As the 2011 year draws to a close, a large number of Eligible Professionals are submitting their Attestation for the Medicare EHR Incentive Program (Meaningful Use). The Center for Medicare and Medicaid Services (CMS) has indicated that they will be publishing data on participation in the program, including which EHRs were used to achieve Meaningful Use, after February (though they publish their aggregate participation month-by-month currently – they just don’t disclose which systems have been used).
For those who have enrolled in the Medicaid branch of the program, all that is needed for first-year participation is to demonstrate Adoption, Implementation or Upgrade (AIU) in 2011 (not Attestation, as is needed for the first-year participation in the Medicare program). Given that Practice Fusion is web-based, self-service, and immediately available, those practices who qualify for the Medicaid branch of the program – 30% of the patient volume is paid for (at least in part) by Medicaid, or 20% for pediatricians – and have not yet adopted an EHR, can still do so before the end of the year. No weeks- or months-long wait for a company representative to come out and install a system is needed; it can be done today.
Now, we look ahead to 2012. The picture is a little different, depending on whether an Eligible Professional is attempting to demonstrate Meaningful Use for the first time, or is a successful Medicare Attester in 2011 and is now going for the second year in the program.
First-time attestation in 2012
Many clinicians have elected to wait until 2012 before beginning their Meaningful Use attestation – the EHR incentive program is structured such that the full amount of incentive money (cumulative $44,000 per clinician) is the same for 2011 Attesters and those who wait until 2012. The only disadvantage of waiting is that the Stage 1 criteria for Meaningful Use are applied for 3 years to the earlier Attestation group (2011, 2012 and 2103), whereas Stage 1 applies for only 2 years to the later group (2012 and 2013) – everyone will move to the more-rigorous Stage 2 criteria in 2014, regardless of when the program is started.
For those who have elected to wait until 2012 to begin their Stage 1 Meaningful Use, the process is the same as for 2011 – 90 days of continuous use of the EHR need to be demonstrated in the 2012 calendar year. Unlike 2011, when the program roll-out and product readiness were not available until the end of the year, in 2012 the measurement period can begin right away. That means that by March, the 90 day period can be concluded and Attestation can take place at that time.
In fact, for 2012, any 90-day period can be used as the measure period, depending on the clinician’s readiness. Once the measure period has been completed, then attestation can occur, and incentive money can be dispensed.
2012 for those who attested in 2011
Clinicians who have not yet Attested for 2011, but intend to do so, have until the end of February 2012 to complete their Attestation (for 2011 activity).
Once Attestation for the 2011 year has been completed, the intent of Meaningful Use is to continue the usage of the implemented EHR going-forward. That means that for the second year, and each year thereafter, the full calendar year (not just the 90 day period that applied to the first year) is the measurement period for ensuing reporting.
All the behaviors that were adopted for the first year – eRx for prescribing practices, patient enrollment in the EHR (or printing out of clinical summaries after each visit), capturing all the demographics, coding medications, allergies and diagnoses, etc. – need to be continued as the “way of doing business” using the EHR. That means that keeping track of how one is doing, using the Meaningful Use Dashboard, is a good idea to review on a periodic basis during the course of the 2012 year.
Streamlining the EHR is an ongoing process
As we continue to build and improve upon our EHR, we continue to add important functionality, and to keep our eye on ongoing Meaningful Use. Where identified (by our own internal quality control, as well as by members of our user community who bring their comments to our attention), we strive to improve and streamline our ever-evolving product.
And, given that our system is web-based, self-service, and free, these changes, once implemented, become available to everyone everywhere all at once. That means that no lengthy product-upgrade process and re-installation (often a nightmarish experience with locally-installed EHRs) need be done.
The ability to achieve and demonstrate Meaningful Use in 2012 and years thereafter are, perhaps, the easiest to achieve using the Practice Fusion web-based EHR. The different kinds of Attestation – whether a 90-day window for first-time participants, or the full-year window for subsequent-year Attesters – are all supported as we continue to refine and improve upon our widely-adopted product.
Robert Rowley, MD
Dr. Rowley brings together three areas of expertise, and helps shape Practice Fusion in a unique way. He has been a practicing primary care physician for over 30 years, and as an early EHR adopter, has been practicing without paper charts since 2002. He has been involved in governance and directorship of health care delivery in a managed care setting in California for over 20 years. He also has a strong technology background and helped develop the very first version of Practice Fusion based on tools created for his own practice. As Medical Director of Practice Fusion, Dr. Rowley helps guide the development of the EHR as an essential tool for our doctors, and as a valuable resource for healthcare overall. Follow Dr. Rowley: