Medicaid EHR Provider Incentive Payment Program. September 26, 2011

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1 Medicaid EHR Provider Incentive Payment Program September 26, 2011

2 Definitions Electronic Health Record (EHR)*-An electronic record of health-related information on an individual that conforms to nationally recognized interoperability standards and that can be created, managed, and consulted by authorized clinicians and staff across more than one health care organization. (Individual Focused) Health Information Exchange (HIE)*-The electronic movement of health-related information among organizations according to nationally recognized standards. Health Information Technology (HIT)-allows comprehensive management of medical information and its secure exchange between health care consumers and providers. Broad use of HIT has the potential to improve health care quality, prevent medical errors, increase the efficiency of care provision and reduce unnecessary health care costs, increase administrative efficiencies, decrease paperwork, expand access to affordable care, and improve population health.* *Definitions-National Alliance for HIT and authorized by ONC for Health ITwww.nahit.org 2

3 Presentation Overview Basics of the HIT Governance Structure in Massachusetts Basics of the Medicaid EHR Incentive Payment Program Steps Massachusetts has taken to plan and implement that Medicaid Incentive Program High Level Overview of Application Process 3

4 The Health Information Technology for Economic and Clinical Health (HITECH) Act HITECH Act was passed in February 2009 as part of the American Recovery and Reinvestment Act (ARRA) Establishes as a goal - the utilization of an electronic health record (EHR) for each person in the United States by 2014 Creates reimbursement incentives through Medicare and Medicaid for providers who demonstrate they are meaningful users of federally certified EHR systems through the Office of the National Coordinator (ONC) 4

5 Massachusetts ehealth Institute (MeHI) Background on MeHI MeHI was established through an Act of the Massachusetts Legislature- Chapter 305 MeHI is a division of the Massachusetts Technology Collaborative (MTC) MeHI is responsible for advancing the dissemination of health information technology (HIT) across the Commonwealth, including the deployment of electronic health records (EHR) systems in all health care provider settings that are networked through a statewide health information exchange (HIE). HIT Council which is the governing board of MeHI is chaired by the Secretary of EOHHS and the Medicaid Director is member of HIT Council Collaboration between MeHI and MassHealth Ensuring that there is complete alignment and coordination with statewide and MassHealth/EOHHS HIT initiatives MeHI will have a unit that will be dedicated to supporting key operational functions of the Medicaid Incentive Payment Program 5

6 Medicaid Incentive Program Eligible Providers Eligible Professionals (EPs) who do not practice predominately at a FQHC or RHC Eligible Professionals (EPs) who do practice predominately at a FQHC or RHC Short-term Stay Acute Care Hospitals, Children s Hospitals and Critical Access Hospitals 6

7 Eligible Professionals (EP)-not FQHC/RHC Non-hospital based Physicians (MDs and ODs), Dentists, Certified Nurse Mid-Wives, and Nurse Practitioners Hospital Based EPs are excluded from receiving incentive payments Hospital Based - if 90% or more of an EP s services take place at a setting of Inpatient Hospital or Emergency Room Must meet minimum patient volume thresholds 30% Medicaid Patient Volume Threshold for non-pediatricians 20% Medicaid Patient Volume Threshold for Pediatricians (2/3 of the incentive payment) A CHIP Reduction Factor will be developed by MassHealth and must be applied to the Medicaid encounters in order to meet a CMS requirement that CHIP encounters can not be included in Medicaid patient encounters EPs must waive rights to Medicare Incentive Payments in order to receive Medicaid Incentive Payments EPs can only receive Medicaid Incentive Payment from one state per year 7

8 Eligible Professionals (EP)- Predominately FQHC/RHC Physicians, Dentists, Certified Nurse Mid-Wives, Nurse Practitioners, and Physician Assistants who practice at a FQHC/RHC that is led by a Physician Assistant Practicing Predominately at a FQHC or RHC means 50% or more of their patient encounters at the FQHC or RHC. Must meet minimum patient volume thresholds 30% Needy Individuals Patient Threshold for providers who practice at FQHCs or RHC Needy Individual means an individual receiving care from any of the following (1) Medicaid, Medicaid Waiver, CHIP, Dually Eligible for Medicare and Medicaid (2) Uncompensated Care (3) No cost or reduced cost services on a sliding scale based on the individual s ability to pay EPs must waive rights to Medicare Incentive Payments in order to receive Medicaid Incentive Payments EPs can only receive Medicaid Incentive Payment from one state per year 8

9 Short Stay Acute Care and Children s Hospitals (based on CCN) Acute Care Hospitals, Cancer Hospitals and Critical Access Hospitals that are considered short-term stay hospitals (less than 25 days ALOS) Must meet or exceed 10% minimum Medicaid patient volume thresholds Must have a CCN with the last 4 digits that fall in the range of (0001 through 0879) or ( ) A CHIP Reduction Factor will be developed by MassHealth and applied to the Medicaid encounters in order to meet a CMS requirement that CHIP encounters can not be included in Medicaid patient encounters Children s Hospitals- No minimum Medicaid patient volume threshold Must have a CCN with the last 4 digits that fall in the range of ( ) Hospitals can receive both Medicaid and Medicare EHR Incentive Payments If a hospital is approved by CMS for Medicare Incentives, they are deemed eligible for Medicaid Incentives. The hospital still must show that they are eligible for their Medicaid incentives each year (example: 10% Medicaid patient encounter threshold information) 9

10 Criteria for Receiving Medicaid EHR Incentives in First Payment Year First Payment Year Only- Medicaid Providers demonstrate the following: Adopted Acquired, purchased or secured access to an ONC certified EHR system Implemented Commenced Utilization (example: Staff training, data entry of patient demographic information into EHR) Upgraded Expanded the available functionality of certified EHR technology capable of meeting meaningful use requirements at the practice site or upgraded from existing EHR technology to certified EHR technology per the ONC EHR certification criteria Must be ONC certified EHR technology capable of meeting meaningful use No EHR reporting period 10

11 Criteria for Receiving Medicaid Incentives Payment Years 2-6 In Payment Years 2 through 6 - Medicaid EP and Hospitals must demonstrate Meaningful Use of an ONC Certified EHR systems Stage 1 Meaningful Use Criteria 15 Core Objectives (examples: CPOE, e-prescribing, record demographics, clinical quality measures, etc.) plus 4-5 Objectives from menu set (examples: drug-formulary checks, incorporate clinical lab test results as structured data, generate lists of patients by specific conditions, etc.) 6 Clinical Quality Measures for EPs and 15 Clinical Quality Measures for Hospitals MU Reporting period 90 days for participation year 2 MU Reporting period 365 days for participation beyond year 2 11

12 Medicaid EHR Incentive Payments -EPs Calendar Year $21, $8,500 $21, $8,500 $8,500 $21, $8,500 $8,500 $8,500 $21, $8,500 $8,500 $8,500 $8,500 $21, $8,500 $8,500 $8,500 $8,500 $8,500 $21, $8,500 $8,500 $8,500 $8,500 $8, $8,500 $8,500 $8,500 $8, $8,500 $8,500 $8, $8,500 $8, $8,500 Total $63,750 $63,750 $63,750 $63,750 $63,750 $63,750 Note: 1) Pediatricians with a minimum 20% patient volume may qualify for up to a maximum of $14,167 in the first incentive payment year and to up a maximum of $5,667 in each of the 5 subsequent incentive payment years for no more than a total of $42,500 over the maximum 6 year period. 2) If a Pediatrician meets or exceeds the 30% patient volume threshold they are eligible for the full incentive payment amounts. 12

13 Medicaid EHR Incentive Payments Hospitals The aggregate EHR incentive calculation for Medicaid eligible hospitals is represented mathematically as follows to be paid over 3 to 6 years: (Overall EHR Amount) X (Medicaid Share) 13

14 Funding Sources for Medicaid EHR Incentive Payments Medicaid EHR Incentive Payments to providers are administered by the states but are reimbursed at 100% by CMS Planning, administrative and oversight expenses for states to carry out the Medicaid Incentive Payment provisions are reimbursed at 90% by CMS and 10% by state funds 14

15 CMS required Planning Activities January MassHealth submitted its HIT Planning Advanced Planning Document (HIT PAPD) to CMS for approval May CMS approved MassHealth s request to begin planning activities associated the Medicaid EHR Incentive Payment Program May 2010 thru February MassHealth developed its State Medicaid HIT Plan (SMHP) and submitted the Plan to CMS on March 11, 2011 June CMS approved MassHealth s SMHP available on the July 13, Submitted the HIT Implementation Advance Planning Document (HIT IAPD) which focused on the EHR incentive program operational staffing model and budget to CMS. August 26, CMS approved the HIT IAPD which allowed Massachusetts to take steps to implement the incentive program. September 19, CMS approved Massachusetts request to launch the Medicaid Incentive Program on October 3, 2011!!!! 15

16 MassHealth Specific Plan Options Massachusetts will not have state specific Meaningful Use criteria-standard, standard, standard to federal CMS requirements! Massachusetts is paying the hospital incentives over a 3 year payment period 50% in the first payment year 30% in the second payment year 20% in the third payment year Providers can include FFS claims and MCO encounters when they are establishing their Medicaid Patient Volume Thresholds. They should include encounters for following MassHealth and Medicaid 1115 Waiver Populations: MassHealth Standard, MassHealth Breast/Cervical Cancer Treatment, MassHealth CommonHealth, MassHealth Family Assistance, MassHealth Basic, MassHealth Essential, MassHealth Limited, MassHealth Prenatal, MassHealth Insurance Partnership, Commonwealth Care, MSP, Health Safety Net and Healthy Start Grace periods for applying for first year Medicaid EHR incentive payment: Eligible hospitals will have until December 30, 2011 to apply for their FFY2011 payments Eligible professionals will have until March 30, 2012 to apply for their CY2011 payments Massachusetts is one of thirteen states to collaborate on the development of a system called the Medical Assistance Provider Incentive Repository (MAPIR). MAPIR is a system that will support the following activities: Receive providers incentive payment registrations from CMS Registration and Attestation System (R&A) electronically on a daily basis Allow providers to apply for Massachusetts Medicaid incentives through the EOHHS Provider Online Service Center (POSC) Will interface with the MassHealth claims system for disbursement of the incentive payments 16

17 High Level Flow of Medicaid Incentive Payment Program Providers Eligible for Medicaid Incentives: Hospital, Physician, Dentist, Nurse Practitioner, Cert Nurse Midwife Incentive Payment to Providers Hospital s Step 1 Register at the CMS Registration and Attestation Website (CMS R&A) Provider selects Medicaid and Massachusetts when Massachusetts Launches EP Step 1 Step 3 Step 6 MassHealth System Pays Incentive to Provider Step 3 MassHealth Virtual Gateway Provider Registration and Attestation Provider Enter Eligibility Information, AIU/MU Attestations CMS R&A Step 7 MassHealth Reports Incentive Payments Back to CMS Step 2 CMS sends Files to MassHealth on Daily Basis MAPIR/MMIS Step 4 Incentive Payment Staff Validates Information Incentive Payment Staff Step 5 Incentive Payment Staff Okays Payment 17

18 Initial Estimates of Medicaid EHR Provider Incentive Payments Hospitals Incentive Payments at 100% FFP- Many of the 65 Massachusetts short-term acute care and Critical Access Hospitals will meet 10% Medicaid Patient Threshold including Children s Hospital Approximately $100,000,000-$120,000,000* in total Medicaid Incentive Payments paid to Massachusetts eligible hospitals from Important note: All hospitals must receive their first Medicaid Incentive Payment by *Hospital Estimates are very preliminary charitable care adjustment not included Eligible Providers Incentive Payments at 100% FFP- Using national estimates 20% of Massachusetts EPs may be eligible for Medicaid Incentive Approximately 5,000 6,000 eligible providers in Massachusetts may receive up to $63,750 in Medicaid Incentive Payments Approximately $320,000,000-$382,500,000 in total Medicaid Incentive Payments paid to Massachusetts EPs from Important note: All EPs must receive their first Medicaid Incentive Payment by

19 Links to Key HITECH Websites Basic information about the Massachusetts Medicaid EHR Incentive Payment Program Massachusetts ehealth Institute (MeHI) General CMS Incentive Payment Program Website for both Medicare and Medicaid EHR Incentive Programs The CMS Registration and Attestation Website First Stop in applying for all incentives U.S. Department of Health & Human Services Office of the National Coordinator (ONC) Listing of ONC Certified Health IT Products including EHRs (CHPL) 19