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Electronic health records (EHRs) will play a critical role in getting to a higher quality, safer, more effective healthcare system. The HITECH Act incentives were created to offset the cost of EHR installation for providers who meaningfully use their EHRs. The final rule for “Meaningful Use” of EHRs was released on July 13, 2010. One of the best short summaries of the rule and rationale behind them is the New England Journal of Medicine article written by Office of the National Coordinator former director Dr. David Blumenthal and CMS deputy administrator Marilyn Tavenner.
Wide River TEC can help assist you with your implementation plan and efforts to meet meaningful use, whether or not your clinic chooses to seek reimbursement from the Medicare or Medicaid programs. For additional information about Medicaid or Medicare, see the links below.
MEDICARE/MEDICAID
If you are an RHC or an FQHC, please view the Needy Individuals Criteria for additional information. One source of confusion among healthcare professionals is that there are two separate plans to seek reimbursements for EHR installation, one for Medicare and one for Medicaid. The Medicare program is already established with registration open and available as of January 3, 2011. EHR incentives will be disbursed by Medicare. More information about the registration process for the Medicare plan can be found on the CMS web site.
Each state is responsible for developing their own reimbursement program through Medicaid, a state-administered government health insurance plan with the EHR incentives disbursed through the state. Nebraska’s plan is in the process of development with an anticipated start date of Fall 2011. Although, Nebraska’s plan will be based on the federal requirements, there are several areas that could be changed. We are currently working with the state of Nebraska to assist them in any way we can move this process along. The method of qualification between these two programs also differs. For Medicare, reimbursements are capped at 75 percent of Medicare billings. For Medicaid, qualification is based on having at least 30 percent of your patient volume consist of Medicaid patients. The method of calculating that percentage will also be decided by Nebraska Medicaid. In addition, there are two exceptions to the 30 percent Medicaid threshold. First, federally-qualified health centers such as community health centers and rural health centers need to include “needy individuals” in their calculation of the 30 percent threshold (Needy Individuals Criteria). Second, pediatricians can qualify at a 20 percent threshold, but would only be eligible for two-thirds of the total reimbursement
RURAL HEALTH CENTER QUALIFICATIONS
At the present time, most Rural Health Centers will not be able to qualify for meaningful use incentives. This is because the law as currently written caps Medicare reimbursement at 75% of Medicare Part B billings. Because the cost-based reimbursement of RHCs goes through Medicare Part A, this means that most RHCs would in effect be eligible for $0 in incentive payments. We suspect this was a technical mistake in the legislation due to a lack in understanding of the mechanism of RHC billing. We are currently working on a possible workaround for independent RHCs that also do Medicare Part B work in the ER and hospital. In addition, HR 3458, which would fix this technical error, has been introduced by Congressman Aaron Shock (R-Illinois). The Nebraska Medical Association, Nebraska Academy of Family Physicians, and the Nebraska Rural Health Association have been discussing this with Nebraska congressional representatives.
We would like to point out that because RHCs are still technically eligible, Wide River Technology Extension Center can still receive grant funding to work with your clinic to develop an EHR implementation plan. We think it would be beneficial for your clinic’s long term planning to go ahead and plan for an EHR implementation, even if you decide to delay the actual implementation until after this issue has been sorted out.
To read more, visit HIT Meaningful Use. |