HHS outlines EHR timeline under stimulus

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The Department of Health and Human Services (HHS) said that the Medicare and Medicaid health IT provisions in the American Recovery and Reinvestment Act (ARRA) are designed to promote and provide incentives for the adoption of certified EHRs.

To achieve this goal, the ARRA authorized bonus payments for eligible professionals and hospitals participating in Medicare and Medicaid as an incentive to become meaningful users of certified EHRs.

The law established maximum annual incentive amounts and includes Medicare penalties for failing to meaningfully use EHRs beginning in 2015.

The statute includes three broad criteria for demonstrating one is a "meaningful EHR user" which will be defined as the implementation process moves forward: (1) Meaningful use of certified EHR technology; (2) information exchange; and (3) reporting on measures using EHR. The statute grants the HHS Secretary discretion in defining these terms.

According to the department, sections 4101 and 4102 of ARRA provide Medicare bonus payments to eligible professionals who meaningfully use certified EHRs by calendar years 2011 to 2014 and for hospitals that meaningfully use certified EHRs by fiscal years 2011 to 2015. Starting in 2015, eligible professionals and hospitals failing to meaningfully use certified EHRs will receive reduced Medicare payments.

HHS further established these timeline milestones:
1. Coordinate with ONC to develop policies such as the definition of meaningful use;
2. Develop proposed rules to allow public input to the incentive program policies;
3. Plan systems and other requirements needed to support the incentives programs; and
4. Plan national outreach program.

1. Conduct outreach to eligible professionals and providers and to state Medicaid agencies;
2. Develop systems to support the payment of incentives;
3. Develop final rules to establish policies needed to pay incentives; and
4. Develop systems to monitor and evaluate incentive payments.

No sooner than October 2010
1. Start to pay hospital incentives for Medicare and monitor payments

No sooner than January 2011

1.Start to pay eligible professionals for Medicare and monitor payments
2.Begin and monitor Medicaid incentives payments to eligible professionals and hospitals

2011 - 2016
Continue paying hospital incentives for Medicare and monitor payments

2011 - 2016
Continue paying eligible professionals incentives for Medicare and monitor payments

2011 - 2021
Continue paying Medicaid incentives to eligible professionals and hospitals and monitor payments

2015 and thereafter
Initiate payment reductions to Medicare hospitals and eligible professionals that fail to adopt EHRs

Under the ARRA, the Centers for Medicaid & Medicare Services (CMS) was appropriated $140 million a year for FY2009 through 2015 and $65 million for FY2016 for administrative funding, (funds available until expended). Some funds assess systems to see they meet requirements of incentive program, and some funding will be used to modify, develop, implement, operate and maintain systems needed to support incentive payments to hospitals/eligible professionals.

HHS said that all ARRA programs will be assessed for risk and to ensure that appropriate internal controls are in place throughout the entire funding cycle.