Guest Spot: Meaningful Use -- Have the Right Answers!  (Part I)

Contributed by: Kay Jackson, Compliance and Financial Manager, Iatric Systems, Inc.

If you know the right answers, there are many paths to achieving Meaningful Use, even as early as 2011! Do you know how to get incentive payments and when you can begin receiving them? Do you know the difference between “complete EHR” and “module EHR” certification? Do you know the deadlines to register and attest? Read this article to learn the answers to all of these questions and more.

What is Certified EHR Technology?

If you use MEDITECH, your hospital has EHR (Electronic Health Record) technology. Whether or not it’s certified depends on the version. As of 01/27/2011, MEDITECH MAGIC version 5.6.4, Client/Server version 5.6.4 and 6.0 version 6.05 are all “Certified EHR Technology.”

Still, some questions remain. If your hospital doesn’t use all of MEDITECH’s modules, can it meet Meaningful Use Objectives? Yes, with a little help. Can your hospital use software besides MEDITECH to achieve Meaningful Use? Absolutely!

There are two types of EHR certification:

- Complete EHR Certification: This means the EHR software has been tested and certified by an ONC-ATCB (Office of the National Coordinator - Approved Testing and Certification Body), and the solution meets *all* of the government criteria for a complete EHR. Full EHR systems like MEDITECH, Cerner, Epic and McKesson fall into this category.

- EHR Module Certification: This means the EHR software has been tested and certified by an ONC-ATCB and meets *one or more* Meaningful Use criteria. Vendors like 3M, Iatric Systems, Picis and T-System offer “modules” or products that meet one or more specific criteria and therefore fall into this category.

Your hospital can use MEDITECH’s Certified EHR Technology alone, or it can use MEDITECH plus any combination of other vendor Certified EHR Modules to achieve Meaningful Use.

Where can you find out which vendor products meet specific Meaningful Use criteria? The ONC provides a great tool called Certified Health IT Product List (CHPL). Go to http://onc-chpl.force.com/ehrcert, select “Inpatient Practice Type” then “Search by Criteria Met.”  For example, to find vendors that offer certified medication reconciliation, check the box next to “(j) medication reconciliation” then “Search Matching Products.” Be sure to sort the list by Vendor, and note that there may be multiple pages. Also note the Product Version # to ensure the version your facility uses is certified to meet Meaningful Use. Any module that completes your EHR in meeting Meaningful Use must be certified in order for your facility to be eligible to receive incentive funds.

Where is the official list of Meaningful Use Objectives?

Do a Google search, and you’ll find that many organizations have published a list of Meaningful Use Objectives. The *official* final list was published in the Federal Register on July 28, 2010, and can be found at http://edocket.access.gpo.gov/2010/pdf/2010-17210.pdf. Don’t be put off by how long the document is. Just look for the tables within the file – an Objective can be found in the left column of each table.

Another long but useful list can be found at http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&rgn=div6&view=text&node=42:5.0.1.1.11.1&idno=42 (scroll down to § 495.6 and look for 1(i), 2(i), 3(i), etc.).

For hospitals, there are 14 required “Core Objectives.” There are also 10 “Menu Set Objectives” that are classified as optional, but a hospital is required to achieve at least 5 of the Menu Set criteria. Iatric Systems has developed a summary chart of Core and Menu Set Objectives, which can be found at http://www.iatric.com/Download/Public/Iatric_Meaningful_Use_Summary_Chart_02-2011.pdf.  This summary chart also lists the criteria Iatric Systems solutions meet.

How does a hospital get incentive dollars?

Of course Meaningful Use Objectives must be met in order for a hospital to receive incentive funds. But how do you actually go about getting the money? The answer - your hospital must register and attest.

Registration is the first step, and attestation follows. CMS (Centers for Medicare and Medicaid Services) has developed a very thorough website on registration and attestation:

http://www.cms.gov/EHRIncentivePrograms/20_RegistrationandAttestation.asp#TopOfPage

This page includes a .pdf user guide, video webinar, information on what information you’ll need to register and more.

Another good summary is at http://www.managemypractice.com/how-do-you-get-that-stimulus-money-for-using-an-electronic-medical-record-you-register/. In it, Mary Whaley states that hospitals eligible for EHR incentive payments under both Medicare and Medicaid should select both during the registration process.

What is the difference between Medicare and Medicaid EHR Incentive Programs?

Medicare has its own federal version EHR Incentive Program. The Medicaid EHR Incentive Program is voluntarily for states to implement and may not be available in every state.  Both programs offer incentive payments that may start as early as 2011, and both offer base payments of $2 million.

CMS gives an overview of both programs at http://www.cms.gov/EHRIncentivePrograms/. They have also prepared a nice table comparing the federal and state programs at:

http://www1.cms.gov/EHRIncentivePrograms/Downloads/ComparisonChart.pdf

There is also an ONC recorded (albeit rather long) webinar on the subject available at http://www.tvworldwide.com/events/hhs/101214/default.cfm?id=13110&type=flv&test=0&live=0.

What are the important dates?

CMS displays a nice visual timeline at: http://www.cms.gov/EHRIncentivePrograms/Downloads/EHRIncentProgtimeline508.pdf.

Below is a summary of that timeline:

• Registration opened in January, 2011
• Attestations can be submitted starting in April, 2011
• Incentive payments start in May, 2011
• A hospital attempting to achieve Meaningful Use in 2011 needs to demonstrate it no later than July 1^st (3 months before CMS’ 2012 fiscal year which begins in October)
• To receive an incentive payment for federal fiscal year 2011, hospitals must register and attest by November 30, 2011

Hope this is helpful information. Keep your eye out for Part II and more details next month!

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Kay Jackson is the Software Certification, Compliance and Financial Marketing Manager at Iatric Systems, Inc. Kay is a well-known educator in the MEDITECH community and has been a requested speaker at more than 100 conventions. She will be presenting education on Meaningful Use and other topics at International MUSE 2011 in Nashville, TN. For more information, visit Iatric Systems online at www.iatric.com.