September 2010
The $44,000 question: industry insider responses (Tonio Cutrera)
This is in reference to Melissa Heyboer’s article, “The $44,000 question,” which appeared in Issue 13, 2010. The following is Tonio Cutrera’s responses in their entirety.
Question 1: How will this affect the chiropractic office? i.e., do you think this program is beneficial?
A: Chiropractors will gain substantial benefit from the HITECH Act, not only because of the potential to receive up to $44,000 per provider in the form of enticement payments, but perhaps more importantly, due to the benefits of adopting the use of EHR software. Ultimately, patient care is improved by automating tedious tasks and by providing timely access to patient health information . Doctors can spend more time caring for patients and less time struggling with time-consuming paperwork.
Question 2: What do chiropractor’s need to take advantage of this incentive? How much will it cost, as far as time and money, to implement?
A: There are two important elements for qualification. First, doctors must purchase EHR technology that has been certified to meet the requirements for the achievement of meaningful use by eligible providers. The certification process for EHR technology has been finalized, but as of this writing, the certification bodies have not been established and no EHR systems have been certified.
Secondly, providers must prove "meaningful use" of the EHR technology in order to qualify for incentive payments. The final rule that defines meaningful use was published on July 13, 2010. The rule establishes 25 objectives and measures for Stage 1, which begins in 2011. Stages 2 and 3 have not been finalized, but will have more stringent requirements. So, it is not enough to simply purchase an EHR system. Providers must demonstrate that they are meaningful users of certified EHR technology.
Implementation time and cost will vary, depending on the EHR technology chosen. Providers can prove meaningful use in a modular fashion, using a variety of certified software solutions, provided that all of required objectives and measures are met. Computer equipment, training and technical support will also contribute to the expense of EHR implementation.
The time needed for implementation depends largely on the complexity of the EHR system and the amount of training that is required to transition from paper record-keeping to effective use of an EHR. Luckily, providers can begin the 90-day reporting period to demonstrate meaningful use as late as December 1, 2011 in order to qualify for the 2011 incentive payment. Also, eligible providers can begin using certified EHR in 2012 and still qualify for the maximum amount of incentive funds.
Question 3: Will all chiropractic offices qualify? Can cash-based practices benefit?
A: According to the final meaningful use rule, chiropractors are eligible providers under the HITECH Act. The initial proposed rule included a requirements for providers to use EHR systems in ways that fall outside the scope of practice for
Only Medicare and Medicaid providers are eligible for incentive payments. For Medicare, providers receive 75% of the allowable Medicare charges for a payment year, subject to yearly maximum payments. Medicaid providers can also qualify if a minimum of 30% of encounters are for Medicaid patients. Doctors can qualify for one program only; Medicare or Medicaid.
Question 4: When can chiropractors expect to receive payments?
A: Medicare payments begin as early as May, 2011. The payments for the first year of the incentive program are made after the conclusion of the 90-day reporting period for demonstration and attestation of meaningful use. For each year thereafter, the reporting period is the entire year. Qualifying doctors can receive annual payments for up to five years, beginning as early as 2011. Providers who qualify in 2012 are eligible for the maximum incentive amount . See the following chart:
| Calendar Year | First CY in which the EP Receives an Incentive Payment |
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| 2011 | 2012 | 2013 | 2014 | 2015 and | |
| 2011 | $18,000 |
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| 2012 | $12,000 | $18,000 |
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| 2013 | $8,000 | $12,000 | $15,000 |
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| 2014 | $4,000 | $8,000 | $12,000 | $12,000 |
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| 2015 | $2,000 | $4,000 | $8,000 | $8,000 | $0 |
| 2016 |
| $2,000 | $4,000 | $4,000 | $0 |
| TOTAL | $44,000 | $44,000 | $39,000 | $24,000 | $0 |
Question 5: What questions should chiropractors ask their providers (insurance and software) to ensure they are being compliant?
A: First, chiropractors should educate themselves on the HITECH incentive program. A good source of information is the website of the Office of the National Coordinator for Health IT. The address is http://healthit.hhs.gov. Doctors should question their current or prospective software vendors regarding their intentions for certification and in particular, which of the 25 objectives and measures for Stage 1 will be included in their certified EHR products. Because EHRs can be certified in modules, it is important to know which components of a particular software package can be used to demonstrate meaningful use. Providers will have the ability to use more than one EHR product in order to achieve all objectives for meaningful use. Questions should also be asked regarding the estimated timeline for delivering their certified EHR products.
Question 6: What new products or services do you think will come out of this incentive?
A: There will be a plethora of new ERH products introduced over the next few years. Doctors should use an abundance of caution when choosing an EHR system. Not only must the EHR system be certified for the Stage 1 objectives for achieving meaningful use, but must be capable of being upgraded in subsequent years for the more rigorous requirements for stages 2 and 3.
Many software companies will rush products to market to take advantage of the government stimulus money and may not have the support systems, developers and other resources necessary to sustain the products and to provide upgrades to meet future needs. Doctors would be wise to choose a software vendor that is well-established in the chiropractic market and which has a proven track-record for offering high-quality software products and outstanding service and support.
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