Making Sense of the Medicare and Medicaid Incentives Packages: Meaningful Use Requirements
Tuesday, March 15, 2011
By Chris LaPage
So you have checked a few items off your list: (1) You determined you are an eligible health care provider, (2) You have calculated an estimate incentive payment and realize what's at stake in terms of reimbursement, (3) You have begun the registration process with CMS (Medicare) or the agency in your state administering the Medicaid program, and (4) You purchased an EHR system that is certified by the Office of the National Coordinator Authorized and Testing Certification Body.
Unfortunately, the real work is only just beginning. In order to take advantage of the incentives package, you must meet the objectives and measures established by CMS that proves you are a meaningful user of the EHR you put in place. This is true regardless of whether you seek incentives through the Medicare or Medicaid program. One caveat being that in the initial year of payment, providers going through Medicaid will not have to meet the meaningful use requirements. Instead, Medicaid providers only need to show evidence that they have adopted, implemented or upgraded their EHR to receive the initial payment. However, they must demonstrate meaningful use in the remaining 4-5 years of payment.
Further complicating the situation is the fact that the definition of "meaningful use" is not static, but will evolve over time (3 total stages) as more stringent requirements are put into place. Stage 1 criteria focuses on electronically capturing health information (in a coded format) and using it to track key clinical conditions and communicating that information for care coordination purposes (in a structured format whenever possible). In stage 1, many of the objectives simply require an EHR feature to be activated or available (e.g. - drug-drug, drug-allergy cross-checks) while others require baseline measures to met (e.g. - 30% of patients seen by provider have at least one medication entered using CPOE). Stage 2 meaningful use criteria will expand upon Stage 1 to encourage the use of health IT for continuous quality improvement and the exchange of health information in a structured format. A draft of stage 2 criteria suggests that the measures will be more stringent (e.g. - CPOE requirement moves from 30% to a 60% threshold) and new requirements will take hold, such as adding lab and radiology to the CPOE requirement (rather than just medications in stage 1) and requiring online secure patient messaging (absent from stage 1). Stage 3 criteria will focus on promoting improvements in quality, safety and efficiency with an emphasis on decision support for national high priority conditions, patient access to self-management tools, access to comprehensive patient data and improving population health.
Similar to the structure of the funding levels which provide the most incentives to early adopters, the staging of meaningful use is supposed to support that philosophy. For the initial year of payment, providers will only need to demonstrate that they meet Stage 1 meaningful use criteria. However, in each subsequent year of payment providers must meet the most recent stage defined in final rules issued by CMS. In other words, if you wait until 2013 to become a meaningful user (meet stage 1 criteria) and Stage 3 criteria have been finalized by CMS, the incentive payments will stop if you cannot meet the definition of the more difficult stage 3 meaningful use in 2014. Stage 1 requires individual practitioners to meet 15 required objectives while hospitals are required to achieve 14 objectives. Both types of providers must then select 5 out of 10 objectives (5 deferrals) from a menu set. If an objective does not apply to a certain type of provider, then that item is excluded without counting towards their 5 deferrals. For example, chiropractors do not prescribe medicine so they are excluded from the e-prescribe requirement. The draft of Stage 2 meaningful use requirements indicates that CMS will eliminate the deferrals and add the 10 menu set items to the list of required objectives.
The CMS has provided charts that offer an overview of the various features that must be enabled and objectives that must be met for stage 1 meaningful use. There are a couple of things to keep in mind when reviewing this material. First and foremost, providers can defer up to 5 measures on the charts entitled "Menu Set Objectives" while they must meet all the required objectives. Finally, place close attention to the beginning of each objective as it will note if an objective is solely for an individual practitioner (EP) or hospital. If it has no indication, then the objective applies to both types of providers.
You can access these charts at https://www.cms.gov/EHRIncentivePrograms/Downloads/MU_Stage1_ReqSummary.pdf.