The anticipation is over: Registration for the government's incentive program for electronic health records (EHR) opened Jan. 3. Revealed in February 2009 as part of the then-new stimulus package, the legislation promoting EHRs was aptly named the HITECH Act - the acronym for Health Information Technology for Economic and Clinical Health.
Extensive information was disseminated about the program as details were hammered out. Now, after nearly two years of commentary, consultation and adjustments, the rhetoric phase has ended.
Incentive payments for EHR use are available from Medicare and Medicaid, although dermatologists and other participating providers must choose one or the other. Both programs offer incentives for successful participation; a maximum of $44,000 from Medicare and $64,750 from Medicaid over a five- and six-year period, respectively.
If you're still deciding which program is right for you, be aware that the Medicaid EHR program eligibility criteria are more stringent - 30 percent or more of your annual patient volume must be Medicaid patients.1 In addition, you must demonstrate that you contributed financially to the cost of your EHR system, at least in small part.2 For Medicare, you need only be a physician who participates with Medicare; your annual incentive is based on 75 percent of your total allowed charges, up to a cap.
The recently opened Registration and Attestation System is for all participants, Medicare and Medicaid alike. The best place to start is by downloading the Registration User Guide, available on the program's website. There, you'll learn what you need - a National Provider Identification (NPI) number and an enrollment record in the Provider Enrollment, Chain and Ownership System (PECOS) system, for example - and the steps to register.4
All participants in the Medicare program have the opportunity to complete the registration process now, but less than a quarter of the states managed to open the registration process in concert with the launch of the Medicare incentives. States announcing early registration include Louisiana, Tennessee, Kentucky, Mississippi, North Carolina, South Carolina, Texas, Alaska, Iowa, Oklahoma and Michigan. Three states - Missouri, California and North Dakota - are slated to follow in February, although no dates have been set. For the rest of the nation, CMS reveals only a spring/summer start date.
Registration is required only once during your participation in the program. After you register, it's time to prepare for attestation, which must be done every year. "Attestation" is the government's term for formally reporting that you have complied with the elements of the program. Namely, you need to be a meaningful user of a certified EHR system.5
There are 25 criteria for meaningful use, of which 15 are required, and five must be chosen from a menu of 10.6 These range from simple (capturing patients' demographic information) to complex (giving patients seen in the office an after-visit summary).
You can register for the program now, but the official release of details about the attestation process for the Medicare program won't occur until April 4. If you're participating in the Medicare EHR Incentive program, you'll return to the newly opened Registration and Attestation System to attest to meaningful use. Although registration is performed through the new central system, participants in the Medicaid program will be directed to their state Medicaid agency for the attestation process.
In addition to meeting the meaningful use criteria, participants in both programs must also use a certified EHR system. In this case, certification must come directly from an Authorized Testing and Certification Body (ATCB) commissioned by the Office of the National Coordinator for Health Care Information Technology (ONC).