By Rachna Chaudhari, October 01, 2011
Most dermatologists are aware of the $44,000 incentive available from the Centers for Medicare and Medicaid Services (CMS) for the adoption and “meaningful use” of an electronic health record (EHR). However, the exact specifications required to receive the incentive are not as well known. Physicians are eligible to receive the full Medicare EHR incentive based on two requirements:
- 1. they are a physician with an M.D. or D.O. degree and
- 2. they have at least $24,000 in Medicare Part B allowed charges per year.
If you are a physician with less than $24,000 allowed charges per year, you are still eligible for the incentive, but it will be paid at a lesser rate of 75 percent of the total Medicare Part B allowed charges.
Once you have determined you are eligible for the program, you must select and implement an EHR in your office by Oct. 1, 2012 to receive the full incentive amount. You must select a system that is certified and carries the Office of the National Coordinator Authorized Testing and Certification Body (ONC-ATCB) certification standard. For a full list of certified products, visit http://onc-chpl.force.com/ehrcert. More information on selecting and implementing an EHR is available on the Academy’s website at www.aad.org/hitkit.
After you have implemented the EHR throughout your practice, you can begin participating in the incentive program. To participate you must report on your EHR use through CMS’s online attestation system. The first year of the program only requires a 90-day reporting period, so you must decide when you want to start reporting. You can select any 90-day calendar period as long as your last day of reporting occurs on or before Dec. 31. Once you have selected your 90-day reporting period, visit the CMS website to register for the Medicare EHR Incentive Program at www.cms.gov/EHRIncentivePrograms/20_RegistrationandAttestation.asp. You will be required to enter each physician’s NPPES username and password, whether they are interested in participating in the Medicare or Medicaid EHR Incentive Program, whether you have a certified EHR system, the physician’s national provider identifier (NPI) and tax identification number (TIN), and your business address and phone.[pagebreak]
Once the registration process is complete, the practice can begin reporting the 20 meaningful use measures. All physicians must report a set of 15 core measures and five additional measures from a menu set of 10 measures. (A list of all meaningful use measures is available under EHR Incentives at www.aad.org/hitkit.) However, not all of the measures in either the core measure set or the menu set of 10 additional measures necessarily apply to dermatology. In this case the program allows an exclusion to be reported.
Below are answers to some of AAD members’ most common questions regarding the measures, their exclusions, and how to report.
How do I complete the reporting process and attest to CMS?
After you have completed your 90-day reporting period, you will go back to the CMS website where you registered and select the attestation tab. You will be asked a series of questions and be expected to fill in your numerators and denominators to insure you met the requirements for each measure; your EHR should generate a report to help you complete your attestation. After you submit your information, CMS has stated that you should receive an incentive check within four-six weeks.
Which five measures from the menu set of 10 additional measures should my practice select to report?
Dermatology practices may determine which five are most applicable and report those, however, one of the five must be a public health measure. The applicable public health measures are measure #9: submit electronic data to immunization registries or measure #10: submit electronic syndromic surveillance data to public health agencies. Since neither of these measures apply to dermatologists, they can simply select one and report an exclusion. Thus, dermatology practices would only have to report on four menu set measures in addition to that exclusion. The four menu set measures most applicable to dermatology include:
- Measure #1: Implement drug formulary checks (which entails making sure your EHR is set to do automatic formulary checks).
- Measure #3: Generate one report listing patients of the provider with a specific condition (providers can choose any condition they wish).
- Measure #7: Perform medication reconciliation on patients received from another setting of care or provider (meaning you are updating the system with medication information when you get a new patient).
- Measure #8: Provide a summary of care record for patients transferred to another setting of care or provider.
A list of all menu set measures with full descriptions is available online at www.aad.org/hitkit under EHR Incentives.
What if some of the 15 core and 10 menu set measures don’t apply to my practice?
Many dermatologists have concerns that some of the meaningful use measures do not apply to their practice, however, as noted in the previous question, various measures have exclusions. If physicians meet the criteria for an exclusion for a particular measure they can simply attest to the exclusion in the CMS system. In so doing, they have met the requirements for the measure and would not be required to perform an additional measure to make up for the exclusion.
How should I report the clinical quality measures as there is no exclusion for these?
All providers must report whether they performed clinical quality measures. To satisfy this requirement, providers must attest that they performed three core clinical quality measures and three additional clinical quality measures from a set of 44 measures. If the core clinical quality measures do not apply, providers may have to report on all 44 clinical quality measures.
The three core clinical quality measures dermatologists must report are:
- Hypertension: Blood Pressure Measurement (meaning you have diagnosed hypertension in the patient).
- Preventive Care and Screening: Tobacco Use Assessment and Tobacco Cessation Intervention (meaning you have offered smoking cessation counseling to the patient).
- Adult Weight Screening and Follow-up (meaning you have screened for obesity and offered counseling to the patient).
If providers are only able to report zero denominators or numerators for all three of the core clinical quality measures, the attestation system will ask you to report from this alternate set of core clinical quality measures:
- Weight Assessment and Counseling for Children and Adolescents.
- Preventive Care and Screening: Influenza Immunization for Patients 50 years old.
- Childhood Immunization Status.
Though many of these measures do not apply to dermatology, CMS is not measuring the performance of providers. Thus, providers can report numerators or denominators of zero for measures that do not apply to their specialty. For example, hypertension: blood pressure measurement has a denominator consisting of patients the physician has diagnosed with hypertension. Since most dermatologists do not diagnose hypertension, their denominator for this measure would automatically be zero, even if they measure blood pressure in some patients for other reasons. The denominator and numerator would be reported when the physician attests on the CMS website using data generated by the EHR system based on what the physician has entered in his or her documentation. If you only perform the measure rarely, even on just one patient during the entire reporting period, you can report that and meet the requirement. However, CMS has stated that it is perfectly acceptable to record a zero numerator or denominator as well.
If you report numerators or denominators of zero for the three core and three alternate core clinical quality measures, CMS will require you to report your numerators and denominators for the remaining 38 clinical quality measures. Most EHR systems do not have the capability to account for all clinical quality measures so you are only required to report on those measures that your EHR system has the capability to track.
The reporting required in the EHR incentive program is distinct from the Physician Quality Reporting System. Both programs allow reporting on many of the same measures, although the meaningful use program offers no dermatology-specific measures.
A full list of meaningful use measures with descriptions is available at www.cms.gov/QualityMeasures/03_ElectronicSpecifications.asp.
For more information on the EHR incentive program, visit www.cms.gov/ehrincentiveprograms or email email@example.com.
Steps to achieving meaningful use
- 1. Determine if physician is eligible for the program.
- 2. Select and implement an EHR by Oct. 1 of the year you wish to begin reporting.
- 3. Register for the EHR Incentive Program on the CMS website.
- 4. Begin your 90-day period of reporting and completing the measures through your EHR.
- 5. Attest on the CMS website after the 90-day period is complete.
- 6. Expect an incentive payment four to six weeks after you have successfully attested.
Medicare EHR Incentive Program timeline
| Reporting Year ||Must Begin By ||First Year Payment |
| 2011 || Oct. 1, 2011 || $18,000 |
| 2012 || Oct. 1, 2012 || $18,000 |
| 2013 || Oct. 1, 2013 || $15,000 |
| 2014 || Oct. 1, 2014 || $12,000 |