There has been a great deal of discussion, and conflicting guidance relating to “The American Recovery and Reinvestment Act 2009”, specifically the section known as the Health Information Technology for Economic and Clinical Health Act (HITECH Act).
In particular there has been conflicting discussion about the availability of Medicare bonus payments, beginning in 2011, that would be paid to hospitals and physicians that adopt and use qualifying health IT”. These Bonus payments reimburse eligible providers up to $41,000 for qualified EHR. The conflicting discussions have been ‘whether or not these funds are available to outpatient rehabilitation practices’.
The Department Of Health And Human Services has defined the previously vague terms of ‘Qualified HER’, ‘Certification Requirements’ and ‘Eligible Providers’ in 45 CFR Part 170 RIN 0991-AB58 Health Information Technology: Initial Set of Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology 1
Long story short , the best translation of the definition of ‘eligible providers’ we’ve found is “a physician as defined in Section 1861 ® of the Social Security Act: Doctor of Medicine or Osteopathy, Doctor of Dental Surgery or Dental Medicine, doctor of Podiatric Medicine, Doctor of Optometry or Chiropractor.” 2
‘Sad to say, Outpatient Rehab has not been invited to the $41,000 EHR reimbursement party.
Today, Outpatient Rehab practices are not eligible for the ARRA HITECH bonus payments.
Next subject, certification: There has been a lot of conflicting discussion about CCHIT certification. Some sources advise, ‘Don’t buy software unless it is CCHIT certified’.
Pertinent Facts:
1. www.hipaasurvivalguide.com/downloads/45-CFR-Part-170.pdf
2. http://h184435wp.setupmyblog.com/2010/01/cms-excludes-%E2%80%9Cprovider- based%E2%80%9D-clinics-from-all-ehr-incentives/
3. www.hipaasurvivalguide.com/downloads/45-CFR-Part-170.pdf
Recently, the Senate passed an amended HR 4851, the Continuing Extension Act . This legislation prevents the 21.2% Medicare fee schedule payment cut by extending 2009 rates until May 31, 2010, and is retroactive to March 31.
We’ve dodged the bullet for now. But the issue has not been resolved. This specific threat of lowered reimbursements has not gone away. This 21.2% reduction in the Medicare fee schedule referenced above has been debated and delayed by congress for years.
New threats to reimbursements are on the horizon that you need to be aware of. The HITECH act discusses further healthcare reimbursement cuts in 2011, 2012 and beyond.
Quoting directly form the HITECH Act: 4
(Savings from EHR).... “would reduce Medicare spending by $4.4 billion over the 2011-2019 period”.... .... The CBO expects that state Medicaid programs and private insurance plans would negotiate payment rates with providers that would enable those payers to realize most of the savings from reductions in providers’ operating costs...
.....Because accelerating the use of health IT would lower health care costs for private payers, it would result in lower health insurance premiums in the private sector. As a result, private employers would pay less of their workers’ compensation in the form of tax-advantaged health insurance premiums and more in the form of taxable wages and salaries.....
As written, the HITECH Act, is nothing short of a “silver bullet” for some of our society’s most challenging issues. The HITECH Act promises to:
Regardless of whether or not you believe these benefits will be delivered, the voting public is being promised more for less. We can anticipate strong public support.
4. www.cbo.gov/doc.cfm?index=9966
Systems4PT’s Recommendation: Anticipate market changes. And make a plan to succeed even in tomorrow’s changing environment.
Important point: Do the math for your practice – Because the government already has:
Tomorrow’s lower reimbursement rates will not pay for today’s manual, paper based workflow. The solution is not to “do more tasks on computers”, you are being forced to “eliminate tasks with computers”.
Let’s be more specific. Compare your practice overhead to these metrics:
The practice owner should calculate the financial impact that these efficiencies would have on overhead costs. Hard work, combined with a state of the art system will deliver these levels of efficiency. Today, these moves increase cash flow and profitability. Tomorrow – They’ll just ‘keep you even’ as reimbursement rates are lowered.
Medicare’s PQRI reimbursement program rebates 2% of Medicare payments. These rebates will typically pay for more than half of an integrated E.H.R. system’s cost. Ah ha! There is free money for you as well!
And let’s not loose site of the forest for the trees:
The U.S. Beuro of labor statistics have forecasted a 28% increase in U.S. healthcare patient demand during the next ten years. 5
Under the assumption of universal government healthcare, this forecast jumps to a 40% increase in patient demand. 5
We are blessed to be in a demographic-driven, growth industry. But to thrive – the practice owner needs to plan today, for tomorrow’s reimbursement trends.
5. http://bhpr.hrsa.gov/healthworkforce/reports/changedemo/