Plain Talk about “Meaningful Use”

As part of the stimulus package, there was a provision to encourage the adoption of Electronic Medical Records (EMR) within the health care community.  The idea was to allow health care professionals that implement EMR technology to increase the amount of their reimbursements for treatment of Medicaid and Medicare patients. 

As much as $27 billion may be expended in incentive payments, according to Center for Medicare and Medicaid Services (CMS). Eligible physicians who meet all required objectives could receive as much as $44,000 over five years from Medicare, or $63,750 over six years from Medicaid. Hospitals may receive millions of dollars for meaningful use under both Medicare and Medicaid, the agency said.

It is important to note, that the burden of proof for “Meaningful Use” is on the physician.  The medical practice must certify using a Federal Web Site that it has achieved the goals set out for the “use” of electronic medical records.  A vendor certifying that the product can support the requirements for use is not sufficient for meaningful use; the physician must still utilize that capability for normally 80% of its business transactions.  In January 2011, eligible health care providers and hospitals can begin registering for the EHR incentive program. CMS will manage the registration for both the Medicaid and Medicare incentive programs from one virtual location.

This of course is where normal government regulations versus practical application can become tricky for the health care provider.  As an example, let’s say that your physician practice has a working relationship with a Medical MRI Office and a hospital in your area.  Your practice orders MRIs from both the hospital and the MRI office.  The requirement is that 80% of your practices orders must be generated by a certified EMR. If each of those organizations requires that the physician orders from their system, then you must ensure that their systems are certified and that you order 80% of your orders through those systems.  Now what if one is not certified, then if that is more then 20% of your MRI orders then it appears based on the present guidance that you are not compliant and therefore can not receive the reimbursement payments.  Again it is up to your practice to track and manage this information to determine if you are compliant.

The other important piece of information is that there are presently no “Certified EMR” systems.  There was the belief that a system that was CCHIT11 certified would be grandfathered in my ONC for being a “Certified EMR system”. That did not happen and all systems must now go through a new ONC certification process to become “Certified”. The problem is the amount of time it will take for systems to become certified.  The meaningful use program starts in a month and there is no way that many systems will get certified.  If your practice is using more then one software vendor or if you use capabilities of hospitals or other health organizations, the management of what is certified and what is not is going to be difficult.

What should your organization do?

Our recommendation is to buy the best solution for your business.  Most vendors like us will become “Certified EMR” vendors as the government program is refined.  There is no requirement nor will there be a requirement that only one system be used by you practice to meet the goals of “Meaningful Use”.   Be careful of the vendors that state that they can provide you with “Meaningful Use” capabilities; in truth they can only provide your organizations with certified tools that can be used by you to achieve “meaningful use”.  Without well defined business processes, your practice will not meet “meaningful use” and since you are certifying that you have met the objectives, you are libel not the software vendor if audited.  There will be organizations that pay thousands of dollars for software and will be denied reimbursement because there business processes were not able to prove they achieved the “meaningful use” objectives.

As many government programs, when the reality of the complexity of the challenge is realized, there will be modifications made to make program more functional.  Most likely the deadlines for achieving the goals will be extended or the objectives will become the driving force.  As long as the practice meets the objectives of electronic ordering the system that achieved the objective will be acceptable.  Or previous certifications will be allowed for EMR systems. 

Another thing we know is that achieving the goals of “Meaningful Use” will require new and changed business processes of the medical practice. This will require additional investment of time and money for practices to meet the accounting and certification processes. There are requirements for percentages of patients treated that must be Medicare and Medicaid.  Mack sure you have evaluated the break even before you commit to this program. 

One thing is true either way - the more efficient the software is at increasing productivity, the more it will provide an overall savings to the medical practice.   For this reason, we are developing a “Best Practices” manual that will assist medical practices in implementing business processes that will take advantage of the power of the Medamation solution and allowing organization to achieve “Meaningful Use” of EMR technology.