The Path to Paperless

“Meaningful Use”: The Final Rules

Part 2: Your action plan for implementation.

By Peter J. Polack, MD, FACS

In the September column, we discussed some of the terminology involved in the "meaningful use" rules for EMR financial incentives from the HITECH act of the stimulus bill, including the Core Set and Menu Set Objectives and Measures, along with the timing of the incentive payments.

For the purposes of this column, we'll assume that your practice is considering an official launch beginning either in 2011 or 2012, since those practices that wait until 2013 or later will not be eligible to receive the maximum total incentive payments for meaningful use. Here, then, is a proposed action plan for EMR Meaningful Use Implementation:

The Basics

Make sure you have a certified EMR system. The certification process is still confusing. Although CCHIT is most likely the governing body tasked by CMS for certification, there are still outcries from smaller EMR vendors that feel they are being locked out of certification. The bottom line for practices is to thoroughly research any claims from EMR companies about certification before making a purchase. You also should probably avoid using a "home-grown" application.

Make sure you are using that EMR in compliance with the Meaningful Use criteria for your particular specialty. Refer to previous articles on this topic as well as the CMS Web site for specific thresholds on Core Set (which include certain Clinical Quality measures) and Menu Set objectives. The EMR system needs to store information as "structured data," i.e., data that can be identified by the EMR system, not just free-form text or scanned information. Your practice should obviously be running EMR on all cylinders — you wouldn't want to notify CMS that you will begin reporting two weeks after purchasing your EMR system because you won't be ready.

Get your ducks all in a row. All Eligible Professionals (EP) who wish to claim incentive payments must be enrolled in Medicare or Medicaid. Register via the EHR Incentive Program Web site and decide when to notify CMS that you are ready to begin reporting (see next step).

The incentives are given on an individual basis. This means that if a group practice has one physician who refuses to use EMR, only that physician will forego the incentives; the other physicians in that group will not be penalized. Still, this is obviously a situation that should be avoided, as any debit to the incentive payments affects the entire practice.

Next step: Decide when you will be ready. CMS is giving practices a "grace year" in 2011. There is no financial penalty for a practice that decides to wait until 2012 for implementing EMR. They can still qualify for the full incentive.

Why you would launch in 2011:

► Your practice is already at the 80% threshold for EMR use or will be by the end of this year.
► You want to recoup some of your capital outlay for EMR software and hardware as soon as it is realistically possible.
► All of the meaningful use objectives and quality measures can be demonstrated through an "attestation" process — you basically swear to CMS that you are meeting the objectives — rather than having to do so electronically.

If your practice doesn't meet these "readiness" criteria, don't even think about a 2011 implementation. As I will discuss next time, waiting until 2012 will give you the time to fully prepare for implementation. OM

Peter J. Polack, MD, FACS, is co-managing partner for Ocala Eye, a multisubspecialty ophthalmology practice located in Ocala, Fla. He is also founder of Emedikon, an online practice management resource for physicians and administrators.