If meaningful use of an electronic health record (EHR) system is something your otolaryngology practice has not yet begun to tackle, Michael Koriwchak, MD, attending physician at Ear, Nose and Throat of Georgia in Atlanta and author of the blog “Wired EMR Practice,” has some welcome news: There’s still time.
The financial incentives set by the Centers for Medicare and Medicaid Services (CMS) EHR Incentive Programs—meaningful use—use bonus payments and financial penalties as a carrot-and-stick motivator to promote the use of EHRs in clinical care settings. Most of the country’s roughly 9,200 otolaryngologists are eligible for both the bonus and the censure, according to the American Academy of Otolaryngology-Head and Neck Surgery (AAO-HNS).
Otolaryngology practices that have not begun attempting to demonstrate meaningful use of EHRs must begin reporting data by October 1 of this year to meet a CMS regulation requiring 90 consecutive days of data. Eligible professionals (EPs) have until February 28, 2014 to register and attest to receive the incentive payment based on that data. Those who report on 2013 data will see a bonus of up to $12,000 per physician, while those who don’t report any data will face a 1 percent reduction in their Medicare Physician Fee Schedule (PFS) payments in 2015.
Don’t Panic
Dr. Koriwchak cautioned that while there is still time to earn incentives and avoid the initial 1 percent penalty, practice leaders should move carefully. EHR adoption is tricky, he said, and rushing the process to avoid a one-time, 1 percent reduction might be foolhardy for practices that have yet to even purchase a system certified by the Office of the National Coordinator for Health Information Technology.
“For a practice that has not started looking at EMRs [electronic medical records] yet, I would take the 1 percent penalty in a heartbeat,” he said. “My advice to practices right now is to take your time and do this right. To buy yourself a year costs you 1 percent of your Medicare revenue. If Medicare is 25 percent of your revenue, and you lose 1 percent of that, it’s only 0.25 percent of your total revenue. So run the numbers and find out how much that is. Even if it’s $15,000 or $20,000, that is far less money than it will cost you if you spend $100,000 on a system and it’s a disaster because you chose in haste or implemented poorly.”
Dr. Koriwchak’s practice was an early adopter, but he understands why there are practices that have taken their time. There are three stages of meaningful use, and only Stage 1 is currently active. EPs, hospitals and critical-access hospitals don’t have to qualify for Stage 2 until next year, and Stage 3 is set to begin in 2016. (See “The ABCs of EHRs,” p. 12). CMS penalties for noncompliance climb to 2 percent of PFS payments in 2016 (based on 2014 reporting data) and max out at 3 percent in 2017 (based on 2015 reporting).
“Now is a good time to look at systems, but don’t panic,” added Dr. Koriwchak. “EMR brings huge cultural and operational changes to your practice. You can’t rush the cultural change, you can’t rush the decision making and you can’t rush the acquisition of necessary skills for the docs and the staff. If you move too fast, you’re going to have an expensive disaster on your hands.”
David Nielsen, MD, executive vice president and chief executive officer of AAO-HNS, said practices must look at meaningful use requirements in the context of the broader, generational health care reform initiatives the federal government is pushing.
Meaningful use “is not being implemented in a vacuum, or even in an otherwise stable system,” he said. “One of the great challenges facing otolaryngologists in complying with [the] requirements is the needed harmonization between multiple ongoing reward/penalty programs through CMS in which they are required to participate. These include electronic prescribing, reporting on quality measures for PQRS and the value-based purchasing modifier being developed, which will require physicians to report on quality and cost in the near future.”
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Use Your Voice
Subinoy Das, MD, director of The Ohio State University Sinus and Allergy Center in Columbus and chair of the AAO-HNS Medical Informatics Committee, said many small or rural practices have not moved quickly on EHR adoption because of the cost and perceived associated issues. “The problems with EMR implementation are poor interoperability, decreased ability to efficiently find valuable medical information to make medical decisions, poor interpersonal communication and a significant increase in junk documentation specifically for billing purposes,” he added.
But Dr. Das said that despite their problems, EHRs are quickly becoming mandatory, as the government uses them as a repository from which to mine data it will use to push quality measures. The key for otolaryngologists at this point is to lobby for core measures that are more relevant to the specialty, because the current lists of objectives are more broad-based. AAO-HNS continues to lobby CMS, but, Dr. Das said, the more voices they hear, the stronger the message.
“As a specialist, when we spend a lot of the appointment either looking at a computer screen, checking off boxes that are unnecessary or irrelevant to the appointment, or even if we’re asking questions that have very low relevance to the appointment … it disenfranchises you from the care of your patients,” he said. “Your patients notice all of this. It really harms the patient-physician relationship in subtle but very important ways. So, having quality measures that are relevant to the practice of medicine that you perform is very important.”
Meaningful Use: Q&A with the AAO-HNS
ENTtoday asked the AAO-HNS what otolaryngologists need to know about demonstrating meaningful use of a certified EHR system
ENTtoday: Are most otolaryngologists eligible for health information technology incentives and thus subject to the meaningful use requirements?
AAO-HNS: All doctors of medicine or osteopathy are eligible under the program. There are exemptions to the program that doctors can apply for on an annual basis through the CMS website. Additionally, hospital-based eligible professionals are not eligible for incentive payments. An eligible professional is considered hospital-based if 90 percent or more of his or her services are performed in a hospital inpatient (Place of Service code 21) or emergency room (Place of Service code 23) setting.
Q: What are the deadlines otolaryngologists need to be aware of?
A: If 2013 is the first year an otolaryngologist is participating in the EHR Incentive Program, participants report data for any 90 continuous days in 2013. This means that if this is your first year, you must begin reporting data by October 1 of this year. February 28, 2014 will be the last day for Medicare-eligible professionals to register and attest to receive an incentive payment for data collected in calendar year 2013.
In 2014, according to CMS, all providers, regardless of their stage of meaningful use, are only required to demonstrate meaningful use for a three-month EHR reporting period. For Medicare providers, this three-month reporting period is fixed to the calendar year (for EPs) in order to align with existing CMS quality measurement programs, such as the Physician Quality Reporting System (PQRS). CMS is permitting this one-time three-month reporting period in 2014 so that all providers who must upgrade to 2014 certified EHR technology will have adequate time to implement their new EHR systems.
Q: Are there any specific rules that apply to otolaryngologists?
A: Unfortunately, there are no specific rules. The Academy has advocated through comments to CMS for the agency to consider specialty physicians when determining reporting requirements and will continue to do so.
Q: Does AAO-HNS have any suggestions on core measures, menu measures and clinical quality measures that are particularly applicable to or achievable for otolaryngology providers and groups?
A: The AAO-HNS Medical Informatics Committee provides guidance on five menu set items that may be the least difficult for otolaryngologists to comply with, including:
- generating a list of patients with a specific diagnosis;
- using the EHR to provide patient-specific education resources;
- performing one test to submit data to an immunization registry (not applicable if the registry is unable to receive information electronically);
- performing one test to submit data to a public health agency (not applicable if the agency is unable to receive information electronically); and
- providing a summary of care record if transferring care to another provider.
Recommended clinical quality measures for otolaryngology include but are not limited to:
- Core measures: blood pressure, tobacco screening and adult weight (already required in core objectives).
- Additional measures: appropriate testing for children with pharyngitis, pneumonia vaccination status for older adults, asthma assessment.
Q: How many otolaryngologists have met Stage 1 requirements for the initial 90-day period or the initial one-year period?
A: Data from a 2012 Government Accountability Office report show that in 2011, 14.1 percent of otolaryngologists successfully attested to meaningful use and received an incentive payment. Monthly reports are published by CMS showing the total number of active registrants in the Medicare and Medicaid programs and total physicians paid by specialty. As of February 2013, a total of 3,416 otolaryngologists have received a total of $59,309,447 in incentive payments since the program began, for an average total of more than $17,000 per physician.
Q: Where can members get more information?
A: Visit entnet.org and click on Regulatory and Socioeconomic Advocacy on the lefthand side of the Practice & Advocacy page, and go to “Electronic Health Records and Meaningful Use.”