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					said. “Perhaps as early as 2012, although a
final decision has not been made on that
yet, the objective would be that we would
get machine-to-machine entry,” Con-
stantian said.
    At that point, instead of the EHR spit-    Privacy compliance driving encryption use
ting out a report to the provider to trans-    Complying with data protection and privacy regulations is becoming the
fer to the attestation module, it would        primary reason organizations use encryption, while mitigating data breaches
“directly communicate with our receiving       continues to get less emphasis, according to a recent report by the Ponemon
systems to the NLR. We’re still in the dis-    institute and Symantec Corp.
cussion phase of what that fashion might
be,” he said.                                                                                                  44%
    While awaiting incentives, provid-                                                                            51%
                                                      To comply with privacy or data
ers can check the progress of payments         security regulations and requirements
through a status tab on the same Web                                                                                   64%
site, which is similar to the “Where’s My                                                                                69%
Refund?” feature on the IRS’s site.
    The earliest that a provider can attest—
given the requirement of demonstrat-                                                                                 55%
ing meaningful use for 90 days—will be                                                                                      66%
April 2011, with payments beginning in                    To mitigate data breaches                                            71%
May. Also, providers will not receive their                                                                                  67%
incentives, even if they have attested and                                                                                 63%
been approved as meeting meaningful
use criteria, until they reach a threshold
of billing Medicare for $24,000 in claims.                                                                  40%
                                                                                                                                     FY 2006
That will qualify them for the maximum           To protect our company’s brand or                          40%
                                                       reputation damage resulting                         37%                       FY 2007
of $18,000 incentive in the first year of
                                                                 from a data breach                           45%
meaningful use, Constantian said.                                                                                                    FY 2008
    “Once a month we’re seeing if those                                                                        46%
                                                                                                                                     FY 2009
providers who have attested and who
qualify for the EHR incentives on their                                                                                              FY 2010
responses have reached that threshold
                                                           To avoid having to notify      13%
of $24,000 of Medicare charges,” he said,
                                                            customers or employees               22%
adding that most Medicare providers are
                                                          after a data breach occurs            19%
expected to reach that level at some point
during the year.                                                                               16%
    When providers reach that threshold,
the payment file contractor will gener-                                                 5%
ate electronic payment of the incentives                                                 7%
through the same bank account that they           To ensure that our organization’s       9%
receive payment for Medicare claims.              privacy commitments are honored
Along with the registration Web site,
CMS will also open on Jan. 3, 2011, the
“EHR incentive program information
call center,” which will operate M-F, 8:30                                         0%   10% 20% 30% 40% 50% 60% 70% 80%

a.m.-7:30 p.m. (ET), for questions not an-                                                     Percentage of Respondents
swered on the Web site.
                                               Source: Ponemon Institute: 2010 Annual Study: U.S. Enterprise Encryption Trends
                          —Mary Mosquera

goVernment health it | January–February 2011                                                                                                   7

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