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Chiropractic News

September 2010

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EHR health information expectations made easier with the release of the "Final Rule" by CMS

By Steven J. Kraus, DC, DIBCN, CCSP, FASA, FICC

Today’s chiropractic office is on the brink of major changes in health information requirements. Basically, it’s the start of a plan to connect all of healthcare for the betterment of patient care.

And if your practice isn’t prepared, it will cost you.

With the "Final Rule" on electronic health records (EHR) adoption released July 13, 2010, by CMS, “meaningful use” criteria are finally official. And we now know what it takes for DCs to meet those requirements and become eligible for up to $44,000 in federal incentives.

The good news is you can achieve meaningful use because CMS has granted several exceptions from the original rules released last January for public comment.

DCs and chiropractic organizations personally wrote to CMS and ONC (Office of the National Coordinator of Health Information Technology) declaring reasons for exclusions for items such as e-prescribing and drug reconciliation. 

In response to those requests, CMS changed meaningful use criteria for DCs — both in the “core” and “menu-set” criteria. And, when combined with CMS’s relaxing of some of the other criteria, meaningful use with a certified EHR is easily within most of your reach.

The facts are in

Here are the health information expectations as they pertain to you:

1. As “eligible providers,” you are eligible for up to $44,000 in incentive payments.

2. You will have to meet approximately 13 of the 15 “core” meaningful use items, with exclusions related to e-prescribing.

3. You will need to meet approximately four of the final 10 “menu–set” criteria from a list of 10 additional meaningful use items, making a total of 17 minimum criteria you must meet in order to demonstrate meaningful use of an EHR.

4. The first year for incentive payments is 2011: Meaningful use must be achieved only for a 90-day time frame in 2011, all of 2012, and every year thereafter.

5. EHR software vendors will begin the certification process for their software by 4th quarter 2010.

You’re set up for meaningful use with a certified EHR. Now what?

Once you implement a government-certified EHR in your practice and then meaningfully use that software, you’ll apply for your incentive checks.

You can apply at the end of each year, beginning at the end of the 2011 time frame. In subsequent years, your EHR software should automatically report for you. Payments will be made over a five-year span.

How much will DCs receive in incentive funds?

Payment for each of the five years is 75 percent of Medicare-allowed charges submitted to CMS, up to certain preset amounts.

The maximum amounts are: $18,000 in 2011; $12,000 in 2012; $8,000 in 2013; $4,000 in 2014; and $2,000 in 2015.

It’s important to note this is not an “all or nothing” proposition.

For example, if a DC submits only $10,000 in Medicare-allowed charges for a certain time frame, that doctor would receive $7,500 in incentive funds (75 percent of $10,000 = $7,500).

These payments are intended to help defray the upfront costs of training, implementation, hardware, and software.

What happens if a DC chooses not to implement an EHR?

In addition to the amount of incentive funds you receive decreasing each year, providers not using an EHR will start being penalized in 2015 through lower Medicare reimbursements. So it makes sense to implement sooner rather than later.

More than just monetary benefits

In addition to incentive funds from implementing an EHR, you’ll likely witness savings through fewer medical errors, fewer redundancies in service, and better management of continued treatment for chronic disease.

What must be provided in order to demonstrate meaningful use?

In order for your practice to meet the government’s health information technology “core” objectives, your certified EHR must help you demonstrate:

1. Implement drug-drug and drug-allergy interaction checks.

2. Maintain an up-to-date problem list of current and active diagnoses.

3. Maintain an active medication list.

4. Maintain an active medication allergy list.

5. Record all of the

following demographics: preferred language, gender, race, ethnicity, and date of birth.

6. Record and chart changes in the following vital signs: height, weight, blood pressure, calculate and display body mass index (BMI), and plot and display growth charts for children 2 years old to 20 years old, including BMI.

7. Record smoking status for patients 13 years old or older.

8. Report ambulatory clinical quality measures to CMS, including:

• Hypertension — blood pressure management

• Preventative care and screening measure pair: tobacco use assessment and tobacco cessation intervention.

• Adult weight screening and follow-up.

If the utilization for one or more of the “core” measures is zero, then eligible providers must report results for up to three alternate core measures listed here:

• Preventative care and screening: influenza immunization for patients 50 years of age and older.

• Weight assessment and counseling for children and adolescents.

• Childhood immunization status.

9. Implement one clinical decision support rule relevant to specialty or high-clinical priority, along with the ability to track compliance with that rule.

10. Provide patients with an electronic copy of their health information (including diagnostics test results, problem list, medication lists, and medication allergies) upon request.

11. Clinical summaries provided to patients for more than 50 percent of all office visits within three business days.

12. Capability to electronically exchange key clinical information (for example, problem list, medication list, allergies, and diagnostic test results) among providers of care and patient-authorized entities.

13. Protect electronic health information created or maintained by the certified EHR technology through the implementation of appropriate technical capabilities.

What else?

Additionally, eligible providers must choose five of 10 additional objectives from a list of “menu-set” criteria. But because DCs are granted exceptions, you must demonstrate only four of the following eight objectives:

1. Implement drug-formulary checks.

2. Incorporate clinical lab-test results into EHR as structured data.

3. Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research, or outreach.

4. Send reminders to patients (per patient preference) for preventive/follow-up care.

5. Provide patients with timely electronic access to their health information (including lab results, problem list, medication lists, and allergies) within four business days of the information being available to the eligible provider.

6. Use certified EHR technology to identify patient-specific education resources and provide those resources to the patient if appropriate.

7. The eligible provider who receives a patient from another setting of care or provider of care or believes an encounter is relevant should perform medication reconciliation.

8. The eligible provider who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care should provide a summary care record for each transition of care or referral.

Your EHR: more than meeting HIT standards and collecting incentive funds

The biggest bonus of an EHR is it will help connect you to the healthcare community to access MRI and other radiology and lab data from health information exchanges in the future.

Plus, an EHR can be used to identify the needs of populations of patients across your database and better manage patients for better outcomes.

And it doesn’t stop there.

Consider your EHR’s ability to analyze data (including patient demographics, treatment, and outcomes). It becomes a basis for leveraging better reimbursements, especially if your state could aggregate the data in a de-identified manner to demonstrate all chiropractic outcomes in your state.

That will show the cost-effectiveness and efficacy of chiropractic care. And now the electronic package comes full circle and really begins to pay for itself.

All of these are the right reasons to implement an EHR. The government’s $44,000 incentive to do the right thing is icing on the cake.

The key is choosing a true EHR from a partner who will help guide your implementation process, so you can easily and successfully integrate with the modern day delivery of healthcare.

Steven J. Kraus, DC, DIBCN, CCSP, FASA, FICC, is founder and CEO of Future Health, a provider of chiropractic-specific EHR/practice management software. He can be reached at 888-434-7347.

**To view the chart, "Objectives, measures, and exclusions at-a-glance" for EHR, visit www.ChiroEco.com/EHRChart.

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