The Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) recently announced January 3rd, 2011 as the registration date for providers wishing to participate in the Health Information Technology for Clinical and Economic Health (HITECH) stimulus program. Just as a reminder, HITECH will reimburse up to $44,000 per provider under Medicare and up to $64,000 under Medicaid for those eligible professionals (EPs) that purchase and implement a certified electronic health record (EHR) system. EPs must also utilize their system in accordance with the meaningful use guidelines.

Registration will open on January 3rd for EPs and eligible hospitals (EHs) that want to participate in the Medicare program. Medicaid registration will also open for EPs and EHs in Alaska, Iowa, Kentucky, Louisiana, Oklahoma, Michigan, Mississippi, North Carolina, South Carolina, Tennessee, and Texas. California, Missouri, and North Dakota should begin registration in February. Other states may initiate their programs in the spring and summer. Registration will take place through the CMS website.

Here are some additional key dates for the HITECH stimulus program:

• January 2011 – Some states may begin issuing Medicaid incentive payments
• April 2011 – Attestation for Medicare begins
• May 2011 – First Medicare payments issued
• Oct 3, 2011 – Last day for EPs to begin demonstrating meaningful use for 2011
• Dec 31, 2011 – 2011 payment year ends for EPs.

If you currently have an EHR system, be sure to register for your incentives on January 3rd. You will need to pay close attention to the meaningful use metrics. You must qualify for all 15 core requirements, and five of the ten menu set requirements in order to receive your payments. As always, we urge everyone to scrutinize the security requirement. You must conduct a risk assessment and begin remediation to fulfill this criteria. Keep in mind that risk assessments are not typical parts of EHR systems, and will be easily overlooked.

If you do not currently have an EHR, you will need to implement in 2011 in order to receive the full Medicare reimbursement. You should not rush your EHR decision just to qualify for incentive payments; EHR can provide many benefits regardless of whether your practice participates in the HITECH program. However, if you would like to participate, your practice should not unnecessarily delay its EHR decision. Many experts predict an increase in prices and implementation delays as EPs try to qualify for meaningful use en masse. Please feel free to contact us if you would like any additional information about EHR, risk assessments, or the HITECH program.

Ryan Ricks
Security Officer