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UPDATE: Chiropractors and HHS CMS Electronic Health Records Incentive Program

Final Rule was posted July 28, 2010

 

Edie Hofmann, Compliance Expert

ICCOM

www.ICCOM.org

 

Many chiropractors have asked me to comment on the Medicare & Medicaid EHR Incentive Program.  The final ruling was posted on July 28, 2010.  Although no one knows for sure exactly how this is going to work until it is actually begins.  I am going to try to make this as easy to understand as possible.  Yes, chiropractors are considered an eligible professional (EP) and therefore qualified to receive the incentive payments as long as they follow All of the rules.

 

Background

 

Get ready for a mind twister.  Hope you can keep all of these acronyms straight. J The Centers for Medicare and Medicaid Services (CMS) Electronic Health Record (EHR) Incentive program is all part of the Health Information Technology for Economic and Clinical Health Act (HITECH) programs created by the American Recovery and Reinvestment Act of 2009 (ARRA).  It was established to promote the adoption and “meaningful use” of health information technology (HIT) and electronic health records (EHRs).  These incentive payments are part of a broader effort under the HITECH Act to accelerate the adoption of HIT and utilization of qualified EHRs. 

 

Did you get that?  Keep these acronym definitions close. They will be used throughout this article and you will hear them more and more from CMS and in other articles.  It does not get any easier, but hopefully I can distill it down for you. The final ruling is 276 pages.  There is much to sift through but these are the highlights. 276 pages cannot be distilled completely into a couple of pages and I am not going to try it get it all into this article.  Believe me, this is only the beginning and much more will follow as the entire process moves forward.  My goal is only to give you enough information to make an initial decision concerning participation.  Most doctors I know are mostly interested in how they can get all or at least part of the $44,000.00 they were told was available to each EP.  After finding out exactly what it is going to take, you may or may not be so interested. 

 

Chiropractors Are Eligible. Do You Want to Participate? 

 

To best help you make a decision about participation, there are several things you need to understand.  First, answer a few questions.  Do you take care of many Medicare patients?  The maximum incentive payment is 75% of your year’s Medicare revenue.  What is it going to cost you to upgrade your current practice/patient management software and possibly hardware to be compliant?  Will you have to increase your staff? And probably this is the most important, what kind of time are you personally going to have to invest to become compliant? This will be a hands on process.  You will not easily be able to hand it off to your office manager or CA.  Hopefully, this article will help you decide if you want to participate or not.

 

This program is said to be a voluntary program but there are two parts to the incentive that is designed to encourage or as CMS says “accelerate” your compliance.  One is the direct incentive payments to you and the other is a reduction of your Medicare fee for service reimbursement or as CMS calls it, a “payment adjustment”. This does not really sound like a volunteer program to anyone. 

 

Incentive Payments

 

Your specific incentive payment maximum is 75% of your total allowed charges from services performed and billed during the specified time frame not to exceed the maximum incentive payment in the table below. The later you begin the process, the less money you will receive. You must enroll and demonstrate “meaningful use” of certified Health Information Technology by calendar year (CY) 2012 or your total incentive benefit will be reduced. You must enroll by 2014 or you will receive no incentive payments. No payments will be paid after CY 2015. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Reduction in Reimbursement Payments

 

As said before, there is a second part of the incentive program.  CMS has outlined an incremental payment adjustment for EPs that fail to demonstrate meaningful use starting in the 2015. If you do not successfully demonstrate meaningful use of certified EHR technology, your Medicare physician fee schedule amount for allowed Medicare services will be adjusted by the applicable payment adjustment as follows:

 

2015 – 99 percent of Medicare physician fee schedule covered amount

(reduced 1%)

             2016 – 98 percent of Medicare physician fee schedule covered amount

(reduced another 1%)

2017 and each subsequent year – 97 percent of Medicare physician fee schedule covered amount (reduced another 1%)

 

If CMS determines that for 2018 and subsequent years that less than 75 percent of all EP’s are meaningful users then the payment adjustment will change by one percentage point each year until the payment adjustment reaches 95 percent.

 

I think you get this one, they will be cutting your Medicare reimbursement if you do not choose to participate.

 

 

 

Reference Documents:

 

List 15 Core Set Objectives, 10 Menu Set Objects and 38 Clinical Quality Measures

 

Table 2: Stage 1 Meaningful Use Objectives and Associate Measures Sorted by Core and Menu Set

 

HHS CMS 42 CFR Parts 412, 413, 422 et al. Electronic Health Record Incentive Program; Final Rule

continued on Page 2..

Still confused?  Hope these links help!

 

EHR Attestation  Process and Worksheet

 

E-Book: Selecting the Right EMR

 

Selecting one of the above links will navigate you away from www.ICCOM.org

 

Dates to Remember

· October 3, 2011 – Last day for eligible professionals to begin their 90-day reporting period for calendar year 2011 for the Medicare EHR Incentive Program.

· November 30, 2011 – Last day for eligible hospitals and critical access hospitals to register and attest to receive an Incentive Payment for Federal fiscal year (FY) 2011.

· February 29, 2012 – Last day for eligible professionals to register and attest to receive an Incentive Payment for calendar year (CY) 2011.

 

Remember, if you wait until the 2012 Reporting Year, you will still be eligible to receive all the money available for you.  The reporting period will be longer.  See Table Below