As electronic health records (EHRs) begin to gain popularity among dermatologists, one of the most common concerns facing their practices is how the government’s EHR incentive program will affect their decision to adopt and purchase EHRs. On July 13, 2010, the Centers for Medicare and Medicaid Services (CMS) released its final rule outlining how eligible physicians and hospitals can qualify for specific Medicare and Medicaid incentives for the adoption and use of certified EHR technology. The final rule establishes the program requirements for participating in the EHR incentive program beginning in 2011, and provides both challenges and opportunities for dermatologists interested in adopting EHRs.

Bonus payments available

Authorized under the American Recovery and Reinvestment Act (ARRA) of 2009, the EHR incentive program is expected to stimulate interest in the adoption of EHRs by eligible physicians and hospitals through payments of up to $44,000 over five years under Medicare, or up to $63,750 over six years under Medicaid. Providers will need to meet several requirements to be eligible for the incentive funds, including using a certified EHR system and becoming a meaningful user, the definition of which is outlined in the final rule.

Starting in 2015, dermatologists and other physicians who do not participate in adopting certified EHR systems and becoming meaningful users of this technology will risk reduced Medicare payments. With this final rule, CMS says it is moving ahead to stimulate participation in achieving significant improvements in health care coordination processes and quality outcomes through EHRs.

Thanks to its advocacy efforts, the American Academy of Dermatology Association (AADA), along with other national medical associations and specialty societies, voiced their concerns about the pace and scope of the original implementation requirements. As a result, CMS reduced the number of meaningful use requirements and lowered the reporting thresholds it had previously proposed. Though the program requirements remain challenging, complex and comprehensive — with some 15 core criteria set that all participants must meet, dermatology practices will now have greater flexibility in determining which additional five criteria to report.

Criteria for 2011 and beyond

The final rule keeps many criteria the same as the proposed rule; 2011 will still be the first year eligible providers can apply for the funds and providers participating in the Medicare incentive program may only be allowed to apply for five successive payment years. Thus, if you apply for the funds in 2011 and do not apply in 2012, you will only be eligible to collect your incentive in 2013, 2014, and 2015 and cannot apply for an additional year.

The reporting period is still minimized to 90 days in the first year and a full reporting year in any successive year. Providers who participate in the e-prescribing incentive program the same year they apply for the EHR incentive program will still be ineligible to collect money from both programs, and providers who successfully report and receive incentive dollars will have their names and addresses published on the CMS website.

The major changes between the proposed meaningful use rule and the final rule are in the reporting of measures. The proposed meaningful use rule would have required providers to report on 25 core criteria. The final rule reduces these core criteria to 15 measures and requires providers to report on an additional five measures from a menu set.

Providers will need to attest in 2011 and 2012 on the CMS website that they performed these measures to be eligible for the stimulus dollars. After 2012, CMS will require providers to electronically submit this data to CMS. Providers must begin their participation in this program by Oct. 1, 2012, at the latest, to quality for the full $44,000. Dermatologists may not need to accomplish all core and menu sets of measures. Providers may attest a denominator of zero to a quality measure that does not apply to their specialty.

Dermatologists should assess how the meaningful use requirements will effect their plans to adopt an EHR system, and how they plan to proceed before Oct. 1, 2012. If your practice plans to apply for the EHR incentive funds in 2011, you should continue reporting the e-prescribing measure during that year even though CMS will not distribute payment if you receive the EHR incentive funds.

Providers are expected to report to CMS in 2011 about their e-prescribing performance in order to avoid the penalty of 1 percent in 2012.

Additionally, if you have yet to select an EHR software vendor, you should conduct a practice-wide readiness assessment, workflow analysis, and identify a shortlist of preferred certified vendors.

Consider what certified vendors are able to deliver with regard to the best value in terms of technical capabilities, effect on workflow and financial commitment. A vendor’s value should be determined by its certification status. Ideally, it would benefit the dermatology practice if the vendor is certified for meaningful use to help you qualify for the CMS incentive program — as well as certified for dermatology-specific functionalities to help deliver a satisfactory level of applicability and payoff in dermatologic patient care.

It may also be helpful to test-drive your various EHR options to see how the meaningful use criteria is formatted, presented, and recorded, and to assess the end-user’s degree of comfort with system usability and effect on workflow. Remember, vendors that become certified may have different ways of charting and documenting data. Review, test and verify to your satisfaction before investing in a system. The Academy remains fully committed to assisting its members in making informed decisions and will continue to provide resources and tools that help advance this goal.

This article originally appeared in the September 2010 issue of Dermatology World.