Medicare Incentive: Hurry Up and Wait or Just Hurry Up?

After the opening day of acceptance of physician attestations for Medicare's meaningful use incentive, American Medical News posted an article posing the question whether physicians should wait to register themselves for the program or not.  One would think, "Sure, why not?  Let's get that incentive money rolling in!" but it might not as simple as it looks. 

Good Things Come To Those Who Wait

The article in American Medical News points out that physicians who attest today would need to still prove they meet Meaningful Use Stage 2 criteria next year.  The thing is, Stage 2 criteria is still in its proposal stage and has not yet been officially posted by the Centers for Medicare & Medicaid Services (CMS).  When will Stage 2 be officially defined?  Well...we're not sure yet.  Most likely by the end of the summer this year.  That means the physician has from now until April of next year to meet Stage 2's requirements with just a general idea to go off of.  Once the final draft of the definitions are posted, that leaves maybe, what, 7 or 8 months to make sure everything is in place?  Do you see how the question whether to wait might be an issue?
Everyone likes free money, but physicians really shouldn't feel rushed to attest as soon as humanly possible.  They actually have until the end of 2012 to register to receive the full amount -  $44,000 for Medicare or $63,750 from Medicaid.  Why not wait until the Stage 2 requirements are officially posted and then kill two birds with one stone by implementing EHR technology and practices that meets Stage 2?  Physicians will still receive incentive payments for five years like those who attested in 2011.  Waiting could save money, time and headaches by not having to makes changes in software and hardware if Stage 2's final draft differs greatly from the proposal.  

Just Do It (Now)

On the contrary, some don't see the point in waiting for the meaningful use Step 2 official requirements to come out.  The article referenced to a Rhode Island doctor, Douglas Foreman, DO,  who said he didn't see a reason in waiting.  He wasn't worried about qualifying for Stage 2's requirements and doesn't think other physicians should worry either.  For those who have already implemented an approved EHR system, such as the Methodist Health System in Dallas and the Detroit Medical Center, one could see why they wouldn't bother waiting to register.  According to the proposed criteria, not much changes between Stages 1 and 2.  The difference  is mainly the percentage of patients required to be on the electronic system.  So far, it appears that not a lot of additional software or hardware is required for Stage 2.  The only big difference is the implementation of patient portals for patients to use and giving them access to their own health records in a timely fashion.  This shouldn't be such a significant difference to deter physicians who have already implemented approved EHR systems from really wanting to delay attesting for their Medicare incentive until next year.

Meaningful News About Meaningful Use

April 18th, 2011 marked the first day of acceptance of submissions (referred to as attestations) for the meaningful use electronic health record (EHR) incentives program from Medicare.  Health care providers who meet the guidelines will receive a total of $44,000 up to $64,000 spread out over five years from the Centers for Medicare and Medicaid Services (CMS) if they register in 2011 or 2012.  Providers choose to receive the EHR incentives money from either Medicare or Medicaid, but cannot receive from both.  They are allowed to switch programs if they choose and have to meet the requirements.  The health care providers who attested on the opening day on the 18th could receive their first check as early as mid-May. 

A little back history about the incentive program:  In 2009,  the economic stimulus legislation called American Recovery and Reinvestment Act (ARRA) funded money for the HITECH Act (Health Information Technology for Economic and Clinical Health).  Under HITECH, physicians and practices can qualify for the payments by implementing approved EHR devices and software.  The term "meaningful use" refers to using the implemented technology system for the purpose of improving accuracy of data and streamlining patient care.

Those who attest either this year or in the next, will receive the $18,000 (Medicare) or $21,250 (Medicaid) from CMS the first year.  The amount decreases for each following year and will add up to either $44,000 from Medicare or $64,000 from Medicaid.  There will actually be a penalty for those who start the implementation adoption process in 2013 or later - they will receive a lesser amount of incentive money than those who attested in 2011 or 2012.  Providers who still have not implemented meaningful use in 2015 or later will receive a 1% deduction their yearly Medicare reimbursement.  This percentage of deduction will increase every year they have still not registered.  This penalty will hopefully encourage many health care facilities to adopt a certified EHR system as soon as possible. 

The requirements that need to be met to receive the EHR incentive vary slightly between Medicare and Medicaid.  Medicaid requires physicians to have at least 30% of their patients covered by Medicaid to eligible for that program.  Eligible Medicare doctors can be general practitioners or osteopaths, dental surgeons, podiatrists, optometrists or chiropractors.  Eligible Medicaid doctors can be general practitioners or osteopaths, nurse practitioners, certified nurse-midwives, dentists or physician assistants who work in Federally Qualified Health Center or Rural Health Clinics led by the physician assistant.  The general guidelines for Stage 1 of meaningful use (if attesting in 2011 or 2012) for both Medicare and Medicaid go as follows:  physicians and practices must have an approved EHR/EMR system implemented to provide comprehensive patient health data to the health care team and ensure that patient's records remain secure and confidential.  The EHR system must be used for computerized physician order and prescription entry to avoid errors and improve the quality of information.  An up-to-date problem list, based on active diagnoses,
 is to be maintained and communicated to other members of the medical team so clinical decision support can be applied at the patient's point of care.  Meaningful use implementation also requires practices to provide their patients and their families access to data, knowledge and tools to be able to manage their health and make smart health-related choices.