This column is produced by APA’s Committee on Electronic Health Records, which is chaired by Steven Daviss, M.D. He can be reached at firstname.lastname@example.org.
For those of you who have not yet participated in the federal government’s meaningful use (MU) incentive program, I suspect there have been two major concerns: (1) installing and using an EHR and (2) understanding the MU program, especially its applicability to psychiatrists. An article in the February 1 issue detailed my own experiences with my EHR. In this article, I am going to focus on MU.
Detailed information on the MU program can be found for APA members at http://psychiatry.org/ehr and for nonmembers at http://cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms. The program is open to all physicians who participate in either Medicare or Medicaid. It is currently in Stage 1, with Stage 2 becoming effective in 2014.
The program basically consists of three sets of criteria related to the use of an EHR for managing patient-related data. The reality is that, thus far, it has been primarily geared toward primary care physicians. However, several of the criteria can be bypassed if they don’t apply to your practice. For example, there is a requirement to record vital signs, height, weight, blood pressure, BMI, and growth charts for patients aged 2 to 20, but it can be excluded if the provider believes that these measures “have no relevance to scope of practice.” In addition, many of the criteria can be satisfied even if they apply to only a subset of a provider’s patients. For example, one requirement is the maintenance of a list of current and active diagnoses for more than 80 percent of your patients. There are other criteria that require only that the EHR be capable of performing a certain function, not that the provider has to actually use the function. An example would be the EHR’s being capable of exchanging key clinical information electronically among providers of care.
In general, if psychiatrists are using an EHR to perform the following functions for their patients, they should be able to satisfy the MU criteria:
Maintaining active medication lists.
Maintaining allergies to medications.
Implementing drug-drug-allergy interaction checks.
Maintaining up-to-date lists of active diagnoses.
Entering medication orders.
Implementing drug formulary checks.
Performing medication reconciliation with new patients who are coming from another setting or care provider.
Providing a clinical summary to other settings or care providers for patients who leave your practice, either temporarily or permanently.
Recording basic demographics, including language, gender, race, ethnicity, and date of birth.
Recording smoking status.
Recording lab results.
Creating a list of all patients with a specific diagnosis.
In selecting an EHR, check with each vendor to ensure that the EHR has sufficient functionality to satisfy the MU criteria. It also can be very helpful if the EHR provides some extra assistance. For example, to satisfy the smoking-status requirement, more than half of a physician’s patients need to have their smoking status recorded. My EHR keeps track of the percentage of my patients for whom this has been done. In addition, the vendor I used created short videos for its Web site explaining how to satisfy each requirement.
The procedure for applying for the incentive payment includes first registering for the MU program on the Web site of the Centers for Medicare and Medicaid Services (CMS), at which time you need to indicate which certified EHR you will be using. When you have satisfied all of the criteria needed to receive your incentive payment, you then perform an attestation function that is on the CMS Web site. The site has an excellent attestation worksheet that you can use to ensure that you have met all of the requirements.
The incentive payments are spread out over a maximum of five years for Medicare providers and six years for Medicaid providers. A Medicare provider can receive up to $44,000 and a Medicaid provider up to $63,750. Any provider who participates in both programs can receive an incentive payment from only one of the programs during any one period of eligibility. For Medicare providers, the maximum amount of money they can receive at any one time is based upon a percentage of the dollar amount that they bill to Medicare.
In 2015, Medicare providers who have not started using a certified EHR will begin seeing a claims penalty. However, as the MU program is voluntary for Medicaid providers, they will not be subject to penalties if they do not participate.
I hope I have taken some of the mystery out of the MU program and made participation seem less daunting. The financial incentive can certainly help offset the cost of installing an EHR. Although the program is not perfect, especially for specialists, it is a step forward in encouraging physicians to use EHRs to better manage their patient data. ■