Medicaid Provider Incentive Program
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1 Medicaid Provider Incentive Program The Road to Meaningful Use Ohio Association of Community Health Centers 2013 Spring Conference March 6, 2013 Presenters: Elbony McIntyre, Project Manager Emma Esmont, MHSA
2 Introduction and Overview This session will provide an update on Ohio s Medicaid Provider Incentive Program (MPIP), including a recap of AIU requirements and an overview of Stages 1 and 2 of Meaningful Use. Today s objectives are to: Provide an update on Ohio s MPIP program. Provide an overview of the Stages of Meaningful Use. Provide an overview of the EHR Stage 2 final rule and its impacts on Ohio s MPIP program. 2
3 Today s Topics Why Meaningful Use? Stage 2 Final Rule Overview Program Eligibility General Meaningful Use Requirements Updates to Stage 1 Objectives and Measures Stage 2 Objectives and Measures Question and Answer Session The changes conveyed in the CMS Stage 2 Final Rule, 42 CFR 495, are not retroactive and therefore cannot be applied to previous program/payment years. 3
4 Why Meaningful Use? 4
5 What is Meaningful Use? Meaningful Use is using CEHRT to: Improve quality, safety, efficiency, and reduce health disparities Engage patients and families in their health care Improve care coordination Improve population and public health Maintain privacy and security Stage 2 Emphasizes: Improved quality of patient care Better clinical outcomes Improved population health outcomes Increased transparency and efficiency Empowered individuals More robust research data on health system 5
6 Ohio Medicaid Quality Strategy OMA has adopted three health improvement strategies: Better Care: Improve the overall quality of health care in Ohio by making it more patient centered, reliable, accessible, and safe Healthy People/Healthy Communities: Improve the health of Ohioans receiving Medicaid by supporting proven interventions concerning behavioral, social and environmental determinants of health Practice Best Evidence Medicine: Facilitate the implementation of best clinical practices to Medicaid providers through collaboration and improvement science approaches 6
7 Stages of Meaningful Use Stage 2 Advances Clinical Processes Stage 3 Improved Outcomes Stage 1 Data Capturing and Sharing
8 Why Meaningful Use? 8
9 MPIP Highlights* Ohio reached a significant milestone in January paying more than $204 million to 4,000 eligible professionals and hospitals. Ohio ranks 3 rd in the nation for the total number of Medicaid providers receiving incentive payments. Eligible Professionals Receiving Incentive Payments Eligible Hospitals Receiving Incentive Payments Physicians Optometrists ,857 Dentists Advanced Practice Nurses 131 Children's Hospitals Acute Care Hospitals *Data as of January 31,
10 Stage 2 Final Rule Overview Program Eligibility 10
11 Eligible Providers Physicians 30% - Pediatricians 20% Optometrists 30% Dentists 30% Patient Volume Medicaid Patient Volume Requirements OR the Medicaid EP practices predominantly through an FQHC or RHC. 30% needy individual patient volume threshold Ohio Advanced Practice Nurses (CNPs, CNMs, CRNAs, CNSs) 30% PAs practicing at an FQHC/RHC that is so led by a PA 30% 11
12 New! Patient Volume Encounter Encounter: Now includes individuals enrolled in a Medicaid program. In addition to services rendered on any one day where Medicaid paid for all or part of the service or Medicaid paid the co-pays, cost-sharing, or premiums, eligible professionals and eligible hospitals may now include services rendered on any one day to a Medicaid-enrolled individual, regardless of payment liability. 12
13 Patient Volume Encounters cont Examples of encounters that may now be included are: Claims denied due to service limitation audits Claims denied due to non-covered service Claims denied due to timely filing Services rendered on Medicaid members that were not billed due to the provider s understanding of Medicaid billing rules This does not include claims denied due to the provider or member being ineligible on the date of service. The denominator continues to include all patient encounters, (including zero-pay encounters.) We encourage providers to only use these new encounters if they can t meet patient volume without them. 13
14 Patient Volume Encounters cont At least one clinical location used in the calculation of patient volume must have CEHRT during the payment year for which the eligible professional attests to AIU or meaningful use. Eligible professionals may choose one (or more) clinical sites of practice in order to calculate their patient volume. This calculation does not need to be across all of an eligible professional's sites of practice. However, at least one of the locations where the eligible professional is adopting or meaningfully using CEHRT should be included in the patient volume. For example, if an eligible professional practices in two locations, one with CEHRT and one without, the eligible professional should include the patient volume at least at the site that includes the CEHRT (CMS FAQ10416). 14
15 Medicaid Patient Volume Patient Volume Calculation Reporting Period Any continuous 90-day period in the preceding CY (EPs) or FFY (EH) OR in the 12 months before the provider s attestation. Medicaid Patient Volume Calculation Medicaid Patient Encounters Total Patient Encounters SCHIP. MPIP will no longer adjust patient volume by an SCHIP factor. 15
16 Needy Individual Patient Volume Practices Predominantly An EP practices predominantly when the clinical location for over 50% of their total patient encounters over a period of 6 months within the most recent CY OR within the 12-month period preceding attestation, occurs at an FQHC or RHC. Patient Volume Calculation Reporting Period Any continuous 90-day period in the preceding CY OR in the 12 months before the EP s attestation Needy Individual Patient Volume Calculation Medicaid Patient Volume for EPs practicing predominantly through an FQHC/RHC Needy Individual Patient Encounters Total Patient Encounters 16
17 Reminder! Patient Volume Selection Pediatricians that do not have a Medicaid Patient Volume of 30%, but have a Medicaid Patient Volume of at least 20%, may attest as a Pediatrician. EPs practicing predominantly through an FQHC/RHC that do not have a Medicaid Patient Volume of 30%, but have a Needy Individual Patient Volume of at least 30%, may attest as an EP practicing predominantly through an FQHC/RHC. MPIP allows EPs to enroll as part of a group practice/clinic in order to meet Patient Volume thresholds. 17
18 Non-Hospital Based Non-Hospital Based Determination. CMS has added a new provision for eligible professionals who are determined to be hospital based. An eligible professional who is hospital based may be determined to be non-hospital based, if they can demonstrate that they: Fund the acquisition, implementation, and maintenance of Certified EHR Technology (CEHRT), including supporting hardware and interfaces needed for meaningful use without reimbursement from an eligible hospital, and Use the CEHRT in the inpatient or emergency department (ED) of a hospital (instead of the eligible hospital s CEHRT). 18
19 Non-Hospital Based cont Meaningful Use Impacts: The EP would include in their attestation to meaningful use all encounters at all locations, including those in the inpatient and emergency departments of the hospital, rather than just outpatient locations, as is the case for all other EPs. 19
20 Payment Year One Option Adopt, Implement or Upgrade (AIU) Adopt: to acquire, purchase or secure access to CEHRT capable of meeting MU requirements Implement: to install or begin using CEHRT (must prove actual installation) Upgrade: to improve the functionality of CEHRT capable of meeting MU requirements at the practice site or upgrading current EHR technology to CEHRT NEW! MPIP System Update: For payment year one, eligible professionals will have the option of attesting to AIU requirements or 90-days of Meaningful Use. 20
21 Stage 2 Final Rule Overview General Meaningful Use Requirements 21
22 Meaningful Use Timeline Stage of Meaningful Use 1 st Year TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD
23 Meaningful Use Criteria All measures have been pre-selected and federally defined. Stage 1 Stage 2 Eligible Professionals 15 Core Objectives 5 of 10 Menu Objectives 20 Total Objectives Eligible Professionals 17 Core Objectives 3 of 6 Menu Objectives 20 Total Objectives 23
24 2014 Menu Measure Exclusions When reporting on menu objectives, a provider cannot claim an exclusion, and have it count toward the minimum menu objectives (5 of 10 for Stage 1; 3 of 6 for Stage 2) that they are required to meet, if there are other objectives that the provider can meet. This requirement is applicable to all stages of meaningful use beginning in year
25 Stage 2 Final Rule Overview Updates to Stage 1 Objectives and Measures 25
26 Removed Core & Menu Measures EP EP EP EP 2012 Stage 1 Objective Core: Capability to exchange key clinical information among providers of care and patient authorized entities electronically. Core: Provide patients with an electronic copy of their health information, upon request. Menu: Provide patient with timely electronic access to their health information within 4 business days of the information being available to the EP. Removal Date Payment Year 2013 Payment Year 2014 Payment Year
27 Stage 1 Objective New Stage 1 Core Objective 2014 and Beyond New to Stage 1 in 2014 Provide patients the ability to view online, download and transmit their health information within 4 business days of information being available to EP. Core Objective: E-Copy & Online Access Measure: More than 50% of all unique patients seen by the EP during the EHR reporting period are provided timely (available within 4 business days of information being available to EP) online access to their health information subject to the EPs discretion to withhold certain information. Exclusion: Any EP who neither orders nor creates any of the information listed for inclusion as part of this measure. 27
28 e-rx Exclusion Stage and Beyond Exclusion: Any EP who writes fewer than 100 prescriptions during EHR reporting period OR (New Additional Exclusion) For providers who are not within a 10 mile radius of a pharmacy that accepts electronic prescriptions 28
29 CPOE Alternative Measure Stage and Beyond Providers may select one of the following Denominators: Denominator = Unique Patient with at least one medication in their medication list OR (New Alternative Measure) Denominator = Number of medication orders during the EHR reporting period 29
30 Vital Signs Measure Stage and Beyond Optional 2013, Required 2014 New Measure: More than 50% of all unique patients seen by the EP or admitted to the EH's inpatient or emergency department (POS 21 or 23) during the EHR reporting period have BP (for patients age 3 and over only) and height and weight (for all ages) recorded as structured data. 30
31 Vital Signs Exclusion Stage and Beyond Optional 2013, Required 2014 New Exclusion - any EP who: 1.) Sees no patients 3 years or older is excluded from recording BP; 2.) Believes that all three vital signs of height, weight, and BP have no relevance to their scope of practice is excluded from recording them; 3.) Believes that height and weight are relevant to their scope of practice, but BP is not, is excluded from recording BP ; or 4.) Believes that BP is relevant to their scope of practice, but height and weight are not, is excluded from recording height and weight. 31
32 Stage 2 Final Rule Overview Stage 2 Objectives and Measures 32
33 Stage 2 EP Core Objectives EP must meet all 17 core objectives Core Stage 1 Measure Stage 2 Measure CPOE Use CPOE for more than 30% of unique patients OR for more than 30% of medication orders Use CPOE for more than 60% of medication, 30% of laboratory, and 30% of radiology orders. erx erx for more than 40% erx for more than 50% Demographics Record demographics for more than 50% Record demographics for more than 80% Vital Signs Record vital signs for more than 50% Record vital signs for more than 80% Smoking Status Record smoking status for more than 50% Record smoking status for more than 80% Interventions Labs Patient List Preventive Reminders Patient Access Implement 1 clinical decision support rule. Menu Measure: Incorporate lab results for more than 40% Menu Measure: Generate patient list by specific condition Menu Measure: More than 20% of all unique patients 65 years or older or 5 years old or younger were sent an appropriate reminder during the EHR reporting period Provide online access to health information for more than 50%. Implement 5 clinical decision support interventions and drug/drug and drug/allergy Core Measure: Incorporate lab results for more than 55% Core Measure: Generate patient list by specific condition Core Measure: Use EHR to identify and provide reminders for preventive/follow-up care for more than 10% of patients with 2 or more office visits in the last 2 years Provide online access to health information for more than 50% with more than 5% actually accessing 33
34 Stage 2 EP Core Objectives cont EP must meet all 17 core objectives Core Stage 1 Measure Stage 2 Measure Visit Summaries Education Resources Clinical summaries provided to patients for more than 50% of all office visits within 3 business days Menu Measure: Provide patient-specific education resources more than 10% Provide clinical summaries for more than 50% of office visits within 1 business day Core Measure: Use EHR to identify and provide education resources more than 10% Secure Messages Rx Reconciliation N/A Menu Measure: Medication reconciliation for more than 50% of transitions of care Core Measure: More than 5% of patients send secure messages to their EP Core Measure: Medication reconciliation at more than 50% of transitions of care Summary of Care Menu Measure: Provides a summary of care record for more than 50% of transitions of care and referrals Core Measure: Provide summary of care document for more than 50% of transitions of care and referrals with 10% sent electronically and at least one sent to a recipient with a different EHR vendor or successfully testing with CMS test EHR Immunizations Security Analysis Menu Measure: Perform at least one submission of electronic data to immunization registries and follow up Conduct or review security analysis and incorporate in risk management process Core Measure: Successful ongoing transmission of immunization data Conduct or review security analysis and incorporate in risk management process 34
35 Stage 2 EP Menu Objectives EP must meet 3 of 6 menu objectives Menu Stage 1 Measure Stage 2 Measure Imaging Results N/A More than 10% of imaging results are accessible through CEHRT Family History N/A Record family health history for more than 20% Syndromic Surveillance Cancer Specialized Registry Progress Notes Provide electronic syndromic surveillance data to public health agencies and follow-up N/A N/A N/A Successful ongoing transmission of syndromic surveillance data Successful ongoing transmission of cancer case information Successful ongoing transmission of data to a specialized registry Enter an electronic progress note for more than 30% of unique patients 35
36 2014 Clinical Quality Measures (CQMs) Current Stage All Stages Eligible Professionals 6 out of 44 Eligible Professionals 9 out of 64 Must cover 3 of the 6 Department of Health and Human Services National Quality Strategy domains: - Patient and Family Engagement - Patient Safety - Care Coordination - Population and Public Health - Efficient Use of Healthcare Resources - Clinical Processes/Effectiveness 36
37 Medicare Payment Adjustments Eligible professionals and eligible hospitals that have the option to participate in either MPIP or the Medicare EHR Incentive Programs may be subject to a Medicare Payment Adjustment unless they are meaningful users of certified EHR technology. Meeting AIU requirements does not exempt a provider from a Medicare Payment Adjustment. Applied beginning on October 1, 2014 for eligible hospitals and on January 1, 2015 for eligible professionals. Medicaid eligible professionals and hospitals that can only participate in the Medicaid EHR Incentive Program and do not bill Medicare are not subject to these payment adjustments. For additional information on Medicare Payment Adjustments, please see the CMS Stage 2 Webpage: Guidance/Legislation/EHRIncentivePrograms/Stage_2.html. 37
38 Resources MPIP Website MPIP Resources Page CMS EHR Incentive Programs Guidance/Legislation/EHRIncentivePrograms/Stage_2.html CMS Stage 2 Meaningful Use Specification Sheets EP: Guidance/Legislation/EHRIncentivePrograms/Downloads/Stage2_MeaningfulUseSpecSheet_TableC ontents_eps.pdf EH: Guidance/Legislation/EHRIncentivePrograms/Downloads/Stage2_MeaningfulUseSpecSheet_TableC ontents_eligiblehospitals_cahs.pdf 38
39 Questions 39
40 Contact Us MPIP Mailbox: MPIP Hotline: JFS-MPIP 40
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