By Dr. Steven J. Kraus, DC, DIBCN, FIBCN, FASA, FICC, Founder and CEO, Future Health
The pieces are continuing to come together for DCs and the American Recovery and Reinvestment Act’s (ARRA) incentive program. Sure, it’s taken many 3 years to get in, but this is it, the last year to get in.
The Medicare EHR incentive is happening. And as a DC, the ball is now squarely in your court. 2014 is the absolute last year to be eligible for receiving the incentive checks, with 2 notable deadlines: July 1, and October 1.
This article clearly outlines what your next steps should be for first time (2014) Meaningful Users … and provides a brief history of what brought us to this point.
1) As a DC, you are absolutely eligible for up to $24,000 in ARRA incentives.
At one point there seemed to be some skepticism surrounding whether DCs were even eligible for the ARRA incentive.
That skepticism was finally put to rest once and for all with the January 13, 2010, “Notice of Proposed Rulemaking,” published in the federal register by the Centers for Medicare & Medicaid Services (CMS), in which chiropractors are specifically mentioned by name as eligible providers.
What’s more, CMS specifically modified requirements for DCs so that they could more easily qualify for the incentive by granting several rule exclusions that didn’t apply to chiropractic.
2) The up to $24,000 ARRA incentive isn’t the real reason to implement an EHR.
The reason to implement an EHR is because it’s the right thing to do … for your practice, your patients and yourself.
An EHR, over time, will help you and your staff become more efficient, lower your expenses, give you more time to see patients, reduce audit risks, increase collections and demonstrate your professionalism with high quality records. The up-to-$24,000 incentive is icing on the cake.
3) ARRA incentive money is NOT intended as a reimbursement… it’s an incentive.
The amount you’ll receive isn’t based on how much you spend on your EHR. IT’s based on 75% of your total Medicare-allowed charges submitted. For example, in 2013 you can receive up to $12,000 as long as you: 1) Have up to $16,000 in Medicare-allowed charges throughout the year (lesser amounts still qualify); 2) Use your certified EHR in a meaningful way for 90 consecutive days.
The money is designed as an incentive from the government in order to get you to implement a certified EHR. And it’s intended to help cover the costs of software, hardware, implementation, training with staff and more.
Why would the government pay you to implement an EHR? Because they’ll benefit from efficiencies and standardization of data across the healthcare community and save an estimated $77 billion dollars annually.
Purchasing the most expensive EHR on the market is not going to secure your payment any more than a doctor who paid substantially less.
The amount is based on 3 things:
- Use of a certified EHR in your practice
- Meaningfully using the EHR according to 17 of the criteria
- Applying for the payment at the end of the year
4) How can you determine how much you stand to collect in ARRA incentives?
The amount you stand to collect is based on your Medicare-allowed charges over a certain period of time.
Specifically, you’ll receive 75% of your eligible Medicare-allowed charges, up to the maximum limit for a certain payment year.
The maximum limits are shown in the chart below
So, for example, if you have a certified EHR and meet meaningful use requirements in 2014 – and your annual Medicare-allowed charges submitted total at least $16,000 – you’ll receive 75% of that $16,000, which is $12,000 (the full amount allotted in 2014).
Or, if you had $10,000, say, in annual allowed charges submitted to Medicare for the full calendar year of 2014, then you would still receive 75% of that – which is $7,500 – for 2014.
Another important note is that it makes no difference if you are a participating or non-participating doctor.
To recap: You must be registered as a Medicare provider in order to qualify for incentive funds. The amount is not an all-or-nothing proposition: If your Medicare-allowed charges don’t qualify you for the highest amount, you’ll still collect 75% of your Medicare-allowed submitted charges for services that were provided in that calendar year, no matter what that totals with maximum amounts listed above in the chart.
5) Every DC stands to collect up-to-$24,000 individually… regardless of how many DCs practice in your clinic.
The up-to-$24,000 incentive is per doctors… not per clinic. So each DC in your practice can collect up-to-$24,000, depending on their submitted Medicare-allowed charges.
6) In order to qualify for incentives, you must use a certified HER to the 2014 Edition Standards, as determined by the federal government.
How will you know whether an EHR is completely certified according to the new 2014 standards? Simply by asking the EHR company or you can obtain a listing on the ONC website to look up certified products.
Not all software companies will choose to go through the new 2014 certification process, because it’s expensive and time-consuming. For example, companies who offer standalone software for documentation or billing are not as likely to become certified as an integrated software provider. Some EHR software companies who were certified from 2011-2013 have now had their certifications expire; which means they must get re-certified for the 2014 Edition. When you perform meaningful use in 2014 during your reporting period, the EHR software must be certified according to 2014 Edition standards from the start date of your reporting period.
It’s critical to ensure any software you’re considering is certified before you begin your MU reporting period. What’s more, it’s important to ensure it’s really a TRUE EHR! Do your homework now so you’re not left empty handed when it comes time to collect funds. Be sure it can operate your practice and meet your daily functions.
7) You’ll also need to show that you’re using your certified EHR in a “meaningful way” in order to collect incentive money.
For Stage 1: Most DCs will need to only meet approximately 12 of the 15 “Core” meaningful use items, with exclusions related to e-prescribing. You’ll also need to meet approximately 5 of the final 10 “Menu–Set” criteria from a list of 10 additional meaningful use items, making a total of 17 minimum criteria you must meet in order to demonstrate meaningful use of your EHR for Stage 1.
All 17 criteria are relatively easy for you to obtain … especially considering the exclusions most DCs will be granted.
The meaningful use list includes things like recording the patient’s preferred language, gender, race, ethnicity and date of birth and smoking status. It also includes things like sending reminders to patients for preventive/follow-up care based on their preferences.
It may sound daunting to have to meet approximately 17 requirements. But much like the certification process, you should be able to have your staff complete 90% of the work and your EHR provider should provide guided training to make it easy for you to demonstrate meaningful use with your EHR. The good news is that these 17 items are not required on each visit, but rather they are items or pieces of data that need to be capture in the chart during that year. Most DC’s who have already successfully achieved MU have said it was easy after they received the proper training, which is about 8 hours for the one key staff person and the DC.
8) Penalties begin on January 1, 2015, for all DC’s who have never completed MU prior to October 1, 2014.
If you are thinking about starting MU, then think fast. You need to start by July 1, 2014, in order to complete it by October 1, 2014, in your first year. In doing so, not only are you able to get up to $12,000 in your first year of MU for only 90 days of work; but, you will also avoid payment reductions from your regular Medicare reimbursement checks for patient care that are scheduled to start on January 1, 2015. There is a 1% penalty reduction to all reimbursement checks issue to you from Medicare carriers for 2015 reimbursements if you have not attested for MU by October 1, 2014. The penalties increase and compound each successive year thereafter by an additional 1% annually.
9) It’s in your best interested to implement an EHR sooner rather than later.
Now is the time to implement your EHR. You can take advantage of up-to-$24,000 in government incentives… and you can avoid penalties down the road. There’s really no reason to wait. Choose a partner who has a track record in helping their customers achieve meaningful use and getting DC’s an incentive check. Choose a company that will train you on the MU criteria and how to correctly perform the criteria and how to attest at the end of each year to get your incentive payment.
About the Author
Dr. Steven Kraus is CEO and Founder of Future Health, a chiropractic management software firm that focuses on helping doctors utilize technology, including EHR, to effectively enhance overall practice success. For more information about Future Health SmartCloud—including information on how Future Health SmartCloud can help you meet ARRA requirements for up-to-$24,000 in incentives—visit www.futurehealthsoftware.com. Or call 1-888-919-9919.
How to empower your technology:
Four essential choices that could make or break your investment in electronic health records
When purchasing an EHR, there are four important choices that could make or break your investment. How much you spend is a factor in each, but cost alone is not the only choice.
So what are these four essential choices that can empower (or hinder) how you use your clinic technology? Your choice between cloud-based software or an EHR that runs on a server in your office. Your choice between documentation that is customized to your practice, an EHR system that arrives loaded with general practice templates, or one that requires you to create and load nearly all commonly used material and selections in drop down boxes. Your choice between robust service, maintenance, and training plans, or the least-expensive do-it-yourself support plan you can find. And finally, your choice, whether or not to pursue a certified EHR allowing you to be eligible for incentive payments from Medicare and to have a system that meets federal guidelines.
1. Cloud-based service or local server?
Electronic health records (EHR) have two main platforms for delivery of software and data service options: cloud-based services or software that runs on a local server in your office.
What’s the difference? To keep it simple, you can think of cloud-based service as largely working over the Internet, and a server-based service working through business-class servers in your office. A local server is going to require more hardware cost, IT expertise, and ongoing IT maintenance of your internal network than a cloud-based service, where someone else is managing these components for you, someplace else (ie. The Cloud).
And what about costs? With very rare exceptions, most doctors just do not have the background or experience to set up their own server. Firewalls, user permissions, and the security required for HIPAA really require an IT expert. Depending on the size of your in-office network, the cost of maintaining the network and paying an IT professional could range from $1,500 to $3,500 per year for a small to medium sized practice. Larger clinics can pay $5-15 thousand dollars annually. Since a small business class server could run from $2,000 to $3,000, many clinics will spend about $5,000 annually on their server equipment and maintenance. Plus, every 4-5 years you usually have to replace the server and continually update the operating software the server requires.
Cloud-based EHR systems, on the other hand, can range from $39 to $399 per month depending on the service plan and robustness of the software functionality. There is an upfront licensing fee for purchasing most cloud-based software systems depending on if it is certified software or how much functionality initially comes with it.
With higher maintenance and hardware costs, why would a doctor choose a server? There are three primary reasons why investment in a server would make sense.
- Geographic location and local Internet infrastructure may not offer enough internet bandwidth speed for efficient cloud-based EHRs. If your Internet providers do not have higher speed availability and it is really slow, it can slow down your efficiency and will become an annoyance.
- Large to mid-sized clinics with multiple employees and providers, workstations, and multiple locations may find it cost efficient and user efficient to maintain a server for the flexibility it offers.
- There may already be server components in the clinic with digital radiology and other diagnostics. Upgrading to a larger server environment may not be that much of a jump since the investment is already made in larger practices that already have IT costs as part of their monthly overhead expense.
There is also a fourth aspect to choosing a server that should be mentioned: the psychological component. Some doctors really like being able to see the actual equipment on which all their valuable clinic data is stored. Cloud-based services are stored on high-end fast servers in HIPAA compliant environments. You can’t see them, but you can usually access your data from most anywhere over the internet. Cloud systems are typically more mobile than local server environments.
Besides cost, are there other advantages to cloud-based EHR systems? Security and accessibility are probably the largest advantages. Cloud-based services are responsible for keeping your EHR data safe and secure in their HIPAA controlled environment. With a server, that responsibility is on you. Secondly, with cloud-based services, your clinic data is available from anywhere, just as long as you have a user name and password.
What’s the bottom line? Cost may be the number one factor for server versus cloud, but Internet speed and accessibility are important too. It may be helpful to work with an EHR company that has experience in server-based and cloud-based services to understand all of your options. One myth perpetrated by some is in regards to who owns the data if it resides on the cloud. You still own your patient data and can have a copy of your data should you decide to change software providers.
2. Customization, templates, or the best of both worlds?
Features are where a lot of doctors get hung up. What do they need? What do they want? And what are they really going to use long after the ink is dry on their service contract?
Many doctors want the best of both worlds.
Not wanting to be forced into a small practice box, many doctors say that they want to customize their electronic health records—but only to a point. But they also do not want to do all the work themselves. They would like to have essential practice documentation information arrive loaded on their software. For example, information on orthopedic tests, their interpretation, and even how to perform the tests can be listed in the notes in pre-loaded EHR software. Doctors also want to be able to easily add their information to an already existing library, while being able to turn on/off certain functions that are important to their practice.
They want it to feel personal, out of the box, but also seamless.
If this description fits your own approach to EHR, then take note: this choice may be the most important to your own personal satisfaction with your software. There are some programs that come loaded with dozens and dozens of different screens for every kind of practice—except you cannot really prioritize how they appear, nor turn them off. And there are programs that sell on their customization—but offer little more than a text box for each section of your SOAP note.
What’s the bottom line? Documentation means being able to tell the story of your care as accurately and efficiently as possible. Yes, the best of both worlds is possible to find, but you have to know what is essential to your clinical work flow, and work with a company that understands the variety of options in chiropractic care. If you want all the bells and whistles handy, make sure they will not slow you down—see if you have an option to turn them off, or at least prioritize how they appear. And if you want customization, make sure that does not mean you have to do all the work. You do not have years to get your documentation right, as some doctors have taken years to load and customize their system because it was not pre-loaded with chiropractic specific nomenclature or templates. Having the system pre-loaded with chiropractic templates and list selections is great when combined with the ability to customize lists and insert your way of saying things into the note. Being able to save those commonly used phrases to be used later is a key. The workflow design is important so that you can access those custom methods quickly inside your workflow.
3. Limousine tech support, or bare-bones service?
There are a lot of factors that go into your EHR costs, and perhaps the most significant is your need for service and support. Data storage, managed data services, customer service, and ongoing training for new hires, along with software updates, all have associated costs. These are the bulk of your annual fees for larger, more robust EHR systems.
Do you need a luxury class technical support with e-mail hotlines, click-to-chat, one-on-one trainings, and other help available almost on demand? Or you can you thrive simply on watching a catalog of support videos while utilizing webinar based training, or just a written manual—the bare-bones of tech support?
The largest and most intensive maintenance and support contracts can range up to $6,000 per year for the above features, whereas the bare-bones service and support may only cost $39 per month. What your clinic needs depends on your technical confidence, your staff’s technical confidence, the number of providers in your practice, and of course, patient volume.
What is the bottom line? Some doctors try to get away with the least maintenance costs possible and will skimp on training and support. Beware if you are tempted to save costs here. Paying for technology that empowers your practice is an exercise in futility if you pass up the upgrades, support, and training necessary to help your clinic run at maximum efficiency. Many doctors are often unaware of the full features and functionality of their software due to lack of training or due to an “I can figure it out on my own” mentality. Plus, with government regulations changing and the health care industry advancing in EHR technologies, keeping your system updated is crucial to staying compliant.
4. Medicare incentive payments: is it worth it or not?
Adopting an EHR system for the CMS incentive program is not a good reason to adopt EHR if it is your only reason. That said, this $24,000 incentive payment is moving some doctors to adopting an EHR system faster than they would have otherwise, and they want to know: is it worth it? Here are some guidelines to help you make this choice:
- Does your clinic have Medicare patients, and does the dollar amount of the allowed submitted charges for those patients total more than $5,000 in a calendar year? If the amount is less than $5,000 then working to demonstrate meaningful use may or may not be worth it since your payment will be around $3750 at best. This $5K threshold is merely an opinion and not any federal regulation. After helping guide hundreds of DC’s to receive a check for $18,000.00 in just their first 90 days of MU (meaningful use), I can tell you that the amount of work to achieve MU was mostly done by their staff who needed about 6-8 hours of training to fully understand it all. Now, it’s just part of their normal duties and seems natural as they complete the data entry requirement without thinking about it.
- If your clinic goes over $5,000 in allowed submitted charges for Medicare patients, do you have a few hours per week free to deal with MU? If your schedule is mostly booked and you have no down time, then the opportunity costs may not be worth it unless you have a staff person available who can do 90% of the data entry work for you for a few hours a week. Ninety percent of MU criteria can be performed by staff.
- If you have more than $5,000 in submitted charges, and your schedule is regularly open a few hours per week with down time, then it will most definitely be worthwhile to demonstrate meaningful use with your EHR program to qualify for the CMS incentive payment for up to $24,000.00. The amount you can receive is based on 75% of your allowed submitted charges in a calendar year; that will determine the incentive amount that you are eligible for over a 4-year period with maximum threshold amounts capped each successive year. You can learn more about the CMS incentive rules by downloading an article that explains it very well at www.ehrresourcecenter.com
With the right combination of allowed submitted charges, Medicare patient volume, and down time, most clinics can pay for the bulk of their EHR system, covering the costs of hardware, software, and time invested to train and prove meaningful use.
What is the bottom line? If incentives for meaningful use will help raise your profit and pay you for your time, then incentives make sense. But keep in mind that a certified EHR is still worthwhile even if incentive money is not available. You know the saying, as Medicare goes, so too goes private insurance, and it may not be long before a certified EHR is necessary to be on a panel of preferred providers for general health insurance carriers. The sooner you adopt a certified EHR, the sooner you reap the benefits of a more efficient practice. (Note: CMS will begin penalizing providers who do not perform MU with a certified EHR, starting in 2015.)
These four essential choices will not only affect how much money you spend on EHR, but will also help or hinder how well you use your clinic technology. These choices will determine whether your technology actually empowers your clinic, or if the technology becomes just another cost of doing business. Who can help you make the right choices for your clinic? You can start by finding a company which understands each of these essential choices and even offers solutions from both sides of each issue. None of these choices has a universal right or wrong answer, just an answer that is best for your clinic. Will your choice be the empowering choice for you?
Steven J. Kraus, DC, DIBCN, CCSP, FASA, FICC, is Founder and CEO of Future Health―a chiropractic management software firm that focuses on helping doctors utilize technology, including EHR, to effectively enhance overall practice success. He is an acknowledged expert in Health IT, including EHR (electronic health records) and the up-to-$24,000 ARRA incentive program to implement EHR.
He lectures to state associations and at industry events regarding EHR and the relationship to documentation presenting monthly webinars on how EHR usage will impact doctors of chiropractic. For more information, visit www.FutureHealthSoftware.com or call Toll Free 1-888-919-9919, ext. 652.
By Steven J. Kraus, DC, DIBCN, CCSP, FASA, FICC
Cloud computing is not only going to permanently change the way you interact with you clinic records and software but is going to change the security and accessibility of our clinical and patient data as well. Shifting to the cloud will alter the way you practice and will finally recognize our profession for the contributions we make to our nation’s health.
Cloud computing is going to change the way chiropractors practice in three ways:
1) Data back-up will be less costly and easier to maintain
2) Data will be more secure and permanent
3) Data will be more accessible to us and our patients
What is cloud computing?
Cloud computing: an internet accessible database of your clinic’s patient chart and your practice management systems data. This happens when the Internet itself becomes the connecting method where your data is stored and managed.
First, cloud computing will not be like current web-based programs. These programs allow you access to the software through a web browser, where you sign-in through web-browser, and everything is stored on a web server.
Second, cloud computing is not like the “client-server” model where the software and the data is stored within the four walls of your clinic. This model deals with computers that need software programs that then need licenses which we then have to install on our machines and go from there. Larger clinics have to have an internal network hooked to an internal server.
The benefits and weaknesses
The major benefit of the browser-based model is that it’s simple. There’s no extensive software to install, and not a lot of hardware to buy, just access to the Internet. This simplicity does come with a price: the software itself is simplified and it cannot be as graphics-heavy and robust.
The strengths and weaknesses of the client-server model are actually the opposite. The client-server is faster and can be graphics-heavy, because everything is stored locally. This then involves more hardware, infrastructure, and running of servers.
Internet-computing with power
Cloud computing effectively offers us the robust software that we are used to with the client-server model, along with the simplicity of the web-browser model. Much of the software is stored on your local PCs. But the connection to the cloud’s servers means you can network your computers without a server inside your office. When you log-on to your clinic software suite through your computer, you will be using the EHR software loaded on your PC for screen interfaces. You will be using the internet to access the cloud servers for your database.
Lower Costs and easier to access data
With Internet-based data you need less “stuff” to make your software work, and that means savings. The cloud model simplifies the process of establishing and implementing an EHR into a clinic. With a few regular computers hooked up to the cloud through a local high speed Internet connection, the office is ready to go.
As technology advances we are able to save more and more data in smaller and smaller spaces. This combined with the fact that the HIPAA-compliant paper-file storage units, file folders, and all the accessories that make paper records work, will not be necessary, further reducing costs.
This technology is relatively simple: with less hardware, and everything being stored remotely on cheaper memory, cloud computing will eventually decrease the costs associated with electronic health records.
Safer and more permanent records
We tend to think that digital data is more vulnerable than paper records, but nothing is further from the truth. Just like credit card data, banking data, and your Amazon purchase history, private health information will be adequately protected and secured by federal standards like encryption technology.
Cloud data is so accessible because of what makes it safer than paper: redundancy. When you write a SOAP note by hand, you get one copy of that SOAP note. When you write a SOAP note within an electronic health record on the cloud, you get that original note, a backup, and even a second and third backup on different servers.
More accessibility and transparency
Cloud computing will protect our data from prying eyes and give us the ability to aggregate patient de-identified data to demonstrate our outcomes. Outcomes data is going to be more transparent to our patients and the health care community as we move forward.
Cloud computing will also allow faster sharing of records in a multidisciplinary or interdisciplinary setting. In the traditional electronic health record model, we would electronically fax or email a narrative report. Soon there will be state-operated Health Information Exchanges (HIE) that will allow you to obtain information on your patients. In the near future of cloud computing, we might see medical doctors logging in to HIE to see their patient health data and learn that chiropractic care has resulted in a successful outcome for the patients.
Less costly, safer and secure, faster access
The shift to running our clinic software through powerful remote servers is going to reduce hardware requirements needed to run clinics. It is also going to make our data storage less costly and more secure, and ultimately more accessible, to better improve the care we deliver to our patients.
You Teach, They Learn…and Keep Coming Back
Most people already have a predetermined notion of medicine instilled in their minds. It’s been there ever since birth as medicine controlled most aspects of pregnancy and delivery of a child. These notions are further enforced as people continue to see mainstream doctors as they get older and these doctors plant seeds of knowledge into their patients’ minds. By watching shows such as Grey’s Anatomy, Bones, and House, patients get more ideas planted in their heads about the way they think medicine should work.
Unfortunately, there’s never any shows about chiropractors or they work they do on people’s bodies. Only a handful of people ever go to a chiropractor at all, and the only way they can really influence anyone else’s opinion of a chiropractor is through word of mouth, and this isn’t always the most trustworthy form of marketing for any field.
With chiropractic, the first few visits are critical with a treatment plan. Since patients have this preconceived notion of what treatment is like, if they decide that they don’t need to be seen or follow through with treatment orders, they’ll just stop because their minds tell them that they’ll be fine without finishing the treatment. Chiropractic has the solution to this.
What needs to happen is patient education on behalf of all chiropractors. We need to show what the strengths of our practices are, and we can do this through helping them understand why we recommend certain exercises and diet suggestions.
Three things can be done to help a patient understand why a specific treatment would be beneficial to him or her:
- Don’t explain or convince.
- Determine the patient’s role.
- Ensure commitment to the program.
Don’t explain or convince.
When trying to teach a new technique or reasoning behind a certain technique to a patient, don’t sit there and try to explain to them the terms behind the treatment, and certainly don’t sit there and try to convince them that they need this treatment. It works much better to calmly tell the patient that by seeing him, you’re deciding whether a treatment would be a good fit for him or not, which intrigues the patient a little bit by thinking that they’re getting a pinch of special treatment. When you see the patient for the next visit, that’s when it is beneficial to you to explain to him why a specific treatment would be right for him.
Determine the patient’s role.
The patient needs to understand that in order for his treatment to work, he needs to know what he must do to complete his part of the treatment. Most treatments assigned to patients require work from both the patient and the physician, whether it be certain exercises that must be done or a specific diet that must be followed. Answer any questions the patient might have and assure them that you will be with them every step of the way to fully complete treatments.
Ensure commitment to the program.
Make sure that your patient will commit to the program and follow your recommendations. If they don’t, then it’s your decision to do something about it. Instead of begging and pleading with your patient to follow your orders, let them know that you’re here to help, and it will make them better if they do their share. Tell them what they need to do and ask if they’re willing to do it. Chances are that they’ll jump on the bandwagon and prepare themselves for the challenge.
Another way that you can influence your patients by educating them is your waiting room materials. This seems pretty obvious, but if a patient has to wait a few extra minutes before their appointment, they’ll usually pick up something to read or look at their surroundings. Provide them with informational materials to read and perhaps a few posters on the walls to give them something to look at while they wait for their appointment.
Dynamic Chiropractic, an online chiropractic resource, provides chiropractors with a full-color handout meant for patients to read in the waiting room. It’s called To Your Health and it’s received praise from chiropractors for its information doled out to patients. These articles can spark discussions between you and your patients.
One of the most revolutionary forms of patient education is the [pm: virtual forms] that are surfacing. Instead of those boring posters that sit in the exam rooms or waiting rooms, chiropractors are implementing virtual posters, where a video is projected onto a screen for the patient to watch before she meets with the doctor for her appointment. Mini-videos are also available. Even if the subject in the video isn’t exactly what the patient is being seen for, the idea is that the patient retains that information, say about headaches, and when a friend or family member suffers from headaches, she can tell her friend or family member to go visit the chiropractor to have those headaches treated. You can learn more about this revolutionary form of patient education at the Future Health Software website.
Patient education is a very important tool for making your patients aware of the reasoning beyond the treatments you are prescribing. If your patients trust you and like you, they will refer you to their friends and family members, bringing in more revenue for you. Implement new forms of patient education to make your clinic a clinic of the future.
CMS Releases Meaningful Use Stage 2 Requirements
What it means if you’re already using EHR software … and what it means if you’re planning to start next year
By Steven J. Kraus, DC, DIBCN, CCSP, FASA, FICC
CMS recently released its final rules for Stage 2 Meaningful Use under the American Recovery and Reinvestment Act and the specific Health Information Technology for Economic and Clinical Health (ARRA-HITECH) Act.
At more than 600 pages, the rules are extremely detailed. Initial reactions are fairly positive, and it appears that CMS took into account the comments provided on the proposed rules by groups like the ACA and individual providers like me.
Here are 9 key takeaways from the newly released rules:
1) Requirement of Stage 2 Meaningful Use criteria delayed
Under the proposed rules, providers were to progress to Stage 2 Meaningful Use criteria after two program years of meeting Stage 1 criteria.
For example, Medicare providers who first demonstrated Meaningful Use in 2011 would need to meet Stage 2 criteria in 2013. CMS has now delayed the onset of Stage 2 criteria so that the earliest a provider would have to demonstrate Stage 2 criteria is 2014.
This chart outlines required Meaningful Use stages based on the first year a Medicare provider begins participating in the program.
Note: Providers who were early demonstrators of Meaningful Use in 2011 will now meet three consecutive years of Stage 1 criteria before advancing to the Stage 2 criteria in 2014.
All other providers would meet two years of Meaningful Use under the Stage 1 criteria before advancing to the Stage 2 criteria in their 3rd year.
2) 3-month EHR reporting period for Stage 2 in 2014 only
Those who completed their first year of Meaningful Use in 2011 or 2012 will only need to complete 90 days of Stage 2 Meaningful Use in 2014. Note: This 90-day Stage 2 timeframe is ONLY for those who successfully demonstrated Meaningful Use in 2011. Then, in 2015, these providers must complete a full year of Meaningful Use.
Those who begin Stage 1 Meaningful Use in 2013 will complete their first year of Stage 2 in 2015 and will be required to do so for the entire year.
Please don’t confuse this 90-day timeframe of Stage 2 with the first year Stage 1 90-day timeframe. All providers who begin Stage 1―no matter what the year―will only have to complete 90 days of Stage 1 Meaningful Use their first year.
It should be noted that, while you only need to demonstrate Meaningful Use for 3 months, you still have the full 12 months to accrue Medicare-eligible billings and maximize your incentive amount.
3) Stage 2 retains core and menu-set criteria structure for Meaningful Use objectives
Although some Stage 1 objectives were combined or eliminated, most of the Stage 1 criteria continue in Stage 2, and some menu-set criteria have become core objectives under Stage 2. For some Stage 2 objectives, the threshold percentages that providers must meet for the objective has been raised.
4) Stage 2 criteria consists of 20 objectives
To demonstrate Meaningful Use under Stage 2 criteria, providers must meet 17 core objectives and 3 menu objectives, for a total of 20 objectives. For the menu objectives, providers must select 3 items from a list of 6 options.
5) Core and menu set criteria for Stage 2 Meaningful Use
Physicians must report on all 17 core objectives:
- Use computerized provider order entry (CPOE) for medication, laboratory and radiology orders
- Generate and transmit permissible prescriptions electronically (eRx)
- Record demographic information
- Record and chart changes in vital signs
- Record smoking status for patients 13 years old or older
- Use clinical decision support to improve performance on high-priority health conditions
- Provide patients the ability to view online, download and transmit their health information
- Provide clinical summaries for patients for each office visit
- Protect electronic health information created or maintained by the Certified EHR Technology
- Incorporate clinical lab-test results into Certified EHR Technology
- Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research, or outreach
- Use clinically relevant information to identify patients who should receive reminders for preventive/follow-up care
- Use certified EHR technology to identify patient-specific education resources
- Perform medication reconciliation
- Provide summary of care record for each transition of care or referral
- Submit electronic data to immunization registries
- Use secure electronic messaging to communicate with patients on relevant health information
Physicians must report on 3 of 6 Menu Set Objectives:
- Submit electronic syndromic surveillance data to public health agencies
- Record electronic notes in patient records
- Imaging results accessible through CEHRT
- Record patient family health history
- Identify and report cancer cases to a state cancer registry
- Identify and report specific cases to a specialized registry (other than a cancer registry)
6) Clinical Quality Measures (CQMs)
All providers are required to report on CQMs in order to demonstrate Meaningful Use.
Beginning in 2014, all providers … regardless of their stage of Meaningful Use … will report on CQMs in the same way.
Providers must report on 9 of 64 total CQMs. In addition, all providers must select CQMs from at least 3 of the 6 key health care policy domains recommended by the Department of Health and Human Services’ National Quality Strategy, which includes:
- Patient and Family Engagement
- Patient Safety
- Care Coordination
- Population and Public Health
- Efficient Use of Healthcare Resources
- Clinical Processes/Effectiveness
7) Patient viewing, downloading and transmitting health information
One of the most controversial rules has to do with providing patients with the ability to view, download and transmit their health information. As such, providers must move forward with a patient portal, such as a PHR like Microsoft HealthVault, or an actual portal to their EHR.
This is a significant change from Stage 1, and it will take a significant effort to educate patients and get them to initiate the exchange. In the final rule, CMS lowered the threshold to 5% and added a “broadband exclusion” for rural areas with limited broadband access.
Because secure messaging has to be initiated by patients, providers will be challenged to educate patients on the availability of secure messaging as a communication option, and it remains to be seen how doable that will be.
In short, it’s doable, but may be a challenge for DCs less technically savvy.
8) Health information exchange between EHR vendors and organizations
With the goal of furthering interoperability, the proposed rule sought to ensure that providers were exchanging health data with users of other EHR vendor systems and with other organizations.
CMS will require providers to conduct one or more successful data exchange tests with a “CMS designated test EHR” during the EHR reporting period. According to CMS, the intent of that proposed rule is to foster electronic exchange outside established vendor and organization networks.
In the final rule, only one demonstration of this cross-vendor organizational capability is required. This will be a one-time test for the whole year and should be an easy criterion to perform and cross off to achieve compliance for getting the incentive.
9) Secure messaging with patients
One Stage 2 core objective is to use secure electronic messaging in order to communicate with patients on relevant health information. A secure message must be sent using the electronic 2013 Future Health messaging function of Certified EHR software to at least 5% of unique patients you see during the reporting period.
The incentive: deadlines and rewards
If you have not yet started Meaningful Use, the most you can now receive is $24,000 (from a previous high of $44,000). But you must begin Meaningful Use by October 2014 to collect up to $24,000.
If you do not start by October 3, 2014, you will get zero dollars.
Many DCs lament that they need to make more money. Compliance with this program will take several hours of work … most of which can be performed by your staff … and you can collect up to $24,000 per provider over the next five years …with $15,000.00 allowed for just 90 days of effort in 2013 for first-time meaningful users.
Ninety percent of Meaningful Use criteria can be performed by your staff. More than 4,400 DCs have already successfully achieved Meaningful Use. Most of those DCs received the maximum amount of $18,000 for their first year of Meaningful Use. This is a golden opportunity to inject more than $2 billion into our profession.
Take advantage of something all health care providers are implementing anyway. EHR will soon be a standard of practice. You can do it with training, determination, and simply taking your first step: Choose to do it now and get paid for it, rather than forced to do it later with no incentive money. You can be a leader or a follower.
Steven J. Kraus, DC, DIBCN, CCSP, FASA, FICC, is Founder and CEO of Future Health―a chiropractic management software firm that focuses on helping doctors utilize technology, including EHR, to effectively enhance overall practice success. He is an acknowledged expert in Health IT, including EHR (electronic health records) and the up-to-$24,000 ARRA incentive program to implement EHR.
Dr. Kraus has served―and continues to serve―on numerous committees and boards, including:
- ACA Computer & Technology Advisory
- ACA Legislative Commission
- ACA Quality Assurance and Accountability Committee
He lectures to state associations and at industry events regarding EHR and the relationship to documentation, and he presents monthly webinars on how EHR usage will impact doctors of chiropractic. For more information, visit www.FutureHealthSoftware.com or call Aaron Reynolds toll free at 1-888-919-9919, ext. 207.
What is a PHR and what is an EHR?
These two acronyms will see a lot of airtime in the next several years. But what do they mean?
PHR The personal health record (PHR) is an electronic, universally available, lifelong resource of health information used by individuals to make health decisions. People own and manage their information in the PHR, which comes from healthcare providers and the individual. The PHR is maintained in a secure and private environment, with the individual determining rights of access. The PHR is separate from and does not replace the legal record of any provider.
EHR An electronic health record refers to a medical record in digital format. An EHR is usually accessed on a computer, often over a network. The data can include patient demographics, medical history, medicine and allergy lists (including immunization status), laboratory test results, radiology images, billing records and advanced directives. How the information got to the EHR could be from internal creation of the clinic or via outside sources like other providers digital records or imaging studies from the diagnostic center or reports from specialist providers.
The primary distinction between a PHR and an EHR is that the patient controls information in the PHR, while the doctor or hospital—or both—controls information in the EHR.