Today, Hall Render published an article providing some practical guidance and points for consideration when implementing an EHR donation arrangement.  Please click here to view the article.

CMS’s most recent monthly report for the EHR Incentive Program shows rapid growth in the number of Eligible Hospitals and Eligible Providers registered for the program and receiving payments under the programs.  In December, Medicare payment tripled with $89 million in payments to Eligible Professionals and $374 million in payments to Eligible Hospitals and CAHs.   Total Medicare payments for all of 2011 were $274 million for Eligible Hospitals and $1.1 billion for Eligible Hospitals and CAHs.  Additionally, the approved Medicaid programs paid out $295 million to Eligible Professionals and $853 million to Eligible Hospitals in 2011.  

Not only did the payments rapidly increase but the number of entities registering for the program also increased.  In December, 18,819 entities registered for the EHR Incentive Program bringing the total number of registered participants to 176,049. 

The full report is available on the CMS website via the link above.

Secretary of Health and Human Services, Kathleen Sebelius, announced on November 30, 2011 (See News Release) that Eligible Providers and Eligible Hospitals (“Recipients”) meeting the Stage 1 meaningful use criteria for the Medicare/Medicaid Electronic Health Records Incentive (“EHR Incentives”) established under the HITECH Act will not be required to meet the Stage 2 criteria until 2014.   The meaningful use final regulations that were published July 28, 2010 indicated that Recipients achieving meaningful use in 2011 would be required to meet the not yet published Stage 2 meaningful use criteria in 2013.  This announced change is a welcome relief to many Recipients attaining meaningful use in 2011 giving them one additional year before being required to meet the yet to be announced Stage 2 meaningful use criteria.

While the final ACO Rules (“Final Rules”) have done away with the importance of participaitng phyisicians being meaningful users of an EHR under the HITECH EHR Incentive Program (“Meaningful Users”), the importance of meaningful use by participating primary care providers has not gone away.

CMS sought to align an ACO’s use of Electronic Health Records (“EHR”) with the EHR Incentive Program in the proposed ACO rules (“Proposed Rules”).  The Proposed Rules required that 50 percent of primary care physicians be Meaningful Users by the beginning of the second performance year.  The Final Rules, however, do not require a pre-determined percentage of physicians to be Meaningful Users as an ACO condition of participation, but rather will measure the percent of primary care physicians who successfully become Meaningful Users.  This measure will be assessed on a sliding scale and CMS will weight an ACO’s performance on this measure as twice that of any other measure for scoring purposes and for determining compliance with quality performance requirements.  The Final Rules are structured to emphasize and reward an ACO who’s physicians become Meaningful Users.