News from the AOA's Blog

The federal government’s much anticipated electronic health records (EHR) incentive program officially began Jan. 3 with the launch of the new Medicare & Medicaid EHR Incentive Program Registration and Attestation System, the release of new step-by-step Registration User Guides, and a push by officials to bring health care practitioners and institutions into the program as quickly as possible.

To encourage early registration, the U.S. Centers for Medicare & Medicaid Services (CMS) announced that health care practitioners will not be required to have certified EHR systems in place or provider enrollment records in CMS’ Provider Enrollment, Chain and Ownership System (PECOS) in order to register for the EHR incentive program – effectively easing previously announced registration requirements.

Under the five-year Health Information Technology for Economic and Clinical Health (HITECH) incentive program, eligible health care practitioners will be able to quality for up to a total of $44,000 in incentive payments through Medicare ($48,400 in federally designated health profession shortage areas), or up to $63,750 through Medicaid, by implementing EHR systems that have been certified for use in the program and meeting designated EHR utilization criteria, known as the “meaningful use” standards.

The Medicare incentive program was mandated under federal law to begin on Jan. 3.  Medicaid EHR incentive programs could begin as early as that date, although not all states were ready to participate on that date, the CMS acknowledges (see box on page 28). Optometrists are specifically included the Medicare incentive program nationwide; however, they can qualify for EHR incentives through Medicaid only in those states that recognize optometrists as providers of physician services under that program.

During 2011 and 2012, health care practitioners will be able to qualify for Medicare incentives by achieving HHS-designated Stage 1 meaningful use, a process that involves achieving 20 utilization objectives.  The Stage 1 objectives consist of a group of 15 “core” objectives required for all practitioners and a list of “menu” elements from which practitioners may select five and defer five.

To earn incentives for Stage 1 meaningful use, health care practitioners must attest compliance with the specified objectives for 90 days.

“We encourage providers to register for the Medicare and/or Medicaid EHR Incentive Program(s) as soon as possible,” CMS officials urge on the agency Web site’s new “Attestation and Registration” page (www.cms.gov/EHRIncentivePrograms/20_RegistrationandAttestation.asp).

Eligible health care professionals can enter the incentive program by logging onto the Medicare & Medicaid EHR Incentive Program Registration and Attestation System Web page (https://ehrincentives.cms.gov), which practitioners will also use to attest compliance with the meaningful use standards.

Practitioners can then register by entering:

• A National Provider Identifier (NPI), and
• A National Plan and Provider Enumeration System (NPPES) user ID and password.

Health care professionals must also enter or verify basic identification and contact information such as name, street address, telephone number, and e-mail address.

Practitioners who reassign benefits will also be required to provide a Payee Tax Identification Number and payee NPI.

“You can register before you have a certified EHR. Register even if you do not have an enrollment record in PECOS,” CMS officials emphasize on the agency Web site.

The NPPES ID and password will satisfy a requirement for a CMS Identity and Access Management (I&A) User ID and Password in the registration process, agency officials says. The NPPES ID and password are also used to access PECOS. Health care practitioners who do not have an active User ID and Password for NPPES or PECOS can request them via the NPPES Web site (https://nppes.cms.hhs.gov). Practitioners will need a type 1 NPI (type 2 for businesses), a Taxpayer Identification Number (TIN), and the address listed on their IRS Form CP-575.  They will also need to mail a copy of IRS Form CP-575 as directed in the NPPES application.

CMS officials plan to begin accepting attestation of compliance with the meaningful use standards under the Medicare incentive program as early as April and issue the first bonus payments under that program in May. The agency actually announced the first incentive payment under the Medicaid incentive program within days of the program’s opening.

While early entry into the incentive programs can help to ensure maximum bonus payments, not all practitioners will opt to enroll during the opening weeks, the AOA Health Information Technology Subcommittee acknowledges.

However, virtually all practitioners who wish to earn incentives under the programs should begin now to ensure they have the up-to-date NPI, NPPES and PECOS listings that will ultimately be required for participation in the incentive programs, the subcommittee advises. Practitioners should also begin planning the purchase or updating of office software to meet EHR incentive programs certification standards and develop plans for meeting the incentive program’s meaningful use standards, subcommittee members adds.

Step-by-step instructions are provided in the CMS’s new Registration User Guide for Eligible Professionals, which can be accessed on the CMS Web page at http://www.cms.gov/EHRIncentivePrograms/Downloads/EHRMedicareEP_RegistrationUserGuide.pdf.

Steps to prepare for the implementation of an EHR system in a health care practice and the securing of incentive payments are outlined on the CMS Web site’s Path to Payment page (www.cms.gov/EHRIncentivePrograms/10_PathtoPayment.asp#TopOfPage).

The CMS EHR Information Center is open to assist the EHR Provider Community with inquiries. The center is in operation 7:30 a.m. – 6:30 p.m. (Central Time) Monday through Friday, except federal holidays, and can be reached at 888-734-6433 (primary number) or 888-734-6563 (TTY number).

Additional information on the registration process for the incentive programs will appear in the Practice Strategies section of the April edition of Optometry: Journal of the American Optometric Association.

Links to resources mentioned in this article can be access on the AOA Web site EHR page (www.aoa.org/EHR).