“We're now working toward actually making all of this a reality, and we have less than six months to do it,” said Karen Trudel, deputy director of the Office of E-Health Standards & Services at the CMS. Trudel gave a status report this morning to the federally chartered Health IT Standards Committee meeting on the multibillion-dollar CMS-run EHR subsidy program created under the American Recovery and Reinvestment Act of 2009.
Medicare and Medicaid providers will be able to register on the same computerized tracking system, according to Trudel. Combining both will help states coordinate their Medicaid subsidy programs with the Medicare program run by the CMS, Trudel said. The system will track providers' “attestations” that they have met the requirements of the meaningful-use section of the CMS rule as well as payments, according to Trudel.
Registrations for both office-based physicians and hospitals won't be accepted until Jan. 1, 2011, Trudel said, even though the “payment year” for hospitals begins on Oct. 1, 2010. The payment year for physicians begins Jan. 1, 2011.
To be paid their subsidies, hospitals and physicians must meet the meaningful-use standards of the rule using a certified electronic health-record system for 90 consecutive days.
So, according to Trudel, if an eligible physician or hospital completes its 90-day period in the first three months of the year and attests to having met the meaningful-use criteria “we'll be able to roll a payment out to them in May,” Trudel said.
But several questions submitted to Trudel by Health IT Standards Committee members proved problematic.
John Halamka, committee co-chairman, asked whether the reimbursements paid to office-based physicians would be counted by the Internal Revenue Service as taxable income. Trudel said that question was out of her purview. Halamka is chief information officer of Harvard Medical School and CIO of 621-bed Beth Israel Deaconess Medical Center, Boston.
Fellow committee member Judith Faulkner, founder and CEO of Epic Systems Corp., asked whether a hospital provider had to have an EHR certified throughout the entire 90-day meaningful-use period.
Faulkner said there are lots of EHR systems in place at providers. None, however, can be certified as capable of meeting the meaningful-use criteria as required by the rule to be eligible for subsidy payments because no organization has yet received authorization from HHS for certification testing.
Trudel paused to get clarification. A few minutes later, she received an answer to Faulkner's question.
“The answer is no,” Trudel said. A hospital must attest at the end of the 90-period that it had met meaningful-use criteria and had a certified system at the time of attestation, according to Trudel.
Doug Fridsma, acting director of the Standards and Interoperability Office at the Office of the National Coordinator for Health Information Technology at HHS, also gave an update at the meeting of HHS procedure to authorize certification testing bodies.
Fridsma said multiple organizations have submitted applications to be authorized to test and certify EHRs under the federal subsidy program.
“We are hoping to evaluate those as quickly as we can and get them stood up,” he said.
Faulkner asked whether he thought “we're going to make” the Jan. 1, 2011, start date by having both these certification and testing organizations and vendors with tested products in place by then.
Fridsma made no promises.
He said his hope is that having multiple testing and certifications organizations authorized will “eliminate some of the bottlenecks.” Still, he said, there will be “challenges” to get systems certified if providers “bundle” pieces of EHR systems together to achieve meaningful use, a common scenario at many hospitals.
“We are working as hard as we can to meet those timelines and get the capability in place,” Fridsma said.