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All About Meaningful Use

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Page 1: Meaningful Use example

All About Meaningful Use

Page 2: Meaningful Use example

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Table of Contents

All About Meaningful Use.............3

All About Incentives...........................4-13

All About Participation..................................14

All About IFMC HITREC.......................................15-16

In Partnership with: The Office of the National Coordinator for Health Information Technology (ONC) U.S. Department of Health and Human Services grant 90RC0004/01. IA-HITREC-11/10-158a

Page 3: Meaningful Use example

The American Recovery and Reinvestment Act of 2009 was signed into law on February 17, 2009. The law included the Health Information Technology for Economic and Clinical Health Act, or the “HITECH Act,” which established programs under Medicare and Medicaid to provide incentive payments for the “meaningful use” of a certified electronic health record. The Office of the National Coordinator for Health Information Technology (ONC) has responsibility

All About Meaningful Usefor developing standards, implementation specifications, and certification criteria for EHR technology.

On July 13, 2010, the final rule for meaningful use was released. The final rule defines the objectives that providers must meet to qualify for the meaningful use incentive payments and identifies the technical capabilities required for certified EHR technology.

The goals of the HITECH Act focus on improving the quality, safety, and efficiency of health care, reducing health disparities, engaging patients and families, improving care coordination, improving population and public health and ensuring adequate privacy and security protections for personal health information.

The HITECH Act requires the health care community to demonstrate meaningful use of EHRs to achieve the five outcomes listed below.

• Improve quality, safety, efficiency, and a reduction in health disparities

Providers will be required to attest to and/or submit data according to ONC guidelines for care goals that will be assessed through EHR-targeted quality and/or functional measures.

• Engage patients and families

Providers will be required to attest and/or submit data according to ONC guidelines that they provide patients and families with timely access to data, knowledge, and tools to make informed decisions and to manage their health.

• Improve care coordination

Providers will be required to attest and/or submit data according to ONC guidelines that they exchange meaningful clinical information among professional health care teams.

• Improve population and public health

Providers will be required to attest and/or submit data according to ONC guidelines that they communicate with public health agencies.

• Ensuring adequate privacy and security protections for personal health information

Providers will be required to attest to and/or submit data according to ONC guidelines for the protection of electronic health data created or maintained by certified EHR technology.

Goals of Meaningful Use

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Page 4: Meaningful Use example

The American Recovery and Reinvestment Act (Recovery Act) of 2009 provides for incentive payments for Medicare eligible pro-fessionals (EPs) who are meaningful users of certified electronic health record (EHR) technology. Section 1848(o)(5)(C) as added by the Recovery Act section 4101 defines the term eligible profession-al to mean a physician as defined in section 1861(r), which includes the following five types of professionals: doctor of medicine or osteopathy, a doctor of oral surgery or dental medicine, a doctor of podiatric medicine, a doctor of optometry, or a chiropractor. These professionals are eligible for incentive payments for the “meaningful use” of certified EHR technology, if all program requirements are met. Hospital-based EPs are not eligible to participate in the EHR

incentive program. An EP is considered to be hospital-based if the EP furnishes 90 percent of his or her services in a hospital inpatient or emergency room setting.

EPs may not receive EHR incentive payments from both the Medicare and Medicaid programs in the same year. In the event an EP qualifies for EHR incentive payments from both the Medicare and Medicaid programs, the EP must elect to receive payments from only one program. After an EP qualifies for an EHR incentive payment under one program but before 2015, an EP may switch between the Medicare and Medicaid programs one time. Upon switching programs, the EP will be placed in the payment year the EP would have been in had the EP not switched programs. For example, if an EP decides to switch after attesting to meaningful use of certified EHR technology for a Medicare Fee-for-Service (FFS) incentive payment for the second payment year, then the EP would be in the third payment year for purposes of the Medicaid incentive payments.

Medicare Electronic Health Record Incentive Program for Eligible Professionals

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All About Incentives – Medicare

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3

Participation in Other CMS Incentive Programs

An EP who participates in the Medicare EHR incentive program may also participate in the Physician Quality Report-ing System. However, if an EP elects to receive an EHR incentive payment through the Medicare Program, the EP is not eligible to receive an incentive payment through the Electronic Prescribing (eRx) incentive program. On the contrary, EPs who receive an EHR payment through the Medicaid Program are eligible to also receive an incentive payment through the eRx incentive program provided they meet all the requirements of the eRx program.

Fee-for-Service Medicare Incentive Payment

Incentive Payment - CalculationUnder FFS Medicare, the payment incentive amount, subject to an annual limit, is equal to 75 percent of an EP’s Medicare physician fee schedule allowed charges submitted not later than 2 months after the end of the calendar year. This means that, for 2011, the EHR incentive payment for an EP would be, subject to an annual limit, equal to 75 percent of the EP’s Medicare physician fee schedule allowed charges for CY 2011, based on claims for services performed by the EP from January 1, 2011 through December 31, 2011, and submitted to the EP’s Medicare contrac-tor (MAC/carrier) no later than February 29, 2012.

Incentive Payment - Time Frame EPs can begin receiving incentive payments in any calendar year (CY) from 2011 to 2014. EPs may receive Medicare incentive payments for up to five years, depending on the year in which the EP first becomes a meaningful user of certified EHR technology.

Medicare EPs who successfully demonstrate meaningful use and receive a Medicare EHR incentive payment in the first or second year of the incentive program (2011 or 2012) may qualify to receive payments for the full five years. However, Medicare EPs who first successfully demonstrate meaningful use for 2013 can only receive incentive pay-ments for four years and will receive less than the maximum possible incentive payment. Accordingly EPs who start participating in 2014 can only receive incentive payments for three years and will also receive less than the maximum

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incentive payment possible. An EP who first successfully demonstrates meaningful use of certified EHR technology for 2015 will not qualify for any Medicare EHR incentive payments. In addition, starting in 2015, an EP who does not successfully demonstrate meaningful use of certified EHR technology use will be subject to reduced physician fee schedule payments.

Medicare EHR incentive payments will be made on a rolling basis after CMS has ascertained that the EP met mean-ingful use for the reporting period and the EP has met the maximum allowable charges threshold. In the event that the EP does not meet the maximum allowed charges threshold by the end of the calendar year, payment will be made following the deadline to submit claims for the period.

Incentive Program - Annual LimitsEPs who successfully demonstrate meaningful use of certified EHR technology during the relevant EHR reporting period may be eligible for an incentive payment amount, subject to an annual limit, equal to 75 percent of the EP’s Medicare allowed charges submitted not later than two months after the end of the calendar year. Table 1 illustrates the maximum incentive payments an EP can receive by year and the total incentive payments possible if an EP suc-cessfully demonstrates meaningful use and qualifies for an incentive payment each year. As shown, the total amount of the incentive payment an EP can receive is dependent in part on the year in which the EP successfully demon-strates meaningful use.

Health Professional Shortage AreaSection 1848(o)(1)(B)(iv) of the Act provides that the amount of the annual EHR incentive payment limit for each pay-ment year be increased by 10 percent for EPs who predominantly furnish more than 50 percent of services in an area that is designated by the Secretary (under section 332(a)(1)(A) of the PHS Act) as a geographic health professional shortage area (HPSA). CMS will use the frequency of services provided over a one-year period from January 1 to December 31 rather than allowed charges to determine if an EP qualifies for an HPSA bonus. EPs who predominantly furnish services in an HPSA who do not accrue the maximum allowed charges will be paid according to the statutory formula at 75 percent of the allowed charges.

Calendar YearMaximum Incentive Payments Based on the First CY

in Which an EP Participates in the Program2011 2012 2013 2014

2011 $18,0002012 $12,000 $18,0002013 $8,000 $12,000 $15,0002014 $4,000 $8,000 $12,000 $12,0002015 $2,000 $4,000 $8,000 $8,0002016 $2,000 $4,000 $4,000Total $44,000 $44,000 $39,000 $24,000

Table 1: Maximum Incentive Payments Based on the First CY in Which an EP Participates in the Program

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Table 2 shows the maximum incentive payments for EPs who qualify for the higher HPSA limit.

Payment Adjustments Beginning in 2015If an EP does not successfully demonstrate meaningful use of certified EHR technology, the EP’s Medicare physician fee schedule amount for covered professional services will be adjusted by the applicable payment adjustment speci-fied in the Recovery Act beginning in 2015. The payment adjustments will be as follows:

• 2015—99 percent of Medicare physician fee schedule covered amount• 2016—98 percent of Medicare physician fee schedule covered amount• 2017 and each subsequent year—97 percent of Medicare physician fee schedule covered amount

If it is determined that for 2018 and subsequent years that less than 75 percent of EPs are meaningful users then the payment adjustment will change by one percentage point each year until the payment adjustment reaches 95 percent.

The Recovery Act allows for a hardship exception, which, if applicable, could exempt certain EPs from the payment adjustment. The exemption is subject to annual renewal, but in no case will a hardship exemption be given for more than five years. Note: More information on payment adjustments and the requirements to qualify for a hard-ship exemption will be provided in future rulemaking prior to the 2015 effective date.

Medicare Advantage (MA) Incentive Payments

Section 1853(I)(1) of the Act, as added by the Recovery Act, also provides for incentive payments to qualifying MA organizations (MAO) for their affiliated EPs who are meaningful users of certified EHR technology. Specifically an MA EP as defined by section 1853(l)(2) of the Act, as added by the Recovery Act must either:

• Furnish, on average, at least 20 hours/week of patient-care services and be employed by the qualifying MAO or• Be employed by, or be a partner of, an entity that through contract with the qualifying MAO furnishes at least 80

percent of the entity’s Medicare patient care services to enrollees of the qualifying MAO

Calendar YearMaximum Incentive Payments for an EP Who Qualifies for an HPSA Bonus Payment

Based on the First CY in Which the EP Participates in the Program2011 2012 2013 2014

2011 $19,8002012 $13,200 $19,8002013 $8,800 $13,200 $16,5002014 $4,400 $8,800 $13,200 $13,2002015 $2,200 $4,400 $8,800 $8,8002016 $2,200 $4,400 $4,400

Total $48,400($4,400 increase)

$48,400($4,400 increase)

$42,900($3,900 increase)

$26,400($2,400 increase)

Table 2: Maximum Incentive Payments for an EP Who Qualifies for an HPSA Bonus Payment Based on the First CY in Which the EP Participates in the Program

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If an MA EP meets these guidelines and the MAO can attest that the MA EP is a meaningful user of certified EHR technology the MAO can receive an incentive payment in accordance with Table 3. Similar to the Medicare FFS incentive program MA organizations are not eligible for incentive payments for hospital based EPs.

Section 1853(l)(3)(B) of the Act, as added by the Recovery Act, specifically states that duplicate payments may not be made for EPs eligible for both the FFS incentive payment and the MA incentive payment. Section 1853(l)(3)(B)(I) says that if an EP is eligible to receive an incentive payment from both the Medicare FFS and MA programs, the Medicare

Calendar YearMaximum Incentive Payments Based on the First CY in Which

the MAO EP Participates in the Program2011 2012 2013 2014

2011 $18,0002012 $12,000 $18,0002013 $8,000 $12,000 $15,0002014 $4,000 $8,000 $12,000 $12,0002015 $2,000 $4,000 $8,000 $8,0002016 $2,000 $4,000 $4,000Total $44,000 $44,000 $39,000 $24,000

Table 3: Maximum Incentive Payments Based on the First CY in Which the MAO EP Participates in the Program

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FFS payment will be made first but only if it is for the maximum amount due for that payment year. Therefore, before a payment can be made to a qualifying MAO for an EP, CMS will determine if that EP has already been paid the maxi-mum for that year through the Medicare FFS Program. If the EP received the maximum incentive payment available for that payment year from the Medicare FFS Program then the MAO would not be eligible to receive an MA incentive payment for that EP for that payment year.

If, however, the EP did not receive the maximum possible incentive payment possible for the payment year, then the MAO will receive the incentive payment solely through the MA incentive program. Payment solely under the MA pro-gram for EPs who qualify for incentive payments under both FFS and MA, but who did not earn the maximum bonus under FFS, is required by section 1853(l)(3)(B)(II) of the Act.

Additional Resources

For more information on the EHR incentive program, see http://www.cms.gov/EHRIncentivePrograms/ on the CMS website.

ICN# 903695 (November 2010)

This fact sheet was prepared as a service to the public and is not intended to grant rights or impose obligations. This fact sheet may contain references or links to statutes, regulations, or other policy materials. The information provided is only intended to be a general summary. It is not intended to take the place of either the written law or regulations. We encourage readers to review the specific statutes, regulations, and other interpretive materials for a full and accurate statement of their contents.

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Medicaid Electronic Health Record Incentive Payments for Eligible Professionals

The American Recovery and Reinvestment Act (Recovery Act) of 2009 provides for incentive payments for Medicaid eligible professionals (EPs) who adopt, implement, upgrade, or meaningfully use certified electronic health record (EHR) technology in their first year of participation in the program and successfully demonstrate meaningful use in subsequent years. Section 1903(t)(3)(B) of the Recovery Act defines the term eligible professional to mean the fol-lowing five types of Medicaid professionals: Physicians, dentists, certified nurse-midwives, nurse practitioners, and physician assistants practicing in an Federally Qualified Health Center (FQHC) or a Rural Health Clinic (RHC) led by a physician assistant. Hospital-based EPs are generally not eligible to participate in the EHR incentive program. The only exception is that Medicaid EPs practicing predominately in an FQHC or RHC are not subject to the hospital-based exclusion. Note: The definition of a hospital-based EP is included in the final regulation CMS issued on July 13, 2010.

EPs may not receive EHR incentive payments from both the Medicare and Medicaid programs in the same year. In the event an EP qualifies for EHR incentive payments from both the Medicare and Medicaid programs, the EP must elect to receive payments from only one program and may only switch between the two programs once prior to 2015 after receiving an incentive. Furthermore, an EP who selects Medicaid must only receive incentive payments from one state in any payment year. Note: Details about program election are included in the final regulation CMS issued on July 13, 2010.

In addition, in contrast to the Medicare EHR Incentive Program, EPs who receive an EHR incentive payment through the Medicaid Program may also be eligible to receive an incentive payment through the Medicare eRx Incentive Program provided they meet all the requirements of the eRx Program.

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All About Incentives – Medicaid

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Incentive Payment – Medicaid Patient Volume Requirements

To be eligible to participate in the Medicaid EHR Incentive Program, an EP must either: (1) Meet certain Medicaid patient volume thresholds or (2) practice predominantly in an FQHC or RHC where 30 percent of the patient volume is derived from needy individuals.1 One exception to this rule is that a pediatrician may have at least 20 percent Med-icaid patient volume and still qualify but at a reduced incentive.

Table 1 demonstrates the above-referenced patient volume thresholds per provider type.

Table 1: Patient Volume Thresholds per Provider Type

Entity Minimum Medicaid Patient Volume Threshold (percent) Or the

Medicaid EP practices

predominately in an FQHC or RHC with a 30 percent “needy

individual” patient volume

threshold

Physician 30 Pediatrician 20

Dentist 30 Certified nurse-midwife 30

Nurse practitioner 30 Physician assistant when practicing

in an FQHC/RHC led by a physician assistant

30

Incentive Payment - Patient Volume Calculation

The Medicaid patient volume methodology will be designated by the State Medicaid Agency and approved by CMS. Note: The final rule describes acceptable methods for estimating patient volume. In determining patient vol-ume thresholds, EPs should include individuals enrolled in Medicaid managed care organizations, prepaid inpatient health plans, prepaid ambulatory health plans, and Medicaid medical home programs or Primary Care Case Management.

1 Section 1903(t)(3)(F) of the Act defines needy individuals as individuals meeting any of the following three criteria: (1) They are receiving medi-cal assistance from Medicaid or the Children’s Health Insurance Program (CHIP); (2) they are furnished uncompensated care by the provider; or (3) they are furnished services at either no cost or reduced cost based on a sliding scale determined by the individual’s ability to pay.

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Incentive Payment - Timeframe

The EHR Incentive Program is voluntary for state Medicaid agencies. In other words, if a state decides to opt out of the incentive program, EPs in that state will be unable to receive an incentive payment through Medicaid. State Medicaid agencies may begin offering a program as early as January 2011. The last year to begin participating in the Medicaid EHR Incentive Program is 2016. EPs may receive Medicaid EHR incentive payments for up to six years; 2021 is the final year for Medicaid EHR incentive payments.

Incentive Program - Payment Amounts

EPs, who adopt, implement, upgrade, or meaningfully use certified EHR technology in their first year of participation in the program and successfully demonstrate meaningful use in subsequent years may be eligible for an incentive payment of $21,250. In subsequent years of payment a Medicaid EP’s incentive payment will be limited to $8,500.

Pediatricians who meet the 30 percent patient volume requirement may qualify to receive the maximum incentive payments. Incentive payments for pediatricians who meet the 20 percent Medicaid patient volume but fall short of the 30 percent Medicaid patient volume are reduced to two-thirds of the incentive payment. This means some pediatri-cians may receive $14,167 in the first year and $5,667 in subsequent years.

Table 2 illustrates the maximum Medicaid EHR incentive payments an EP can receive by year and the total incentive payments possible if an EP successfully qualifies for an incentive payment each year.

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Table 2: Medicaid EHR Incentive Payments by Calendar Year

Year Medicaid EPs Who Adopted In

2011 2012 2013 2014 2015 2016 2011 $21,250 2012 $8,500 $21,250 2013 $8,500 $8,500 $21,250 2014 $8,500 $8,500 $8,500 $21,250 2015 $8,500 $8,500 $8,500 $8,500 $21,250 2016 $8,500 $8,500 $8,500 $8,500 $8,500 $21,250 2017 $8,500 $8,500 $8,500 $8,500 $8,500 2018 $8,500 $8,500 $8,500 $8,500 2019 $8,500 $8,500 $8,500 2020 $8,500 $8,500 2021 $8,500 Total $63,750 $63,750 $63,750 $63,750 $63,750 $63,750

Note: The total for pediatricians who meet the 20 percent patient volume but fall short of the 30 percent patient volume is $14,167 in the first year and $5,667 in subsequent years. This adds up to a maximum Med-icaid EHR incentive payment of $42,500 over a six-year period.

Additional Resources

For more information on the EHR incentive program, see http://www.cms.gov/EHRIncentivePrograms/ on the CMS website.

Pub# 954759, ICN# 904763 (November 2010)

This fact sheet was prepared as a service to the public and is not intended to grant rights or impose obligations. This fact sheet may contain references or links to statutes, regulations, or other policy materials. The information provided is only intended to be a general summary. It is not intended to take the place of either the written law or regulations. We encourage readers to review the specific statutes, regulations, and other interpretive materials for a full and accurate statement of their contents.

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All About Participation – How to RegisterHow to Qualify

The CMS Web site outlines how providers may qualify for incentive payments. Meaningful use requirements must be met in the following ways:

• Medicare EHR incentive program - Eligible professionals and hospitals must successfully demonstrate meaningful use of certified electronic health record technology every year they participate in the program.

• Medicaid EHR incentive program - Eligible professionals and hospitals may qualify for incentive payments for the adoption, implementation, upgrade or the demonstration of meaningful use in their first year of participation. They must successfully demonstrate meaningful use for the remaining years they participate in the program.

More specific information on eligibility can be found at www.cms.gov/EHRIncentivePrograms. Click on “Eligibility - Eligible Professionals”.

How to Register

The Medicare EHR Incentive Program will begin in early 2011. Registration for the Medicare program will be available starting on January 3, 2011. The Medicaid EHR Incentive Programs can also begin in 2011, but actual start dates will vary by State. There are several steps professionals should take to be prepared for registration when it is made available.

Step 1:Be enrolled in Medicare FFS, MA, or Medicaid (FFS or managed care).

Step 2:Have a National Provider Identifier (NPI). For more information on applying for an NPI, visitwww.cms.gov/NationalProvIdentStand.

Step 3:Use certified EHR technology. Medicaid providers may adopt, implement, or upgrade in their first year. For a listing of Complete EHRs and EHR Modules that have been tested and certified under the Temporary Certification Program, visit onc-chpl.force.com/ehrcert.

Step 4:All Medicare providers and Medicaid eligible hospitals must be enrolled in PECOS .

For more information on PECOS, visit www.cms.gov/EHRIncentivePrograms and click on “Registration and Attestation”. You can download the Medicare EP PECOS Notification PDF posted under Downloads on that page.

Step 5:Register via the EHR Incentive Program Web site when available, by visiting www.cms.gov/EHRIncentivePrograms and clicking on “Registration and Attestation”.

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All About IFMC HITREC

IFMC HITREC is one of a select group of organizations in the U.S. designated as having the experience and capacity necessary to assist health care providers with electronic health records.

For providers who do not currently have an EHR system, IFMC HITREC will help you choose and implement one in your office.

For providers who already have a system, we can help you meet the

criteria for incentive payments from Medicare or Medicaid for the meaningful use of EHRs.

The Trusted Advisor in Health IT

What is IFMC HITREC? An independent, non-profit

organization, providing technical assistance, guidance, and information to support and accelerate providers’ efforts to become meaningful users of certified EHR technology

Experienced local health information technology and quality improvement professionals with intimate knowledge of the Iowa medical community

Part of a national network of 62 regional extension centers with direct, rapid and reliable access to a pipeline of key information on health IT and meaningful EHR use

Works in partnership with the Iowa/Nebraska Primary Care Association and INConcertCare, Inc. to service community and rural health centers.

IFMC HITREC 1776 West Lakes Parkway, West Des Moines, IA 50266

Phone: 800.373.2964

Visit us online at www.iowahitrec.org

We are here to help.

Helping you achieve success with electronic health records.

What do we offer? Support through every step. IFMC HITREC is a support and resource center making the implementation or upgrade of EHRs easier for providers throughout the process. Ultimately, our aim is to help increase quality of care for patients, overall productivity, and improve the quality of work/life balance for you by helping providers achieve meaningful use of EHR systems. Our core service areas include: EHR implementation and project

management Meaningful use gap analysis and

action plans Practice assessments at every step

of the process Practice/workflow redesign HIT education and training Vendor selection & financial

consultation Privacy and security Partnering with state and national

health information exchange Ongoing technical assistance

Why participate? The time to act is NOW! Our priority is helping providers understand and take advantage of the full benefits of EHRs. We offer solutions that will enable providers to: Improve patient safety and quality

of care while reducing costs associated with medical errors, duplicate tests, and administering paper records and claims

Easily navigate the EHR vendor marketplace by having supported access to recommended certified systems

Use EHRs in a meaningful way so that patient information is available when and where it is needed, and care is coordinated across provider teams

Achieve EHR meaningful use objectives from the very beginning, maximizing incentives and minimizing burdens associated with implementing new electronic systems

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All About IFMC HITREC – Who Qualifies for REC Services?

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• Primary Care Practices with 10 or fewer professionals with prescriptive privileges

• Public & Critical Access Hospitals providing primary care

• MDs, DOs, NPs, PAs, in the specialties of Internal Med, Family Practice, Pediatrics, OB/GYN and Geriatrics

• Community & Rural Health Centers that predominantly serve the uninsured, underinsured and medically

underserved

All About IFMC HITREC – Pricing and Services

Milestones Services Selected Vendors*

All Other Vendors

Milestone 1 Assessment

& Planning

• MU understanding Assessment:

• EHR readiness assessment • EHR goal setting • Practice profile • Office staff survey • Workflow process mapping

• Review assessments Planning:

• Define EHR goals • Identify target improvement

opportunities • Discuss change management

strategies • Perform MU goal setting

$510** $510**

Milestone 2

EHR Selection &

Implementation

• Provide EHR preferred vendor list and advise on selection process

Selection:

• Begin to prepare staff and office for EHR system

• Educate practice in change management concepts

• Utilize project tools and optimize shared learning

• Facilitate communications between clinic and vendor(s)

• Prepare staff and office for EHR implementation

Implementation:

• Assist clinic in holding vendors accountable for hardware and software installation and configuration timelines

• Proactively monitor MU components of implementation and vendor training

$410** $860**

Milestone 3 Evaluation

& Improvement

• Conduct post “go live” review of implementation process

Evaluation:

• Conduct MU and EHR implementation analysis

• Perform MU gap analysis • Conduct MU reporting analysis • Post-implementation electronic

workflow analysis • Utilize project tools and optimize

shared learning

• Review EHR impact analysis Improvement:

• Refine electronic workflow for efficiency and MU

• Identify additional care management process improvement opportunities

$305** $455**

*Selected Vendors Include: AllScripts, eMDs, eClinicalWorks, SuccessEHS, Inc., Greenway Medical Technologies, McKesson **Term Pricing (Effective Date through February 7, 2012). One time fee per provider FTE.