Neurologists who do not take prompt action to register and qualify for the federal EHR meaningful use incentives may forfeit a substantial amount of money.
To earn the full $44,000 in incentive payments, physicians (or EPs for “eligible providers”) must complete the attestation process by Dec. 31, 2012. If EPs wait until 2013 to begin the attestation process, they can earn only $39,000. Those who wait until 2014 to qualify will only be eligible for $24,000 in payments.
Technically, EPs only have to submit 90 days of clinical data obtained through their certified EHR system to qualify for Stage 1 payments. Therefore EPs could potentially begin the Stage 1 reporting period as late as Oct. 3, 2012 and still be eligible to receive the maximum incentive payment.
In practical terms, however, it takes most physician practices at least two to three months to install the certified EHR, adjust workflow, and “get up to speed” in collecting and submitting the needed clinical information for successful attestation.
At stake is more than incentives; Medicare penalties are on the way. Physicians who do not meet the federal EHR meaningful use standards by October 2014 will face Medicare payment cuts of one percent in 2015 and two percent in 2016.
As of March 1, 2012, 44,014 eligible professionals had received $792 million in incentive programs under the Medicare meaningful use program. Another 29,931 had received payments under the Medicaid program (physicians must choose one program). While this is a major achievement, it represents only 10 percent of the practicing physicians in the U.S.
Any practice leader who is still “standing on the sidelines” waiting to make a decision about adopting an EHR does not fully understand the financial stakes.
Here are five steps neurologists can take to register and qualify for the meaningful use incentive program.
1. Understand the various Medicare incentive payments—and penalties
The adoption of an advanced EHR can pave the way for complying with other reward programs.
Neurologists who did not meet the Medicare Electronic Prescribing (eRx) requirements in the January 1 – June 30, 2011 period will face a one percent penalty to their fee schedule this year. Penalties increase to 1.5 and two percent in coming years.
To participate in the current Physician Quality Reporting System (PQRS), neurologists may choose to report information on individual clinical quality measures or measures groups. These include measures for epilepsy, Parkinson's disease, dementia measures and sleep.
Neurologists who report successfully in the 2012 PQRS Incentive Program are eligible to receive a 0.5 percent bonus payment on their total estimated Medicare Part B Fee Schedule. There is quite a bit of overlap between the EHR and PQRS programs. It is currently possible to receive both meaningful use incentives and PQRS payments, however, separate filing is required. This is likely to change in the future, since CMS has proposed a new option where physicians could “file once” and get credit for both programs.
2. Select an EHR designed for specialist physician practices
Many busy specialist physicians will face a number of new data collection requirements when qualifying for meaningful use. While primary care physicians often see patients for follow-up visits, specialists see many first-time patients each day. Thus, collecting the needed information from patients in a timely manner becomes critical.
For example, the meaningful use requirements require providers to collect vital signs on patient visits. Some neurologists may not have been routinely collecting this information, so this could require a workflow change. While vital signs can be collected by nurses or medical assistants, the physician will need to document his/her evaluation of the patient. Thus, neurologists should look for an EHR system that can speed up the data entry process through dictation or templates designed for ease-of-use and click minimization.
In addition, neurologists will want an EHR that can communicate easily with hospitals and laboratories. The EHR should be able to receive and store results from EMG and NCV tests, as well as X-rays and CT scans.
Finally, physicians should always “test drive” features of EHRs under consideration, such as chart review, e-prescribing, or order creation and tracking to make sure they are comfortable with the data entry and retrieval process.
3. Ask patients to self-report demographics
Another meaningful use standard requires practices to collect patient demographics as structured data, including preferred language, gender, race, ethnicity, and date of birth. This is also likely to be a new data collection task for many neurologists.
Patients are used to self-reporting this information in many business situations; it makes sense to have them do this in the waiting room. Some medical offices are providing check-in kiosks or iPads to patients for this purpose.
If your practice serves many elderly patients, you may want to consider staying with a paper solution. One option is to collect the needed demographic with “bubble-in” or Scantron forms that can be fed into optical mark readers, which will then load the data to your EHR system. Before purchasing the forms or optical scanners, check with your EHR to ensure full compatibility.
4. Use A Patient Portal for clinical summaries
Under the meaningful use rules, the physician's office must provide clinical summaries to patients within three business days of the visit. For a busy practice, it can be difficult to complete and print out the summary in time to hand it to the patient before he/she leaves the office. Printing and mailing the summary later (within three days) is an option, but costly and time consuming.
One cost-effective alternative is to install a patient portal; a web-based application that allows patients to interact with their providers. Many, but not all, certified EHRs come with patient portals.
When the practice has installed a patient portal, staff can quickly upload the clinical summary to the web site to be viewed by the patient. Note that the current meaningful use standards do not require that patients read or download this clinical summary; it just needs to be “provided,” which is generally interpreted as being sent electronically.
5. Ask your IT consultant or EHR vendor for help
Your EHR vendor should be an effective technology partner for your practice as you seek to meet the meaningful use requirements. Your vendor should be able to counsel you and your staff on the needed workflow changes and suggest new procedures to handle the new data reporting requirements. Ideally, the vendor can work with you on test runs to make sure all the necessary data fields are being populated correctly.
The Center for Medicare Services (CMS) has created a “test site” with an interactive worksheet that physicians or practice managers can use to see if they currently meet the requirements. This test worksheet is available here: https://www.cms.gov/EHRIncentivePrograms/Downloads/ EP_Attestation_Worksheet.pdf
We have reached “the tipping point” in terms of EHR adoption. Penalties for failing to e-prescribe began this year, and in 2014 and 2015 physicians will face mounting financial penalties from Medicare and Medicaid if they don't adopt an EHR. Commercial insurers are also adopting various kinds of accountable care programs that require submission of clinical data. Within five years, the only way a physician practice will be able to operate without an EHR would be if it moved to an all-cash, concierge type model.
Zubin Emsley is chief executive officer of ChartLogic Inc. For more information, see www. ChartLogic.com.