EHR Incentive Program – clarifying the timeline

The Centers for Medicare & Medicaid Services (CMS) under HHS announced its proposed final rule for the Electronic Health Record Incentive Program on Dec 30, 2009.  Despite the long weekend, many people have been working overtime reading through the 556 page document and making comments on their blogs.  Just do a search on and you’d see many well written as well as less than fully informed opinions.

For those who are defined as “Eligible Professionals” under the document (essentially physicians) as well as vendors in the EHR ecosystem, there are a few interesting points about the incentive payments that are worth noting:

  1. ONC will define the requirement for a “qualified EHR” in an upcoming announcement.  The certification body also has not been announced.
  2. While there is always a chance politics and execution can screw up the plan, people should realize that it is not a mere act of buying and installing an EHR that enables a physician to receive the $44,000 payment over 5 years.  There are specific reporting and process requirement that the physician needs to fulfill before the payments are made.  This isn’t a simple give away to EHR vendors.  It will be interesting to see how they will “assist” their customers to get certified for EHR use.
  3. The maximum first year payment is $18,000 and it declines till it reaches $0 in the 6th year.  For physicians working in geographically Health Professional Shortage Area (HPSA), the maximum incentive amount for each year is increased by 10%.
  4. A physician needs to start “meaningfully use” an EHR by October 1 of the year that he or she intends to claim as year 1.  He or she would have to use the EHR meaningfully for the entire year in subsequent years.
  5. The Meaningful Use requirements that have been released is for stage 1.  There will be additional stage 2 and stage 3 requirements to be announced by end of 2011 and end of 2013 respectively.

The timeline is reasonably clear now.  Even though the initial bar for certification will be lenient, getting certified for the incentive may still not lead to the ultimate goal of encouraging adoption of EHR, i.e. improving delivery of care and lowering costs.

CMS is trying to change not just the way thing are done but also forcing the data integration issues to the forefront.  That is a rather weak area in a lot of the current EHR solutions (not in the sense that the feature is not available but that it is usually an expensive and time consuming customization).  As Ken Terry said in his blog, “physicians must incorporate at least half of lab results in their EHRs as structured data. That requires interfaces with their major labs, but such interfaces may be unavailable or may be too expensive for some practices“.

If you are interested in reading a synopsis of the CMS document but can’t be bothered to read through the entire 556 pages, you can start with this post.  Whether you are a clinician, a technologist or marketer, there is something worth digging into there.

Now a question for the readers, what is your plan with respect to EHR?  Already done and implemented, wait-and-see or something else?

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