2011 is almost here; the new year will bring us more than champagne and fireworks. This year, January 1st will start the first HITECH reporting period. In case you missed it, the HITECH Act will reimburse eligible professionals (EPs) for purchasing and implementing a certified electronic health record (EHR) system and using it in a meaningful way. The Center for Medicare and Medicaid Services (CMS) will reimburse EPs up to $44,000 per provider under Medicare, and up to $64,000 per provider under Medicaid.

CMS breaks the payments up over a five year period, with most of the money coming in 2011 and 2012. Payments continue until 2015. EPs that adopt in 2011 or 2012 may receive the full reimbursement amount. EPs that adopt in 2013 or 2014 will receive substantially less; those that adopt in 2015 will receive no payments. However, late adopters may be penalized. CMS plans to cut payments to EPs who are not meaningful users up to five percent, beginning in 2015.

EPs should keep in mind that $44,000 is the maximum reimbursement per provider. An EP’s actual payment depends on how much they bill Medicare in allowable charges each year. The more allowable charges, the more CMS will pay in stimulus.

As I previously mentioned, January 1st, 2011 marks the beginning of the first reporting period. EPs who already use EHR can start reporting meaningful use at this time. Attestation begins in April 2011. During attestation, EHR software will submit an EPs meaningful use metrics. EPs will be eligible for payments if they have met all the requirements. In May, CMS expects to reimburse those who have shown meaningful use during the first reporting period.

What does this mean for you, the provider? If you already have an EHR, it means you need to take a good look at the meaningful use metrics and make sure you are hitting your marks. Meaningful use has a set of features that are required, and each feature has a metric that tells you how much or how often you must use that feature to qualify.

Pay special attention to the risk assessment requirement. Risk assessments are not features of EHR software, so it will be easy to overlook. Meaningful use core requirement 14 requires you to “conduct or review a security risk analysis, implement security updates as necessary, and correct identified security deficiencies.” Do not neglect this requirement!

If you don’t already have an EHR, you still have time to qualify for the full reimbursement. Under no circumstances should you make a rushed decision to adopt an EHR. That being said, you should also not unnecessarily delay, either. There are already many certified EHRs, and many more are certified every day. Please feel free to contact us if you would like more information on certified EHR, risk assessments, or would like us to perform a needs analysis for your practice.

Ryan Ricks
Security Officer