August 9, 2010
EMR Stimulus Meaningful Use Checklist
Written by: John- EHR
- Electronic Health Record
- Electronic Medical Record
- EMR
- EMR Consulting
- EMR Implementation
- Meaningful Use
A recent comment from Jim Hook from The Fox Group had a nice checklist of items that doctors and practice managers could start doing to make sure that their EMR implementation is ready to meet the meaningful use standards. This isn’t an exhaustive list, but I thought was a good list for those providers wanting to being their preparation for showing meaningful use and obtaining the EMR stimulus money.
Everyone should keep in mind that there are no systems “Certified” at this point.
Here are some things to check as you get ready to claim your incentives for EHR Meaningful Use under the HITECH Act. This information is based on (EPs) qualifying for the Medicare incentives.
1) Start talking to your vendor about their plans to submit their EHR software for certification as “Certified EHR Technology”. The system does not have to be certified as of January 1, but it does need to be certified by the end of the 90-day period you are using to attest to your EHR Meaningful Use.
2) Keep in mind that if you are using a stand-alone EMR product with an existing legacy practice management (PM) system, the system needs to be Certified EHR Technology also. This is because some of the functions of a certified system, such as recording patient demographics electronically, are most likely functions of your PM system, not the EMR product. So talk to that vendor, too.
3) Verify that any eligible provider attesting to meeting EHR Meaningful Use objectives provides 10% or more of his/her Medicare services in an outpatient setting (not inpatient or in a hospital ED). CMS will look at the percent of services rendered in an outpatient setting for the fiscal year ending 09/30/2010 to determine the IP/OP percentages. Your EHR healthcare consultant must be qualified to do the analytical and reporting work in preparing the self-attestation report, based on the current fiscal year and the individual EHR Meaningful Use objectives in place, starting January 2011.
4) Make sure all eligible providers you are planning to certify for EHR Meaningful Use have an NPI number and are enrolled in PECOS.
5) For EPs in group practices, confirm the tax Id number – group or personal – of each provider for payment of the incentive amount. Payments can be made to either number.
6) CMS will be establishing an Internet-based enrollment process for EPs planning to apply for incentive payments. Keep checking this site for the Registration process, and enroll when it is available.
7) As soon as you start the clock on your 90-day period, make sure you are meeting all the EHR Meaningful Use objectives applicable to your practice, and, for objectives with numerical thresholds, that you are attaining the levels specified. If your EHR system is Certified EHR Technology, it should be capable of supporting all Stage 1 Meaningful Use objectives.
8) Monitor the CMS website on EHR Incentive Programs to determine the format of the attestation for 2011. And keep in mind that accuracy is paramount; attesting to EHR Meaningful Use is making a claim to a Federal program. And the penalties for false claims are significant!
Attestations can be completed as early as April, 2011, and CMS has stated payments will be made in May. For EPs seeking incentive payments under the Medicaid / Medical program, visit the CMS website for further information.
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“If your EHR system is Certified EHR Technology, it should be capable of supporting all Stage 1 Meaningful Use objectives.”
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Actually, that is the core requirement of certification. Not “should” — “must.”
One more item on the list: ask your EMR vendor if it supports dictation and transcription. Dictation is still the most efficient means of documentation and is a facilitator for EMR adoption. Ask your transcription service for an interface. MU does not exclude dictation of the narrative (HPI, Assessment, Plan, progress notes, etc).
Laura,
You can use dictation and show meaningful use, but there’s no requirement to use dictation in order to show meaningful use. In fact, my guess is that the majority of doctors will show meaningful use without dictation. Although, there’s certainly an interesting battle going on between dictation and granular point and click data entry and everything in between.
@Bobby … are RECs signing up EHR vendors in advance of any of them being certified?
I imagine that RECs are starting with the CCHIT certified products from the larger vendors under the probably accurate assumption that they will be among the first HITECH certified.
I imagine most small group practices unless they have already implemented an EHR or are in progress … will probably hold off to see who gets certified.
Should be a very interesting and fast paced next eight months as EHRs are certified by the to be determined certifiers … to enable practices to report their MU performance at the end of April … and receive their CMS check in May.
Can I get a quick show of hands of those who think that’s all going to happen like CMS and ONC say it will?
Don, we don’t “sign up” any EHR vendors. HealthInsight (my REC) is assiduously “vendor neutral.” Our provider clients make the final call, based on our comprehensive collaborative assessment of their needs. We don’t contract for them.
Some other RECs, however, are announcing short lists of “preferred vendors.” I view that practice with dubiety.
As far as “certification,” there are a number of major EHR vendors for whom I’d say it’s a safe bet (virtually all of them are hawking unequivocal guarantees of ARRA Certification). Though, this is another area in which the ONC cart is out ahead of the horse.
Bobby… I understand the difference you make between the perspective of your REC and the actions of others.
Not sure how you can be neutral and at the same time provide recommendations to practices … but am sure there may be ways to boil down the key features of all the products a practice might consider. Tough to do that without making a recommendation.
Unlike your REC CalIPSO has put out an RFP to vendors on 22 Jul that was due back by 6 Aug and vendors will be notified of selection on 13 Aug this Friday. No where in their RFP do they require ONC certification of course. Wonder what will happen when one of their ‘client’ practices signs up an EHR provider that was a selected vendor on CalIPSO’s list … fails to be ONC certified?
Don B,
Do you really think that there are any EHR vendors that would make a REC list that won’t become certified? I’m predicting that 98% or more of EMR providers will become certified.
John … how many EHR certification companies have been approved? How many EHR companies are going to be certified by an undetermined number of potential certification companies by 30 Apr 2011 (the end of the first eligible 90 day period)?
I’d say most will be, but I guess we’ll see.
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