In case you are not familiar with the HITECH Act, congress passed it as part of the larger ARRA stimulus legislation early in 2009. HITECH will reimburse eligible providers (EPs) for implementing a certified EHR system and using in a “meaningful” way. HITECH will reimburse EPs up to $44,000 under Medicare and up to $64,000 under Medicaid. However, state participation is voluntary, so check with your state government if you are interested in the Medicaid program.

The Centers for Medicare and Medicaid Services (CMS) will issue incentive payments to EPs and hospitals beginning in May 2011. In order to receive payments, providers will have to register in January. EPs and hospitals will need to use their EHR software according to the meaningful use guidelines for 90 days before they can attest. EPs and hospitals that wish to take advantage of the first payment period must have an EHR fully implemented and operational before January 1, 2011.

Those that already have an EHR should perform a self-audit to see if their system supports the final meaningful use requirements. Remember, the final meaningful use criteria consist of a core set of 15 mandatory requirements and a menu set, from which EPs must choose five options to implement. EPs who fear their existing system does not meet the requirements should contact their sales or service representative as soon as possible.

EPs who do not currently have an EHR in place need to move quickly if they wish to take advantage of the first payment period. There are several factors EPs must consider. First, no EHR software is currently certified for meaningful use compliance. HHS is working to approve independent bodies, such as CCHIT and the Drummond Group, to certify EHRs. HHS expects there to be approximately five or six certifying bodies, which could begin accepting EHR applications in late September or early October.

Most EPs seem to be waiting on certification, which could be a mistake. Right now many EHR vendors are offering great deals to encourage early adoption. Most analysts predict a huge surge in demand once certifications are in place. That means vendors will be backlogged and will probably have an installation waiting list. It also means that implementation and training teams are more likely to include new recruits rather than seasoned, experienced professionals. Simple economics suggests that a spike in demand will cause a price increase if EHR vendors maintain similar or slightly greater capacity.

EPs wanting to get in on the first payment period need to get busy. If they already have an EHR, they need to inspect their systems to see if they qualify. If they do not have an EHR, they need to look at purchasing a system in the next 30 to 60 days to remain ahead of the curve. Waiting on formal certification is a mistake. Any credible EHR vendor who does not want to go out of business will achieve certification.

Ryan Ricks
Security Officer