Blumenthal Letter #22: Ready for Jan 3 EHR Incentives Registration?

Registration for EHR Incentive Programs
Starts January 3, 2011: Are You Ready?

Dr. David Blumenthal

Dr. David Blumenthal

A Message from Dr. David Blumenthal, the National Coordinator for Health Information Technology
December 27, 2010

Published by ONC on 12/27/2010 and republished here.

The New Year is just around the corner, and so is another milestone in our nation’s work to improve health care through health information technology. Starting on January 3, 2011, eligible health care professionals, hospitals, and critical access hospitals may register to participate in the Medicare and Medicaid EHR Incentive Programs.

This is an auspicious time. Nearly two years ago, the Health Information Technology for Economic and Clinical Health (HITECH) Act, part of the American Recovery and Reinvestment Act of 2009, was signed into law. Since then Department of Health and Human Services (HHS) agencies like the Office of the National Coordinator for Health Information Technology (ONC), the Centers for Medicare & Medicaid Services (CMS), the Office for Civil Rights (OCR), and others have implemented HITECH policies and programs to help providers adopt and achieve meaningful use of certified electronic health record technology and ensure that electronic health information remains private and secure.

[See Blumenthal's review of 2010, originally posted on ONC's Health IT Buzz blog.]

Why Become a Meaningful User?

Qualify for financial incentives from the federal government
Eligible professionals who demonstrate meaningful use have the opportunity to receive incentive payments through the Medicare and Medicaid EHR Incentive Programs—up to $44,000 from Medicare, or $63,750 from Medicaid.  Under both Medicare and Medicaid, eligible hospitals may receive millions of dollars for implementing and meaningfully using certified EHR technology. Providers can get started now with the help of financial incentives from the federal government. If they wait, those incentives may not be available. And financial penalties are scheduled to take effect in five years. 

Build a sustainable medical practice
The next generation of health care professionals will expect and demand that their own medical facility home have a state-of-the-art information system.  Becoming a meaningful user of electronic health records will allow providers who are building their practices to recruit and retain talented young clinicians.

Improve the safety and quality of health care 
The meaningful use of electronic health records will help health care providers and hospitals offer higher quality and safer care. By adopting electronic health records in a meaningful way, providers and hospitals can:

  • See the whole picture. All of a patient’s health information—medical history, diagnoses, medications, lab and test results—is in one place. Providers don’t have to settle for a snapshot when they can have the entire album.
  • Coordinate care. Providers involved in a patient’s care can access, enter, and share information in an electronic health record.
  • Make better decisions. With more comprehensive health information at their fingertips, providers can make better testing, diagnostic, and treatment decisions.
  • Save time and money. Providers who have implemented electronic health records say they spend less time searching for paper charts, transcribing, calling labs or pharmacies, reporting, and fixing coding errors.

ONC and CMS: Here To Help

Registration for the incentive programs may be close at hand, but so is assistance. If you need help in registering for the Medicare and Medicaid EHR Incentive Programs or selecting a certified EHR system, ONC and CMS have resources and services to help you.

  • The Medicare and Medicaid EHR Incentive Programs website contains educational resources and fact sheets with information to help eligible professionals and hospitals adopt, implement, and upgrade certified EHR technology and demonstrate meaningful use to receive EHR incentive payments.
  • Regional Extension Centers, which cover every region of the country, provide on-the-ground technical assistance to health care providers working to adopt and meaningfully use certified EHR technology.
  • The Health IT Workforce Development Program prepares skilled workers for new jobs in health IT.

Connecting to Your Community
ONC also has other programs in place to help advance the meaningful use of certified EHR technology and health information exchange:

As 2010 comes to a close, we are well on our way as a nation to achieving the benefits of widespread adoption of EHRs. If you haven’t made any preparations to register to receive incentive payments, I encourage you to get started now. Resolve today to become a meaningful user in 2011.

Sincerely,
David Blumenthal, MD, MPP
National Coordinator for Health Information Technology 
The Office of the National Coordinator for Health Information Technology (ONC) encourages you to share this information as we work together to enhance the quality, safety and value of care and the health of all Americans through the use of electronic health records and health information technology.

For more information and to receive regular updates from the Office of the National Coordinator for Health Information Technology, please subscribe to our Health IT News list.

Directions for CMS EHR Incentives Registration

Registration and Attestation Begins January 3, 2011
Program Directions
Excerpted from CMS EHR Incentives Program on 12/26/2010.

Registration for the Medicare and Medicaid EHR Incentive Programs opens on January 3, 2011. We encourage providers to register for the Medicare and/or Medicaid EHR Incentive Program(s) as soon as possible. You can register before you have a certified EHR. Register even if you do not have an enrollment record in PECOS.

A link to Registration will be available on CMS EHR Incentives Program site.

Please Note: Although the Medicaid EHR Incentive Programs will begin January 3, 2011, not all states will be ready to participate on this date. Information on when registration will be available for Medicaid EHR Incentive Programs in specific States is posted at Medicaid State Information.

“It is important for a dually-eligible hospital to select “Both Medicare and Medicaid” from the start of registration in order to maintain this option.” Hospitals and Eligible Professionals should read the notes below under the heading “What else do I need to know about registration?

[Registration for state Medicaid programs opens in the following states on January 3, 2011:

* Alaska
* Iowa
* Kentucky
* Louisiana
* Oklahoma
* Michigan
* Mississippi
* North Carolina
* South Carolina
* Tennessee
* Texas

Registration for state Medicaid programs opens in the following states in February 2011:

* California
* Missouri
* North Dakota

Other states likely will launch their Medicaid EHR Incentive Programs during the spring and summer of 2011.]

e-Healthcare Marketing note: It’s important for hospitals and eligible professionals in ALL STATES to register when registration opens and not delay registering on the CMS site until their state Medicaid programs are ready. See further note below in red under the heading “What else do I need to know about registration?

What can you do now for the Medicare and Medicaid EHR Incentive Programs?

Make sure you have enrollment records in the appropriate systems. You’ll need:

  • A National Provider Identifier (NPI)
    • All eligible professionals, eligible hospitals, and critical access hospitals (CAHs) must have a National Provider Identifier (NPI) to participate in the Medicare and Medicaid EHR Incentive Programs.
  • An enrollment record in the Provider Enrollment, Chain and Ownership System (PECOS)
    • All eligible hospitals and Medicare eligible professionals must have an enrollment record in PECOS to participate in the EHR Incentive Programs. (Note: Eligible professionals who are only participating in the Medicaid EHR Incentive Program are not required to be enrolled in PECOS.)
    • If you do not have an enrollment record in PECOS, you should still register for the Medicare and Medicaid EHR Incentive Programs.

CMS Identity and Access Management (I&A) User ID and Password

  • Eligible Professionals:
    • Eligible professionals can use the same User ID and Password they use for the National Plan and Provider Enumeration System (NPPES). This is also the same User ID and Password that is used to access PECOS.
    • If you do not have an active User ID and Password for NPPES or PECOS, request them via Identity & Access Management. You will need your type 2 NPI, your Taxpayer Identification Number (TIN), and your address from IRS Form CP-575. You will also need to mail a copy of IRS Form CP-575 as directed.
  • Hospitals/Critical Access Hospitals:
    • Authorized Officials can use the same User ID and Password they use to access PECOS.
    • If you do not have an Authorized Official with access to PECOS, request a User ID and Password via Identity & Access Management. You will need your type 2 NPI, your Taxpayer Identification Number (TIN), and your address from the IRS Form CP-575. You will need to mail a copy of the IRS Form CP-575 as directed.
    • Additional hospital staff will need to request access to the “EHR Incentive Programs” application through Identity & Access Management and be approved by the Hospital’s Authorized Official.

What information will you need when you register?

Registering for the Medicare and Medicaid EHR Incentive Programs is easy when you have the following information available during the process:

Eligible Professionals

  • National Provider Identifier (NPI).
  • National Plan and Provider Enumeration System (NPPES) User ID and Password.
  • Payee Tax Identification Number (if you are reassigning your benefits).
  • Payee National Provider Identifier (NPI)(if you are reassigning your benefits).

Hospitals

  • CMS Identity and Access Management (I&A) User ID and Password.
  • CMS Certification Number (CCN).
  • National Provider Identifier (NPI).
  • Hospital Tax Identification Number.

NOTE: You do not have to provide information on the certified EHR technology you are using when you register. However, this information is required when you attest.

What else do I need to know about registration?

Hospitals:
Hospitals that are eligible for EHR incentive payments under both Medicare and Medicaid should select “Both Medicare and Medicaid” during the registration process, even if they plan to apply only for a Medicaid EHR incentive payment by adopting, implementing, or upgrading certified EHR technology. Dually-eligible hospitals can then attest through CMS for their Medicare EHR incentive payment at a later date, if they so desire. It is important for a dually-eligible hospital to select “Both Medicare and Medicaid” from the start of registration in order to maintain this option.

Hospitals that register only for the Medicaid program (or only the Medicare program) will not be able to manually change their registration (i.e., change to “Both Medicare and Medicaid” or from one program to the other) after a payment is initiated and this may cause significant delays in receiving a Medicare EHR incentive payment.

Eligible Professionals:
Eligible professionals eligible for both the Medicare and Medicaid EHR Incentive Programs must choose which incentive program they wish to participate in when they register. Before 2015, an eligible professional may switch programs only once after the first incentive payment is initiated. Most eligible professionals will maximize their incentive payments by participating in the Medicaid EHR Incentive Program.

The Electronic Health Record (EHR) Information Center is open to assist the EHR Provider Community with inquiries.
Hours of operation are:

8:30 a.m. – 4:30 p.m. (Central Time) Monday through Friday (except federal holidays)
1-888-734-6433 (primary number) or 888-734-6563 (TTY number)

Submit an Inquiry to the EHR Information Center

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Downloads
Medicare EP PECOS Notification [PDF, 119KB]
Hospital PECOS Notification [PDF, 160KB]
Related Links Inside CMS
Frequently Asked Questions (FAQs)
Excerpted from CMS Page Modified on 12/23/2010 8:41:41 AM

See e-Healthcare Marketing post for December 23, 2010 press release from ONC and CMS.

EHR INCENTIVES REGISTRATION STARTS JAN. 3, 2011

ELECTRONIC HEALTH RECORDS INCENTIVES REGISTRATION STARTS JAN. 3, 2011

CMS, ONC Outline Resources to Assist Eligible Providers
CMS Press Release on December 22, 2010

Today the Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) announced the availability of registration for the Medicare and Medicaid electronic health record (EHR) incentive programs.  CMS and ONC encouraged broad participation and outlined online and in-person resources that are in place to assist eligible professionals and eligible hospitals who wish to participate.

Beginning Jan. 3, 2011, registration will be available for eligible health care professionals and eligible hospitals who wish to participate in the Medicare EHR incentive program.

On January 3, registration in the Medicaid EHR Incentive Program will also be available in Alaska, Iowa, Kentucky, Louisiana, Oklahoma, Michigan, Mississippi, North Carolina, South Carolina, Tennessee, and Texas.  In February, registration will open in California, Missouri, and North Dakota.  Other states likely will launch their Medicaid EHR Incentive Programs during the spring and summer of 2011.

[See e-Healthcare Marketing post on registration directions.]

“With the start of registration, these landmark programs get underway, and patients, providers, and the nation can begin to enjoy the benefits of widespread adoption of electronic health records,” said CMS Administrator Donald Berwick, MD.  “CMS has many resources available to help providers register and participate, and we look forward to working with eligible professionals and eligible hospitals to facilitate the process, beginning on January 3rd and going forward.”

“It’s time to get connected,” said David Blumenthal, MD, MPP, National Coordinator for Health Information Technology.  “ONC and CMS have worked together over many months to prepare for the startup on January 3rd. ONC’s Certified HIT Product List includes more than 130 certified EHR systems or modules and is updated frequently.  ONC also has hands-on assistance available across the country through 62 Regional Extension Centers

We look forward to continuing to work with CMS to assist eligible providers in 2011 and future years.”

Eligible professionals and eligible hospitals must register in order to participate in the Medicare and Medicaid EHR incentive programs.  They can do so, starting Jan. 3, 2011, at a registration site maintained by CMS.

To prepare for registration, interested providers should first familiarize themselves with the incentive programs’ requirements by visiting CMS’ Official Web Site for the Medicare and Medicaid EHR Incentive Programs.  The site provides general and detailed information on the programs, including tabs on the path to payment, eligibility, meaningful use, certified EHR technology, and frequently asked questions.

CMS announced the following key dates for the Medicare and Medicaid incentive programs’ first year:

  • Jan. 3, 2011 – Registration for the Medicare EHR incentive program begins.
  • Jan. 3, 2011 –States that are ready may launch their incentive programs for Medicaid providers.
  • January 2011 – Some state agencies begin issuing Medicaid EHR incentive payments.
  • April 2011 – Attestation for the Medicare EHR incentive program begins.
  • May 2011 – Issuing of Medicare EHR incentive payments expected to begin.
  • July 3, 2011 – Last day for eligible hospitals to begin their 90-day reporting period to demonstrate meaningful use for the Medicare EHR incentive program for federal FY 2011.
  • Sept. 30, 2011 – Federal FY 2011 payment year ends at midnight for eligible hospitals and critical access hospitals (CAHs).
  • Oct. 3, 2011 – Last day for eligible professionals to begin their 90-day reporting period for calendar year 2011 to demonstrate meaningful use for the Medicare EHR incentive program.
  • Nov. 30, 2011 – Last day for eligible hospitals and CAHs to register and attest to receive an incentive payment for federal fiscal year 2011.
  • Dec. 31, 2011 – Calendar 2011 payment year ends for eligible professionals.

Under the Health Information Technology for Economic and Clinical Health Act (HITECH), part of the American Recovery and Reinvestment Act of 2009, Medicare and Medicaid incentive payments will be available to eligible professionals, eligible hospitals, and critical access hospitals (CAHs) when they adopt certified EHR technology and successfully demonstrate “meaningful use” of the technology in ways that improve quality, safety, and effectiveness of patient-centered care.

Professionals who meet the eligibility requirements for both the Medicare and Medicaid EHR incentive programs must select which program they wish to participate in when they register.  They cannot participate in both programs; however, after receiving payment, they may change their program selection once before 2015.  Hospitals that are eligible for both programs can receive payments from both Medicare and Medicaid.

Some states will launch their Medicaid EHR incentive programs beginning Jan. 3, 2011, but most will launch their programs during the spring and summer.  Eligible providers with questions about their state’s launch date should contact their state Medicaid agency.  Eligible providers seeking to participate in the Medicaid programs must initiate registration at CMS’ registration site but must complete the process through an eligibility verification site maintained by their state Medicaid agency.

Under the EHR incentive programs, eligible professionals can receive as much as $44,000 over a five-year period through Medicare.  For Medicaid, eligible professionals can receive as much as $63,750 over six years.  Under both Medicare and Medicaid, eligible hospitals may receive millions of dollars for implementing and meaningfully using certified EHR technology.

“The benefits of EHRs are widely recognized, and support for the incentive programs is strong in the health care field and among policymakers,” Dr. Berwick said. “The changeover from paper to electronic records will be challenging for clinicians and hospitals, but CMS and ONC have taken steps to ease the transition.  We’ve provided flexibility in meeting the meaningful use requirements, both agencies have conducted extensive outreach, and we have the resources in place to help providers acquire certified EHR technology and meet the programs’ requirements.  Immediate registration is not required, but we encourage eligible providers to sign up as soon as they have certified EHR technology and are prepared to participate.  We are ready to help.”

#  #  #  #  #  #  #

VERY IMPORTANT NOTICE FROM CMS WEB SITE
Hospitals:

Hospitals that are eligible for EHR incentive payments under both Medicare and Medicaid should select “Both Medicare and Medicaid” during the registration process, even if they plan to apply only for a Medicaid EHR incentive payment by adopting, implementing, or upgrading certified EHR technology. Dually-eligible hospitals can then attest through CMS for their Medicare EHR incentive payment at a later date, if they so desire. It is important for a dually-eligible hospital to select “Both Medicare and Medicaid” from the start of registration in order to maintain this option.

Hospitals that register only for the Medicaid program (or only the Medicare program) will not be able to manually change their registration (i.e., change to “Both Medicare and Medicaid” or from one program to the other) after a payment is initiated and this may cause significant delays in receiving a Medicare EHR incentive payment.

Eligible Professionals:
Eligible professionals eligible for both the Medicare and Medicaid EHR Incentive Programs must choose which incentive program they wish to participate in when they register. Before 2015, an eligible professional may switch programs only once after the first incentive payment is initiated. Most eligible professionals will maximize their incentive payments by participating in the Medicaid EHR Incentive Program.

The Electronic Health Record (EHR) Information Center is open to assist the EHR Provider Community with inquiries.
Hours of operation are:

8:30 a.m. – 4:30 p.m. (Central Time) Monday through Friday (except federal holidays)
1-888-734-6433 (primary number) or 888-734-6563 (TTY number)

Submit an Inquiry to the EHR Information Center
###

See e-Healthcare Marketing post on registration directions.

Health IT Special Issue of The American Journal of Managed Care: Dec 2010

AJMC Publishes Health Information Technology Special Issue Online Dec 20, 2010
“Featuring scholarly articles and perspectives from policymakers, payers, providers, pharmaceutical companies, health IT vendors, health services researchers, patients, and medical educators, this [December 2010 special] issue of  The American Journal of Managed Care is a reflection” of  “the  dramatic growth of interest in the potential for HIT to improve health and healthcare delivery,” writes Sachin H. Jain, MD, MBA and David Blumenthal, MD, MPP in their introductory article titled “Health Information Technology Is Leading Multisector Health System Transformation.”  Both Jain and Blumenthal are with the Office of the National Coordinator for Health Information Technology.

Authors of 23 Articles in Special Issue
Sachin H. Jain, MD, MBA; and, David Blumenthal, MD, MPP; Cynthia L. Bero, MPH; and Thomas H. Lee, MD; Aaron McKethan, PhD; and Craig Brammer; John Glaser, PhD; Pete Stark; Newt Gingrich, PhD, MA; and Malik Hasan, MD; James N. Ciriello, MS; and Nalin Kulatilaka, PhD, MS; Seth B. Cohen, MBA, MPA; Kurt D. Grote, MD; Wayne E. Pietraszek, MBA; and Francois Laflamme, MBA; Amol S. Navathe, MD, PhD; and Patrick H. Conway, MD, MSc; Reed V. Tuckson, MD; Denenn Vojta, MD; and Andrew M. Slavitt, MBA; Marc M. Triola, MD; Erica Friedman, MD; Christopher Cimino, MD; Enid M. Geyer, MLS, MBA; Jo Wiederhorn, MSW; and Crystal Mainiero; Nancy L. Davis, PhD; Lloyd Myers, RPh; and Zachary E. Myers; Bryant A. Adibe, BS; and Sachin H. Jain, MD, MBA; Spencer S. Jones, PhD; John L. Adams, PhD; Eric C. Schneider, MD; Jeanne S. Ringel, PhD; and Elizabeth A. McGlynn, PhD; Jeffrey L. Schnipper, MD, MPH; Jeffrey A. Linder, MD, MPH; Matvey B. Palchuk, MD, MS; D. Tony Yu, MD; Kerry E. McColgan, BA; Lynn A. Volk, MHS; Ruslana Tsurikova, MA; Andrea J. Melnikas, BA; Jonathan S. Einbinder, MD, MBA; and Blackford Middleton, MD, MPH, MS;Alexander S. Misono, BA; Sarah L. Cutrona, MD, MPH; Niteesh K. Choudhry, MD, PhD; Michael A. Fischer, MD, MS; Margaret R. Stedman, PhD; Joshua N. Liberman, PhD; Troyen A. Brennan, MD, JD; Sachin H. Jain, MD, MBA; and William H. Shrank, MD, MSHS; Amir Dan Rubin, MBA, MHSA; and Virginia A. McFerran, MA; Fredric E. Blavin, MS; Melinda J. Beeuwkes Buntin, PhD; and Charles P. Friedman, PhD Robert D. Hill, PhD; Marilyn K. Luptak, PhD, MSW; Randall W. Rupper, MD, MPH; Byron Bair, MD; Cherie Peterson, RN, MS; Nancy Dailey, MSN, RN-BC; and Bret L. Hicken, PhD, MSPH; Jeffrey A. Linder, MD, MPH; Jeffrey L. Schnipper, MD, MPH; Ruslana Tsurikova, Msc, MA; D. Tony Yu, MD, MPH; Lynn A. Volk, MHS; Andrea J. Melnikas, MPH; Matvey B. Palchuk, MD, MS; Maya Olsha-Yehiav, MS; and Blackford Middleton, MD, MPH, MSc; Emily Ruth Maxson, BS; Melinda J. Beeuwkes Buntin, PhD; and Farzad Mostashari, MD, ScM; Daniel C. Armijo, MHSA; Eric J. Lammers, MPP; and Dean G. Smith, PhD; Katlyn L. Nemani, BA.

Look for an upcoming post on e-Healthcare Marketing reviewing this special issue of AJMC.

Blumenthal Blogs to Clarify EHR Certification Re: ‘Meaningful Use’

Affirming Flexibility…With Certified EHR Systems
Thursday, December 23rd, 2010 | Posted by: Dr. David Blumenthal on ONC Health IT Buzz blog and republished here by e-Healthcare Marketing

Today on our FAQ page, we are posting a revised Question and Answer regarding an issue that has recently caused confusion in our meaningful use regulations:  namely, the flexibility that providers have to defer performance on some Stage 1 meaningful use objectives; and how that squares with the requirement that providers must nonetheless possess fully-certified EHR systems.

The new FAQ is meant to clarify this two-part requirement. But we should make it equally clear that our policy has not changed:

  • As stated in our final regulations, providers are given the flexibility to defer as many as five “menu set” objectives during Stage 1 and still achieve meaningful use. That means providers have flexibility to stage their adoption and implementation of EHRs in sync with their plans to defer certain menu set objectives.
  • But as also stated in our final regulations, we require EHR systems themselves be certified against all criteria adopted by the Secretary. So even though a provider has the option of deferring some objectives during Stage 1, the EHR system in the provider’s possession must be certified against all functions. Possession means having a legal right to access and use, at the provider’s discretion, all of the Stage 1 functions of a fully-certified system – but it does not imply that the provider must fully implement every one of these functions.

To understand this two-part approach, we need to look back to the development of the meaningful use regulations.  From the beginning, this process was aimed at achieving the right balance – a balance between the need to achieve effective and rapid adoption of EHRs throughout the United States; and at the same time to be realistic about the challenges facing providers on the road to meaningful use.

In our final regulations, I believe HHS achieved the needed balance:

  1. We identified the objectives that constituted meaningful use in Stage 1.  These objectives are part of a coherent, longer-range plan for EHR adoption and meaningful use. We will build on these objectives as we graduate through Stage 2 and 3 of the transition process.
  2. But at the same time, for these initial years, we recognized the challenge that this transition will pose to providers. For that reason, we gave providers flexibility in their own “staging” choices, permitting them to defer performing on as many as five of the 10 “menu set” objectives. This guarantee of flexibility, provided in our final regulations, has not been changed.

Why did we require that EHRs be certified as capable of meeting all of the certification criteria for meaningful use, even though we allowed flexibility concerning which criteria providers actually had to meet? There were several reasons.

First, our regulation stated that in Stage 2 of Meaningful Use, we will require that providers meet all the requirements laid out in Stage 1, including all 10 of objectives on the options menu. Having records capable of meeting all 10 objectives allows providers to get a head start on Stage 2 of meaningful use.

Second, we expect that some providers may try and fail to meet meaningful use objectives on one or more of the menu criteria.  If their records are not capable of meeting the other optional objectives, they may be unable to obtain and implement the capabilities they lack in time to qualify for meaningful use.  Thus, the requirement that certified EHRs possess the capability to meet all requirements actually gives providers the flexibility to experiment with multiple approaches to meeting meaningful use– and guarantees that if they fall short, they will not be left high and dry. This flexibility is only possible when the provider has access to certified technology for all Stage 1 functions.

The details of these requirements can be found in the new FAQ , and I invite you to read and comment. I hope it will be clear that these two elements are not in conflict, but rather represent the balance that has characterized the evolution of the meaningful use process.  Finally, I hope it will be clear that there has been no change in the guarantee of provider flexibility during Stage 1.

To achieve EHR-based health care, we need to build a strong technology foundation. But at the same time, we need to recognize that providers have varying circumstances and different needs, and we seek to accommodate those differences as we support the transition to EHRs. In that spirit, we are delivering on the promise in our final regulations to give providers the flexibility they require to succeed in adoption and meaningful use of EHRs.

Colleen Woods Asks “Where are the NJ Healthcare Innovators?!!”

From: Colleen Woods, NJ Health IT Coordinator
To: New Jersey Healthcare Innovators,
NJ Health IT Community
Re: Calling for Innovations for Supplemental ONC Funding
Date: Dec 21, 2010
High Priority
Most of you are aware that the Office of the National Coordinator issued a supplemental funding opportunity to the State Health Information Exchange Cooperative Agreement Program.  As required, on December 10th,2010,  I responded that New Jersey would apply for the supplemental funding, knowing that we have many exciting projects in place that could be advanced with just a bit of additional funds.

There are five challenge “themes” that the feds view as potential barriers to full national health information exchange. They are seeking innovative ideas/solutions from those of you who know healthcare delivery the best.  The themes are:
  • Achieving Health Goals through Health Information Exchange
  • Improving Long Term and Post Acute Care Transitions
  • Consumer Mediated Information Exchange
  • Enabling Advance Query for Patient Care
  • Fostering Distributed Population-Level Analytics

For more information please see a PDF of the  ONC’s funding announcement: http://goo.gl/oGc7Q

Or to see all the funding documents, go to Grants.gov:http://goo.gl/0dk3i

I know there are a lot of good ideas and projects already underway that would qualify for this funding opportunity. (Jeff, Becky, Jim, Tom, Dave, Tom, Linda, Lou, Judy, Neal, Al, Bob et al…..) , but the award requires a quick response.  Applications need to be sent to by the NJ State Coordinator’s Office ONC by January 5th, 2011. I would proud to submit any ideas you have that would meet the ONC challenge.  Please feel free to call me to discuss.

My best wishes to you and your families for a Happy Holiday Season!

Colleen

Colleen Woods
NJ Health IT Coordinator
Governor’s Office
(609)777-2609
colleen.woods@gov.state.nj.us

Synopsis of the Supplemental State HIE Challenge Program
“This funding announcement for the Health Information Exchange Challenge Program encourages breakthrough progress for nationwide health information exchange in five challenge areas identified as key needs since Federal and State governments began implementation of the HITECH Act. The awards will fund the development of technology and approaches that will be developed in pilot sites and then shared, reused, and leveraged by other states and communities to increase nationwide interoperability. The five themes include: 1. Achieving health goals through health information exchange 2. Improving long-term and post-acute care transitions 3. Giving patients access to their own health information 4. Developing tools and approaches to search for and share granular patient data (such as specific lab results for a given time period) 5. Fostering strategies for population-level analysis Awards will range between $1 million and $2 million each, and will be in the form of supplemental funding to State Health Information Exchange Cooperative Agreements, which have provided approximately half a billion dollars to states and State designated entities to enable health information exchange. Funding for this initiative is approximately $16 million which ONC anticipates will support 10 awards.”
–Synopsis from grants.gov

New EHR FAQs Added to ONC/CMS sites on eRx, Clinical Info Exchange

CMS and ONC both Add to FAQs related to Health Information Exchange on 12/12/2010
Link to PDF of ONC’s 22 Regulations FAQs. Note FAQ #21 not yet posted.
The following FAQs were excerpted on 12/18/2010.

ONC Question [12-10-022-1]:

Does the certification criterion pertaining to electronic prescribing, which references certain content exchange standards (i.e., NCPDP SCRIPT 8.1 and NCPDP SCRIPT 10.6), require that a Complete EHR or EHR Module be capable of electronically exchanging information with only external recipients (i.e., recipients that are not part of that legal entity) according to the appropriate standard (and implementation specifications) or does it apply more broadly?

Answer:
For the certification criterion pertaining to electronic prescribing (45 CFR 170.304(b)), which references those two content exchange standards adopted at 45 CFR 170.205(b) and the vocabulary standard 170.207(d) (i.e., any source vocabulary that is included in RxNorm), a Complete EHR or EHR Module must be certified as being capable of electronically generating and transmitting prescriptions and prescription-related information to external recipients in accordance with the appropriate adopted standard(s) (and implementation specifications). These standards were adopted for the purpose of enabling a user of Certified EHR Technology to “exchange” electronically certain health information, as indicated in the first sentence of the regulatory section and the section title, and as alluded to in various other parts of the Standards and Certification Criteria Interim Final and Final Rules.

We intended the capability required by this certification criterion and the referenced standards and implementation specifications to apply to the electronic exchange of prescription information between different legal entities (e.g., from an eligible professional’s Certified EHR Technology to a pharmacy that is not part of the eligible professional’s legal entity), to complement how CMS has generally described “exchange” in the context of meaningful use as information “sent between different legal entities with distinct certified EHR technology or other system that can accept the information….” (75 FR 44361-62). In the Standards and Certification Criteria Interim Final Rule and in the Standards and Certification Criteria final rule, we discussed current Medicare Part D electronic prescribing regulatory requirements for using NCPDP SCRIPT 8.1, and the anticipated use of NCPDP SCRIPT 10.6. (75 FR 2031-32, 75 FR 44625-26). In both rules, we also had explained that the purpose of the adopted standards and certification criteria was not to specify how or when Certified EHR Technology must be used, but only what capabilities Certified EHR Technology must include. (75 FR 2022-23, 75 FR 44592-93). We sought to align the adopted standards, implementation specifications, and certification criteria with certain already established regulatory requirements to ensure that Certified EHR Technology would provide a base-level of capabilities to assist users in meeting those other regulatory requirements. (See, for example, 75 FR 44591, and 75 FR 44598.) Then, when discussing electronic prescribing, we referred to the adopted NCPDP SCRIPT standard as a standard required under the Medicare Part D e-prescribing regulations when “an entity sends prescriptions outside the entity (for example, from an HMO to a non-HMO pharmacy)….” (75 FR 2031-32, 75 FR 44592). Consequently, with respect to the capability a Complete EHR or EHR Module must demonstrate in order to be certified to the certification criterion adopted at 170.304(b), a Complete EHR or EHR Module must be capable of electronically transmitting prescriptions and prescription-related information to external recipients according to NCPDP SCRIPT 8.1 or 10.6 in addition to the adopted vocabulary standard for medications at 45 CFR 170.207(d).

This approach is consistent with a principle we established in the Standards and Certification Criteria Interim Final Rule where we sought to ensure that eligible health care providers seeking to meaningfully use Certified EHR Technology and engaging in electronic exchange would be able to do so in a manner that would be compliant with other applicable law. Thus, with respect to electronic prescribing, we adopted NCPDP SCRIPT 8.1 and 10.6 to ensure that when an eligible professional electronically transmits a prescription or prescription-related information for Medicare Part D covered drugs for Medicare Part D eligible individuals to, for example, a pharmacy that is not part of the legal entity of the eligible professional, the eligible professional would be able to do so using Certified EHR Technology and also comply with the Medicare Part D e-prescribing rules.

See CMS FAQ 10284 [ or immediately below] for information about how these transmissions should be counted.

CMS Question 10284 FAQ on EHR Incentive Program
For the meaningful use objective of “generate and transmit prescriptions electronically (eRx)” for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Program, how should the numerator and denominator be calculated? Should electronic prescriptions fulfilled by an internal pharmacy be included in the numerator?

Published 12/17/2010 11:34 AM   |    Updated 12/17/2010 11:41 AM   |    Answer ID 10284

ANSWER
The denominator for this objective consists of the number of prescriptions written for drugs requiring a prescription in order to be dispensed, other than controlled substances, during the EHR reporting period. The numerator consists of the number of prescriptions in the denominator generated and transmitted electronically using certified EHR technology. In order to meet the measure of this objective, 40 percent of all permissible prescriptions written by the EP must be generated and transmitted electronically according to the applicable certification criteria and associated standards adopted for certified EHR technology as specified by the Office of the National Coordinator for Health IT (ONC).

ONC has released an FAQ stating that “with respect to the capability a Complete EHR or EHR Module must demonstrate in order to be certified to the certification criterion adopted at 170.304(b), a Complete EHR or EHR Module must be capable of electronically transmitting prescriptions to external recipients according to NCPDP SCRIPT 8.1 or 10.6 in addition to the adopted vocabulary standard for medications (45 CFR 170.207(d)).”  Given such FAQ, prescriptions transmitted electronically within an organization (the same legal entity) would not need to use these NCPDP standards. However, an EP’s EHR must meet all applicable certification criteria and be certified as having the capability of meeting the external transmission requirements of §170.304(b).  In addition, the EHR that is used to transmit prescriptions within the organization would need to be Certified EHR Technology.

The EP would include in the numerator and denominator both types of electronic transmissions (those within and outside the organization) for the measure of this objective. We further clarify that for purposes of counting prescriptions “generated and transmitted electronically,” we consider the generation and transmission of prescriptions to occur constructively if the prescriber and dispenser are the same person and/or are accessing the same record in an integrated EHR to creating an order in a system that is electronically transmitted to an internal pharmacy.

For more information about the Medicare and Medicaid EHR Incentive Program, please visit http://www.cms.gov/EHRIncentivePrograms.

ONC Question [12-10-023-1]:
Could an interface that transmits lab results in HL7 message format between a hospital laboratory system and a physician’s EHR (presuming that the transmissions were occurring between two different legal entities) satisfy the certification criteria related to the exchange of key clinical information in 45 CFR 170.304(i) and 45 CFR 170.306(f)? If not, please specify the required data types and exchange characteristics that must be part of the required clinical information exchange.

Answer:
As implied in the question, for certification a Complete EHR or an EHR Module must have the capability to electronically receive and display, and transmit certain key clinical information in accordance with one of two separate certification criteria (45 CFR 170.304(i) or 45 CFR 170.306(f)), depending on the setting for which the EHR technology is designed (ambulatory or inpatient, respectively). Generally speaking, these certification criteria require two types of information exchange capabilities – the capability to:

  1. Electronically receive and display a patient’s summary record, from other providers and organizations including, at a minimum, diagnostic tests results, problem list, medication list, and medication allergy list in accordance with the continuity of care document (CCD) standard (and the HITSP/C321 implementation specifications) or the continuity of care record (CCR) standard and that upon receipt of a patient summary record formatted according to the alternative standard, display it in human readable format.
  2. Electronically transmit a patient summary record to other providers and organizations including, at a minimum, diagnostic test results, problem list, medication list, and medication allergy list using the CCD standard (and the HITSP/C32 implementation specifications) or the CCR standard while also representing specific named data elements (problems, laboratory test results, and medications) according to adopted standards.

Note: The above uses language from 45 CFR 170.304(i). The certification criterion adopted at 45 CFR 170.306(f) also includes “procedures” as a required, standardized data element within these exchange capabilities.

Therefore, an interface that transmits lab results in HL7 message format between a hospital laboratory system and a physician’s EHR (where the transmission is occurring between two different legal entities) would not qualify as an exchange of key clinical information that complies with the requirements of either of these two certification criteria. The interface would not satisfy the required capabilities included within the adopted certification criteria, and more specifically, the ability to transmit a patient summary record in accordance with the CCD standard (and the HITSP/C32 implementation specifications) or the CCR standard.

1HITSP Summary Documents Using HL7 Continuity of Care Document (CCD)

‘Health IT: Making Health Care Better’: Commentary on America’s Health Rankings Site

‘Health IT: Making Health Care Better’ by Sachin Jain
On the Web site dedicated for 20 years to using data to promote better health in the United States, Sachin H. Jain, MD, MBA, wrote a commentary on the role of the national HITECH initiative to collect and exchange health information for better patient care.  Titled  “Health IT: Making Health Care Better,” Jain’s commentary appears on the 21st Edition of America’s Health Rankings®: A Call to Action for Individuals and Their Communities. Jain is special assistant to the National Coordinator for Health Information Technology.

Jain discusses using electronic health records to improve patient quality management, encourage better clincal decisions, providing health information where and when it is needed, and getting information from here to there.

To read Jain’s commentary, click here.

Blumenthal Letter #21: 2010 ONC Update [and Welcome to 2010 ONC Conference]

2010 ONC Update
Dr. David BlumenthalA Message from Dr. David Blumenthal, the National Coordinator for Health Information TechnologyDecember 10, 2010
Accessed from ONC site 12/13/2010.

The Office of the National Coordinator for Health Information Technology (ONC), the Centers for Medicare & Medicaid Services (CMS), the Office for Civil Rights (OCR), and other HHS agencies are dedicated to improving the nation’s health care through health information technology (health IT).

Since the Health Information Technology for Economic and Clinical Health (HITECH) Act was signed into law in February 2009, we have established a number of initiatives that will help make it possible for providers to achieve meaningful use and for Americans to benefit from electronic health records as part of a modernized, interconnected, and vastly improved system of care delivery.

This year alone, we have established a number of important policies and programs to help lay the foundation for providers to begin their journey toward meaningful use. These include: 

It’s been a busy year for health IT at HHS.

We are looking forward to discussing more about all of our HITECH initiatives to date, as well as our future activities, at the upcoming 2010 ONC Update Meeting on December 14 and 15.

Over the course of this two-day meeting, we are offering a number of sessions that will give participants a better understanding of the HITECH regulations and the role that HITECH plays in health system change and health care reform. Some session topics include:

  • HITECH programs that support providers in achieving meaningful use
  • How HITECH initiatives will promote consumer empowerment and public engagement
  • Privacy and security policies

Our panelists and invited speakers include HHS Secretary Kathleen Sebelius and leaders from CDC, CMS, OCR, ONC and organizations who have a stake in our work. We are excited about the opportunity to share information and ideas.

The plenary sessions at this meeting will be streamed through a live webcast. Details about the webcast are available on the ONC website: http://healthit.hhs.gov/ONCMeeting2010.

Thank you in advance for joining us at the 2010 ONC Update Meeting and for supporting our vision of a higher quality, safer, and more efficient health care system enabled by health information technology.

Sincerely,
David Blumenthal, MD, MPP
National Coordinator for Health Information Technology

The Office of the National Coordinator for Health Information Technology (ONC) encourages you to share this information as we work together to enhance the quality, safety and value of care and the health of all Americans through the use of electronic health records and health information technology.

For more information and to receive regular updates from the Office of the National Coordinator for Health Information Technology, please subscribe to  ONC’s Health IT News list.

Two New EHR Testing and Certification Labs; CHPL List shows Additional Software Required

ONC Site Reflects Changes: Additional Test Labs and Additional Software
Two new ONC-Authorized Testing and Certification Bodies (ATCBs) were authorized on December 10, 2010 to test and certify complete EHRs and EHR modules: Mechanicsburg, PA-based ICSA Labs and Denver, CO-based SLI Global Solutions.

Also, the CHPL list or Certified HIT Product List which “provides the authoritative, comprehensive listing of Complete EHRs and EHR Modules that have been tested and certified under the Temporary Certification Program” has been modified to reflect “additional software required.” While most of the additional software required impacts ambulatory systems, it also impacts a number of  Inpatient systems. Email software appears to be the most needed software. In many cases additional components by the vendor are required as well. This area of additional software needs to be further reviewed by this blog and purchasers. The latest list is dated December 4, 2010, but was accessed on December 11, 2010.

ONC-Authorized Testing and Certification Bodies
Excerpted from Office of National Coordinator for Health IT site on 12/11/2010
The following organizations have been selected as ONC-Authorized Testing and Certification Bodies (ATCBs):
  • ICSA Labs – Mechanicsburg PA
    Date of authorization: December 10, 2010.
    Scope of authorization: Complete EHR and EHR Modules.
  • SLI Global Solutions – Denver CO
    Date of authorization: December 10, 2010.
    Scope of authorization: Complete EHR and EHR Modules.
  • Certification Commission for Health Information Technology (CCHIT) – Chicago, Ill.
    Date of authorization: September 3, 2010.
    Scope of authorization: Complete EHR and EHR Modules.
  • Drummond Group, Inc. (DGI) – Austin, Texas.
    Date of authorization: September 3, 2010.
    Scope of authorization: Complete EHR and EHR Modules.
  • InfoGard Laboratories, Inc. – San Luis Obispo, CA
    Date of authorization: September 24, 2010.
    Scope of authorization: Complete EHR and EHR Modules.

The organizations listed above have been authorized to perform Complete EHR and/or EHR Module testing and certification. These ONC-ATCBs are required to test and certify EHRs to the applicable certification criteria adopted by the Secretary under subpart C of Part 170 Part II and Part III as stipulated in the Standards and Certification Criteria Final Rule.

Certification by an ATCB will signify to eligible professionals, hospitals, and critical access hospitals that an EHR technology has the capabilities necessary to support their efforts to meet the goals and objectives of meaningful use.

Learn more about ONC-ATCBs: