You have implemented a certified Electronic Health Record (EHR) program and calculated your potential incentive dollar amount for being a meaningful user, now what?
For Eligible Providers (EP) who qualify for Medicaid and are choosing Medicaid as their means to qualify for the incentive payments, your next step is to complete the Medicaid Registration on line and attest to the capabilities of the system you have implemented. For EPs and Eligible Hospitals (EH) seeking the Medicare payments, the attestation component of registration requires several steps and decision points and the collection of three months of data proving you have achieved meaningful use.
Registration and Attestation
The first step in the registration process is to go to the CMS website and familiarize yourself with the site and download the registration form located at https://ehrincentives.cms.gov The required information you need to initiate the process, such as provider NPI, is also located at this site. You may initiate the registration process any time on line and save your information for completion later.
The first step in completing the attestation is to understand which criteria are simply yes/no answers versus those requiring a report to support your utilization of the system meaningfully. The yes/no criteria are as follows and obviously, you want all yes answers to qualify.
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Core Criteria
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Eligible Provider
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Eligible Hospital
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Implement Drug-Drug and Drug-Allergy
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System must be enabled
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System must be enabled for entire reporting period
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Implement one clinical decision support rule relevant to specialty or high clinical priority along with the ability to track compliance with that rule
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Implement one clinical decision support rule related to a high priority hospital condition and ability to track compliance
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Implement one clinical decision support rule
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Capability to perform exchange of key clinical information
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Capability to perform exchange of key clinical information among providers of care and patient authorized entities electronically
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Must have tested at least once during reporting period the exchange of data electronically
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Ensure adequate privacy and security protections for personal health information
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Conduct or review a security risk analysis
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Conduct or review a security risk analysis
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The Risk Analysis is a yes/no answer; however, you must have a documented report on file to produce for any potential audit. This report may be completed prior to or during your reporting period.
Identifying Gaps
The remaining core criteria require the utilization of reports to demonstrate successful meaningful use utilization. Therefore, the next step in the registration and attestation process is to run the required reports sooner rather than later and identify where the gaps are in achieving the required level in each element.
If a gap exists, a question to consider is “are your work processes allowing staff to easily and correctly enter the information into the appropriate fields” which will allow you to produce the required structured data reports. Will this require re-education or work flow redesigns? This is an area you may have adequate resources for or you may seek outside assistance to propel the process along.
The first report being in regards to Computerized Physician Order Entry (CPOE), will your system run a report that will flag the unique patients and contains the medication lists, identifying the medications that were ordered via CPOE and compare it against your claims that have Place of Service (POS) 21 or 23? Or, will you need to run separate reports and merge the data? This is one of many examples where it will be critical to run an initial report for each core criteria and assess if your workflows are adequately capturing the data.
Choosing the Quality Measures
Determine which ones you can easily run reports for or pertains to your specific services. Run as many reports as you are capable of and identify those that you are already achieving or well on your way to achieving. Once the selection is made, again identify gaps and define any necessary education or workflow changes required to achieve the level required.
Maintaining Achievement
The reporting period definition is any 90-day continuous period within a payment year in which an EP, EH or CAH successfully demonstrates meaningful use of certified EHR technology and a full year for subsequent payment years.
Once you have achieved the required level for each criteria, and you have 3 months of qualifying data to submit, you are ready to complete the submission of the Registration and Attestation. Remember Stephen Covey’s “Begin with the end in mind”.
Source Federal Register/Vol. 75, No. 144/Wednesday, July 28, 2010/Rules and Regulations
Becky Englehardt, CPC, CHC, is a healthcare manager and consultant for HORNE LLP. HORNE LLP is one of the top 50 accounting and business advisory firms in the country, as reported by the Public Accounting Report (PAR), and one of the top 10 accounting and business advisory firms in the Southeast. With offices in Mississippi, Tennessee, Alabama, Louisiana and Texas, the firm serves clients across the nation. For more information on HORNE, visit www.horne-llp.com.