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EMR Ratings: How relevant is CCHIT certification in the HITECH era?

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The Certification Commission for Health Information Technology (CCHIT) has been the leader in EMR/EHR certification and for the past four years has been the lone company recognized by the federal government to certify EMR/EHR systems. However, times are changing.

As described in this article by Chris Thorman of Software Advice, CCHIT will no longer be the lone certifying body and its influence in the market is set to be challenged.

EMR Ratings: How relevant is CCHIT certification in the HITECH era?
By Chris Thorman
Senior Marketing Manager, Software Advice

For nearly four years, the Certification Commission for Health Information Technology (CCHIT) has been the lone entity recognized by the federal government to certify electronic health record systems. Since being named a recognized certifying body by Health and Human Services (HHS) in 2006, CCHIT has awarded certifications to nearly 200 EHR software products based on CCHIT’s standards of functionality, interoperability, usability and security.

However, CCHIT’s role in the EHR market is changing. The Office of the National Coordinator of Health IT (ONC) and the Center for Medicare & Medicaid Services (CMS) announced in early March 2010 that they would name more than one organization to certify EHR software, countering previous claims that CCHIT would become the sole certifying body. The certification requirements are in accordance with 2009’s Health Information Technology for Economic and Clinical Health (HITECH) Act.

As this news swirled around, one doctor called Software Advice and asked: “Is CCHIT dead?

Dead? No. But it appears that the organization’s influence is waning.

In the spirit of point counterpoint, here are three reasons why CCHIT could become less relevant in the EHR industry:

1. Competition with other certifying entities;
2. Influence of regional extension centers; and,
3. Diminishing need for certification.

And here are three reasons why CCHIT could continue to remain relevant:

1. Institutional knowledge;
2. CCHIT products are a bridge to HITECH incentives; and,
3. Need for alternatives to government certification.

Read this full article:

EMR Ratings: How relevant is CCHIT certification in the HITECH era?

Stimulus Incentive FAQs: EHR/EMR certification, meaningful use, eligible providers

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Stimulus package FAQs image

On February 17, 2009, President Obama signed into law the American Reinvestment and Recovery Act of 2009 (ARRA). Under the part of the stimulus plan referred to as the HITECH Act, eligible providers can qualify for up to in $44,000 in Medicare or $63,750 in Medicaid incentives if they demonstrate ‘meaningful use' of a certified electronic health record (EHR, also referred to as electronic medical record or EMR) beginning in 2011.


How does all of this affect psychiatrists, psychologists, and other mental health care providers? Here are the answers to some frequently asked questions regarding the government HITECH stimulus incentives:

  1. What does it mean to be an eligible provider (EP)?
  2. How does this affect mental health professionals? (Am I eligible for stimulus package EHR incentives?)
  3. What is the definition of meaningful use?
  4. How much money can I receive?
  5. Does it matter when I start demonstrating meaningful use?
  6. Does my EHR/EMR need to be CCHIT certified in order for me to receive stimulus incentives?
  7. Which EHRs are government certified?
  8. How do I get paid for meaningful use of a certified EHR?

1. What does it mean to be an eligible provider (EP)?

For hospitals to be eligible, they can be acute care (excluding long term care facilities), critical access hospitals, or children's hospitals.
When it comes to defining an eligible provider for EHR incentive payment purposes, there is a difference between the requirements for Medicare and Medicaid. Medicare defines an eligible provider according to the definition in the Social Security Act section 1861(r):

  1. doctor of medicine or doctor of osteopathy
  2. doctor of dental surgery or dental medicine
  3. doctor of podiatric medicine
  4. doctor of optometry
  5. chiropractor
Medicaid defines an eligible provider as follows (ARRA p. 377):
  1. physician
  2. dentist
  3. certified nurse-midwife
  4. nurse practitioner
  5. physician assistant who is practicing in a Federally Qualified Health Center (FQHCs) or Rural Health Clinic (RHCs) led by a physician assistant

2. How does this affect psychiatrists, psychologists, social workers, and other therapists and mental health professionals? (Am I eligible for stimulus package EHR incentives?)

Under the current stimulus package guidelines, the following mental health professionals are eligible for stimulus money:

Medicare:

  • Psychiatrists (MD)

Medicaid:

  • Psychiatrists (MD)
  • Nurse Practitioners (NP, ARNP)
However, a bill was introduced in April that would allow behavioral, mental health, and substance abuse treatment providers to qualify for incentives (courtesy of this iHealthBeat article).

The new Health Information Technology Extension for Behavioral Health Services Act of 2010 would extend eligibility for stimulus incentive payments to:

  • Behavioral and mental health professionals and clinics
  • Substance abuse professionals and treatment facilities
  • Psychiatric hospitals
  • Licensed psychologists and clinical social workers

3. What is the definition of meaningful use? (Courtesy of this article in Healthcare IT News)

While the final ruling for meaningful use has not yet been released, a preliminary set of guidelines have been published. There are three identified components of Stage I Meaningful Use:

  1. Use of a certified EHR in a meaningful manner such as e-prescribing
  2. Use of certified EHR Technology for the exchange of health information (exchange data with other providers of care or business partners such labs or pharmacies)
  3. Use of certified EHR Technology to submit clinical quality and other measures

The first stage of meaningful use is capturing and sharing the data. Meaningful Use Stage II is advanced clinical processes and Stage III is starting to look at meaningful use of an EHR in the context of improved healthcare outcomes.

Please refer to the end of this FAQ post for the 25 specific criteria for Meaningful Use Stage I taken from the Notice of Proposed Rule Making (NPRM) for meaningful use, which was released on January 13, 2010.

4. How much money can I receive?

Eligible providers who show meaningful use of a certified EHR can receive up to $44,000 (Medicare) OR $63,750 (Medicaid) in government funding. Office-based physicians practicing in rural or underserved areas are eligible for an additional 10% (up to $48,000) in Medicare incentives. These figures represent the maximum allowable incentives under the Medicare and Medicaid programs based on a percentage of actual annual revenue received from Medicare and Medicaid. Providers must choose between applying for the Medicare or Medicaid funding - they may not receive incentives from both.

Here is an outline of the maximum allowable benefits from Medicare (courtesy of CMS Fact Sheet):

First payment year:      $18,000 if first payment year is 2011 or 2012
                                $15,000 if first payment year is 2013
                                $12,000 if first payment year is 2014

Second payment year:  $12,000
Third payment year:     $8,000
Fourth payment year:   $4,000
Fifth payment year:      $2,000

Eligible professionals working in health professional shortage areas (HPSAs) will receive a 10% increase in incentive payment amounts.

For eligible Medicaid providers, the State is authorized to provide reimbursement for 85% of net average allowable costs of EHR adoption and startup (including support and training) - up to $63,750 over 6 years. Medicaid incentives for EHR adoption will begin in 2011.

For Medicare and Medicaid penalties, see our previous Stimulus Package Incentives for Mental Health Professionals blog post.

5. Does it matter when I start demonstrating meaningful use?

For the Medicaid incentive, you may receive the full $63,750 over a period of 6 years as long as you begin adoption and demonstration of meaningful use between 2011 and 2015.

For the Medicare incentive, as shown in the table above, you can receive the full $44,000 incentive over the course of 5 years if you begin demonstrating meaningful use in 2011 or 2012. It is important to note that incentive money will equal 75% of what you receive from Medicare in a given year. So if you anticipate that your Medicare payments will be substantially higher in 2012 than 2011, you may want to begin reporting meaningful use of a certified EHR in 2012.

You will need to receive a minimum of $24,000 in reimbursement from Medicare in your first year of demonstrating meaningful use in order to receive the maximum allowed federal incentive payment. Here is a chart for the amounts you will need to receive in Medicare reimbursements each year in order to receive the maximum incentive payment for that year:

 Year of demonstrating meaningful use (if beginning in 2011 or 2012)

Minimum annual Medicare reimbursement required for
maximum incentive payment
 First year
 $24,000
 Second year
 $18,000
 Third year
 $10,667
 Fourth year
 $5,334
 Fifth year
 $2,667

6. Does my EHR/EMR need to be CCHIT certified in order for me to receive Medicare/Medicaid incentives?

The Office of the National Coordinator for Health IT (ONC) has yet to establish both the certification criteria and the organizations that will serve as certifiers (ONC said it plans to select multiple certifying bodies). While CCHIT has been the sole EMR/EHR certifying body thus far, this alone does not guarantee that it will be among the appointed certifiers nor does it ensure that CCHIT's set of standards will match up with the upcoming government Stimulus standards. See our CCHIT certification blog post.

7. Which EHRs are government certified?

At this time, no EHRs have been certified for government stimulus incentives, since the government has yet to announce official certifying bodies.

8. How do I get paid for meaningful use of a certified EHR?

For Medicare, during the first payment year, all an EP has to do is demonstrate "meaningful use" of a certified EHR for a continuous 90-day period during the payment year. For hospitals, the payment year is October 1st to September 30th and for EPs, the payment year is the calendar year. The meaningful use must begin and end within the payment year.

If you qualify as a Medicaid eligible provider or hospital and at least 30% of your patient volume is from Medicaid (20% for pediatricians and 10% for hospitals), you must be in the process of implementing or upgrading your EHR in order to collect incentive money.

Although details have not yet been released for how EPs will apply for incentive funds, attestation forms are the most likely method (courtesy of Wellsphere).

Medicare incentive payments will be disbursed through Medicare Administrative Contractors (MAC) or carriers to the Tax Identification Number provided by the qualifying eligible provider.

(Continued from 3 above): 25 proposed criteria for Meaningful Use Stage I

The following 25 specific criteria for Meaningful Use Stage I were taken from the Notice of Proposed Rule Making (NPRM) for meaningful use, which was released on January 13, 2010. The public comment period for the NPRM closed on March 15, 2010.

[1] Objective: Use CPOE (Computerized Physician Order Entry).
Measure: CPOE is used for at least 80 percent of all orders.

[2] Objective: Implement drug-drug, drug-allergy, drug- formulary checks.
Measure: The EP (Eligible Provider) has enabled this functionality.

[3] Objective: Maintain an up-to-date problem list of current and active diagnoses based on ICD-9-CM or SNOMED CT®
Measure: At least 80 percent of all unique patients seen by the EP have at least one entry or an indication of none recorded as structured data.

[4] Objective: Generate and transmit permissible prescriptions electronically (eRx).
Measure: At least 75 percent of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technology.

[5] Objective: Maintain active medication list.
Measure: At least 80 percent of all unique patients seen by the EP have at least one entry (or an indication of "none" if the patient is not currently prescribed any medication) recorded as structured data.

[6] Objective: Maintain active medication allergy list.
Measure: At least 80 percent of all unique patients seen by the EP have at least one entry (or an indication of "none" if the patient has no medication allergies) recorded as structured data.

[7] Objective: Record demographics.
Measure: At least 80 percent of all unique patients seen by the EP or admitted to the eligible hospital have demographics recorded as structured data.

[8] Objective: Record and chart changes in vital signs.
Measure: For at least 80 percent of all unique patients age 2 and over seen by the EP, record blood pressure and BMI; additionally, plot growth chart for children age 2 to 20.

[9] Objective: Record smoking status for patients 13 years old or older.
Measure: At least 80 percent of all unique patients 13 years old or older seen by the EP "smoking status" recorded.

[10] Objective: Incorporate clinical lab test results into EHR as structured data.
Measure: At least 50 percent of all clinical lab tests results ordered by the EP or by an authorized provider of the eligible hospital during the EHR reporting period whose results are in either in a positive/negative or numerical format are incorporated in certified EHR technology as structured data.

[11] Objective: Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research, and outreach.
Measure: Generate at least one report listing patients of the EP with a specific condition.

[12] Objective: Report ambulatory quality measures to CMS or the States.
Measure: For 2011, an EP would provide the aggregate numerator and denominator through attestation as discussed in section II.A.3 of this proposed rule. For 2012, an EP would electronically submit the measures are discussed in section II.A.3 of this proposed rule.

[13] Objective: Send reminders to patients per patient preference for preventive/ follow-up care.
Measure: Reminder sent to at least 50 percent of all unique patients seen by the EP that are 50 and over.

[14] Objective: Implement five clinical decision support rules relevant to specialty or high clinical priority, including for diagnostic test ordering, along with the ability to track compliance with those rules.
Measure: Implement five clinical decision support rules relevant to the clinical quality metrics the EP is responsible for as described further in section II.A.3.

[15] Objective: Check insurance eligibility electronically from public and private payers.
Measure: Insurance eligibility checked electronically for at least 80 percent of all unique patients seen by the EP.

[16] Objective: Submit claims electronically to public and private payers.
Measure: At least 80 percent of all claims filed electronically by the EP.

[17] Objective: Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, and allergies) upon request.
Measure: At least 80 percent of all patients who request an electronic copy of their health information are provided it within 48 hours.

[18] Objective: Provide patients with timely electronic access to their health information (including lab results, problem list, medication lists, allergies).
Measure: At least 10 percent of all unique patients seen by the EP are provided timely electronic access to their health information.

[19] Objective: Provide clinical summaries to patients for each office visit.
Measure: Clinical summaries provided to patients for at least 80 percent of all office visits.

[20] Objective: Capability to exchange key clinical information (for example, problem list, medication list, allergies, and diagnostic test results), among providers of care and patient authorized entities electronically.
Measure: Perform at least one test of certified EHR technology's capacity to electronically exchange key clinical information.

[21] Objective: Perform medication reconciliation at relevant encounters and each transition of care.
Measure: Perform medication reconciliation for at least 80 percent of relevant encounters and transitions of care.

[22] Objective: Provide summary care record for each transition of care and referral.
Measure: Provide summary of care record for at least 80 percent of transitions of care and referrals.

[23] Objective: Capability to submit electronic data to immunization registries and actual submission where required and accepted.
Measure: Perform at least one test of certified EHR technology's capacity to submit electronic data to immunization registries.

[24] Objective: Capability to provide electronic syndromic surveillance data to public health agencies and actual transmission according to applicable law and practice.
Measure: Perform at least one test of certified EHR technology's capacity to provide electronic syndromic surveillance data to public health agencies (unless none of the public health agencies to which an EP or eligible hospital submits such information have the capacity to receive the information electronically).

[25] Objective: Protect electronic health information maintained using certified EHR technology through the implementation of appropriate technical capabilities.
Measure: Conduct or review a security risk analysis in accordance with the requirements under 45 CFR 164.308 (a)(1) and implement security updates as necessary.

Start a dialogue! Feel free to leave comments and ask questions here.

Psychiatric EMR/EHR: is CCHIT certification needed for Stimulus incentives?

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CCHIT certification necessary for EMR / EHR stimulus incentive?

With the release of preliminary government guidelines for ‘meaningful use' of a certified EMR/EHR, many providers are wondering whether they need to have an EMR that is certified by the Certification Commission for Healthcare IT (CCHIT) in order to receive government Stimulus incentives.

The answer, for now, is no.


The Office of the National Coordinator for Health IT (ONC) has yet to establish both the certification criteria and the organizations that will serve as certifiers (ONC said it plans to select multiple certifying bodies). While CCHIT has been the sole EMR/EHR certifying body thus far, this alone does not guarantee that it will be among the appointed certifiers nor does it ensure that CCHIT's set of standards will match up with the upcoming government Stimulus standards.

This leaves open the possibility that a previously CCHIT-certified EMR/EHR may not meet all Stimulus certification criteria and will require additional certification. For this reason, many EMR/EHR vendors are awaiting the release of official government standards and certifying organizations before moving forward with certification.

Stay informed as EMR/EHR certification updates are posted - subscribe to Vālant's blog!

Additional Information:
Center for Medicare and Medicaid Services (CMS) Frequently Asked Questions


Stimulus Package incentives for mental health professionals

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Economic Stimulus Package ImageOn February 17th, President Obama signed into law the American Recovery and Reinvestment Act of 2009, which aims to stimulate the economy through investments in many different fields - one being healthcare information technology. Under what is referred to as the HITECH Act, the government will grant $20.8 billion in Medicaid and Medicare incentives for physicians and hospitals to adopt EHRs (electronic health records).

The terms EHR (electronic health record) and EMR (electronic medical record) are often used interchangeably.

Incentives (increased payments/reimbursements) will begin in fiscal year 2011, with the largest reimbursements within the first year and decreasing amounts for each subsequent year. Penalties (reduction in fee schedules) for lack of adoption will begin in fiscal year 2015.

Who qualifies?

The HITECH act states that eligible professionals who demonstrate meaningful use of a certified EHR will qualify for these incentives. Here is a breakdown of these terms:

Eligible professional: An eligible professional is an office-based physician. Eligible professionals can have employment relationships with hospitals, but the bulk of services must be provided outside of a hospital setting.

Meaningful use: Meaningful use will include use of ePrescribing and quality measures reporting as designated by the Health and Human Services Secretary.

Certified EHR: HIT Standards Committee is currently establishing standards for certification of EHRs - the deadline for having standards set is December 31, 2009. (Vālant is closely tracking certification developments and is fully committed to complying with standards and achieving certification.)

What are the incentive payments and penalties?

Providers may receive reimbursement incentives from either Medicare or Medicaid (not both).

MEDICARE INCENTIVE

Providers may receive up to $44,000 over five years for proving meaningful use of a certified EHR.

First payment year:      $18,000 if first payment year is 2011 or 2012
                                $15,000 if first payment year is 2013
                                $12,000 if first payment year is 2014

Second payment year:  $12,000
Third payment year:     $8,000
Fourth payment year:   $4,000
Fifth payment year:      $2,000

Eligible professionals working in health professional shortage areas (HPSAs) will receive a 10% increase in incentive payment amounts.

MEDICARE PENALTY

Providers who have not begun to demonstrate meaningful use of an EHR by 2015 will experience a reduction in Medicare fee schedules as follows:

2015: 99%
2016: 98%
2017 and on: 97%

MEDICAID INCENTIVE

In order to qualify for the Medicaid incentive, providers must rely on Medicaid assistance for at least 30% of their patient volume. For eligible Medicaid providers, the State is authorized to provide reimbursement for 85% of net average allowable costs of EHR adoption and startup - up to $63,750 over 6 years. Medicaid incentives for EHR adoption will begin in 2011. There are no set Medicaid penalties for lack of EHR adoption.

Vālant's blog will be updated as further incentive and certification details are released by the Secretary. Subscribe to our blog to receive an update as soon as more information becomes available.

 Additional Information

Summary of Key Health Information Technology Provisions from the Stimulus Package

From the Healthcare Information and Management Systems Society (HIMSS

The American Recovery and Reinvestment Act of 2009

The full legal document (HITECH Act is Title XIII, pages 112 - 165) 

 

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