There are three big takeaways physician practices should note in the Electronic Health Record (EHR) Incentive Program final rule.
- You only need to report 20 meaningful use objectives, not all of the 25 measures in the proposed rule released six months ago.
- You either meet meaningful use requirements by the end of 2014 or face the consequences. Medicare payments will drop by 1% in 2015 for those who fail to (meaningfully) use an EHR in 2014.
- It's unclear how you will show or report to CMS that you are meeting meaningful use requirements.
On the third point, here's the applicable excerpt from the final rule:
Except for the clinical quality measures (for which we require electronic reporting in CY or FY 2012 and subsequent years as discussed above), satisfaction of meaningful use objectives and associated measures may be demonstrated through attestation. Specifically, we will require that EPs, eligible hospitals and CAHs attest through a secure mechanism, such as through claims based reporting or an online portal. For the Medicare FFS and MA EHR incentive programs, CMS will issue additional guidance on this mechanism. For the Medicaid EHR incentive program, the States will include additional information in the State Medicaid HIT plans they submit to CMS to implement the program. We will require that an EP, eligible hospital or CAH would, through a one-time attestation following the completion of the EHR reporting period for a given payment year, identify the certified EHR technology they are utilizing and the results of their performance on all the measures associated with the reported objectives of meaningful use. We would require attestation through a secure mechanism because we do not believe that HIT will advance enough from its current state to allow for more automated and/or documented options of demonstrating meaningful use. As HIT matures we expect to base demonstration more on automated reporting by certified EHR technologies, such as the direct electronic reporting of measures both clinical and non clinical and documented participation in HIE. The first example is to the move from attestation for clinical quality measures to direct reporting in 2012 and subsequent years for EPs, eligible hospitals and CAHs. As HIT advances we expect to move more of the objectives away from being demonstrated through attestation. However, given the current state of HIT, we believe that imposing such demonstration requirements for 2011 would pose significant barriers to participation in the EHR incentive programs.
For further reading: David Blumenthal penned an article about the meaningful use rule for the New England Journal of Medicine.