Meaningful Use – what about stand-alone billing systems?

When the ONC passed its final recommendations to the Centers for Medicare and Medicaid Services (CMS) for both Meaningful Use and for Certification, it created a set of 25 items that physicians need to demonstrate in 2011 to be eligible for Stage 1 incentive payments.

EHR vendors have been focusing intently on these criteria, looking to ensure Certification (once certifying bodies have been approved – to date, nobody has been approved as HHS Certification organizations). The Certification documents describe “Certified EHR Technology,” which can be achieved either through a “Certified EHR” (that addresses all 25 items), or through a combination of “Certified EHR Modules” (which can be certified to address one or more of the 25 items).

Of note, one of the items being proposed is the ability to “submit claims electronically to public and private payers” (item 17). The Meaningful Use criteria for this item is that physicians file at least 80% of all claims electronically.

This item raises some questions. Approximately half of physician practices carry out their own billing in-house, and may use either stand-alone billing software or billing (“practice management”) components of more comprehensive EHR products. The other half of practices outsource their billing to external billers or billing agencies, which use software of their own choosing (and the physician rarely even knows what particular system is being used). Outsourced billing can occur regardless of whether a practice uses an EHR system, or a paper system – even an EHR system that has the capability to do billing may not be utilized for the practice’s billing activity, since the system used by the outside biller is what is actually put to use.

Generally, this would not be a problem, from the Meaningful Use perspective – it would be easy to demonstrate that at least 80% of all bills created are sent out electronically. In fact, given that billing software is a mature industry that has been around for several decades, most practices are likely achieving this measure currently.

The question comes up around Certification. Billing software has historically never been part of EHR certification (previously done by CCHIT) – it never had to. Going through a Certification process would imply a business expense to a billing software vendor that was never before needed. But, depending on how CMS interprets this item, the only way that a physician could qualify for the “electronic claims submission” item of Meaningful Use would be to ensure that this is being done via a “Certified EHR Module” or part of a comprehensive “Certified EHR” system. Where does that leave stand-alone, widely-used medical billing systems? Will these systems need to certify themselves as a “Certified EHR Module?”

To date, none of the stand-alone billing systems have addressed this issue of Certification for Meaningful Use – or at least, have not done so publicly. Some clarification by CMS is needed here. Does a billing system that is able to send billing to CMS electronically become de facto Certified for this Module? The Certification documents are currently in their 60-day public comment period, and an opinion by CMS on this question would be welcomed.

Robert Rowley, MD
Chief Medical Officer, Practice Fusion, Inc.