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Providers may or may not meet 'meaningful-use' criteria
A Medicaid provider may have spent a great deal of time and money to adopt electronic health record (EHR) technology, but can he or she demonstrate that this tool meets the Centers for Medicare & Medicaid Services (CMS) criteria for "meaningful use"? If not, that provider won't qualify for federal incentives for EHR, enacted under the American Recovery and Reinvestment Act of 2009.
Now that CMS has issued its proposed definition of meaningful use, however, state Medicaid directors have a better idea of the challenges that lie ahead.
"CMS has spent an extraordinary amount of time and effort in seeking public comment and asking for recommendations in multiple areas," says Patricia MacTaggart, a lead research scientist/lecturer at George Washington University's Health Policy Department in Washington, DC. "So, it is expected that the detail of the regulation will change based on the anticipated large number of comments CMS will receive for both Medicare and Medicaid. The definition itself may not change, but how it is implemented may alter."
One of the core principles appears to be standardization. "This is a good thing for everyone purchasers, providers, and consumers," says Ms. MacTaggart. "CMS did an excellent job of seeking to 'stage' the process. Parameters were put around risk areas, such as the potential of double counting across state lines and between Medicare and Medicaid."
Implementation discussions have centered around three main questions that need to be answered, says Ms. MacTaggart. What if states want to require more flexibility? What about the other Medicaid providers? And what about the expectations related to timelines and "state share" of funding?
CMS is proposing a "repository" for data on meaningful use providers. For Medicaid, the first payment year requirement allows for incentives for adopting, implementing, and upgrading. There is no requirement for "meaningful use" until the following year.
CMS also has stipulated the requirements for states to follow for adopting, implementing, and upgrading. "Adopt" means to acquire and install with evidence of an acquisition of a certified EHR, "implement" refers to commencing utilization, which might include training staff or getting data-sharing agreements in place, and "upgrade" refers to using expanded functionality that will be required for a certified EHR. "States will have implementation options within those requirements," says Ms. MacTaggart.
After the initial payment year, providers will need to meet the meaningful-use definition. "Some practical issues will relate to if the adopt, implement, or upgrade is in the last three months of a payment year," says Ms. MacTaggart. "They will be eligible for payment for adopting/implementing/upgrading, but they will need to meet the meaningful use requirement for a full year the next year. Whether they can and do fully utilize this immediately is an unknown. So, there may be a year gap, which is allowed and anticipated under the proposed regulation."
Ms. MacTaggart says Medicaid agencies have three critical things they should be doing right now. First, they need to educate state staff and providers on the rules of engagement for incentives under meaningful use. "They also should be managing expectations related to timelines in order to get the infrastructure in place to support the incentive payments, management of process and oversight, and working with the regional extension centers and other federally funded technical assistance to provide providers with all the tools possible," says Ms. MacTaggart.
Contact Ms. MacTaggart at (202) 994-4227 or Patricia.MacTaggart@gwumc.edu.