Electronic Health Records (EHR) -  Qualifying for Reimbursement Payments

Under the Medicare and Medicaid from Title XIII of the American Recovery and Reinvestment Act of 2009

What does this bill mean to the typical chiropractor?

You probably have heard something about receiving 44K in stimulus money. Most likely some software company, a speaker at a convention, or one of your friends has told you that in order to get your 44K, you will need to buy right away, otherwise, you won't get your share of the stimulus money.

Most doctors want to know how to qualify. According to the latest documentation, there are a number of things combined to allow a chiropractor to qualify for the stimulus money.

1. Must be seeing more than 30% Medicare patients.
2. Must be using a "certified system" (Certification not yet confirmed).
3. Must be able to demonstrate meaningful use (who knows what that  means).

Number 1 alone eliminates a large number of chiropractors. The other items might be possible, but you must consider if spending a large amount of money on software is right for your practice, with or without stimulus money.  Would would be best for your business?

Initially, we were excited when the President announced that stimulus funds would go towards EMR systems. However, when the 2000 page stimulus report was released and we reviewed the sections reporting on EMR we discovered it was very vague on the topic of how payment would be made to doctors. It's hard to answer questions when the bill itself is vague.

It would be nice if other vendors who are promising stimulus refunds list how they are going to have chiropractors meet the requirements by using their software. They seem to all have a lot of talk but they don't have any specific information. They would need to provide documentation showing all the regulations explaining which certification is needed for a product to qualify.

And where is their certification certificate? Does certification really mean anything if you'll never qualify as a chiropractor anyway. A recent search on the CCHIT* (most common certification at this time for large EMR products) website, indicated there are NO Chiropractic products with the certification.

Here is a very important point on certification:

Today the certification is the same cost and has the same feature requirements whether the software is designed for a large hospital or a small specialized practice. It should be easy to realize the needs of those two software products are very different. Shouldn't the certification requirement process and cost for these two types of vendors also be different?

After all, a major benefit for having "certified software" is to help with compatibility between. Without a unique certification for each product it may mean many of the specialty products won't become certified and doctors will have incompatibility with patients' primary doctors' EMR/EHR systems for years to come.

Exactly what is the criteria?

Every one of the stimulus incentives hinged on practices adopting "meaningful use" of the EMR systems in question. This without a doubt is the hitch Up until December 2009, "meaningful use" had not been undefined!

In other words, you could never receive the money unless you ended up using an  EMR that met a certain set of requirements!

It didn't help when this past December the suggested rules regarding "Meaningful Use" ended up being 556 pages long!  Inside the 556 pages there are a total of 25 standards your practice must satisfy in order to attain meaningful use. Here is a summary:

1- Objective: Use computer physician order entry (CPOE)
Measure: CPOE is used for at least 80 percent of all orders

2 -Objective: Implement drug-drug, drug-allergy, drug- formulary checks
Measure: The EP has enabled this functionality

3 - Objective: Maintain an up-to-date problem list of current and active diagnoses based on ICD-9-CM or SNOMED CT®
Measure: At least 80 percent of all unique patients seen by the EP have at least one entry or an indication of none recorded as structured data

4 - Objective: Generate and transmit permissible prescriptions electronically (eRx)
Measure: At least 75 percent of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technology

5- Objective: Maintain active medication list
Measure: At least 80 percent of all unique patients seen by the EP have at least one entry (or an indication of "none" if the patient is not currently prescribed any medication) recorded as structured data

6- Objective: Maintain active medication allergy list
Measure: At least 80 percent of all unique patients seen by the EP have at least one entry (or an indication of "none" if the patient has no medication allergies) recorded as structured data

7 - Objective: Record demographics.
Measure: At least 80 percent of all unique patients seen by the EP or admitted to the eligible hospital have demographics recorded as structured data

8 - Objective: Record and chart changes in vital signs
Measure: For at least 80 percent of all unique patients age 2 and over seen by the EP, record blood pressure and BMI; additionally, plot growth chart for children age 2 to 20

9 - Objective: Record smoking status for patients 13-years-old or older
Measure: At least 80 percent of all unique patients 13-years-old or older seen by the EP "smoking status" recorded

10 - Objective: Incorporate clinical lab-test results into EHR as structured data
Measure: At least 50 percent of all clinical lab tests results ordered by the EP or by an authorized provider of the eligible hospital during the EHR reporting period whose results are in either in a positive/negative or numerical format are incorporated in certified EHR technology as structured data

11 - Objective: Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research, and outreach
Measure: Generate at least one report listing patients of the EP with a specific condition

12 - Objective: Report ambulatory quality measures to CMS or the States.
Measure: For 2011, an EP would provide the aggregate numerator and denominator through attestation as discussed in section II.A.3 of this proposed rule. For 2012, an EP would electronically submit the measures are discussed in section II.A.3. of this proposed rule.

13 - Objective: Send reminders to patients per patient preference for preventive/ follow-up care
Measure: Reminder sent to at least 50 percent of all unique patients seen by the EP that are 50 and over

14 - Objective: Implement five clinical decision support rules relevant to specialty or high clinical priority, including for diagnostic test ordering, along with the ability to track compliance with those rules
Measure: Implement five clinical decision support rules relevant to the clinical quality metrics the EP is responsible for as described further in section II.A.3

15 - Objective: Check insurance eligibility electronically from public and private payers
Measure: Insurance eligibility checked electronically for at least 80 percent of all unique patients seen by the EP

16 - Objective: Submit claims electronically to public and private payers.
Measure: At least 80 percent of all claims filed electronically by the EP

17 - Objective: Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, and allergies) upon request
Measure: At least 80 percent of all patients who request an electronic copy of their health information are provided it within 48 hours

18 - Objective: Provide patients with timely electronic access to their health information (including lab results, problem list, medication lists, allergies)
Measure: At least 10 percent of all unique patients seen by the EP are provided timely electronic access to their health information

19 - Objective: Provide clinical summaries to patients for each office visit
Measure: Clinical summaries provided to patients for at least 80 percent of all office visits

20 - Objective: Capability to exchange key clinical information (for example, problem list, medication list, allergies, and diagnostic test results), among providers of care and patient authorized entities electronically
Measure: Performed at least one test of certified EHR technology's capacity to electronically exchange key clinical information

21 - Objective: Perform medication reconciliation at relevant encounters and each transition of care
Measure: Perform medication reconciliation for at least 80 percent of relevant encounters and transitions of care

22 - Objective: Provide summary care record for each transition of care and referral
Measure: Provide summary of care record for at least 80 percent of transitions of care and referrals

23 - Objective: Capability to submit electronic data to immunization registries and actual submission where required and accepted
Measure: Performed at least one test of certified EHR technology's capacity to submit electronic data to immunization registries

24 - Objective: Capability to provide electronic syndromic surveillance data to public health agencies and actual transmission according to applicable law and practice
Measure: Performed at least one test of certified EHR technology's capacity to provide electronic syndromic surveillance data to public health agencies (unless none of the public health agencies to which an EP or eligible hospital submits such information have the capacity to receive the information electronically)

25 - Objective: Protect electronic health information maintained using certified EHR technology through the implementation of appropriate technical capabilities
Measure: Conduct or review a security risk analysis in accordance with the requirements under 45 CFR 164.308 (a)(1) and implement security updates as necessary

35 years of chiropractic experience and after consulting with 1500+ offices,

the majority of these 25 criteria do not (and should not) pertain to chiropractic.

There just isn't an EMR that can promise stimulus money for the practicing chiropractor.

Recently the Medicare service provider (Palmetto GBA) issued the company's first Quarter findings regarding Medical Reviews they've recently been performing.  Although Palmetto is just one of many companies that administer claims for Medicare, their results reflect tendencies throughout the chiropractic profession and legibility, yes legibility was one of their top 10 findings.

Your current patient treatment records must be quickly read and understood by a third-party.  As a profession, chiropractors need to get their act together right away, not just for Medicare, but also for every third party payer. Fortunately Quixote's SOAP Notes are easy to use, legible, and in your own words!