This post is authored by ACC Health IT Committee Vice-Chair James Tcheng, M.D., F.A.C.C., and Committee member Jeffrey Westcott, M.D., F.A.C.C.

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Earlier this week, CMS completed a crucial step toward the goal of universal use of electronic health records (EHR) by all practitioners for all patients across the nation. The event?  CMS released its final rule that defines how eligible providers and hospitals can successfully participate in its EHR Incentive Program. This program provides payments – up to $44,000 over five years under Medicare and $63,750 under Medicaid – to providers who can meet its requirements of being a “meaningful user” of a certified EHR system.

According to the final rule, to be a “meaningful user,” you will need to use a certified EHR system and satisfy a series of measures, including 15 core requirements and five out of 10 optional requirements (for a list of these requirements, read this perspective piece by David Blumenthal, M.D., M.P.P., director of the Office of the National Coordinator, or ONC). These include a key core requirement – quality reporting – that builds on the remarkable achievements of the past several decades of the cardiovascular community in improving outcomes of our cardiovascular patients.

The Proposed vs. the Final Rule
CMS received nearly 2,000 comments on its initial “notice of proposed rulemaking” for the program, including extensive feedback authored by the ACC on your behalf.  We were deeply concerned about how CMS proposed to define meaningful use, as the first version included difficult and complex requirements that would have made it virtually impossible for you to participate in the program.

CMS and ONC have clearly been listening. They made extensive changes to the proposed rule in the final rule. For example, in the proposed rule, physicians would have had to meet 25 very specific requirements in their entirety to qualify for the program. This was changed to 15 “core set” requirements, plus your choice of five out of 10 “menu set” optional requirements.

And the metrics for achieving compliance with most of the requirements have been scaled back.  A prime example is computerized physician order entry (CPOE). The initial proposal would have required physicians to use CPOE for 80% of all orders.  Although the Final Rule requires a CPOE system that is able to capture orders for medication prescriptions, laboratory, and radiology / imaging studies, the performance measure for Stage 1 is only that physicians will have used CPOE to author 30 percent or more of medication prescriptions – a significantly reduced requirement.

Additional flexibility has also been added with respect to clinical quality measurement. Rather than requiring practitioners to report on three core measures and a rigid, pre-defined set of 3-5 specialty measures, the Final Rule requires reporting on a total of six measures – a combination of three core measures AND any three additional measures of the providers choosing. There are even alternative core measures that can be substituted for the base core measures.

CMS and ONC did remove several requirements (primarily administrative transactions) from the list of requirements. The proposed rule required professionals to submit claims electronically, as well as to perform the HIPAA eligibility transaction. The ACC and other professional associations successfully argued that these requirements were inappropriate at this time, especially with respect to the HIPAA eligibility transaction, which most health plans, including Medicare, have not fully implemented at this time.

The large number of changes reflects that they listened to the feedback they received. Their changes will help make the program goals – improved quality and patient care – attainable to a larger number of physicians. [more]

ACC Involvement
Over the last year, the ACC provided extensive feedback to both CMS and ONC that helped shape the program. In particular, we focused on making sure that the objectives, measures, and criteria align with what can be reasonably be achieved by you in your everyday practice. For example, we were quite vocal that the all-or-none approach (i.e., every provider had to satisfy all 25 measures) was not reasonable and would result in the program becoming a disincentive, and that the method for calculating metrics of a number of the measures would necessitate arduous, time-consuming, manual, paper-based processes. In the Final Rule, all of these concerns and more were addressed. Overall, our assessment of the Final Rule is that it has struck a nice balance between policy objectives and what can be readily achieved now. Nice work, CMS and ONC.

In addition, the ACC has been part of a special group working directly with CMS and ONC to prepare for the launch of this new program. The ACC is one of the only specialty organizations invited to partner with CMS and ONC to get out information to our members and to provide feedback to CMS and ONC. The College sees this partnership as a key relationship-builder, where the ONC and CMS will get valuable feedback from our members, which they can in turn use to make participation in the program easier.

Ready to Participate?
With the final rule out, the program is nearly ready to get started. Beginning in January 2011, cardiovascular professionals can register to participate in the program. Because the reporting period for a provider’s first year of participation is any consecutive 90 day period (this is true whether you start in 2011, 2012, etc.), providers will be able to file a claim for first year participation beginning in April. CMS anticipates making the first payments the following month. So, in less than a year, your practice could be earning pretty hefty payments (by government standards) in incentives.

Resources
The ACC has developed a comprehensive EHR Toolkit to help cardiovascular professionals select and implement the right system for their individual practice environment. The toolkit includes case studies, selection criteria and access to ACC-approved EHR selection consultants.

Additional resources focusing specifically on the EHR incentive program are in the process of being developed now that the final rule has been released, so pay close attention to the Advocate and CardioSource.org in the coming months. We'll also have more information on the Final Rule there. In addition, CMS has developed a comprehensive website that includes FAQs and other information about meaningful use and the federal incentive program in general.

We’re interested in hearing your thoughts. You can leave a comment below by clicking on the “comment” link at the bottom of this post, or you can participate in a forum on EHRs on CardioSource.org.

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