Technology
A CCHIT Certified® EHR is NOT equivalent to an ONCATCB certified EHR. To qualify under the EHR Incentive Programs, an EHR must be ONC-ATCB certified. ONC-ATCB certified products can be found at http://onc-chpl.force. com/ehrcert.
A practice does not necessarily need to purchase a new EHR in order to qualify for Meaningful Use incentives. Whether new or existing, as long as the EHR version being used is ONC-ATCB certified, that EHR will qualify as "certified" under Meaningful Use requirements. Also, note that practices do not need to have a certified EHR in place in order to register for the EHR incentive programs, but a certified EHR solution will be needed for attestation.
To qualify for the Medicaid EHR Incentive Program, you must have adopted, implemented or upgraded to an ONC-ATCB certified EHR before receiving an incentive payment for the first reporting year. Under the Medicare EHR Incentive Program, EPs must demonstrate Meaningful Use using certified EHR technology before being eligible to receive an EHR incentive payment in the first reporting year. Also, keep in mind that your Practice Management (PM) software does NOT need to be ONC-ATCB certified- only your EHR needs to be certified.
Meaningful Use
Meaningful Use requirements WILL change over time. Providers will be required to meet three stages of Meaningful Use; each stage will add new requirements to previous ones. Stage 1 is well-defined now and applies to 2011 and 2012; Stage 2, focusing on advanced clinical processes, begins in 2013; and Stage 3, focusing on improved outcomes, will start in 2015. Stages 2 and 3 will be furthered defined and finalized in future rules.
Demonstrating Meaningful Use involves meeting 25 objectives/measures. The EP must meet 15 Core Objectives and five Objectives from a menu set of 10, with one of those five being a public health objective.
Also, demonstrating Meaningful Use involves meeting six of 44 Clinical Quality Measures. An EP must meet the three Core measures, or substitute with Alternative Core measures, and select and meet an additional three Clinical Quality Measures from the menu set of 38.
Reporting
Medicaid requires only that an EP "Adopt, Implement or Upgrade" in the first year. An EP must Adopt a certified EHR, Implement a certified EHR, or Upgrade to a certified EHR. Medicare requires that you report Meaningful Use each year (90 days in Year One, full year reporting for Years 2 through 5).
Incentives
The maximum incentive amount for most providers under Medicare is $44,000. The maximum incentive amount for most providers under Medicaid is $63,750.
It pays to adopt early! Under Medicare, a provider can earn a maximum of $44,000 in incentive payments over a five year period, including $18,000 for those adopting in 2011 and 2012. Under Medicaid, a provider can earn a maximum of $63,750 in incentive payments over a six year period, including $21,250 in the first year of adoption. Providers have already started receiving payments.
Penalties
If an EP elects NOT to participate in the EHR Incentive programs, he or she WILL be penalized under the Medicare Incentive Program guidelines. A physician who accepts Medicare patients and does not become a meaningful user will be penalized for lack of use starting in 2015; this will occur through reduced Medicare claim payments, increasing in subsequent years of non-use.
The first year in which total available incentive amounts are reduced under Medicare is 2013. The first year in which penalties start under Medicare is 2015. If an EP elects NOT to participate in the Medicaid EHR Incentive Program, he/she will not be penalized at this time.