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Over one-quarter of the economic stimulus spending authorized by the American Recovery and Reinvestment Act of 2009 (ARRA) will be earmarked for health care – primarily to incentivize providers to adopt electronic health records (EHR). Much of this is detailed in the section entitled the Health Information Technology for Economic and Clinical Health act (HITECH). Incentive payments, estimated by the Congressional Budget Office to total as much as $36 billion by fiscal year 2015, will be made to providers to adopt EHRs. The goal is to have an EHR in place for every American by 2014.

Key provisions include:

Significant Medicare and Medicaid financial incentives to hospitals and physician achieving “meaningful use of a “certified” EHR product.  These started in 2011, and continue for up to 5 years, with payments tapering off each year.

Penalties if “meaningful use” of a “certified” EHR product is not achieved by 2016. 

Significant changes to HIPAA rules

Collection of more and better data on quality of care measures

Improvement of interoperability and the sharing of clinical information across health care organizations at the local and regional level

Formally establishing and funding ($2 billion) the Office of the National Coordinator (ONC) to carry out the provisions of the act. 

Providing over $10 billion in funds for various agencies/ programs, much of which will be made available to health care organizations via grants at the federal, state and local levels.

 

Strategic Impact

This “carrot and stick” legislation is clearly aimed at motivating health care providers to move more quickly to adopt and use EHRs. Providers will need to understand the meaningful use objectives and metrics, and determine whether they’re on an EHR adoption path that will lead to meaningful use. Medicare and Medicare incentives for “Meaningful Use” are significant. Each eligible provider could receive $44,000 from Medicaid or $63,750 from Medicaid. Hospitals could receive $2 million plus an amount per discharge. A 440 bed hospital for example, could receive over $8,000,000. Providers will need to understand which incentives (Medicare, Medicaid, or both) they qualify for, and how the timing of implementations may affect their incentive value. Hence, you need to have a practical and achievable plan of action.

Move decisively and appropriately

Health care providers could begin receiving "meaningful use" incentive payments as early as May 2011. To do so providers must register and demonstrate meaningful use of a certified electronic health record system for 90 consecutive days. While incentive payments will continue for up to 5 years, they will gradually decline. The later you qualify, the less you will receive. You must allow ample time to implement and fine tune use of the system. The final Stage 1 rules require that hospitals meet a “core” set of 14 objectives, along with a selection of 5 objectives from a “menu” of 10 objectives. EPs must meet a core set of 15 objectives, along with the 5 of 10 menu objectives. There is an ability to claim that an objective is inapplicable.

Stage 1 priorities are to:

Improve quality, safety, efficiency, and reduce health disparities

Engage patients and families in their health care

Improve health care coordination

Improve population and public heath

Ensure adequate privacy and security protections for personal health information

Dates and deadlines were not extended. Stages 2 and 3 will "raise the bar" by emphasizing advanced clinical processes and improved health outcomes.   

How CCG Can Help

CCG is committed to providing strategic information technology consulting services to the health care industry. Our core competencies are ideally aligned with the work you have ahead of you to benefit from the ARRA.  Specific ways in which we can help include:

· Strategy and Assessment: We can assist you to Create, Update or Validate your strategy. To achieve the maximum incentives you need to be planning now and acting soon. We have seen the need for multimillion dollar investments even when no changes in software suppliers are contemplated. The quickest solution will usually be with your current supplier(s). However, in some cases the updates required can be about as expensive as replacement solutions.

· HIPAA: Assist with updating your HIPAA privacy and security program to incorporate the new rules; and reinforce the old 

· Vendor selection and implementation: Usually the most challenging incentive requirement is CPOE. Even with the relaxed requirements, often state and local law requires the physician to enter the medication order. Many HIS systems have historically focused on providing information to physicians but have not gained significant physician utilization in entering orders. If you need to go to market for an EHR, or for other systems/technologies surrounding it, we can help you make and implement good decisions

· Guide you through an objective vendor selection process

· Negotiate a fair and timely contract

· Develop a strong implementation plan

· Assist in implementation management    

Examples

· A rural Midwestern hospital system with multiple clinics and a significant behavioral health and home health operation found both the ambulatory and CPOE functionality of their current supplier to be inadequate for meaningful use. We assisted them in analyzing the alternative of upgrading and supplementing the software from their current supplier. At the same time we assisted with the review of alternatives that would entirely replace the current HIS supplier. The market has solutions that were not available when this organization chose its current supplier.

· A urban hospital with over 50 qualifying physicians developed a plan to address the upgrades to the three IT systems that would be necessary for them to achieve meaningful use (Inpatient, Ambulatory and ED). The incentives were projected to exceed $9 million, the upgrade costs were projected to exceed $10 million. No new vendors were involved. We were asked to review the plan, validate the assumptions and identify any cost saving alternatives. We completed the activity in two weeks identifying savings and alternatives that reduced the cost by several million dollars. 

 

 

Contact Us

ARRA / HITECH and Meaningful Use Incentives

 Cavanaugh

      Consulting Group

CavanaughConsulting.org

Link to our Profession Staff

 

Phone: 708-645-1235

Fax:708-913-9910

E-mail:

Support@CavanaughConsulting.org

 

Quotes

 

“Make everything as simple as possible, but not simpler.” Albert Einstein

 

 

“it’s important to note that the legislation wisely rewards, not the installation of EHR technology, but the effective use of that technology.” MED3OOO, Jay Anders M.D., Chief Medical Information Officer

 

…we believe that it will be common in the near future for Certified EHR Technology to be assembled from several replaceable and swappable EHR Modules. Health & Human Services, Interim Final Rule on Standards, December 2009 p.41

 

 

"It is highly unlikely that an organization can fully comply with its obligations under HIPAA and the ARRA HITECH without implementing automated systems for patient and user privacy auditing, managing and aggregating accounting of disclosures and identity management.”  John Houston, University of Pittsburgh Medical Center (UPMC) Vice President Privacy and Security Officer
 

 

“In the original proposal, we identified a broad set of objectives, all of which would need to be met. This included 23 objectives for hospitals and 25 for clinicians. The DHHS received many comments that this approach was too demanding and inflexible, an all-or-nothing test that too few providers would be likely to pass.  In the final regulation, we have divided these elements into two groups: a set of core objectives that constitute an essential starting point for meaningful use of EHRs and a separate menu of additional important activities from which providers will choose several to implement in the first 2 years. David Blumenthal, M.D., M.P.P., national coordinator for HIT, and Marilyn Tavenner, R.N., M.H.A., principal deputy administrator of CMS