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How does Meaningful Use impact health IT for oral health?

On July 28, 2010, the U.S. Department of Health and Human Services (HHS) announced the Final Rule on the Initial Set of Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology and the Final Rule on the Electronic Health Record Incentive Program.  These documents set forth the directives for implementing the provisions of the American Recovery and Reinvestment Act of 2009 (ARRA) related to the meaningful use of electronic health records (EHRs).  The meaningful use incentive program, operated by the Centers for Medicare and Medicaid Services (CMS), provides eligible providers and eligible hospitals payment incentives to acquire, adopt, and meaningfully use EHRs.  Eligible providers, including dentists, can qualify to receive incentives from both the Medicare or Medicaid incentive programs. However, since many dental procedures are not covered by the Medicare program, most dentists will only be eligible to receive incentive payments from the Medicaid meaningful use incentive program.  Dentists qualifying for incentives under the Medicaid program must meet the criterion, as stated in the Final Rule, that “the EP must have at least 30 percent patient volume attributable to those who are receiving Medicaid (p. 44485)”.  While providers are also eligible for incentive payments if they are pediatricians with at least 20 percent of their patient volume attributable to Medicaid, pediatric dentists must still attest to the 30% Medicaid patient volume threshold in order to receive payments.  However, dentists are eligible to receive incentives if they practice at Federally Qualified Health Centers (FQHCs) or rural health centers with at least 30% of patients classified as “needy individuals” (including Medicaid and CHIP beneficiaries). 

Furthermore, in order to qualify for meaningful use incentive payments, the EHRs must be certified and meet the criteria established under the final EHR certification rule.  The Office of the National Coordinator for Health Information Technology (ONC) notes that “the final rule establishes the required capabilities and related standards and implementation specifications that Certified EHR Technology will need to include to, at a minimum, support the achievement of meaningful use Stage 1 by eligible health care providers under the Medicare and Medicaid EHR Incentive Programs.” This is a particular challenge for dentists looking to adopt health IT because as noted above, there are a number of EHRs which offer dental modules, including VistA (developed by the VA) and RPMS (developed by the Indian Health Service), but as of early 2011, no standalone dental EHR or EHR dental modules have been certified for meaningful use.

There are a number of challenges and barriers to the adoption of health IT and/or meaningful use that are particularly relevant to oral health providers. These include:

Lack of currently available certified dental health records

  • The absence of EHRs with diagnostic, therapeutic, or decision support applications appropriate for dentists, such as the functionality to capture, store, display, and analyze digital images
  • Lack of standalone dental EHRs or EHR modules that are certified for meaningful use
  • Difficulty in meeting the eligibility thresholds for Medicaid or needy patient population
  • Lack of proven interoperability between medical and dental EHRs
  • Lack of software for oral health that meets the certification criteria of the Certification Commission for Health Information Technology (CCHIT)
  • Inability to meet criteria surrounding quality reporting.

Although challenges currently exist, there are emerging opportunities for health IT and oral health care.  Advances in health IT systems, and increased awareness about the needs of dental providers with respect to health IT, EHRs, and requirements of meaningful use are just a few potential avenues to help mitigate these barriers. Organizations, such as Regional Extension Centers (RECs), can be used to promote partnerships within the dental community to assist dentists with the adoption and implementation of health IT. Additionally, although quality measures specific to oral health were not included in stage 1 of meaningful use, they may be included in later stages.

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