In an Oct. 4 webinar titled "How the HITECH Regulations Impact the Use of Health Information Technology in ASCs," Robert Hussey, head of the government relations practice at Minneapolis-based Snow Communications, discussed how "meaningful use" requirements apply to ambulatory surgery centers and the physicians that use them.
Mr. Hussey began the presentation by giving an overview of the HITECH program, which passed in Feb. 2009 as part of the federal stimulus bill. The federal government set aside approximately $27 billion for health information technology initiatives, allocating funds to reimburse eligible professionals and hospitals for "meaningful use" of "certified" EHRs . The incentive program was divided into three stages, to be implemented in 2011, 2013 and 2015.
Meaningful use: stage 1
Mr. Hussey said stage 1 of meaningful use places an emphasis on promoting adoption of electronic health records. The meaningful use requirements are organized into 25 criteria, and the criteria are divided into "core criteria" and "menu" options to promote flexibility and allow providers and hospitals to defer up to 5 of the 10 menu criteria for stage one.
Stage 1 of meaningful use began in Oct. 2010 for hospitals and Jan. 2011 for eligible professionals, and approximately 1,900 hospitals and 89,000 EPs had registered with the program as of Aug. 30. CMS estimates that eligible professionals have received $42 million in Medicare incentive payouts as of Aug. 30 and that hospitals have received $220 million.
Meaningful use: stage 2
Mr. Hussey said stage 2 of meaningful use will differ from stage 1 in its expansion of scope and the movement of some requirements from the "menu" to the "core criteria." For example, requirements for computerized physician order entry will expand from 30 percent to 60 percent of orders, and some criteria — such as the drug formulary check — will become core measure under stage 2. This stage is designed to promote interoperability and the exchange of health information between providers, Mr. Hussey said.
What does HITECH mean for ASCs?
Though ambulatory surgery centers are not eligible for EHR incentive funds — and are, in fact, conspicuously absent from the final rule for the EHR Incentive Program — surgery centers may still be affected by HITECH. The most pressing issue for ASCS is the 50 percent threshold rule for EP eligibility, which says that to be a meaningful EHR user, an EP must have 50 percent or more of their patient encounters during the EHR reporting period at a practice or location equipped with certified EHR technology.
According to Mr. Hussey, patient encounters in the ambulatory surgery center would be used in calculating the 50 percent threshold for certified EHR. According to CMS, as long as an eligible professional has certified EHR technology available for 50 percent or more of their patient encounters during the EHR reporting period, they only have to include those encounters where certified EHR technology is available at the start of the reporting period.
CMS clarified that surgery centers don't necessarily need to be physically equipped with an EHR system. CMS only requires that EHR be used to meet the measures of meaningful use objectives, meaning the system could have a "variety of configurations." If certified EHR technology is available at the ASC (either because the ASC implements it or the physician's technology is available through a portable device), the encounters at the ASC would be included in meaningful use calculations.
Conclusions
Mr. Hussey concluded that ASC patient encounters can help EPs qualify for meaningful use incentive payments, but the ASC must meet one of the following criteria for the EP to qualify:
• The ASC must have certified EHR technology installed onsite to record patient encounters.
• The EP must record the ASC encounter in real-time via an online link to the EP's office EHR system.
• The EP must record the ASC encounter on a certified system upon returning to his or her office.
• The EP must have some other "configuration" that allows the ASC encounter to be recorded with certified EHR technology.
Mr. Hussey said the HITECH rules have some unexpected consequences for providers. For one, CMS will not reimburse for a pre-procedural consult conducted in a GI physician's office, incenting the physician to conduct more patient encounters at the ASC. However, the HITECH requirement that 50 percent or more of patient encounters occur in a setting equipped with certified HER technology incents GI physicians to see patients in their office if their ASCs are not equipped.
Download the recording of the webinar here.
Download the PDF version of the webinar here.
Related Articles Featuring ProVation:
5 Things Surgery Centers Need to Know About Meaningful Use and the 50% Rule
Overcoming ICD-10 Physician Documentation Challenges: Q&A With Dr. Steve Claypool and Allison Errickson of ProVation Medical
Mr. Hussey began the presentation by giving an overview of the HITECH program, which passed in Feb. 2009 as part of the federal stimulus bill. The federal government set aside approximately $27 billion for health information technology initiatives, allocating funds to reimburse eligible professionals and hospitals for "meaningful use" of "certified" EHRs . The incentive program was divided into three stages, to be implemented in 2011, 2013 and 2015.
Meaningful use: stage 1
Mr. Hussey said stage 1 of meaningful use places an emphasis on promoting adoption of electronic health records. The meaningful use requirements are organized into 25 criteria, and the criteria are divided into "core criteria" and "menu" options to promote flexibility and allow providers and hospitals to defer up to 5 of the 10 menu criteria for stage one.
Stage 1 of meaningful use began in Oct. 2010 for hospitals and Jan. 2011 for eligible professionals, and approximately 1,900 hospitals and 89,000 EPs had registered with the program as of Aug. 30. CMS estimates that eligible professionals have received $42 million in Medicare incentive payouts as of Aug. 30 and that hospitals have received $220 million.
Meaningful use: stage 2
Mr. Hussey said stage 2 of meaningful use will differ from stage 1 in its expansion of scope and the movement of some requirements from the "menu" to the "core criteria." For example, requirements for computerized physician order entry will expand from 30 percent to 60 percent of orders, and some criteria — such as the drug formulary check — will become core measure under stage 2. This stage is designed to promote interoperability and the exchange of health information between providers, Mr. Hussey said.
What does HITECH mean for ASCs?
Though ambulatory surgery centers are not eligible for EHR incentive funds — and are, in fact, conspicuously absent from the final rule for the EHR Incentive Program — surgery centers may still be affected by HITECH. The most pressing issue for ASCS is the 50 percent threshold rule for EP eligibility, which says that to be a meaningful EHR user, an EP must have 50 percent or more of their patient encounters during the EHR reporting period at a practice or location equipped with certified EHR technology.
According to Mr. Hussey, patient encounters in the ambulatory surgery center would be used in calculating the 50 percent threshold for certified EHR. According to CMS, as long as an eligible professional has certified EHR technology available for 50 percent or more of their patient encounters during the EHR reporting period, they only have to include those encounters where certified EHR technology is available at the start of the reporting period.
CMS clarified that surgery centers don't necessarily need to be physically equipped with an EHR system. CMS only requires that EHR be used to meet the measures of meaningful use objectives, meaning the system could have a "variety of configurations." If certified EHR technology is available at the ASC (either because the ASC implements it or the physician's technology is available through a portable device), the encounters at the ASC would be included in meaningful use calculations.
Conclusions
Mr. Hussey concluded that ASC patient encounters can help EPs qualify for meaningful use incentive payments, but the ASC must meet one of the following criteria for the EP to qualify:
• The ASC must have certified EHR technology installed onsite to record patient encounters.
• The EP must record the ASC encounter in real-time via an online link to the EP's office EHR system.
• The EP must record the ASC encounter on a certified system upon returning to his or her office.
• The EP must have some other "configuration" that allows the ASC encounter to be recorded with certified EHR technology.
Mr. Hussey said the HITECH rules have some unexpected consequences for providers. For one, CMS will not reimburse for a pre-procedural consult conducted in a GI physician's office, incenting the physician to conduct more patient encounters at the ASC. However, the HITECH requirement that 50 percent or more of patient encounters occur in a setting equipped with certified HER technology incents GI physicians to see patients in their office if their ASCs are not equipped.
Download the recording of the webinar here.
Download the PDF version of the webinar here.
Related Articles Featuring ProVation:
5 Things Surgery Centers Need to Know About Meaningful Use and the 50% Rule
Overcoming ICD-10 Physician Documentation Challenges: Q&A With Dr. Steve Claypool and Allison Errickson of ProVation Medical