Enrolling as a Meaningful User

I am now the proud member of the 100% enrollment club of the HITECH meaningful use incentive program. All this really means is that I have completed the online registration at http://cms.gov/EHRIncentiveprogram. You actually don’t even need to have implemented your EMR yet-but will need that information when completing the attestation portion of the process. What this also means is that if I jump through all of the “Meaningful Use” hoops (including the fifteen core criteria and five of the ten menu items), then I will qualify for the HITECH bonus, which can be as much as $44,000 on the Medicare side. If you qualify for the Medicaid incentive program, your potential bonus monies are $64,000, and you can receive $21,000 immediately just for installing a certified product—without even demonstrating that you know how to turn on a computer. However, in order to qualify for the Medicaid program, apparently at least 30% of you practice has to serve Medicaid patients (and the additional amount of money is the very least the government can do to compensate you for the additional layers of difficulty in trying to care for your patients).

The registration process itself is fairly quick and painless. However, before you begin, be sure that whoever is completing the registration has completed the scavenger hunt needed in obtaining the following critical pieces of information:

· Your NPPES user ID and Password. This was the system used in order to obtain your NPI number. If you do not have access to that information, a simple phone call and knowledge of everything you have ever done in your whole life will get you access to the data. Of course, if you don’t have an NPI number, now would be a very good time to get one.

· Your groupNPI number (not the individual physician NPI number)

As mentioned above, you don’t even need to have in place an EMR, making the statistic that 14,000 physicians have enrolled in the program to date meaningless in terms of how many of those will be able to demonstrate meaningful use.

Of course, after I completed my registration, which took about 15 minutes, I then watched the instructional video from my particular EMR vendor. During that video, it was emphasized at least 15 times that as a user of that software I should under no circumstances enroll in the incentive program independent of them. Apparently, enrolling users is a service they are going to provide physicians who utilize their software. In addition, they divulge “insider” information that the online registration process will become more streamlined around March. For example, in group practices, each individual provider must complete the registration process, but the updated version will include the functionality to input one group number, and all providers in that group will automatically be registered.

There is certainly no need to hurry up to enroll, since for 2011, you need to begin collecting your data by October 1, 2011. This will enable you to get the ninety days of information collected in order to qualify. Of course, the earlier you demonstrate meaningful use, the quicker your incentive monies should arrive—supposedly 15 to 45 days after submission of attestation data.

One point of confusion regarding the various available incentive programs regards the status of e-prescribing. This function is part of Meaningful Use and is also a possible activity for the PQRI incentive. Plus, there is a separate e-prescribing incentive program. Apparently, if you are enrolled in the Medicare EMR program, you can also qualify for PQRI funds, but not the e-prescibing incentive program. If you are enrolled in the Medicaid EMR program, you can still qualify for all three incentives.

In David Blumenthal’s recent video, he reported that 41% of physicians who work in a practice setting report that they intend to enroll in the incentive program (and 80% will do so within the first two years of the program), 80% of hospitals intend to participate, and 80% of these express that they intend to begin their participation within the first two years of the program. Dr. Blumenthal touts the availability of the local regional extension centers (RECS) as a resource for technical assistance for those practices without such expertise. However, their mission is to support primary care physicians, particularly those in rural areas and those practices that treat traditionally underserved populations. I doubt that as neurologists, the RECs are going to provide us with any type of support.

The $44,000 will go a long way to offset any financial investments needed for EMR implementation and Meaningful Use. However, the workflow changes required in converting your practice to entirely electronic can be challenging and disruptive. This may impact your productivity. Finally, with the legal status of Obamacare in constitutional limbo, there is a possibility that this stimulus program may get de-funded. Caveat emptor.