submit information including name, NPI, TIN (that will receive the incentive payments) and whether the provider is participating in the Medicare or Medicaid program. The website will track both Medicare and Medicaid payments to insure against fraud and abuse.

In order to receive payments, providers will have to prove they are meaningful users. For 2011 and 2012, providers will attest to this fact via a secure, online portal that is currently in development. In addition to attestation, providers will have to identify the certified EHR technology they are using as well as submit reports on product use and clinical metrics. Many of these reports should come from and be a feature of your certified EHR. Providers are expected to keep copies of these records for six years.

Core Set Measures

• Use CPOE (Computerized Physician Order Entry) to order medications for more than 30% of all unique patients with at least one medication in their medication list.
• Enable drug-drug and drug-allergy interaction check functionality on the EHR for the entire reporting period.*
• Maintain an up-to-date problem list of current diagnoses for 80% of all patients. If there are no problems, indicate no problems are known.
• Maintain an up-to-date list of active medications for 80% of all patients.
• Maintain an up-to-date problem list of medication allergies for 80% of all patients.
• Generate and transmit prescriptions electronically for 40% of prescriptions written by the provider.
• Record demographics for at least 50% of patients.*
• Record and chart changes in vital signs for at least 50% of patients.*
• Record smoking status for 50% of patients 13 and older.*
• Report ambulatory clinical quality measures to CMS.*
• Implement one clinical decision support rule relevant to the provider's specialty.
• Provide at least 50% of patients with an electronic copy of their health information, upon request, within 3 business days.*
• Provide at least 50% of patients with clinical summaries of their office visit within 3 business days.*
• Perform at least one test of the certified EHR technology's capacity to electronically exchange key clinical information.*
• For the EHR and its related IT network, conduct a security risk analysis and implement security updates as necessary; correct security deficiencies.*

Menu Set Measures

• Enable drug-formulary checking functionality and have access to a formulary for the EHR reporting period.*
• Incorporate clinical lab-test results into the EHR as structured data for at least 40% of all lab test results.*
• Generate at least one report listing patients with a specific condition.*
• Send reminders to 20% of all patients, 65 years or older, per patient preference for follow-up care.*
• Provide at least 10% of all unique patients timely access to health information within 4 business days of the information being available to the provider.*
• Provide patient-specific education resources to at least 10% of all unique patients.*
• Perform medication reconciliation at least 50% of the time for patients transitioned from another setting of care.
• Provide a summary care record for at least 50% of patients for patients being transitioned to another setting of care.
• Perform at least one test of the certified EHR's capability to submit electronic data to immunization registries.*
• Perform at least one test of the certified EHR's capability to submit syndromic surveillance data to public health agencies.*

*These functions may be performed by nursing, administrative or IT staff

It is expected that EHR vendors will provide the capability to generate much of the above mentioned information within their software and they will also assist physicians in conducting data exchange testing.

Meaningful Use Reporting Period – Physicians will receive HITECH funds based on being a meaningful user during an EHR reporting period. For the first EHR reporting period, physicians must meaningfully use the EHR for 90 continuous days. To receive maximum HITECH funds, the first EHR reporting period must be in 2011 or 2012. Although the first reporting period is only 90 days long, the second and subsequent reporting periods must conform to a calendar year. For instance, if a physician first qualifies based on a period of July 1 – September 30, 2011, the second reporting period will be the calendar year 2012. In order to qualify for payment, at least 50% of a physician's patient encounters must use a certified EHR. This allows physicians practicing in multiple settings to qualify.

Payment – There will be a single, consolidated annual incentive payment. Medicare will be paid by CMS and Medicaid from a state agency or designated intermediary. Payments will be made on a rolling basis – as soon as a physician has demonstrated meaningful use for the applicable reporting period and has reached the threshold for maximum payment (or the calendar year has ended). Payments will be made based on NPI (National Provider Identifier). A payment can be reassigned to an employer. Note that you can receive both PQRI payments and HITECH payments.

BEI is a privately owned business that has been providing IT support services to organizations of all sizes throughout the Washington DC metro area since 1987. BEI provides network design, installation, support, maintenance and procurement services to hundreds of clients in the region, with a focus on healthcare IT. We are a Microsoft Gold Certified Partner and specialize in Microsoft-based networks as well as other leading LAN/WAN technologies.

BEI is a member of the VMGMA (Virginia Medical Group Management Association), the MCMS (Montgomery County Medical Society), the Northern Virginia Practice Management Association, HIMSS (Healthcare Information and Management Systems Society) and MS-HUG (Microsoft Health Users Group).

Jonathan Krasner | jonathan.krasner@beinetworks.com | 703-528-8300 x105