Achieving “Meaningful Use” Without Tears

Being prepared early will translate to bonus payments.

Peter J. Polack MD, FACS

Like many things in life, you can either choose to do something or wait until something happens to you. Many physicians are taking the latter approach when it comes to electronic medical records implementation and the meaningful use (MU) incentives from CMS. Their feeling is that it would be safer to wait until EMR systems are perfected, to wait until the government certifies a particular EMR system, or until the MU requirements are 100% unambiguous. But these things may never come to pass. And after 2012, the MU incentives will start to decrease and then reimbursement penalties will kick in. This article will explain the steps you can take now to be in the best position to collect MU bonus payments when they become available to your practice.

Meaningful Use: What's the Point?

In his 2004 State of the Union address, President George W. Bush outlined his plan for the adoption of electronic health records that could be easily accessed by all citizens in the United States. The Department of Health and Human Services then created a 10-year plan to achieve that goal, although there was no specific funding set. Then, in 2009, as part of the American Recovery and Reinvestment Act of 2009, the HITECH Act (Health Information Technology in Economic and Clinical Health) allocated almost $30 billion to push the adoption of EHR through the use of financial incentives. Subsequently, rules were created that required those providers seeking incentives to prove they were using certified electronic health records technology according to a set of guidelines of quality healthcare, or in a “meaningful use” manner.

Deciding When to Start

In our practice, we had transitioned our old practice management (EPM) system to a new one with an integrated EMR a few years ago, but felt it prudent to wait a bit before we attempted to implement the EMR module. That came about at the end of 2008, so now that we have about 2.5 years of “live” experience with EMR, we are turning our attention to the MU incentives. But we haven't been idly sitting by. Using software we developed in-house, we have been qualifying for both PQRS (Physician Quality Reporting System) and e-Rx (electronic prescribing) incentives since their inception, in 2007 and 2009, respectively. Those have resulted in as much as a 4% bonus of our annual Medicare fees.

Although Stage 1 of Meaningful Use officially begins in 2011—with Stages 2 and 3 slated for 2013 and 2015, respectively—we decided that we would wait until 2012 before seeking the MU incentives. The Office of the National Coordinator on Healthcare IT (ONC) announced that practices can qualify for the full MU incentives starting either in 2011 or 2012. The ONC also ruled that practices can get PQRS incentives concurrently with the MU incentives. So why would we wait another year? ONC also ruled that MU would disqualify e-Rx incentives, so this would give us another year of e-prescribing bonuses plus another year to get our practice ready for MU. This means, however, that we have only one year to prepare for Stage 2 in 2013 instead of two, but that requirement mostly builds on the work that needs to be done for Stage 1.

Some practices are ahead of the curve. Horizon Eye Care is an eight-doctor ophthalmology practice in Margate, NJ. Like our practice, they use an integrated EMR/EPM system, but they have been using the EMR module for the past 10 years. According to Sandra Regenye, Director of Billing at the practice, they were ready to qualify for MU this year, but also decided to wait until 2012, since there was no decrease in the total incentives for waiting. And in addition to being able to collect e-Rx incentives for 2011 (which as I mentioned are excluded under MU), this is allowing their practice to perform simulations to test run the reporting process.

Ms. Regenye points out that it is the practice that must be a meaningful user of EMR, not the EMR system itself. “If you are not using your EMR in an appropriate manner, then you are not a ‘meaningful user.' Even the best, certified EMR system cannot magically qualify you for MU incentives. There is no ‘plug-and-play' for meaningful use.”

Getting Ready for the Reporting Process

For this year, the first year of meaningful use, practices are only required to attest to the fact that they are meeting the MU requirements. Attestation means you are collecting the data in some fashion, even if you are only doing it manually, as on a spreadsheet. For 2012, practices will need to actually collect and submit the data to CMS. The attestation process officially began on April 18, 2011. CMS offers webinars and updates with specific details. Ms. Regenye says these have not been totally clear “but they are getting better.” She also recommends that all practices register with Medicare now, even if they don't have an EMR system yet.

For 2012, attestation alone is insufficient. CMS will require practices to officially report on their meaningful use criteria, which for most practices will be a total of 20 (all 15 Core Set and five out of the 10 Menu Set items). Some items in the Core Set only need to have functionality enabled (such as Exchanging Critical Information) or performed at least once (Security Risk Analysis). Others will become a daily part of a practice's workflow (such as Demographics or Smoking Status) and must meet a certain threshold (such as 50% of the number of unique patients seen for the year), unless they are not appropriate for that practice specialty. For a complete list of the meaningful use criteria, visit the cms.gov Web site.

Many certified EHR systems will have a means to upload the report files to CMS, either directly or using report-generating software, while other practices may use a third-party solution such as registries, the same ones that were helping them report PQRS. But while Stage 1 may consist of simply requiring a practice to report on a specific criterion, Stage 2 may contain additional requirements and higher thresholds. An example of this would be providing a Clinical Summary Report for a patient. In Stage 1, you can document the preferred format but do not necessarily need to supply it in that format, whereas in Stage 2, you might have to comply with that specific request. And this can make the reporting process that much more onerous.

For those practices that haven't yet done so, Ms. Regenye has some recommendations for getting a start on meaningful use:

► Make sure you are using a certified EHR system. For a list of certified EHR systems, go to http://onc-chpl.force.com/ehrcert.
► Make sure you have a solid understanding of the MU requirements.
► Do your homework. Don't count on any one resource to base your plan on. Check your EMR vendor's resources, CMS or OMB, for example, for webinars, podcasts and white papers.
► Go through all of the measures to see which ones apply specifically to your practice. For example, vital signs would not be an appropriate measurement for an ophthalmology practice, so the denominator for reporting purposes would be zero.
► Take a look at your workflow processes and see how they are potentially impacted by the collection of data for the requirements. An example would be the preferred language of the patient—when is it collected, by whom, where is the information stored and is it a required field in your EMR system? (It should be.)
► Then check your EMR templates to see where this information is entered and stored. It may not be where you need it, when you need it.
► Have an idea how you will do the reporting. Again, for 2011 only attestation is required. But in 2012 and beyond, reports will need to be submitted to CMS. Your EMR system needs to be able to collect the data you need, if not actually submit it.

Like the Boy Scouts, Be Prepared

Follow these relatively simple steps now and you will not be pressured or overwhelmed when the time comes to actually report the documentation required of your practice. The keys to qualifying for MU bonuses are:

► Make the decision when to begin reporting (2011 or 2012).
► Gather all the relevant information you can.
► Know exactly what is expected of your practice in meeting the MU requirements.

Though you may have to make some adjustments along the way, having the basic foundation in place for MU compliance now will position your practice favorably for the future. OM

Peter J. Polack, MD, FACS, is co-managing partner for Ocala Eye, a multisubspecialty ophthalmology practice located in Ocala, Fla. He also is the writer of Path to Paperless, a long-running column in Ophthalmology Management that keeps ophthalmology practices updated on the appropriate use of the latest technology available for practice management.

How I'm Working Towards Meeting “Meaningful-Use“ Criteria By Joseph Sokol, MD

For those who have been down the road with Medicare on incentive programs (think PQRS), the EHR “meaningful use” incentives can appear to be yet another set of hoops to jump through and acronyms to master. As a physician who implemented EHR more than four years ago and one who can attest to the patient benefits, I view the incentives as an opportunity to finally get paid for having done the right thing for my patients. So, here's the approach I'm planning and what I'd advise for those who want to stay on track to qualify for the incentives this year. Talk with Your EHR Vendor Your first call should be to your EHR vendor — ideally one who has achieved ONC certification. You must use an ONC-ATCB Certified 2011/2012 EHR that supports all activities required to demonstrate meaningful use (a list of all certified health IT products is available at http://onc-chpl.force.com/ehrcert). ONC refers to the Office of the National Coordinator for Health Information Technology (the government agency entrusted with helping physicians to implement EHR) and ATCB denotes “authorized testing and certification body,” (there are five: CCHIT, Drummond, ICSA Labs, InfoGard and SLI Global). ONC-ATCB certification is mandatory to qualify for meaningful use bonuses. Bear in mind that certification is both product-specific and version-specific. Confirm with your vendor that the version you are using is in compliance with the ONC-ATCB certification process. Your EHR vendor should be able to show you how the system will support you in collecting and reporting on the data required by CMS. They should also be able to provide you with overall guidance on the process for collecting the incentives. This includes registration, reporting/attestation and any important deadlines you need to meet. Register to Report To receive the federal EHR incentive, the first step is to register. This is perhaps one of the biggest hassles you'll experience in your EHR journey. I suggest setting aside time to focus on completing the registration process; again, get your vendor involved if you need help. You'll find step-by-step instructions by logging on to the CMS Web site www.cms.gov/EHRIncentivePrograms/20_RegistrationandAttestation.asp. Use Your EHR Software to Track Your Progress Whenever possible, make things easier on yourself with the built-in meaningful use reporting your system offers. For example, I use Compulink's Ophthalmology Advantage, which helps me run nightly reports to make sure captured data is correct, and the reports are complete. If I've missed something, the reports will let me know what data is missing, and I can address the issue immediately. This will help me get it right the first time and, hopefully, lead to a quicker government payout of the bonus. Compulink also incorporates meaningful use checks in their Health Care Maintenance tool that will remind me of items I may have forgotten to document during the exam. There is enough flexibility with the meaningful use menu set requirements that you can find the ones that apply most closely to ophthalmology, and in fact you should already have customized your system to run through the criteria you'll use most, and which will be exempted under most conditions. Instructions on how to complete the registration process are spelled out in detail on the CMS Web site. And Remember… As challenging as the EHR meaningful use process may seem to physicians, the government has put the biggest proof of meaningful use burden on EHR software vendors, who have undergone software upgrades and the ONC certification process to make sure systems track what the government is looking for. In fact, the certified version of the software does most of the work for achieving meaningful use. So rely on your vendor to assist in the process and help you get off to a good start. Joseph Sokol, MD, is a glaucoma specialist in private practice at CT Eye Specialists in Shelton, Conn.