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Stimulus Funds Include Physician Incentives (and Penalties) to Encourage EMR Adoption

The Health Information Technology for Economic and Clinical Health Act (HITECH) is part of the Americian Recovery and Reinvestment Act (ARRA) of 2009 and provides around $19 billion for health information exchange infrastructure including incentive payments to physicians adopting EHRs and other health information technologies. Physician reimbursement penalites for not using health information technology (HIT) begin in 2015 with a 1% reduction in Medicare and Medicaid reimbursement which increases to 3% over 3 years.  The following chart is an example of the incentive payment schedule for eligible physicians who care for Medicare patients:

First Payment Year

2011

2012

2013

2014

2015

2016

Maximum Potential

2011

$18,000

$12,000

$8,000

$4,000

$2,000

-

$44,000

2012

 

$18,000

$12,000

$8,000

$4,000

$2,000

$44,000

2013

 

 

$15,000

$12,000

$8,000

$4,000

$39,000

2014

 

 

 

$12,000

$8,000

$4,000

$24,000

To be eligible for incentive payments, physicians must:

  1. Meet minimum threshhold Medicare or Medicaid payor mixes.  For example, non-hospital-based pediatricians with a 20% Medicaid payor mix will be eligible for up to $42,500, and those with 30% a Medicaid mix will be eligible for $63,750. 
  2. Demonstrate "meaningful use" of certified EHR technology (will include e-prescribing)
  3. Submit clinical quality measures as selected by the Health and Human Services (HHS) Secretary (similar to the PQRI  or pay-for-performance programs). 
  4. Be able to connect to electronic exchanges of health information

The American Medical Association's (AMA) Summary provides additional information on the incentive payments.  Important details and definitions, however, are yet to be determined and will be released by HHS later this year. It is important for physicians to ensure that their interests are represented as the details are discussed and determined. For example, a hot item of current discussions is the definition of "meaningful use".  The AMA and state medical societies are among the physician voices that are active in a national dialogue defining this term.  Other unclear items include how payor mix will be determined, what constitutes a certified EHR, what the required clinical quality measures will be, how physicians will submit quality measures and what type of electronic exchanges of health information are expected to be connected to. 

As an advocate for the use of clinical technologies to improve the quality of care, I am excited about the potential for the incentive program to stimulate a more rapid adoption of EHRs.  However, I am wary about the undetermined details and definitions of the incentive program.  Physicians will want to see the government avoid creating an incentive program that is heavy on more administrative controls over clinical decision-making and on demanding untenable changes to the busy physician's day (such as complex, time-consuming reporting requirements).  I am also concerned about physicians feeling rushed into EHR implementations that, due to time constraints, might fail to be attentive to the redesign of physician work flow that is needed for successful implementations.  Because of the potential for these negative impacts, I implore physicians to ensure that their professional associations and organizations are engaged in the ongoing national health information technology dialogue and to share your ideas/concerns with them. 

drmattmurray

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