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If I am implementing an EHR for the first time, what do I need to do now?

The most important step towards participation in the EHR Incentive Program is to make sure that the EHR system that you adopt is certified by an ONC Authorized Testing and Certification Body.  ATCBs are authorized organizations that test and certify that complete EHRs and EHR modules are compliant with the standards, implementation specifications, and certification criteria.  A list of all EHRs and EHR modules certified by the ONC-Authorized Testing and Certification Bodies (ATCBs) is now available on ONC’s website.  This Certified HIT Product List is updated frequently as newly certified products are reported to ONC.

As you decide which EHR technology to purchase, and as you prepare to install and implement your EHR, you may wish to contact your local Health IT Regional Extension Center (REC) in your area.  ONC has funded 62 RECs across the country.  These furnish assistance, including education, outreach, and technical assistance, and will help you select, successfully implement and meaningfully use certified EHR technology.   

If you choose to adopt, implement, or upgrade an EHR in order to receive Medicaid incentive payments, you may need to show proof that you have purchased an EHR.  You may also need to show that you have contributed at least 15 percent of the cost of the EHR.  The incentive pays for up to 85 percent of the cost of the EHR ($21,500 the first year; $8,500 the following five years) and providers are responsible for paying 15 percent of the cost ($3,500 the first year; $1,500 the following five years).  If you have assigned your payment to an FQHC or RHC, it is assumed that your employer made this contribution.   

In this case, you will not need to report on the Meaningful Use objectives and measures during this first year if you adopt, implement or upgrade an EHR.  During your second year of participation, however, you will need to electronically report on these measures for a continuous 90-day period.  For future years, you will need to report on these criteria for the full year.  

Registration for the Medicaid EHR Incentive Program opened in nine states on January 3, 2011.  Another three states began registering providers in February 2011.  Other states likely will launch their Medicaid EHR Incentive Programs during the spring and summer of 2011.  Once registration in your state is open, you may register before your EHR system has been certified but you will not begin to receive incentive payments until your EHR system is certified.  CMS’ Registration and Attestation webpage has up to date information about how to register.  

Eligible professionals under the Medicaid Incentive Program can register whether or not their state has initiated their program and CMS will pass their information on the state once the state initiates their program.  To register, all eligible hospitals and Medicare providers will need a National Provider Identifier (NPI) and be enrolled in the CMS Provider Enrollment, Chain and Ownership System (PECOS).  Medicaid eligible professionals who are only participating in the Medicaid Incentive Program are not required to enroll in PECOS.  

Related Resources:

Certified Health IT Product List – ONC’s list of EHR products that have been certified by the ONC-Authorized Testing and Certification Bodies.
2011 EHR Selection Guidelines for Health Centers – In collaboration with key stakeholders, HRSA’s recommended guidelines lists key considerations for health centers selecting an EHR vendor.
Initial EHR Standards – ONC’s details on EHR certification and attaining Meaningful Use.
Temporary Certification Program – ONC’s temporary certification program for EHR systems.
The American Recovery and Reinvestment Act of 2009: Frequently Asked Questions – Issued by NACHC prior to the July 28, 2010 Final Rule, this provides a useful explanation of the funding available for community health centers through ARRA and which government agencies control these funds.