Why optometrists should act on electronic health records now

Article Outline

• Medicare EHR Incentive Program
• Medicaid EHR Incentive Program
• Medicare e-Prescribing Incentive Program
• An urgent matter

Electronic health records (EHRs) can markedly improve health care quality, safety, and efficiency as well as facilitate the nation's effort to reduce health care disparities among disadvantaged populations, according to the U.S. Department of Health & Human Services (HHS). EHRs are considered a fundament element in the government's overall strategy to reform the American health care system. By now, most health care practitioners know that a Nationwide Health Information Network (NHIN), under development to provide interoperable EHRs for all Americans, is set for launch in 2014. A relatively new government entity, the Office of the National Coordinator of Health Information Technology (ONCHIT) has even been established within the HHS to oversee the new national EHR system.

Optometrists have plenty of good reasons to implement EHRs in their practices. Enhanced patient care is, of course, the primary reason. Access to EHRs can help ensure that the optometrist has a full and complete patient history and health care record to rely on when evaluating, diagnosing, and making therapeutic recommendations for a patient. Diagnostic decision-making support and patient education features are rapidly being incorporated into EHR programs. Electronic record systems can also greatly facilitate referral of patients to or from an optometric practice to ensure that patients receive all necessary care. Used properly in conjunction with digital diagnostic equipment management solutions and office management software, EHRs can greatly enhance practice efficiency. Perhaps most importantly, EHRs can help ensure that optometric practices remain an important part of the American health care system. The optometric practice with a fully functioning electronic health records system is well prepared to play an integral role on the primary health care team. Conversely, the practice that does not have access to EHRs risks being shut out.

Until recently, it could be said that optometrists had some credible reasons for hesitating on EHR implementation. A lack of nationally recognized standards and certification programs for eye care EHRs has left many optometrists feeling uncertain that available EHR programs would meet all of their practice requirements or be interoperable with systems in other health care practices. And, of course, the cost of EHR systems has been a concern.

However, optometrists now have solid reasons to act on the implementation of EHRs in their practices immediately. Under the federal American Recovery and Reinvestment Act (commonly known as the Recovery Act or simply the “stimulus bill”), the Medicare and Medicaid programs have been authorized, for a limited period, to issue incentive payments for health care practices that adopt EHR technology.

Under the Medicare EHR Incentive Program, the federal government will, beginning on January 1, 2011, offer up to $18,000 a year in incentives for practices that install qualifying EHR systems and meet use requirements. However, Medicare practitioners will have only 5 years to take part in the EHR incentive program. Maximum incentives gradually will be scaled down over the course of the program. That means early adaptors will reap the greatest benefits. They may also face the fewest hurdles in qualifying for the incentives, as some believe government rules regarding EHR utilization could become more stringent over time. A practitioner who qualifies for maximum incentives early could earn as much as $48,400 over 5 years to help offset the cost of an EHR system. Practitioners who do not implement EHR technology in their practices, on the other hand, will face Medicare payments penalties in the relatively near future.

In addition, practitioners who implement EHR systems and use them in prescribing pharmaceuticals will eventually qualify for payments under the separate Medicare e-Prescribing Incentive Program. It will also help avoid penalties that Medicare plans to impose for failure to prescribe electronically beginning in 2012. (Timelines for implementation of Medicare EHR and e-prescribing incentives and penalties are outlined in Table 1.)

Table 1. Timeline of Medicare EHR and e-prescribing provider incentives and penalties

∗Professionals receiving EHR incentives cannot receive eRx incentive.

†Incentives continue for 5 years or through 2016, whichever is earlier. No incentives are started after 2014.

A third initiative, the Medicaid EHR Incentive Program offers assistance for practices that primarily serve disadvantaged populations and do not take part in the Medicare EHR Incentive Program.

Established under the Recovery Act provision collectively known as the Health Information Technology for Economic and Clinical Health Act (HiTECH Act), the Medicare and Medicaid EHR incentive programs, like the other provisions of the stimulus package, were announced in February 2009. In December, the HHS proposed EHR software standards for use in the incentive program (and eventually the NHIN). The HHS announced utilization goals that practitioners will have to meet to qualify for the incentives. That effectively means that optometrists and other health practitioners could begin to prepare their offices and take part in the incentive programs. A quick review of the rules for the incentive programs reveals why there may never be a better time to actively pursue the implementation of EHRs in an optometric practice.

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Medicare EHR Incentive Program 

The Medicare EHR Incentive Program will make incentive payments available to eligible professionals (EPs) who achieve “meaningful use” of “certified” EHRs. Practitioners who meet EHR use and certification criteria will qualify for incentive payments equal to 75% of their annual Medicare allowable charges for covered services. (Providers who practice in health professional shortage areas will receive an additional 10% increase, and providers who work in rural areas will receive an additional 25% increase.) However, the incentives are subject to graduated payment caps. A special provision will reward “early adopters” who take steps to qualify for incentives early.

The EHR incentives will be paid from 2011 through 2016. Practitioners can qualify for incentive payments for a total of 5 years. Under the graduated caps, maximum payments will generally be as follows:

However, the payment cap for early adopters who initially qualify for payments in 2011 or 2012 will be increased to $18,000 per practitioner. The last year in which practitioners will be able to qualify for initial incentive payments will be 2014. Whether a practitioner initially qualifies for incentives during the first year of the program or a subsequent year, no incentives will be issued for EHR use after 2016.

That means individual practitioners could earn up to $44,000 in incentive payments over 5 years (and up to $48,400 with a 10% bonus in Health Professional Shortage Areas). Group practices (with, for example, 4 optometrists) could receive more.

Meanwhile, practitioners who fail to implement EHRs will become subject to Medicare penalties. In 2015, any health care provider who claims payment for Medicare and Medicaid services but does not qualify as a meaningful user of a certified EHR will be assessed penalties against their claim payments in the following amounts:

In 2018 and thereafter, should the HHS find less than 75% of eligible Medicare providers are making meaningful use of certified EHRs, the department will reduce payments an additional 1 percentage point each year, up to a maximum of 5%.

For additional information on the Medicare EHR Incentive Program (as well as the Medicaid EHR Incentive Program described below) see the CMS Medicare/Medicaid EHR Incentive Fact Sheet (www.cms.hhs.gov/apps/media/press/factsheet.asp?Counter=3466).

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Medicaid EHR Incentive Program 

The Recovery Act also provides federal funding that will allow state Medicaid programs to issue incentives to eligible professionals—including physicians—who use EHRs. To qualify, Medicaid providers will have to meet minimum Medicaid patient volume percentages and must waive rights to Medicare EHR incentives. Eligible Medicaid providers could receive up to 85% of the net average allowable cost of certified EHR technology, including support and training, up to specified maximums with incentive payments to be available for no more than a 6-year period. To be eligible for incentive payments not associated with the initial adoption, implementation, or upgrade of EHR technology, a provider has to demonstrate meaningful use of the EHR technology through a process to be approved jointly by the state and HHS to ensure the EHR system is being used to address the unique needs of special disadvantaged populations. The HHS emphasizes that practitioners may not receive an incentive under both Medicare and Medicaid in a given year.

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Medicare e-Prescribing Incentive Program 

Authorized under the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA), the Medicare e-Prescribing Incentive program provides incentive payments to eligible health care professionals who qualify as “successful e-prescribers” (see McVeigh F, E-prescribing in the optometric practice. Optometry 2008;79;692-701). Launched on January 1, 2009, the Medicare e-Prescribing Incentive program is separate and distinct from the Medicare Physician Quality Reporting Initiative (PQRI). That means eligible professionals do not need to participate in PQRI to participate in the Electronic Prescribing Incentive Program. However, the e-prescribing measure developed for PQRI is being used as the criteria for incentives under the e-prescribing program. Practitioners cannot receive incentives under both the Medicare EHR and eRx program at the same time. However, implementation of an EHR system can help practitioners qualify for e-prescribing bonuses after the EHR incentive programs expires as well as avoid planned penalties for failure to prescribe pharmaceuticals electronically.

During 2010, the first year of the Medicare e-Prescribing Incentive Program, successful e-prescribers will receive an incentive payment equal to 2% of their total estimated allowed Medicare Part B charges during the reporting period. The incentive will be reduced to a 1% incentive in 2011 and 2012; and then to 0.5% in 2013.

Eligible professionals who are not “successful e-prescribers” by 2012 will be subject to “differential payment” penalties. They will receive only 99% of their total allowed Medicare Part B charges in 2012, 98.5% in 2013, and 98% in 2014.

To be a “successful e-prescriber,” a physician or other eligible professional must report on the e-prescribing quality measure in at least 50% of the cases in which the measure is reportable. A qualified e-prescribing system must be used. E-prescribing systems fall into 2 categories: (1) stand-alone systems for e-prescribing only and (2) electronic health record (EHR) system with e-prescribing functionality.

A qualified e-prescribing system must provide the health care practitioner the capacity to:

In addition, the system should meet Medicare Part D messaging specifications implemented on April 1, 2009.

To be considered a successful individual e-prescriber, eligible to receive an incentive payment, a health care practitioner must generate and report 1 or more electronically issued prescription during a minimum of 25 unique visits per year.

For additional information, see the U.S. Centers for Medicare & Medicaid Services Web site e-Prescribing Incentive page (www.cms.hhs.gov/ERXIncentive).

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An urgent matter 

HHS administrators clearly envision a time in the very near future when all health care practitioners will have and use EHRs. They understand that EHR systems can represent a significant outlay for a health care practitioner. As a result, they are making the Medicare EHR Incentive Program, Medicare e-Prescribing Incentive Program, and Medicaid EHR Incentive Program available to help practitioners cover the cost. How much assistance optometrists can potentially realize from these incentive programs will vary greatly from practice to practice. However, virtually any practice will benefit from acting on EHR implementation while incentives are available and penalties can be avoided. And, it should be emphasized, the sooner they act, the better. Even if a practitioner selects and orders an EHR system today, lead time on delivery could be 3 to 4 months. The conversion from paper to EHR practice could then take additional weeks or months, given the time necessary for installation and staff training. Practices that do not yet have systems in place will have to act expeditiously to qualify for the maximum Medicare EHR incentives that will be available in 2011 and 2012 or avoid Medicare e-prescribing penalties that take effect in 2012. Nevertheless, optometrists are now presented with what may well be a once-in-a-career opportunity for assistance in covering the cost of an EHR system. With America rapidly moving toward a system of electronic health records, acting to implement EHRs now will certainly benefit a practice, and it is definitely the right thing to do for patients.