Meaningful Use for Anesthesia Billing, What to Expect

UPDATE: CMS recently announced the renaming of the Electronic Health Record (EHR) Incentive Programs to the Promoting Interoperability (PI) Programs.^[1] According to the agency, this change is being made to “continue the agency’s focus on improving patients’ access to health information and reducing the time and cost required of providers to comply with the programs’ requirements”.

Background

The American Recovery and Reinvestment Act of 2009 (ARRA) mandated that payment adjustments should be applied to Medicare eligible professionals (EPs), eligible hospitals, and critical access hospitals (CAH) that are not meaningful users of certified electronic health record technology (CEHRT) under the PI Programs (formerly EHR Incentive Programs).

In 2011, the three stages^[2] of the Medicare and Medicaid PI Programs (formerly EHR Incentive Programs) were introduced by CMS, to encourage EPs, eligible hospitals, and CAHs to adopt, implement, upgrade (AIU), and demonstrate meaningful use of certified EHR technology.

Stage 1 established requirements for the electronic capture of clinical data, including providing patients with electronic copies of health information.

Stage 2 expanded upon the Stage 1 criteria with a focus on advancing clinical processes and ensuring that the meaningful use of EHRs supported the aims and priorities of the National Quality Strategy. Stage 2 criteria also encouraged use of CEHRT for continuous quality improvement at the point of care and the exchange of information in the most structured format possible.

Stage 3 centers on the use of CEHRT to support interoperability and data sharing for all participants under the PI Programs.

CMS notes that providers who have not successfully demonstrated meaningful use in a prior year and are seeking to demonstrate meaningful use for the first time in 2017 to avoid the 2018 payment adjustment must attest to Modified Stage 2 objectives and measures.

Stage 3 Program Requirements for Providers Attesting to their State’s Medicaid Promoting PI Programs

• All providers are required to attest to a single set of objectives and measures.
• For EPs and eligible hospitals, there are 8 objectives^[3],^[4]

1. Protect electronic protected health information (ePHI) created or maintained by the CEHRT through the implementation of appropriate technical, administrative, and physical safeguards.
2. Generate and transmit permissible prescriptions electronically (eRx).
3. Implement clinical decision support (CDS) interventions focused on improving performance on high-priority health conditions.
4. Use computerized provider order entry (CPOE) for medication, laboratory, and diagnostic imaging orders directly entered by any licensed healthcare professional, credentialed medical assistant, or a medical staff member credentialed to and performing the equivalent duties of a credentialed medical assistant, who can enter orders into the medical record per state, local, and professional guidelines.
5. Patient Electronic Access – The EP provides patients (or patient-authorized representative) with timely electronic access to their health information and patient-specific education.
6. Coordination of Care – Use CEHRT to engage with patients or their authorized representatives about the patient’s care.
7. Health Information Exchange – The EP provides a summary of care record when transitioning or referring their patient to another setting of care, receives or retrieves a summary of care record upon the receipt of a transition or referral or upon the first patient encounter with a new patient, and incorporates summary of care information from other providers into their EHR using the functions of CEHRT.
8. Public Health Reporting – the EP is in active engagement with a public health agency or clinical data registry to submit electronic public health data in a meaningful way using certified EHR technology, except where prohibited, and in accordance with applicable law and practice. To meet Stage 3 requirements, all providers must use technology certified to the 2015 Edition. A provider who has technology certified to a combination of the 2015 Edition and 2014 Edition may potentially attest to the Stage 3 requirements if the mix of certified technologies would not prohibit them from meeting the Stage 3 measures. However, a provider who has technology certified to the 2014 Edition only may not attest to Stage 3.

• CMS notes that there are no alternate exclusions or specifications available.

There are changes to the measure calculations policy, which specifies that actions included the numerator must occur within the EHR reporting period if that period is a full calendar year, or if it is less than a full calendar year, within the calendar year in which the EHR

This article is not legal advice and readers are encouraged to consult with their attorney on any matters related to this or similar topics. 

[1] 2018 PI Program Requirements for Medicare

[2] 2018 PI Program Requirements for Medicare

[3] Eligible Professionals (EPs) and Eligible Clinicians;

[4] Eligible Hospitals and Critical Access Hospitals (CAHs);