A lot of the gunk in the 556 CMS document is geared towards hospitals and hospital reporting. When I say “gunk” I mean mind numbing scores of pages that will cause your eyes to tear and honestly feels like it is 90% or more dedicated to hospitals. There are comments about EPs (eligible professionals), but you will have to sort or search for specifics.
The “companion piece”, from ONCHIT, that discusses the goals and languages of intercommunication for “certified” EHRs, starts to get interesting around page 63 where they talk about the 4 categories of standards they want to address: vocabulary, content exchange, transportation/transportability (common protocol standards), and privacy & security. As doctors this is the area you won’t have to worry about the details of, it will be up to your vendors, like us, to make sure that our, and your, EHR programs are up to snuff. However, specifics of what you will need to be reporting you will need to be aware of.
On the positive side, the various committees are dedicated to the concept of keeping the definitions and specifics between the Medicare and Medicaid programs the same, rather than having two different animals, they can have a shared beastie wearing the same coat. The wisest thing I think they could have done, for starters.
On page 30 of the CMS (556 page) document, they define the balance they want to achieve with meaningful use: improved healthcare, reform of health care, widespread EHR adoption, and they don’t want to impose unnecessary burden on health care providers. In all of the documentation their goals are to decrease duplicate, erroneous, and improper claim reporting, and to increase health outcomes for patients. They also want to give a “transparency” to healthcare that the government is striving for in many areas.
The plan for implementation is to work in three phases: Phase 1 for 2011 reporting and functioning will go into effect Oct 1, 2010 for 2011, at this point; Phase 2 implementation for 2013; and Phase 3 implementation for 2015. These documents are interim standards and are up for review over the next 60 days… They don’t think they’ll have a “final ruling” until after March 2010, after that ruling is issued the standards will go in to effect 60 days after the final rules have been published.
There was one area in the larger CMS document that caused me to pause, and it seemed like they had not decided on what they were going to do, but it looked like their might be no “extra” benefit for early EHR adopters if they go the way I saw in around page 304 and 305. They have a couple of graphs to look at for Medicaid EPs (eligible professionals), At first, for those that jumped in on the first year there could be up to over $21,250 in potential benefits, that would go down to $8500 each, for an additional five years, this lists as a total potential benefit of $63,750. However, they are looking at another option that would allow them to drop that initial start up incentive of $21,250 and just go for the 5 years at $8500 each, for a total potential benefit of $42,500. They claim that this second option is the one they would like. It doesn’t penalize “early adopters” who can still get money early, but it figures into its equation that those that have already adopted EHRs don’t need the “extra incentive” to start. If anyone else takes a look at that has other understanding or interpretations I would love to hear them and put some of them out there for others to consider. It simply sounds like a way to save up to $21,250 potential dollars per EP to me.
The biggest advantage I could seen in their documentation for starting earlier 2011 versus later, 2015 and beyond, was that you can implement the stage changes (phase 1 through phase 3) with them, slowly, as they come up, rather than going from phase 1 to 3 or a direct jump to phase 3 all at once. This would allow you to adapt and catch your breath as you go.
As always, I see no option for you but that you will eventually have to get into an EHR, the decision for you will be on what terms you choose to do so: Yours or Theirs.
The links above will get you the actual PDF documentation.
Penny Henriksen
Genius Solution's writer and editor
newsletter2009 @ geniussolutions.com
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