Terry Ketchersid, MD, MBA
It has been just over two years since the President signed the American Recovery and Reinvestment Act of 2009.
 
A not so minor footnote within this statute is the HITECH Act, which put over $19 billion of financial incentives on the table for hospitals and eligible providers that are able to demonstrate meaningful use of a certified electronic health record (EHR). A lot of work has taken place in the last two years, and the first wave of providers is now in the midst of demonstrating meaningful use. Health IT Services Group has been the market leader in nephrology-specific EHR, and in this article I will share some lessons we have learned in the course ofour implementation.

Fundamentally, the EHR incentive program consists of three sequential steps:
1) implement a certified EHR, 2) use the EHR to demonstrate meaningful use, and 3) attest to CMS that you have done so. Most of the heavy lifting occurs in step 2, which will be the focus of this review (but that’s not to say step 1 is a walk in the park). I am going to assume you are already using a certified EHR, so the challenge is to demonstrate that you are a meaningful user in the eyes of CMS. For those of you still looking for an EHR, CMS has created a website that displays every certified EHR.
This list, which is updated weekly, is known as the Certified Health IT Product List (CHPL) and can be found here: http://onc-chpl.force.com/ehrcert.

With certified EHR technology in place, you are now ready to demonstrate meaningful use. There are three important items to consider before you start. First, are you a “hospital-based” provider? CMS defines such individuals as providers who render at least 90 percent of their care in a location defined by CMS billing POS codes 21 or 23 (hospital inpatient and emergency room, respectively). Hospital-based providers are not eligible for the CMS EHR incentive program, but neither are they subject to the financial penalties set to begin in 2015.

Second, when you register you will have the option of selecting one of three paths to take: Medicare fee for service (FFS), Medicare Advantage (MA), or Medicaid. All nephrologists who have cleared the hospital-based hurdle above should generally qualify through the Medicare FFS track. The Medicare Advantage track requires a substantial amount of your care be delivered through a single MA plan—a very unlikely scenario for the typical nephrologist. So your decision will most likely come down to the Medicaid or Medicare FFS program.