After reviewing more than 2,000 comments about its original proposal, the federal government substantially modified the criteria for so-called “meaningful use” of electronic health record technology.
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The final rule, issued by the Centers for Medicare & Medicaid Services (CMS) in late July, will make it easier for neurologists and other physicians to qualify for the government's financial incentives — but that does not mean it will be easy to do so.
“Clearly, they listened to many different physician societies who wrote to CMS asking for a more flexible way to move toward meaningful use of an EHR,” said Gregory Esper, MD, director of general neurology at Emory University School of Medicine. “I still think that the incentive will be difficult to obtain without a significant and multifaceted investment of money, time, and people.”
Beginning in 2011, physicians can earn up to $44,000 in incentive payments over five years if they meet certain criteria; those who do not embrace EHRs by 2015 will be hit with financial penalties. (Neurologists who serve a heavy Medicaid population may be eligible for up to $63,750 through a related Medicaid incentive program.)
David C. Kibbe, MD, an advisor to the AAN Practice Management and Technology (PMT) Committee, said the CMS final rule supports the government's agenda for EHR adoption but scaled back the pace of the effort. For example, physicians must comply with 20 objectives, rather than 25, as cited in the original proposal.
The 20 objectives in Stage 1 include 15 core objectives and a menu of others, from which physicians can choose five. (See “Stage 1 Meaningful Use Objectives.”) Many objectives have been modified so they are easier to meet. For example, computerized physician order entry remains a Stage 1 criteria; however, the proposed measure—“use CPOE physician order entry for 80 percent of medications, laboratory, radiology/imaging, and referrals”— has been cut back to “use CPOE for at least one medication for at least 30 percent of patients that have medication lists.”
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“I think the final rule, without giving up on the idea, significantly takes out a lot of the risk for individual neurologists by making it much more likely that they will be able to meet all the requirements and get the payments,” said Daniel Hier, MD, a member of the AAN PMT Subcommittee. “I actually think that the rule is going to be the tipping point” for broad adoption of EHR technology.
WHAT TO DO NOW
Neurologists who already use EHR technology must study the meaningful use criteria, see what they need to do differently to be eligible for the incentives, develop a work plan, and start adding the functions needed for incentive-earning success.
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What about those who currently use no electronic functions? Take a deep breath and do not buy anything.
“The last thing you want to do is go out and look at products,” said Dr. Kibbe, founding director of the American Academy of Family Physicians Center for Health Information Technology.
Rather, he advises physicians to study the criteria and think about how the workflow of the practice will need to change to meet various objectives. Some neurologists may prefer to choose several modules that each perform a single function, such as electronic prescribing, while others will want a complete EHR that provides all the “meaningful use” functions.
While that decision is being made, start reworking processes to prepare for EHR adoption and wait for the right technology to show up on the shelves.
“There's not a product out there that I know of that has been designed to meet all of the features and functions in the final rule with expandability to meet Stage 2 and Stage 3,” Dr. Kibbe said. “Those products are going to be coming on the market this year, but they're not there yet.”
Stage 2 will go into effect in 2013 and Stage 3 in 2015, but the criteria for those stages have not yet been revealed. CMS officials have said that those stages will build on the Stage 1 criteria, meaning that higher levels of use and more detailed reporting will be required.
To comply with the incentive program, physicians must use EHR technology that has been certified by a government-designated organization, but the certification system has not been rolled out yet.
Do not buy any system unless a vendor guarantees in writing that it will be certified, experts suggest. However, Dr. Hier, a professor at the University of Illinois College of Medicine until he became a physician executive at Cerner Corp. last year — a health information technology company — advises neurologists not to use certification alone to make a purchase decision.
“Even though all the vendors could be certified and could be capable, there are individual differences between products that can make a difference in terms of how happy a neurologist is with one or the other,” Dr. Hier said. “It is worth the effort to investigate the choices and to test-drive them. Get references, and make sure you're buying something that's going to fit the way you practice.”
To avoid impulse shopping, Dr. Hier recommends that AAN members educate themselves by checking out the EHR information assembled by the PMT Subcommittee: www.aan.com/go/practice/hit.
IS IT WORTH THE MONEY?
In presentations at AAN meetings in recent years, the PMT Subcommittee has estimated that the five-year cost for implementing EHR technology is between $25,000 and $50,000 per clinician. That is why Dr. Hier is optimistic that the government's $44,000 incentive will spur neurologists to join the EHR revolution.
“Most practices probably do not have the resources to do this without the incentive payments,” he said. “I think that the incentives are very important to our neurologists.”
Dr. Kibbe thinks $44,000 may not motivate some technology-shy physicians; the most important reason to adopt EHR technology is to prepare for the future. CMS will start penalizing physicians who are not sharing patient information electronically by 2015; before that, health care payment will increasingly move to pay-for-performance programs, accountable care organizations and other situations that require neurologists to exchange information in new ways.
“I think that many members are going to gravitate to EHRs simply because it will be difficult to see patients and do business without them,” Dr. Esper said. “If practices really take stock of medical care now and in the future, it will be hard to argue against adopting a certified electronic solution for patient care.”