Louis just sent out a quick analysis of the released proposed rule, and I thought it worth repeating to our readers here. More to come…
Dear All,
For anyone who hasn’t yet heard, the final HIT Incentive Rule was released today. Below are links to the rule and other related information. My initial impression (having skimmed through parts of the 864 page rule) is that the rural message has been heard. Some of the high points include:
- CAHs are now eligible for Medicaid incentives (if they meet the 10% Medicaid utilization threshhold). Moreover, they will receive incentives based on the Acute Care Hospital (PPS) formula, which is a lump sum payment that could come close to $1,000,000 or more over a several year period.
- CPOE, while still required (and raised from a 10% to 30% requirement), has been made much easier to achieve: Orders entered by “licensed professionals” (even if they are not the ordering physician) will count toward the 30%. This is Huge, as it will allow RNs and pharmacists to enter physicians orders to meet the requirement. Only medication orders will be counted. ER orders will also now be counted.
- The CAH eligible expense definition remains unchanged. ”Depreciable costs necessary for the administration of certified EHRs” will count for the bonus. The defintion remains ambiguous. I’ve been told behind the scenes that the intention is for the CAH bonus to be expansive, but this is an area we will need to get additional clarification on.
I will be reviewing and blogging on the rule over the next several days.
Louis
