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Under the new Electronic Health Records (EHR) Incentive Program created under the American Recovery and Reinvestment Act (ARRA), a majority of anesthesiologists will be deemed “eligible professionals” and thus theoretically eligible to receive the incentive payments for the “meaningful use” of EHRs. The full incentive payments would be $44,000 per physician if they meet the meaningful use requirements beginning in 2011 or 2012. If a physician does not begin meaningfully using an EHR, payment penalties will begin in 2015.
Under the program there are two categories of professionals, “hospital-based eligible professionals” and “eligible professionals.” Hospital-based eligible professionals, despite the name, are actually not eligible to receive the incentive payments (and are exempt from future penalties) because the thinking was that they would use their hospital’s EHR. To be deemed a hospital based eligible professional, one needs to provide 90% or more of their covered services in an inpatient or emergency room setting. This is determined by looking at the place of service codes (POS codes) on all the codes one submits under Medicare (21 for inpatient and 23 for ER). The majority of anesthesiologists do not provide 90 percent or more of their covered services in the inpatient or ER setting unless one exclusively does cardiac, transplant or critical care work, which is rare. The majority of the codes submitted by anesthesiologists are for work done in the outpatient, ASC or office-based setting and therefore, by definition, most anesthesiologists will be deemed “eligible professionals” and thus technically eligible to receive the incentive payments.
In order to receive the incentive payments one needs to meaningfully use a “certified EHR.” Because anesthesiologists were not initially intended to be deemed “eligible professionals,” the meaningful use requirements do not necessarily reflect the practice of anesthesiology and thus it will be difficult for anesthesiologists to achieve meaningful use based on the current requirements. In addition, at this time there are very few, if any, certified Anesthesia Information Management Systems (AIMS) out there and it is unclear whether all vendors will seek certification as they are waiting for some guidance as well. There are also questions of whether an anesthesiologist would need to use a combination of a hospital’s EHR and an AIMS system to meet meaningful use or whether they could simply use an AIMS and be exempt from the other requirements.
ASA staff has brought this problem to the attention of both CMS and the Office of National Coordinator (ONC). Currently, they have their hands full with trying to implement the program for the majority of eligible professionals and anesthesiologists are not at the top of their priority list at the moment. ASA is hoping that CMS will come out with some guidance for anesthesiologists as to how they can achieve meaningful use and receive the incentive payments or, at the very least, have hospitals obtain credit for the use of AIMS while allowing anesthesiologists to avoid penalties. ASA staff has been and will continue to push them to do so.
For more information please visit http://www.cms.gov/EHRIncentivePrograms/.
