CMS Clarifies Meaningful Use and Eligible Providers

By Janice G. Jacobs, CPA, CPC, CCS, ROCC

The term “meaningful use” in reference to the stimulus payment for electronic health records (EHRs) has been a source of confusion for providers who want criteria compliance with the incentive. To clarify further, Congress established the following three requirements for meaningful use:

1. Using EHRs in a meaningful manner

2. Interoperability to enhance the quality of care provided to (a) patient

3. The ability to report quality measures to the Centers for Medicare & Medicaid Services (CMS)

CMS plans on phasing the meaningful use criteria in three stages, building upon one another. The first stage begins in 2011, the second stage in 2013, and the third and last stage in 2015. Advances in health information technology (HIT) will be incorporated into each subsequent stage.

A brief overview of the three stages is as follows:

Stage 1—Involves standardizing health information into a coded format, tracking, incorporating clinical decision support tools, and reporting quality measures.

Stage 2—Includes all components of Stage 1 plus expands HIT use to improve quality of care, provides for the exchange of information in a structured format, and requires the ability to transmit diagnostic testing information.

Stage 3—Includes components of Stages 1 and 2 plus expands the meaningful use criteria for improved quality of care, safety and efficiency, and includes a means for patients to access their own records and self-help tools.

CMS also clarified that an eligible professional (EP) is a nonhospital-based physician who receives reimbursement from either Medicare or Medicaid and who uses certified EHR technology (CEHR). Each EP is entitled to receive an incentive payment individually, provided he or she meets the meaningful use criteria. This means it is true that each physician in a group practice, regardless of the group’s size, is eligible to receive the full incentive payment. EPs must participate in either the Medicare or Medicaid incentive program. Eligible hospitals may participate in both.

Hospital-based eligible professionals (HBEPs) are not eligible for incentive payments through the Medicare program. The reason being HBEPs such as pathologists, anesthesiologists, or emergency department (ED) physicians furnish services covered under the Medicare program during the hospital’s reporting period and while using the hospital’s facilities and equipment including the hospital’s EHRs.

In the proposed rule, EPs who receive incentive payments in the first year have to satisfy Stage 1 requirements in 2011 and 2012. CMS will update the meaningful use criteria in time for the 2013 payment year and, as a result, Stage 2 criteria has to be met in 2013 and 2014 for corresponding incentive payments EP eligibility. Stage 3 criteria needs to be implemented in 2015 for EPs to receive their final incentive payment.

A complete breakdown of each stage of the meaningful use criteria is found in the “Summary of the Proposed Rule for the Medicare and Medicaid Electronic Health Records (EHR) Incentive Program (Eligible Professionals only)”.

Note: This article is a follow-up to “EHR Primer: Get the Basics,” pages 14-15, in the February 2010 Coding Edge.

Janice G. Jacobs, CPA, CPC, CCS, ROCC, is a director in Huron Consulting Group’s Life Sciences Practice with over 25 years of health care billing, coding, and reimbursement experience. During her career, she has performed documentation, coding, billing, and charge description master (CDM) reviews. She recently served as interim director of coding compliance at a major West Coast academic medical center, where she worked extensively with the Radiation Oncology department. She is a certified public accountant licensed in Pennsylvania, and serves on the National Advisory Board (NAB) of the AAPC.


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