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ARRA and Health Information Technology for
Economic and Clinical Health Act (HITECH)
Early in 2009, the American Recovery and Reinvestment Act (ARRA) was signed into law and, through a portion called the Health Information Technology for Economic and Clinical Health (HITECH) Act changed the health information technology environment as we had known it. The HITECH Act establishes federal leadership to advance the use of Health Information Technology to save lives and reduce costs through programs addressing funding for the technical infrastructure and adoption of health information technology (including both acquisitions of systems as well as appropriate training for effective utilization) and addresses key policy areas regarding the privacy and security of personal health information. It supports these programs through the investment of $36 billion into the health information technology infrastructures along with allotments of incentives to encourage the adoption and implementation of electronic health records and the active exchange of health information for the purposes of patient centric care as well as public health initiatives.
HIT Funding under ARRA
- $2 billion in direct funding for HIT efforts channeled through HHS and ONC
- $300 million reserved for support of regional health information exchange efforts
- $20 million reserved for NIST to work on HIT enterprise integration
- $20.819 billion in incentives through the Medicare and Medicaid reimbursement systems to assist providers in adopting EHRs
Other HIT- related Stimulus spending
- $85 million for health IT, including telehealth services, within the Indian Health Service
- $1.5 billion for construction, renovation, and equipment for health centers through the Health Resources and Services Administration
- $500 million for SSA to improve processing of disability/retirement claims ($40M for HIT)
- $1.1billion for comparative effectiveness research within the Agency for Healthcare Research and Quality (AHRQ), National Institutes of Health (NIH), and the Department of Health and Human Services (HHS)
- $50 million for information technology within the Veterans Benefits Administration
- $2.5 billion for the U.S. Department of Agriculture's Distance Learning, Telemedicine, and Broadband Program
- $4.7 billion for the National Telecommunications and Information Administration's Broadband Technology Opportunities Program
HITECH allocates $2 billion in direct funding for HIT efforts through the ONC. These funds will be used to support standards development, evaluation and validation; infrastructure for health information exchange (HIE); grants to states for the purpose of furthering EHR adoption; improvements in HIT manpower; the establishment of Regional Health Information Technology Resource Centers, Extension Programs, Enterprise Integration Research Centers, etc.
Additionally, $34 Billion is allotted for incentive bonuses for providers meeting "meaningful use" of EHR systems as determined by the Secretary of Health and Human Services ($17 billion direct funding plus an addition $17 billion from anticipated savings produced from a more efficient system
HITECH will be administered by the Office of the National Coordinator for Health Information Technology (ONC), which was created by the Bush administration in 2004. The HITECH Act provides for the creation of two advisory committees to, the HIT Standards Committee and the HIT Policy Committee, to guide ONC in the development and execution of the strategic plan addressing the goals of the Act.
Meaningful Use Overview
The 2009 American Recovery and Reinvestment Act (ARRA) authorizes the Centers for Medicare & Medicaid Services (CMS) to provide a reimbursement incentive for providers who are "meaningful users" of an electronic health record (EHR). CMS estimates that between $14.1 and $27.5 billion in funding will be distributed through the EHR Meaningful Use incentive program.
Like their colleagues throughout medicine, many rheumatology providers practice in settings that use paper medical records. Through the EHR Meaningful Use program, the government is incentivizing providers and hospitals to:
- adopt EHRs
- implement the systems locally in ways that fully realize the potential of electronic systems
- use the EHRs to exchange data
- among non-affiliated providers
- for secondary analyses
The requirements for the program encourage providers to use their electronic systems fully (e.g., as more than simply an electronic medical chart) opening the potential for greater efficiency, improved quality, and effectively coordinated care. Meaningful users have the potential to earn as much as $44,000 over 5 years in the Medicare program, or $63,750 over 6 years in the Medicaid program. Starting in 2015, Medicare will implement payment reductions for eligible providers who are not meaningful EHR users.
The Meaningful Use Incentive Program will be defined through three stages of rulemaking. Stage 1 will begin in 2011, Stage 2 in 2013, and Stage 3 in 2015. New requirements will be added at each stage, as noted below.
The Stage 1 Meaningful Use standards 
, implementation specifications, and certification criteria for EHR technology were announced by CMS on July 13, 2010.
The EHR Meaningful Use program will likely have significant implications for rheumatology providers. It is only one component of the broader Health Information Technology for Economic and Clinical Health (HITECH ) Act , introduced as part of ARRA. HITECH’s reach includes the development of a framework and infrastructure to support health information technology adoption and implementation, health information exchange infrastructure, HIT workforce training, and health information and communication systems research and development.
Available Incentives
Eligible providers can participate in the EHR Incentive Program through one of two programs. One incentive program targets providers who see large volumes of Medicaid patients and another focuses on physicians seeing Medicare patients.
Medicare
Physicians who accept Medicare patients can receive up to $44,000 over the five years. These incentive payments begin in 2011 and gradually phase down. Starting in 2015, providers are expected to have adopted and be actively utilizing an EHR in compliance with the "meaningful use" definition or they will be subject to financial penalties under Medicare.
Medicare incentive payments are capped at 75% of allowable Medicare charges, up to $18,000 for the first payment year. Maximum incentive payments are reduced in subsequent years: $15,000, $12,000, $8,000, $4,000, and $2000.
For eligible professionals in a rural health professional shortage area, the incentive payment amounts are increased by 10 percent.
Medicaid
Eligible providers for Medicaid incentives include:
- Non-hospital based professionals with at least 30% patient volume from Medicaid
- Non-hospital based pediatricians who have at least 20% of patient volume from Medicaid
Eligible providers can receive incentive payments of up to $63,750 over 6 years.
No reductions in Medicaid payments will be made if a provider does not adopt certified EHR technology, although incentives are available only through 2021, and providers must start receiving payments by 2016.
It is important to note that the Secretary may exempt hospitals and providers from penalties on a case-by-case basis for hardship situations. Providers may not receive multiple incentives. Those who qualify for both Medicare and Medicaid incentives must choose to pursue benefits through only one program
Participating in the EHR Incentive Program and other CMS Incentive Programs
The EHR Incentive program is a new program, and it is separate from other active CMS incentive programs, such as Physicians Quality Reporting Initiative (PQRI) and e-Prescribing.
If you participate as a Medicare eligible professional, you cannot receive incentive payments from both the Medicare EHR incentive program and the e-Prescribing program in the same year. If you participate as a Medicaid EP, you may participate in both the Medicaid EHR incentive program and the e-Prescribing program at the same time, as long as you meet the eligibility requirements for both programs.
Other Medicare Incentive Programs |
Eligible for HITECH EHR Incentive Program? |
Medicare Physician Quality Reporting Initiative(PQRI) |
Yes, if the EP is eligible |
Medicare Electronic Health Record Demonstration(EHR Demo) |
Yes, if the EP is eligible |
Medicare Care Management Performance Demonstration(MCMP) |
Yes, if the practice is eligible. The MCMP demo will end before EHR incentive payments are available. |
Electronic Prescribing(eRx) Incentive Program |
If the EP chooses to practice in the Medicare EHR Incentive Program, they cannot participate in the Medicare eRx Incentive Program simultaneously in the same program year. If the EP chooses to participate in the Medicaid EHR Incentive Program, they can participate in the Medicare eRx Incentive Program simultaneously. |
How it Works
In order to qualify for the EHR Incentive payments, the program requires that three criteria are met and states the program will provide incentive payments to:
- eligible professionals (EPs), eligible hospitals, and critical access hospitals (CAHs)
- that are meaningful users
- of certified EHR technology.
Eligible Providers
In order to participate in the Medicare and Medicaid EHR incentive programs, rheumatologists must meet the eligibility criteria defined in the EHR Incentive Program Final Rule. The incentive payments are based on individual providers and each eligible professional your practice may qualify for an incentive payment provided they successfully demonstrate meaningful use.
+ More information on Provider Eligibility for the EHR Incentive Program
- More information on Provider Eligibility for the EHR Incentive Program
Medicare Eligible Professionals (EPs)
Most rheumatology providers meet the Medicare definition of Eligible Provider (defined as Doctor of Medicine or Osteopathy, Doctor of Dental Surgery or Dental Medicine, Doctor of Podiatric Medicine, Doctor of Optometyr, and Chiropractors that are legally authorized to practice under state law). A hospital-based EP who furnishes 90% or more of his/her services in the hospital setting is not qualified as an EP to receive meaningful use incentives.
A qualified EP that demonstrates meaningful use of a certified EHR can receive incentive payments starting as early as 2011. Incentive payments are available for meaningful users for up to five years (ending in 2016). The maximum total incentive payment is $44,000.00 for the Medicare program.
Beginning in 2015, EPs that are not meaningful users will incur negative Medicare payment adjustments for their covered services.
You do not have to be a Medicare Participating Provider to be eligible.
Medicaid Eligible Professionals (EPs)
Rheumatology providers may also be an EP under the Medicaid program (defined as Physicians, Dentists, Nurse Practitioners, Certified Nurse Midwives, and Physician Assistants who practice predominately at a FQHC/RHC that is lead by a physician assistant). A hospital-based EP who furnishes 90% or more of his/her services in the hospital setting is not qualified as an EP to receive meaningful use incentives.
Qualified EPs that make efforts to adopt, implement, upgrade, or meaningfully use a certified EHR can receive incentive payments in their first year of participation. In subsequent years the EP must demonstrate meaningful use of a certified EHR to receive incentive payments. To receive payments for the Medicaid incentive, the EP may not also receive payments from Medicare for meaningful use.
One-Time Switch Policy
EPs who meet the eligibility requirements for both the Medicare and Medicaid incentive programs can participate in only one program, and will have to designate one for participation. After their initial designation, EPs are allowed to change their program selection only once during payment years 2012 through 2014.
» More information on Meaningful use Registration and Payments
Meaningful Use Requirements/Measures
To qualify for Medicare or Medicaid incentive payments, eligible professionals must successfully demonstrate meaningful use for each year of participation in the program.
+ More information on Meaningful Use requirements and measures
- More information on Meaningful Use requirements and measures
CMS will require reporting of health information technology (IT) functionality measures and clinical quality measures related to improving safety and delivering quality core services. For Stage 1, providers and hospitals will need to report performance on the two types of measures:
- Health IT Functionality measures: These measures assess the extent to which a provider or hospital is using the EHR. For Stage 1 meaningful use there are 25 provider measures and 23 hospital measures. Most of the measures require the provider or hospital to meet a certain target.
- Clinical Quality measures: These measures show how meaningful use and other initiatives have indicated the care that patients receive. These measures will be reported for each provider and hospital. For Stage 1, Medicare requires providers to report on 3 core measures and 3 - 5 additional measures that vary depending on the provider's specialty of care. For Stage 1 meaningful use, providers and hospitals are not required to meet any targets for clinical quality measures.
Reporting to CMS for the 2011 program year of Stage 1 Meaningful Use will be through attestation and EPs must report utilization of the certified EHR technology on 90 consecutive days (subsequent program years require utilization for a full 12 months). Attestation must be thru a secure mechanism, such as health information exchange organization, registry, or CMS developed secure online portal.
» More information on demonstrating and reporting on the Meaningful Use Criteria
Administrative Requirements
Beyond actually doing the Meaningful Use work, providers must adhere to administrative requirements. In January 2011, all providers must register via the EHR Incentive Program website; be enrolled in Medicare FFS, MA, or Medicaid (FFS or managed care); have a National Provider Identifier (NPI); use certified EHR technology to demonstrate Meaningful Use (Medicaid providers may adopt, implement, or upgrade in their first year) and all Medicare providers and Medicaid eligible hospitals must be enrolled in PECOS.
» More information on the administrative requirements for Program Registration and Payments
Certified EHRs
The EHR Incentive Programs require the use of certified EHR technology in order to qualify for the incentive payments.
+ More information on Meaningful Use requirements and measures
- More information on Meaningful Use requirements and measures
In order to be considered a ‘Meaningful User’, the EHR Incentive Program requires that the eligible provider use a certified EHR system. Certification ensures that the EHR adheres to specified standards and is technically able to provide a secure environment for sharing information with other health care providers, patients, and public health entities. To demonstrate this, the EHR system must be tested and certified to support:
- use in a "meaningful" manner
- use for electronic exchange of health information
- use to submit clinical quality and other measures to the government
On June 18, 2010, the Office of the National Coordinator for Health Information Technology (ONC) issued a final rule establishing a temporary certification program and process for selecting organizations to test and certify Complete EHRs and EHR Modules as Certified EHR Technology. This temporary certification program will be used to ensure that "Certified EHR Technology" is available for adoption by eligible professionals, eligible hospitals and critical access hospitals for purposes of qualifying for meaningful use incentives in the first demonstration year, 2011.
ONC has stated that it expects authorized organizations will be testing and certifying EHRs by the end of summer 2010, which will allow for certified EHR products to be on the market in the fall of 2010. As more EHR technology products and systems become widely available, adoption of HIT will ideally accelerate as providers and hospitals are able to qualify for federal incentives.
+ How does testing and certification work?
- How does testing and certification work?
There are several federal agencies working together to develop the criteria for testing and certification of EHR systems according to the requirements of Meaningful use. These groups include:
- The Policy and Standards Committees will create and define the meaningful use criteria
- ONCHIT is responsible for selecting independent third party certification bodies
- NIST is responsible for coming up with the test materials (assertions, procedures, methods, tools, data, etc).
- Third-party testing bodies are responsible for actually performing the tests and validating and verifying conformance to NIST's test plans. There will be more than one body approved for EHR testing.
- Third-party certification bodies are responsible for reviewing output from testing bodies and recommending certification to ONCHIT. Once a certification body recommends approval, the product is "certified" (and not before that time).
Upon the "opening" of the certifying bodies, vendors can submit their EHR products to be tested and certified. Hospitals and practices who have developed their own EHR systems can also seek to have their existing systems tested and certified. Complete EHRs may be certified as well as EHR modules that meet at least one of the certification criterions. Once a product is certified, it will be published on the ONC web site. It is expected that the first EHRs will be certified and listed on the ONC web site in fall 2010.
+ How do I find a certified EHR system or verify that my current system is certified?
- How do I find a certified EHR system or verify that my current system is certified?
To support providers in identifying certified products, the ONC will post a list of certified products on their website (link to be added as soon as the site goes live) and will continually update the listing of EHR systems and EHR modules upon receipt of 'certified status' from authorized certification bodies.
It is important to remember to remember that these certification requirements only test to support the objectives (and measures) for meaningful use. The ONC and NIST focus on standards to support the use of the EHR system according to the development of the national data exchange infrastructure. Meaningful use certification serves an important purpose in the adoption and utilization of clinical information technology, but it serves a very narrow scope.
Rheumatologists seeking to implement a new EHR system or module should still carefully review to ensure that the system meets all those usability and functionality needs of the practice. Also keep in mind that meaningful use certification does not replace CCHIT certification which is a much more robust review of EHR system security and functionality.
For more information on EHR adoption, please visit our partner site, AmericanEHR Partners.
Meaningful Use Criteria
The definition of meaningful use is one of the most critical pieces in the implementation of the HITECH Act. This definition will have a huge impact on the types of HIT systems implemented in physician practices and hospitals across the United States, the technical standards that EHR systems use (and the standards which other systems must align to), and the clinical and data exchange processes which take the highest priority. The definition could impact the efficiency of rheumatology practices and the quality and safety of care provided.
The definition of meaningful use will be expanded in three stages, setting the bar higher and requiring more features and more data exchange and sharing in each stage. Stage 2 (est. 2013) and Stage 3 (est. 2015) will continue to expand on the Stage 1 baseline and be developed through future rule making.
Meaningful Use Stage 1 (2011/ 2012)
Reporting on Stage 1 Functional and Interoperability Measures
To successfully achieve meaningful use, eligible providers will have to report on a series of EHR functionality and interoperability objectives and a set of Clinical Quality Measures as defined by CMS in the final rule .
Meaningful use criteria for Medicare eligible providers are divided into a set of 15 core EHR functionality and interoperability objectives and a separate menu of 10 additional advanced objectives from which providers will choose 5 to implement during stage 1. Although the core objectives are all required to be a meaningful user, the menu provides some room for rheumatologists to pick their own path toward full EHR implementation and meaningful use.
A full listing of Stage 1 Meaningful Use Core Objectives
A full listing of Menu Set of Objectives and Measures
Providers will be required to demonstrate their compliance with the functionality/interoperability objectives by reporting functionality/interoperability measures. These measures will be calculated by 1 of 3 methods:
- Through the EHR only. The count for these measures is limited to information for patients whose records are maintained in the certified EHR.
- Attestation. This is a simple yes or no statement such as, "yes, the drug interaction alerting system is switched on".
- EHR and Paper records. EHR must have ability to tabulate patient’s records stored in the EHR, however, if thresholds are not met through those patient records stored in the EHR, there are some situations where manual counting is needed to meet a measure. For example: A physician has seen 100 patients during the EHR reporting period. To meet a measure, the physician is required to report that 80% of his/her patients have an up-to-date problem list. However, only 60 of the 100 patient records have been recorded in the EHR with an up-to-date problem list. In this scenario, the physician would need to ensure that he/she has prepared an up-to-date problem list for an additional 20 patients whose electronic records are not yet in the EHR, thus, requiring a manual counting process to meet the 80% threshold requirement.
It is important for rheumatologists to note that these objectives and associated measures are based on individual unique patients (not patient visits). The unique patient is defined as a patient who is seen more than 1 time during the EHR reporting period and they are only counted once for the measure reporting. This should make meeting measure thresholds easier for those who have many patients they see only once during the reporting period (e.g. for a consult).
Reporting on Stage 1 Clinical Quality Metrics
The Stage 1 core objectives include the reporting of clinical quality measures to CMS for the Medicare program or to states for the Medicaid program. For Stage 1, CMS requires reporting of clinical quality measures based on data in the EHR system:
- Core Clinical quality measures
- Alternate core clinical quality measures (these measures are reported in place of a core measure which may not apply to the provider)
- A menu set from which providers must choose 3 quality measures to report
A full listing of Core Clinical Quality Measures
A full listing of Alternate Core Clinical Quality Measures
A full listing of Menu Set Clinical Quality Measures
Clinical Quality Measures will be reported by attestation methodology and the submission of summary information to CMS. If the capability exists by CY 2012, HHS may require electronic submission of the data directly from the EHR system.
What if the clinical quality measures aren’t applicable to my practice? Although CMS requires all EPs to report core quality measures to achieve meaningful use, there is no requirement to satisfy a minimum value for any of the denominator, numerator or exclusion fields for clinical quality measures and EPs are not penalized as long as they:
- have adopted a certified EHR
- the EHR calculates the required measure
- the EP submits the required clinical quality information to CMS or the state.
The value for any or all of those fields, as reported to CMS or the States, may be zero. If the denominator for one or more of the Core Measures is zero (meaning that the measure is not applicable to the EP's patient population), EPs will be required to report results for up to three Alternate Core Measures.
Similarly, the EP may report 2 values for the 3 measures selected from the menu set. If so, the EP will have to attest that all of the other clinical quality measures from the menu set calculated by the certified EHR technology have a value of zero in the denominator. If this is done, the EP is exempt from reporting any of the additional clinical quality measures.
CMS limits the clinical quality measures to those for which electronic specifications are available as of the date of publishing of the final rule. EHR specifications for meaningful use are obtained from the specification documents for the CMS EHR incentive program and in order for an EHR to be certified, it must be able to calculate measure numerators, denominators and exclusions for each of the clinical quality measures listed in the Final Rule .
More information on Registration and Reporting
Next Steps
1) REVIEW THE MEANINGFUL USE REQUIREMENTS, MEASURES, AND TIMELINES
- Are you eligible for the incentive program?
- Where do you stand in regards to current technology and EHR utilization?
- How might the meaningful use requirements impact your workflow?
- Are you ready to pursue meaningful use incentives?
- How does EHR meaningful use fit into the long term HIT goals for your practice? MU will be achieved most successfully if coordinated with your broader HIT plan supporting the clinical, administrative and business functions of your practice
2) IDENTIFY YOUR CURRENT READINESS STATE: DO YOU ALREADY HAVE AN EHR SYSTEM?
If yes, start a conversation with your vendor regarding their plans for meaningful use.
- Does your vendor plan to pursue ONC-ATCB certification for meaningful use? If not, will you be able to upgrade your software or will you have to adopt and implement a new EHR system? (The system does not have to be certified as of January 1, but it does need to be certified by the end of the 90-day period you are using to attest to your EHR Meaningful Use in year 1.)
- How does your EHR system compare to the meaningful use requirements? Keep in mind that systems will obtain certification based on their ability to support ALL of the meaningful use objectives, which might mean that you will need to upgrade your system or add additional modules such as a patient portal.
- What do system upgrades or additional modules needed for meaningful use mean for your vendor contracting and business agreements? Many vendors are offering discounts, guarantees, and delayed payment based on the incentive timeline. What is your vendor offering?
If no, begin the EHR selection and implementation process. Work with your vendor(s) to ensure that all systems are installed and customized for your practice and that all interfaces are working. Remember that the incentive program begins in 2011, but you have until October of 2012 to begin reporting to receive the full incentive amount.
3) GET YOUR TEAM ONBOARD AND DEVELOP A PLAN
- Bringing your practice staff on board with meaningful use is a key step to success. Achieving meaningful use will involve your whole team. Clinical and administrative staff should be involved from the beginning.
Meet with your team to assess what's happening in your practice and identify internal barriers to EHR utilization and meaningful use.
Review your practice's current workflow and utilization of the EHR system. Is everyone consistently and fully using the EHR system? What data is collected and where?
Perform a gap analysis. Assess your current infrastructure against meaningful use requirements to determine your compliance with functionality and interoperability criteria. What systems or modules will need to be newly adopted? Is new data collection required? Is your system set up to collect it?
Develop an approach and prioritized roadmap, along with estimated costs, to achieve the meaningful use requirements. What resources do you have available to you?
Develop a strategic plan for integrating IT.
Redesign workflow: craft a plan/workflow for each of the meaningful use requirements, including identifying which data points are needed in the EHR system, such as demographic info and vital signs. All team members (clinical, administrative, and support staff) should understand their roles in inputting these data.
Participate in EHR implementation planning. Work with your vendors on implementing the meaningful use measures and standards. Conduct internal pilot tests to evaluate the effectiveness of your plan, and make changes as needed. Is the workflow feasible? Are expectations realistic? After rollout, put into place measurement tools to assess meaningful use compliance and use them!
- Develop an oversight structure.
4) MEANINGFUL USE
Begin to utilize the EHR, tracking all meaningful use objectives. The leaders identified as your oversight team should monitor for meaningful use, provide support, and review metrics on an ongoing basis. Your practice team is your greatest asset in successfully meeting the meaningful use criteria and metrics; ongoing attention to their role in the EHR utilization and the meaningful use program is worthwhile. Coordinate checkins and regular assessments as well as development and training when necessary and maintain a high level of continuity throughout the practice. For every functionality and interoperability objective, measure and report progress.
5) REGISTER, REPORT AND IMPROVE
Eligible professionals should register according to CMS guidance utilizing the registration portal (to be launched in January). Keep in mind that the 5 year payment timeframe begins as soon as you register for the Medicare program, so wait until you are ready to report and submit attestation for meaningful use before registering. Make sure you are meeting all the EHR Meaningful Use objectives applicable to your practice, and, for objectives with numerical thresholds, that you are attaining the levels specified. If your EHR system is Certified EHR Technology, it should be capable of supporting all Stage 1 Meaningful Use objectives. Monitor the CMS website on EHR Incentive Programs to determine the format of the attestation for 2011. And keep in mind that accuracy is paramount; attesting to EHR Meaningful Use is making a claim to a Federal program.
6) INFLUENCE RULEMAKING AND GUIDANCE
As you begin to implement meaningful use in your practice, keep the ACR posted. We want to hear about any issues that you have as well and best practices that you can pass on to others. We will be tracking your experience and concerns and will use them as we work with the ONC and CMS on Stages 2 and 3 final rules and guidance.
Please contact Itara Barnes in the ACRs Quality and health informatics department at .
Registration and Payment Information
Registration
All eligible providers must register via the CMS EHR Incentive Program Website.
In order to participate, all Medicare providers must:
- Be enrolled in Medicare FFS, MA, or Medicaid (FFS or managed care)
- Be enrolled in PECOS
- Use certified EHR technology
- Have a National Provider Identifier (NPI)
- Register provider Name, NPI, business address, phone, Tax payer ID Number (TIN) via the CMS EHR Incentive Program Registration Portal
For Medicaid providers:
- States that are participating will interface with to the EHR Incentive Program registration website
- States will ask providers to provide and/or attest to additional information in order to make accurate and timely payments, such as:
- Patient Volume,
- Licensure,
- Adoption/Implementation/Utilization or Meaningful Use,
- Certified EHR Technology
Medicare Incentive Payment Timeframe
EPs can begin receiving incentive payments in any CY from 2011 to 2014 and may receive incentive payments for up to five years, depending on the year in which the EP first becomes a meaningful user of certified EHR technology. For example, if an EP successfully demonstrates meaningful use and receives a Medicare EHR incentive payment in the first or second year of the incentive program (2011 or 2012); the EP may qualify to receive payments for the full five years.
Medicare EPs that first successfully demonstrate meaningful use for 2013 can only receive incentive payments for four years and will receive less than the maximum possible incentive payment. Accordingly EPs who start participating in 2014 can only receive incentive payments for three years and will also receive less than the maximum incentive payment possible. An EP who first successfully demonstrates meaningful use of certified EHR technology for 2015 will not qualify for any Medicare EHR incentive payments. In addition, starting in 2015, an EP who does not successfully demonstrate meaningful use of certified EHR technology will be subject to reduced physician fee schedule payments.
The rule also requires that each payment year "immediately follow" the prior year, meaning that every year subsequent to the first payment year is a payment year regardless of whether an incentive payment is received by the EP. For example, if a Medicare EP receives an incentive in CY 2011, but does not successfully demonstrate meaningful use or otherwise fails to qualify for the incentive in CY 2012, CY 2012 still counts as one of the EP's five payment years. In this example, the maximum incentive payment that would apply for this Medicare EP not practicing predominately in a health professional shortage area (HPSA) would be $18,000 in 2011, $8,000 in 2013, $4,000 in 2014, and $2,000 in 2015 . The EP would have qualified for a maximum incentive payment of $12,000 in 2012, but did not qualify as a meaningful user for this year.
No incentives may be made under the Medicare EHR incentive program after 2016.
Incentive Payment Calculation
Under FFS Medicare, the payment incentive amount, subject to an annual limit, is equal to 75% of an EP's Medicare physician fee schedule allowed charges submitted not later than two months after the end of the calendar year (subject to annual limit). This means that, for 2011, the EHR incentive payment for an EP would be, subject to an annual limit, equal to 75% of the EP's Medicare physician fee schedule allowed charges for CY 2011, based on claims for services performed by the EP from January 1, 2011 through December 31, 2011, and submitted to the EP's Medicare contractor (MAC/carrier) no later than February 29, 2012.
Payment Accounting under Medicare
CMS will conduct selected compliance reviews of EPs who are of recipients of incentive payments in order to validate provider eligibility and verify meaningful use.
CMS will recoup overpayments made under the incentive payment programs that result from incorrect or fraudulent attestations, quality measures, cost data, patient data, or any other submission required to establish eligibility or to qualify for a payment.
Medicare FFS EPs and eligible hospitals will need to maintain evidence of qualification to receive incentive payments for 10 years after the date they register for the incentive program.
Resources/Calendar of Events
OVERVIEW OF THE EHR INCENTIVE PROGRAM (MEANINGFUL USE)
EHR STANDARDS AND CERTIFICATION
REGULATIONS
AMERICAN RECOVERY AND REINVESTMENT ACT (ARRA)
CMS EHR INCENTIVE PROGRAM (MEANINGFUL USE)
ONC RULE ON STANDARDS AND CERTIFICATION
NIST HIT TESTING STANDARDS
EHR RESOURCES
The HITECH Act provides for updates to HIPPA and addresses privacy and security as it relates to electronic media. The ACR is currently reviewing this information and will post an overview and resources soon!
Health IT InfrastructureBack to Top
ARRA recognizes the critical links between all facets the supporting the eHealth infrastructure, including clinical information systems, Health information exchange organizations, broadband, and telehealth. It ensures that funding, incentives, standards and continued refinement of relevant policy will focus on improving health care delivery and addressing the needs of rheumatologists as they relate clinical care, public health, and research.
The Act instructs the Department of Health and Human Services to invest in the infrastructure necessary to allow for and promote the electronic exchange and use of health information for each individual in the United States and provides immediate funding for health information technology infrastructure, training, dissemination of best practices, telemedicine, inclusion of health information technology in clinical education and State grants to promote HIT. Additionally, the act works to update and strengthen existing laws and HIPAA privacy protections to facilitate the secure movement of appropriate information through the health care system.
+ Health Information Exchange
- Health Information Exchange
ARRA funding seeks to lower the technical, organizational and legal costs associated with health information exchange through a certification framework, grants to states to facilitate infrastructure, grants to develop HIT regional extension centers that will encourage effective and efficient use of technology, and support through a nationwide health information network governance authority. It is expected that these resources, combined with the approximately $48B incentive payments (and penalties) tied to “meaningful use” of EHR systems (including clinical data exchange) can create a business imperative for more information exchange.
More information on Health Information Exchange
Health Information Exchange Organizations
To address the lack of infrastructure for the exchange of health information, the federal government is channeling more than $560 million in HITECH Act monies to state governments to lead the development of exchange capabilities within and across their jurisdictions. According to HHS, the states receiving grant monies to build health information exchange programs will:
- Develop and implement up to date privacy and security requirements for HIE
- Develop directories and technical services to enable interoperability within and across states
- Coordinate with Medicaid and state public health programs to enable information exchange and support monitoring of provider participation in HIE
- Remove barriers that may hinder effective HIE, particularly those related to interoperability across laboratories, hospitals, clinician offices, health plans and other health information exchange partners;
- Ensure an effective model for HIE governance and accountability is in place; and
- Convene health care stakeholders to build trust in and support for a statewide approach to HIE
You can find more information about Health information exchange organizations in your area by contacting your state medical society, state or regional chapter of the Health Information Management Systems Society (HIMSS), checking out the State-Level Consensus Project website for a listing of state initiatives, or by contacting the office of your state Chief Information Officer. You can also find a listing of HIE initiatives located in the directory concluding the ehealth collaborative survey.
Standards facilitating exchange and the Nationwide Health Information Network
The ONC is also accelerating ongoing work to develop a secure, interoperable, standards-based "network of networks" that will connect rheumatologists to patients, care team providers, and others involved in supporting health and healthcare. The Nationwide Health information network (NHIN) will be made of many interconnected state, regional, and local HIEs using supporting technologies, standards, laws, policies, programs, and practices that enable interoperability. The network is built on a core set of capabilities to enable nationwide information exchange encompassing a diverse set of organizations, technologies and approaches.
The HITECH Act establishes a transparent and open process for the development of standards, implementation specifications, and certification criteria that will allow for the nationwide electronic exchange of information.
+ Broadband and Telehealth
- Broadband and Telehealth
ARRA includes more than $7 billion to expand broadband internet access and use and promote adoption of telehealth and distance learning.
Affordable, secure and reliable broadband connections are a foundational element to effective and efficient eHealth are crucial to making telehealth and health information exchange possible.
These efforts to extend telehealth applications to underserved communities afford new opportunities to not only improve patient care but also to facilitate research that will lead to better health outcomes in those communities. Improvements in the availability of broadband and health-related hardware and software make it possible to create new models of remote consultation among providers, assess medical images, and establish new ways for clinicians to interact with patients. Resources available through various ARRA programs give crucial support necessary to realize the vision of technology-enabled health care reform.
More information on the Broadband Initiatives Program
+ EHR Certification and Incentives for 'Meaningful Use'
- EHR Certification and Incentives for 'Meaningful Use'
The value of eHealth is greatest when it is supported by clinical and administrative information technology, such as interoperable EHRs, that enable providers in different care settings to readily exchange, integrate, and act on patient information.
In order to support the adoption of EHR systems that facilitate appropriate data utilization and exchange, the HITECH Act establishes a certification program to review core EHR functionalities and provides financial incentives to providers for using certified electronic health records that have the capability to support the exchange of health information according to defined standards.
More information on the Meaningful Use Incentive Program and EHR Certification.
+ EHR State Loan Fund
- EHR State Loan Fund
The HITECH Act provides for additional funds to States for low-interest loans to help providers finance the adoption and implementation of qualified electronic health record systems. Loans under this section may be used by a healthcare provider to carry out such activities as:
- Facilitate the purchase of certified EHR technology;
- Enhance the utilization of certified EHR technology;
- Train personnel in the use of such technology; or,
- Improve the secure electronic exchange of health information
For more information on loans available in your state, contact your Regional HIT Extension Center.
+ Federally Qualified Health Centers
- Federally Qualified Health Centers
ARRA allocates $1.5 billion to HRSA to fund capital needs at federally qualified health centers, primarily construction, renovation and equipment, and the acquisition of health information technology, including telehealth equipment.
+ Indian Health Service
- Indian Health Service
ARRA appropriates $85 million for HIS’s health IT activities. These funds will be used to support HIT related activities that fit the HIS mission to improve access to and the quality and safety of health care, and to improve the overall health of Native American and Alaska Native patients and populations. Funded Health IT activities will include those related to:
- The Resource and Patient Management System: EHR modernization, personal health record, enhancement of the population health application, acquisition of a practice management system, and architecture enhancements
- Telehealth infrastructure and development: security enhancements and network upgrades.
Strategic Framework
ONC is mandated under the HITECH Act to consult with federal agencies, to update the Federal Health IT Strategic Plan published in June 2008. The 2008 Strategic Plan focused on the 2008 to 2012 timeframe and was intended "to guide the nationwide implementation of interoperable health information technology in both the public and private health care sectors that will reduce medical errors, improve quality, and produce greater value for health care expenditures."
The strategic framework covers the strategic themes, principles, objectives, and strategies ONC plans to address in its 2010 strategic plan. The Plan will focus on the 2011-2015 time period, "as well as lay the groundwork for the period beyond 2015 to create a learning health system through the effective use of HIT."
The scope of the framework is defined as:
- encompassing three levels:
- The full array of entities in the public and private sectors who have a role in affecting and implementing the use of HIT to improve health and health care;
- The broad array of Federal HIT policies, regulations, systems, and activities; and
- The specific mandate, authorities, and role of the ONC.
- Emphasizing the implementation of legislative imperatives to achieve widespread adoption and meaningful use of HIT.
- Focusing on features that would be essential to continue the adoption and value of HIT beyond ARRA funding.
- The Framework focuses on 2011 through 2015 time period and on laying the ground work for the period beyond 2015 to create a learning health system through the effective use of HIT.
The information can be found, on the ONC website.
Leadership
The Office of the National Coordinator for Health Information Technology (ONC)
The Office of the National Coordinator for Health Information Technology (ONC) is at the forefront of the administration’s health IT efforts and is a resource to the entire health system to support the adoption of health information technology and the promotion of nationwide health information exchange to improve health care. ONC is organizationally located within the Office of the Secretary for the U.S. Department of Health and Human Services (HHS).
ONC is the principal Federal entity charged with coordination of nationwide efforts to implement and use the most advanced health information technology and the electronic exchange of health information. The position of National Coordinator was created in 2004, through an Executive Order, and legislatively mandated in the Health Information Technology for Economic and Clinical Health Act (HITECH Act) of 2009.
ONC is responsible for the coordination of efforts to implement and use HIT to promote the nationwide exchange of health information to improve health care. ONC’s mission includes:
- promoting the development of a nationwide IT infrastructure that allows for electronic use and exchange of health information that, among other functions, ensures data security, advances health care quality, reduces health care costs, provides for clinical decision support, improves public health, promotes early detection, prevention, and management of chronic diseases, and improves efforts to reduce heal disparities;
- HIT policy coordination; providing leadership in the development, recognition, and implementation of standards and the certification of HIT products;
- strategic planning for HIT adoption and health information exchange; and
- establishing governance for the Nationwide Health Information Network (NHIN).
Organizational Structure and Offices
The Office of the Chief Scientist is responsible for research and for identifying innovations in information technology that can be applied in health care settings, and which will be the ONC interface for international activities.
The Office of Economic Analysis and Modeling provides analyses to the National Coordinator, including advanced modeling of the U.S. health care system for simulating the micro- and macroeconomic effects of investing in health IT.
The Office of the Chief Privacy Officer, a position mandated by the Recovery Act, advises on privacy, security, and data stewardship of electronic health information and coordinate ONC’s privacy and related efforts with similar privacy officers in other Federal agencies, State and regional agencies, and foreign countries.
The Office of the Deputy National Coordinator for Operations is responsible for activities that are vital to supporting ONC’s numerous programs and enhancing ONC’s ability to communication about health IT.
This office comprises:
- The Office of Communications, which is responsible for stakeholder communications and constituency relations
- The Office of Mission Support, which supports day-to-day operations, including new grants processing, contracts management, budget execution and reporting, and human resources
- The Office of Oversight, which assures oversight of grants, internal and external performance reporting, and auditing
- The Office of Strategic Initiatives to oversee internal strategic planning, special projects, and budget formulation
The Office of the Deputy National Coordinator for Programs and Policy assumes functions previously performed by the Office of Health Information Technology Adoption, the Office of Interoperability and Standards, the Office of Adoption Provider Support, the Office of State and Community Programs, and the Office of Policy and Planning. The new office will lead ONC programs related to health information exchange, regional extension centers, training of the health IT workforce, and the development of technical standards for interoperability, security, and certification of health IT systems
The new office comprises:
- The Office of Standards and Interoperability, with responsibility for standards, security, certification, the Nationwide Health Information Network, Federal Health Architecture and the CONNECT program
- The Office of Provider Adoption Support, which administers the Regional Extension Centers program and health IT workforce development
- The Office of State and Community Programs, which administers the state-level health information exchange program and the Beacon Communities Program
- The Office of Policy and Planning, which is realigned to include all policy development, including privacy and security policy, and is liaison with legal affairs and legislative affairs, regulations development and externally focused strategic planning
Federal Advisory Committees
+ Health IT Policy Committee (a Federal Advisory Committee)
- Health IT Policy Committee (a Federal Advisory Committee)
The Health IT Policy Committee will make recommendations to the National Coordinator for Health IT on a policy framework for the development and adoption of a nationwide health information infrastructure, including standards for the exchange of patient medical information. The American Recovery and Reinvestment Act of 2009 (ARRA) provides that the Health IT Policy Committee shall at least make recommendations on standards, implementation specifications, and certifications criteria in eight specific areas.
Seven HIT Policy Committee workgroups have been formed as sub-committees to the parent FACA. These workgroups meet periodically to discuss their topics, present their findings at HIT Policy Committee meetings, and make recommendations to the HIT Policy Committee.
The HIT Policy Committee workgroups are:
- Meaningful Use
The Meaningful Use Workgroup will make recommendations to the HIT Policy Committee on how to define meaningful use in the short- and long-term; the ways in which electronic health records (EHRs) can support meaningful use; and how providers can demonstrate meaningful use.
- Certification/Adoption
The Certification/Adoption Workgroup will make recommendations to the HIT Policy Committee on issues related to the adoption of certified electronic health records that support meaningful use, including issues related to certification, health information extension centers and workforce training.
- Information Exchange
The Information Exchange Workgroup will make recommendations to the HIT Policy Committee on policies, guidance governance, sustainability, architectural, and implementation approaches to enable the exchange of health information and increase capacity for health information exchange over time.
- Nationwide Health Information Network (NHIN)
The NHIN Workgroup will create a set of recommendations for a policy and technical framework that allows the internet to be used for the secure and standards-based exchange of health information in a way that is both open to all and fosters innovation.
- Strategic Plan
The Strategic Plan Workgroup will advise the National Coordinator on strategic policy framework.
- Privacy & Security Policy
The Privacy & Security Policy Workgroup will address Privacy and Security in the health IT policy context. At a very high level, the new Privacy & Security Policy Workgroup will define and address the policy challenges related to privacy and security; discuss a set of principles around privacy and security; and various methods of ensuring privacy and security.
- Enrollment Workgroup
The workgroup will respond to a section of the Affordable Care Act which asks the HIT Policy and HIT Standards Committees to come up with a set of standards which would facilitate enrollment in Federal and state health and human services programs. This might include standards for: Electronic matching across state and Federal data; Retrieval and submission of electronic documentation for verification; Reuse of eligibility information; Capability for individuals to maintain eligibility information online; and Notification of eligibility.
+ Health IT Standards Committee (a Federal Advisory Committee)
- Health IT Standards Committee (a Federal Advisory Committee)
The Health IT Standards Committee is charged with making recommendations to the National Coordinator for Health IT on standards, implementation specifications, and certification criteria for the electronic exchange and use of health information. Initially, the Health IT Standards Committee will focus on the policies developed by the Health IT Policy Committee’s initial eight areas. Within 90 days of the signing of ARRA, the Health IT Standards Committee must develop a schedule for the assessment of policy recommendations developed by the Health IT Policy Committee, to be updated annually. In developing, harmonizing, or recognizing standards and implementation specifications, the Health IT Standards Committee will also provide for the testing of the same by the National Institute for Standards and Technology (NIST).
Four HIT Standards Committee workgroups have been formed as sub-committees to the parent FACA. These workgroups meet periodically to discuss their topics, present their findings at HIT Standards Committee meetings, and make recommendations to the HIT Standards Committee.
The HIT Standards Committee workgroups are:
Clinical Operations
The Clinical Operations Workgroup will make recommendations to the HIT Standards Committee on requirements for EHR certification criteria, standards, and implementation certifications related to clinical operations.
The HIT Standards Committee's Clinical Operations Workgroup set up a Vocabulary Task Force to address vocabulary subsets and value sets as facilitators and enablers of "meaningful use." The Vocabulary Task Force meets monthly under the auspices of the parent Workgroup.
- Clinical Quality
The Clinical Quality Workgroup will make recommendations to the HIT Standards Committee on quality measures that should be included in the definition of Meaningful Use and future EHR certification requirements.
- Privacy & Security
The Privacy & Security Standards Workgroup will make recommendations to the HIT Standards Committee on privacy and Security requirements that should be included in standards, certification criteria, and implementation specifications.
- Implementation
The Implementation Workgroup will bring forward "real-world" implementation experience into the Standards Committee recommendations with special emphasis on strategies to accelerate the adoption of proposed standards, or mitigate barriers, if any.
Current Other Committees
+ National Committee on Vital and Health Statistics (NCVHS) (1949 – present)
- National Committee on Vital and Health Statistics (NCVHS) (1949 – present)
The NCVHS advises the Secretary of Health and Human Services on health data, statistics, and national health information policy.
Past Committees
+ American Health Information Community (AHIC) and AHIC Workgroups (2005 – 2008)
- American Health Information Community (AHIC) and AHIC Workgroups (2005 – 2008)
The American Health Information Community (AHIC) advised HHS recommended actions to achieve a common interoperability framework for HIT.
National Governor's Association: State Alliance for e-Health
To work to improve the nation's health care system and enable states to increase the efficiency and effectiveness of health information technology (HIT), the NGA Center formed a collaborative body known as the State Alliance for e-Health(State Alliance).
The State Alliance provides a nationwide forum through which stakeholders can work together to identify inter- and intrastate-based health information technology policies and best practices and explore solutions to programmatic and legal issues related to the exchange of health information.
The State Alliance is co-chaired by Vermont Gov. Jim Douglas and Tennessee Gov. Phil Bredesen who guide the efforts of governors, state legislators, attorneys general, insurance commissioners and others to help them develop real-world solutions and model practices for improving the quality and efficiency of health care.
Workforce
The provisions of the HITECH Act are specifically designed to work together to provide the necessary assistance and technical support to providers, enable coordination and alignment within and among states, establish connectivity to the public health community in case of emergencies, and assure the workforce is properly trained and equipped to be meaningful users of EHRs. Combined these programs build the foundation for every American to benefit from an electronic health record, as part of a modernized, interconnected, and vastly improved system of care delivery.
Regional Extension Centers
The HITECH Act authorizes a Health Information Technology Extension Program. The extension program consists of Regional Extension Centers and a national Health Information Technology Research Center (HITRC). The regional centers will offer technical assistance, guidance, and information on best practices to support and accelerate health care providers’ efforts to implement and become meaningful users of Electronic Health Records (EHRs) to improve the quality and value of health care. The extension program will establish an estimated 70 (or more) regional centers, each serving a defined geographic area.
Services are open to specialists, however in the initial two year budget period, HITECH directs the regional centers to give priority support to primary care providers in small practices, public and critical access hospitals, community health centers and rural health clinics, and other settings that predominantly serve uninsured and medically underserved populations. During this time, the regional extension centers collectively must serve at least 100,000 primary care providers, through participating non-profit organizations, in achieving meaningful use of EHRs and enabling nationwide health information exchange.
The regional centers will offer services in the following areas:
- Education and Outreach
Disseminate knowledge about the effective strategies and practices to select, implement, and meaningfully use certified EHR technology to improve quality and value of healthcare
- National Learning Consortium
Participate in the National Learning Consortium facilitated by the HITRC and share tools and materials developed through the cooperative agreement with other Regional Centers, interested stakeholders, and the public.
- Local Workforce Support
Partner with local resources, such as community colleges, to promote integration of health IT into the initial and ongoing training of health professionals and supporting staff.
- Practice and Workflow Redesign
Support for practice and workflow redesign necessary to achieve meaningful use of EHRs
- Functional Interoperability and Health Information Exchange
Assist priority primary-care providers in connecting to available health information exchange infrastructure(s).
- Vendor Selection & Group Purchasing
Help providers select the highest-value option -- the option that offers the greatest opportunity to achieve and maintain meaningful use of EHRs and improved quality of care at the most favorable cost of ownership and operation, including both the initial acquisition of the technology, cost of implementation, and ongoing maintenance and predictable needed upgrades over time.
- Each Regional Center will offer unbiased advice on the systems and services best suited to enable the priority primary-care providers to become meaningful users of EHRs. Regional Centers will avoid entering into business arrangements creating an actual or apparent conflict of interest with the Regional Center’s obligation to act solely in the best interests of advancing meaningful use of certified health IT by providers it serves.
- Applicants are required to submit a Conflict of Interest Certification with the vendors that that they’ve identified. If vendors have not yet been identified applicant can leave the vendor portion of the certification blank for the moment.
- Privacy and Security Best Practices
Support providers in implementing best practices in the privacy and security of personal health information.
- Implementation and Project Management
Support end-to-end project management over the entire EHR implementation process, including individualized and on-site coaching, consultation, troubleshooting.
- Progress Towards Meaningful Use
Participate in program training and be able to provide their clients effective assistance in attaining meaningful use.
The Extension Program will also establish a HIT Research Center, funded separately, to gather relevant information on effective practices and help the regional centers collaborate with one another and with relevant stakeholders to identify and share best practices in EHR adoption, effective use, and provider support.
Academic Curricula and Medical Health Informatics Education Programs
These programs provide for grant funds for demonstration projects to develop academic curricula integrating certified EHR technology in the clinical education of health professionals, and to provide for assistance to institutions of higher education to establish or expand medical health informatics education programs, including certification, undergraduate, and masters degree programs for both healthcare and IT students to ensure the rapid and effective development and utilization of HIT.
- Community College Consortia to Educate Health Information Technology Professionals Program
A grant program that seeks to rapidly create health IT education and training programs at Community Colleges or expand existing programs. Community Colleges funded under this initiative will establish intensive, non-degree training programs that can be completed in six months or less. This is one component of the Health IT Workforce Program.
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- Curriculum Development Centers Program
A grant program to provide $10 million in grants to institutions of higher education (or consortia thereof) to support health information technology (health IT) curriculum development. This is one component of the Health IT Workforce Program.
» Read more
- Program of Assistance for University-Based Training
A grant program to rapidly increase the availability of individuals qualified to serve in specific health information technology professional roles requiring university-level training. This is one component of the Health IT Workforce Program.
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- Competency Examination for Individuals Completing Non-Degree Training Program
A grant program to provide $6 million in grants to an institution of higher education (or consortia thereof) to support the development and initial administration of a set of health IT competency examinations. This is one component of the Health IT Workforce Program.
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Research Programs:
HITECH authorized funds for HIT related research focused on achieving breakthrough advances to address well-documented problems that have impeded adoption of health IT and accelerating progress towards achieving nationwide meaningful use of health IT in support of a high-performing, continuously-learning health care system.
- Strategic Health IT Advanced Research Projects (SHARP) Program
A grant program to fund research focused on achieving breakthrough advances to address well-documented problems that have impeded adoption: 1) Security of Health Information Technology; 2) Patient-Centered Cognitive Support; 3) Healthcare Application and Network Platform Architectures; and, 4) Secondary Use of EHR Data.
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- Beacon Community Program
A grant program for communities to build and strengthen their health information technology (health IT) infrastructure and exchange capabilities. These communities will demonstrate the vision of a future where hospitals, clinicians, and patients are meaningful users of health IT, and together the community achieves measurable improvements in health care quality, safety, efficiency, and population health.
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