Incentive payments via Medicare and Medicaid reimbursements to hospitals and clinicians for implementing electronic medical records under the 2009 HITECH Act (Health Information Technology for Economic and Clinical Health) require the “meaningful use of EHRs to achieve specified improvements in care delivery”, not just adoption of a hardware and software system.
On July 14, 2010 the ONC (Office of National Coordinator) of HIT (Health Information Technology) of DHHS (Department of Health and Human Services) released “The Final Rule” of “meaningful use” criteria/regulations that will have to be met by both hospitals and clinicians to receive HITECH incentive money.
Number of pages of regulations/criteria in “The Final Rule”: 846
Number of years The Final Rule will actually “rule”: 2
- The Final Rule is no where near “final”. It will merely govern the first two years of HITECH incentive payments and will be revised as the ratcheting up of EHRs standards and implementation occur over the 10 years covered by the HITECH Act.
Total amount of money estimated to be paid out over the 5 years of HITECH incentives: $27 Billion
Amount per clinician estimated to be paid out for HITECH incentives over 5 years by Medicare and Medicaid respectively: $44,000 / $63,750
Deadline for EHR implementation by clinicians to obtain the maximum incentive payments: October 2011
Year in which incentive payment is replaced by a reduction in reimbursement rates (“penalties”) for hospitals which have not implemented “meaningful use” of EHRs : 2015
Number of core measures (“data elements”) that are mandatory for “meaningful use”: 15
- These measures are basic identification and demographic data elements that are essential to any medical record and represent a reduction from the original 23 measures. (ex. vital signs, allergies, medication list, problem list, smoking history, etc.)
Per cent of patient EHRs that must have these mandatory measures by 2011: 30 – 80% depending on the data element
- This represents a major change from the initial draft that called for 100 % compliance in the first two years.
- CPOE (computer provider order entry) will be required only for medication orders and the compliance threshold will be at least one CPOE medication order for 30% of the patients.
Number of optional measures to be chosen by the clinician or hospital for inclusion: 5 out of a list of 10
- Ex. incorporate lab data as a structural data element, produce summary of care for referrals or transfers, summit immunization data to registries, etc. Many of these also have less than 100% compliance requirements.
- Recording of advance directive status (Health Care Proxy) in 50% of patients 65 years or older is one optional measure specifically for hospitals.
- Patient access to their records via PHR (Personal Health Record) or a Patient Portal is NOT a listed criteria yet.
Number of quality measures that are mandatory under HITECH to report to DHHS electronically in 2011-12: 6
- The three mandatory ones, blood pressure level, tobacco use, and adult weight screening, and three additional ones chosen by the clinician from a myriad of “quality measures” represent a marked reduction in the “burden of quality reporting” contained in the initial draft.
Number of Regional Extension Centers to be established by DHHS to help hospitals and clinicians implement EHRs: 70
- See article by Atul Gawande, MD proposing the application of the successful agricultural “extension agents” model of 1914 to health care reform of 2010 in New Yorker magazine 12/14/09. See also Alain Enthoven’s critical rebuttal of the model in Health Affairs 12/22/09.
Words from the letters of the acronyms of EHRs, ONC, and HIT: “RECON THIs”
- Loose translation: Keep your eyes posted for many future developments.
- Also, better than “CHRIsT, NO!”
1. Health Care Blog, July 14, 2010, “Meaningful Use” Margalit Gur-Arie
2. NEJM online, Health Care Reform Center, “Meaningful Use Regulations”, July 13, 2010, David Blumenthal