As reported in Healthcare IT News “The Health Resources and Service Administration has made available $12 million in grants for rural healthcare network organizations to help them become meaningful users of certified electronic health records.” According to HRSA officials “the grants may support health IT activities, such as development of a strategic plan for electronic health records (EHRs), workforce analysis, purchase of health IT equipment and installation of broadband for connectivity.” For more details see http://www.healthcareitnews.com/news/hrsa-puts-12m-rural-health-networks.
Attestation for EHR Incentive Programs Available
April 27, 2011 By
Earlier this month, CMS launched the attestation portion of the EHR Incentive Payment Program. Beginning on April 18th, eligible professionals and hospitals are now able to attest to meaningful use (or adopt, implement or upgrade for Medicaid). Along with the attestation itself, CMS launched its Meaningful Use Attestation Calculator, a wizard which walks eligible professionals and hospitals through the meaningful use objectives and enables the entity to determine if it can successfully meet the meaningful use standards prior to filling out the registration form.
For those providers that are able to begin the registration and attestation process, access to registration and attestation is available here. The CMS website also has a user guide that is helpful when registering as well as FAQs. To be eligible for either the Medicare or Medicaid EHR Incentive Programs an eligible professional or hospital must be using certified EHR technology. The ONC provides a list of which EHR systems are “certified.”
In addition, CMS is offering teleconferences regarding registration and attestation:
- Tuesday, May 3, 2:00 – 3:30 p.m. ET – Register to join this call if you are an eligible hospital or CAH who wants to learn more about the attestation process for the Medicare EHR Incentive Program.
- Thursday, May 5, 1:30 – 3:00 p.m. ET– Register to join this call if you are an EP who wants to learn more about the attestation process for the Medicare EHR Incentive Program.
Some states are also offering webinars about the Medicaid EHR Incentive Payment Program and how to register. Registration for the Medicaid EHR Incentive Program requires both registration with CMS and on the state level. However, eligible professionals and hospitals will not be able to register with CMS for the Medicaid EHR Incentive Program until their state is ready to start its Medicaid EHR Incentive Program. Washington expects to go-live in June 2010; California plans to go-live this Summer for eligible professionals.
If you have questions regarding the Medicare or Medicaid EHR Incentive Programs or would like some assistance with understanding meaningful use or calculating patient volume (Medicaid) please contact Elana Zana or Dave Schoolcraft.
Washington Announces Medicaid EHR Incentive Program Training Webinars
March 18, 2011 By
Yesterday, Washington State announced upcoming training webinars for the Medicaid EHR Incentive Programs. These webinars are designed to help hospitals and eligible professionals prepare for their participation in the Medicaid EHR Incentive Programs. Washington anticipates rolling out the Medicaid EHR Incentive Program in June.
Program Planning & Implementation Update (WSHA specific)
Wed., March 23
10-11 AM
https://www2.gotomeeting.com/register/638732130
Program Planning & Implementation Update
Wed., April 13th
10-11 AM
https://www2.gotomeeting.com/register/727138786
Qualifying For Incentives & Meeting Required Patient Volume Thresholds
Wed., April 27th
10-11 AM
https://www2.gotomeeting.com/register/212646515
Overview Of Adopting, Implementing & Upgrading EHR Systems (AIU) & Meaningful Use
Wed., May 11th
10-11 AM
https://www2.gotomeeting.com/register/183445538
Registering for the Medicaid EHR Incentive Program
Wed., May 25th
10-11 AM
https://www2.gotomeeting.com/register/332772211
Incentive Payments & Reassignment Process
Wed., June 8th
10-11 AM
https://www2.gotomeeting.com/register/518246379
Attestation & the Audit Trail
Wed., June 22nd
10-11 AM
https://www2.gotomeeting.com/register/592783331
For more information regarding the Washington Medicaid EHR Incentive Program click here.
Medicaid providers are eligible for up to $63,750 in Incentive Payments over the six years of the program. If you would like more information about determining your hospital’s or practice’s eligibility, meaningful use, or calculating your estimated incentive payments please contact Elana Zana.
Modification in Medicaid EHR Incentive Program Calculation – Net Average Allowable Cost
February 14, 2011 By
In December 2010, Congress passed the Medicare and Medicaid Extenders Act of 2010. Along with a variety of other changes, Congress modified one of the inputs in calculating the incentive amount under the Medicaid EHR Incentive Program, specifically the Net Average Allowable Cost calculation.
In the original enactment of the ARRA, the Medicaid EHR Incentive Payments were based on a formula which required that the Secretary of HHS determine the average allowable cost for certified EHR technology, and allow eligible professionals to collect incentive payments in an amount not to exceed 85% of the net average allowable cost, or $21,250 (in the first year or $8,500 in subsequent years) whichever amount is smaller. Determining the net average allowable cost, per the HHS Final Rule, was not an easy feat. HHS determined that the average allowable cost for certified EHR technology for the first year was $54,000 and therefore a provider was allowed to collect up to $29,000 of cash gifts towards the certified EHR technology without seeing a reduction in their EHR Incentive Payment. The Net Average Allowable Cost was calculated as follows:
1st Year Incentive = ($54,000 – cash gift for EHR) * 85% or $21,250 (whichever is smaller)
2nd-6th Year Incentive = ($20,610 – cash gift for EHR) * 85% or $8,500 (whichever is smaller)
Providers were also responsible for showing that they have contributed at least 15% of the net average allowable cost to the purchase or utilization of certified EHR technology. The Final Rule created a detailed description of what items may be included and excluded from the 15% calculation, as well as any gifts for EHR technology.
Congress has since changed these complicated calculations, making it easier on eligible professionals.
The new change recently passed by Congress relating to the incentive calculation is the assumption that the provider has expended at least 15% of the net average allowable cost provided that the EHR Incentive Payment to the provider is not in excess of the 85% of the net average allowable cost. In other words, Congress will now assume that as long as the Medicaid EHR Incentive Payment does not exceed $21,250 in the first year and $8,500 thereafter, the eligible professional is assumed to have paid the remaining 15% and is therefore eligible for the entire Medicaid EHR Incentive amount.
These changes are still subject to HHS releasing new rules interpreting Congress’s enactment and accordingly modifying the Final Rule issued this summer. However, in light of Congress’s intent it appears that the change will ease the confusion on how to compute the net average allowable cost and to determine whether a Medicaid provider has adequately paid for certified EHR technology.
Registration for Medicare EHR Incentive Payments Starts January 3rd
December 28, 2010 By
Starting on January 3rd, 2011, registration for the HITECH Electronic Health Record Medicare Incentive Payments will open. This registration is available for both eligible professionals and eligible hospitals, including Critical Access Hospitals. The registration link will be available starting on January 3rd and can be accessed here. Registration for the Medicaid EHR Incentive Payments will be available for the following states: Alaska, Iowa, Kentucky, Louisiana, Oklahoma, Michigan, Mississippi, North Carolina, South Carolina, Tennessee, and Texas. In February, registration will likely open in California, Missouri, and North Dakota. It is anticipated that other states, including Washington, will launch their Medicaid EHR Incentive Programs during the spring and summer of 2011.
For mor information regarding the Medicare Incentive Payments see the CMS press release. For a general overview of the HITECH incentive payments please read our previous blog posts for physicians and hospitals. As a disclaimer, these blog posts were written prior to the issuance of the Final Rules but provide a good overview of the statutory requirements.
CMS has also issued tip sheet regarding Stage 1 Meaningful Use for hospitals, and Critical Access Hospitals, click here to access the tip sheet. The tip sheet for eligible professionals can be accessed here. Additional information may be obtained by contacting CMS or your State directly (CMS and State Medicaid Contact List & Information).
If you would like further information regarding achieving Meaningful Use, registering for the Medicare Incentive Payments, or assistance calculating the Medicare or Medicaid incentive payments please contact Dave Schoolcraft or Elana Zana.
Initial Certification of EHR Technology
October 5, 2010 By
The Drummond Group and CCHIT announced this week the certification of EHR technology. CCHIT certified 33 complete EHRs and modules, click here to access the list. The Drummond Group certified 3 complete EHRs and modules, click here to access the list. The certification of these EHRs is significant because meaningfully using certified EHR technology is required to qualify for the Medicare and Medicaid incentive payments. Hospitals and eligible providers may use either a complete EHR system to show meaningful use or a set of modules that combine create a complete EHR system.
For more information regarding meaningful use and certification visit the ONC FAQ page.
Critical Access Hospital Incentive Payments
August 30, 2010 By
CMS has issued a Critical Access Hospital (CAH) Tip Sheet to assist CAH’s in evaluating eligibility under the Medicare EHR Incentive Payment program. Though, CAH’s are now eligible for Medicaid EHR Incentive Payments, this eligibility is similar to all other acute care hospitals. CAH’s are not entitled to a different calculation formula for Medicaid EHR Incentive Payments.
To view the Medicare CAH Tip Sheet click here.
To view the Medicaid Tip Sheet for Acute Care Hospitals click here.
If you have questions or need assistance in calculating the estimated Medicare or Medicaid Incentive Payments for your hospital or with achieving meaningful use please contact Elana Zana.
CMS Launches EHR Incentive Payment Website
August 18, 2010 By
To help answer questions regarding meaningful use and the EHR incentive payments, CMS has launched an EHR Incentive Program website. The website provides FAQ’s, CMS presentations, fact sheets, and more. To view the site click here.
Final Rule for Breach Notification Delayed
July 29, 2010 By
HHS announced this week that it will be delaying publication of the HIPAA breach notification final rules. These rules were originally expected to be published in the Federal Register later this summer. HHS is expected to delay the publication of these rules for several more months.
Below is the text of the HHS press release:
The Interim Final Rule for Breach Notification for Unsecured Protected Health Information, issued pursuant to the Health Information Technology for Economic and Clinical Health (HITECH) Act, was published in the Federal Register on August 24, 2009, and became effective on September 23, 2009. During the 60-day public comment period on the Interim Final Rule, HHS received approximately 120 comments.
HHS reviewed the public comment on the interim rule and developed a final rule, which was submitted to the Office of Management and Budget (OMB) for Executive Order 12866 regulatory review on May 14, 2010. At this time, however, HHS is withdrawing the breach notification final rule from OMB review to allow for further consideration, given the Department’s experience to date in administering the regulations. This is a complex issue and the Administration is committed to ensuring that individuals’ health information is secured to the extent possible to avoid unauthorized uses and disclosures, and that individuals are appropriately notified when incidents do occur. We intend to publish a final rule in the Federal Register in the coming months.
If you have questions regarding the interim breach notification rules please contact David Schoolcraft or Elana Zana.
CMS Presentation on Meaningful Use & EHR Incentives Final Rules
July 22, 2010 By
On July 13, CMS issued the Medicare and Medicaid Programs Electronic Health Record Incentive Program Final Rules. These final rules were published in the Federal Register on July 28th.
On July 22nd, CMS hosted a conference call to explain the changes in the Final Rules as compared to the Proposed Rules. Some key changes include:
- Inclusion of Critical Access Hospitals in the definition of eligible hospital for Medicaid incentives.
- A revised definition of hospital based eligible professionals to exclude only those physicians that provide 90% or more of their services in either an inpatient or emergency department.
- Eligible Professionals and Eligible Hospitals may defer 5 optional “menu set” Meaningful Use reporting objectives.
- Reduction in measure thresholds for Meaningful Use reporting objectives.
To view the CMS slide presentation click here. ONC has also published a slide deck entitled “Supporting Meaningful Use” that provides helpful guidance. CMS has also launched an EHR Incentives website which has fact sheets, press releases, general information, and instructions on how to participate, also on the website will be the transcript of the CMS conference call.
In addition, CMS has published the Health Information Technology: Initial Set of Standards, Implementation Specifications, and Certification Criteria for EHR Technology. For more information on these Standards click here.
If you have questions regarding how these final rules will affect your practice please contact Elana Zana.
