One of the most important topics at the intersection of nephrology and health IT is the CMS EHR incentive program. Starting next year nephrologists have the opportunity to earn $44,000 over the ensuing 5 years by demonstrating meaningful use of a certified EHR. Using a classic “carrot and stick” approach, CMS will begin reducing the Medicare physician fee schedule in 2015 for those unable to demonstrate meaningful use.
Sounds simple right? In fact, this program likely will present significant challenges for most nephrology practices. For 2011 and 2012 demonstrating meaningful use requires the nephrologist to report on 20 distinct stage 1 meaningful use objectives. Many objectives establish a threshold that must be exceeded. For example, at least 80% of patients encountered during the reporting period must have a problem record within their problem list (or a notation that the patient has no problems). Others require a simple “yes or no” answer to which the provider must attest. For example, a provider must attest to whether the EHR’s drug-drug and drug-allergy interaction features are enabled during the entire reporting period. If the answer is “no” because the interaction features were not enabled during the entirety of the reporting period, the provider will not succeed in demonstrating meaningful use.
Herein lies one of the challenges of the program. Demonstrating meaningful use employs an “all or none” structure. That is, if I successfully report 19 of 20 meaningful use objectives, but only 79% of my eligible patients have a problem on their problem list, I am not a meaningful user in the eyes of CMS, and I would not receive the financial incentive for the reporting year.
I will be visiting various aspects of meaningful use and its impact on nephrology in the coming weeks. In the meantime, here is an overview of the program. Next week I will explore the structure of the incentive in greater detail.
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