- Successfully register for the Medicare EHR Incentive Program;
- Meet meaningful use criteria using certified EHR technology; and
- Successfully attest, using CMS' Web-based system, that you have met meaningful use criteria using certified EHR technology.
Of course, meeting these requirements are not quite as straightforward as ONC leads one to believe, despite the fact that ONC has done yeoman's work in providing high quality and enormously useful content, that only gets you so far. As discussed below, eligible professionals (EP) and eligible hospitals (EH) will have to "legally attest" that the requirements have been met. This requires knowledge (and tracking) of the specific regulations that apply. Why? So that when an audit comes EPs and EHs can make a good faith argument that they have attested according to applicable law. Despite the fact that the raw data for attesting legally is contained within your EHR, your EHR software generally provides little or any guidance regarding how to meet the legal requirements. For that you need a different kind of tool and/or a much deeper understanding of the controlling regulations.
How will I attest for the Medicare and Medicaid Incentive Programs?
Medicare eligible professionals, eligible hospitals and critical access hospitals will have to demonstrate meaningful use through CMS' web-based Registration and Attestation System. In the Medicare & Medicaid EHR Incentive Program Registration and Attestation System, providers will fill in numerators and denominators for the meaningful use objectives and clinical quality measures, indicate if they qualify for exclusions to specific objectives, and legally attest that they have successfully demonstrated meaningful use. A complete EHR system will provide a report of the numerators, denominators and other information. Then you will need to enter that data into our online Attestation System. Providers will qualify for a Medicare EHR incentive payment upon completing a successful online submission through the Attestation System—immediately after you submit your results you will see a summary of your attestation, and whether or not it was successful. The Attestation System for the Medicare EHR Incentive Program will open on April 18, 2011.
For the Medicaid EHR Incentive Program, providers will follow a similar process using their state's Attestation System. Check here to see states' scheduled launch dates for their Medicaid EHR Incentive Programs: http://www.cms.gov/apps/files/statecontacts.pdf.
Looking for best of breed HIPAA Training?
To stay current on the HITECH Act and its quickly changing regulatory scheme visit the HITECH Survival Guide website and/or sign up for our free monthly compliance newsletter. Also, check out our FREE EHR Checklist.
If you need tools that will help with your compliance initiatives then check out the HSG Store. Do you need an Internet Lawyer with HITECH / HIPAA experience?