Proposed Meaningful Use Content and Comment Period. What the American Recovery and Reinvestment Act Means to Medical Practices

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1 Proposed Meaningful Use Content and Comment Period What the American Recovery and Reinvestment Act Means to Medical Practices

2 Session Objectives Gain a basic understanding of CMS EHR Incentive Program. Learn the criteria for meaningful use and how it applies to your practice. Devise strategies to obtain incentive payments and avoid penalties.

3 Part 1: ARRA Stimulus, Keywords Part 2: Meaningful Use Part 3: What you can do now

4 Why Promote EHR/ HIE? According to the ARRA, broad use of health IT will: Improve health care quality Prevent medical errors Reduce health care costs Increase administrative efficiencies Decrease paperwork Expand access to affordable care

5 Proposed Rules from 12/30/2009 On December 30, 2009 HHS released two proposed rules surrounding CMS EHR incentives. This presentation is based on those proposed rules. Final rules will be made later in Public comment is being accepted on both rules until March 15 th. The public is highly encouraged to comment.

6 HITECH Act Health Information Technology for Economic and Clinical Health Act is the HIT component of the American Recovery and Reinvestment Act signed into law on February 17, billion dollars for EHR use and information exchange Medicare and Medicaid Incentives for eligible professionals who have adopted a certified EHR and can demonstrate meaningful use ; Penalties for non-adopters

7 Keyword: Eligible Professional (EP) Medicare Eligibility Criteria: A doctor of: medicine, osteopathy, dental surgery or medicine, podiatry, optometry, or a chiropractor Non-hospital based, i.e., provider bills less than 90% to place of service codes 21, 22 or 23 See Medicare population.

8 Keyword: Eligible Professional (EP) Medicaid Eligibility Criteria: Physicians, dentists, certified nurse-midwives, nurse practitioners, and physician assistants working in FQHC/RHC that are PA led Non-hospital based, i.e., provider bills less than 90% to place of service codes 21, 22 or 23 30% of patient encounters attributed to Medicaid patients; 20% for Peds; needy patients count towards 30% in FQHC/RHC

9 Keyword: Certified EHR The ONC published the interim final rule Initial Set of Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology but did not address the certification process in this rule. Another, separate rule will be published in February with more information.

10 Keyword: Incentives Medicare Incentives Medicaid Incentives Providers must select ONE method No double dipping

11 Double Dipping Rules EPs may switch programs one time prior to 2015 Medicare e-rx program counts towards duplicate payments. Providers practicing in multiple states can only participate in one states program Onus is on the state to ensure EPs are not double dipping

12 Medicare Incentive Beginning January 2011: EPs who adopt and have meaningful use of the EHR as early as 2011 or 2012 may be eligible for up to $44,000 in Medicare incentive payments spread out over five years (increased by 10% for EPs who predominantly furnish services in a health professional shortage area).

13 Medicare Incentives Payout Table Amount You May Receive Each Year Year EHR Use is first demonstrated TOTAL 2011 $18,000 $12,000 $8,000 $4,000 $2,000 $0 $44, $0 $18,000 $12,000 $8,000 $4,000 $2,000 $44, $0 $0 $15,000 $12,000 $8,000 $4,000 $39, $0 $0 $0 $12,000 $8,000 $4,000 $24, /Later $0 $0 $0 $0 $0 $0 $0

14 Medicaid Incentive Medicaid payments also begin January 2011 and continue for 6 years. Unlike Medicare, Medicaid continues full payment thru EPs may receive up to a maximum of $63,750 Upfront payment of $21, 250 for providers who are engaged in efforts to adopt, implement or upgrade to certified technology.

15 Medicaid Incentives Payout Table Amount You May Receive Each Year Year EHR MU is first Shown Yr 1 Yr 2 Yr 3 Yr 4 Yr 5 Yr 6 TOTAL 2011 $ 21,250 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $63, $ 21,250 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $63, $ 21,250 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $63, $ 21,250 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $63, $ 21,250 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $63, $ 21,250 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $63, /Later $0 $0 $0 $0 $0 $0 $0

16 Payment Clarification for Pediatricians Pediatricians with a Medicaid population of 20% may participate; however their incentive payments are limited to 2/3 of the maximum amount or $42,500. Pediatricians with 30% Medicaid population are eligible for the maximum payout of $63, 750.

17 Keyword: Penalty Medicare Penalties: Providers who do not demonstrate meaningful use by 2015 will have a 1% decrease, in %, in % Up to a maximum decrease of 5% CMS will issue another proposed rule addressing penalties prior to 2015 Medicaid Penalties: None determined yet

18 Keyword: Meaningful Use Source: ONC, HIT Policy Committee 2009

19 Part 2: Meaningful Use

20 Medicare vs. Medicaid Medicare meaningful use is defined by the ONC HIT Policy Committee and approved by the Secretary. Medicaid meaningful use is demonstrated through a means that is approved by the State and accepted by the Secretary. The proposed rule suggests a shared minimum definition of meaningful use for Medicare and Medicaid. States may request CMS approval to implement meaningful use measures above the minimum but not below the minimum

21 Meaningful Use Table-Stage 1

22 Meaningful Use Overview HIT Measures 25 HIT measures for eligible professionals Clinical Measures 15 specialty groups 3 core measures for all providers Based on PQRI and NQF measures (See Proposed Rule page 123 for the measures table) Providers must meet all the measures

23 Core Clinical Measures Inquiry regarding tobacco use BP measurement Elderly patients who receive one or two drugs to be avoided (two different numbers)

24 HIT Measures 25 measures 3 HIE 4 Patient Communication 7 Documentation 11 Functionality

25 HIE Measures Capability to exchange key clinical information with other providers/patient approved entities (test) Capability to submit electronic data to immunization registries (test) Capability to provide electronic syndromic surveillance data to public health agencies (test)

26 Patient Communication Measures Send reminders to patients per preference for preventive/follow-up services (50%) Provide patients w/electronic copy of health information upon request w/in 48 hours (80%) Provide patients w/electronic access to health information w/in 96 hours (10%) Provide clinical summaries for each patient office visit (80%)

27 Documentation Measures Maintain up to date problem list (80%) Maintain active medication list (80%) Maintain active medication allergy list (80%) Record: pref language, ins type, gender, race, ethnicity, date of birth (80%)

28 Documentation Measures Record/chart changes in vitals: height, weight, BP, calculate/display BMI, plot and display growth charts for children 2-20, including BMI (80%) Record smoking status (80%) Incorporate lab test results in structured fields (50%)

29 Functionality Measures Use CPOE (80%) Implement interaction checking (drug, allergy, formulary (enable) Generate and transmit e-rx (75%) Generate list of patients w/specific conditions (attest to ability) Report measures to CMS (2011 attest; 2012 electronically submit)

30 Functionality Measures Implement 5 clinical decision support rules (attest) Check insurance eligibility (80%) Submit claims electronically (80%) Perform medication reconciliation at encounter and transition of care (80%)

31 Functionality Measures Provide care summary record for each transition in care (80%) Protect electronic health information created and maintained by the EHR (conduct review)

32 Demonstrating Meaningful Use For 2011, results for all objectives and measures, including clinical quality measures will be reported via attestation to CMS or the State. For 2012, measures will be sent electronically via certified EHR technology to CMS or the State.

33 Meaningful Use Reporting Period In the provider s first year of participation the reporting period will be any 90 day period that occurs within the calendar year For subsequent years of participation the reporting period will be the entire calendar year

34 EHR Incentive Payments Medicare payments will be made via Medicare Administrative Contractors (MACs). Payments made to the Tax Id Number given by the provider Medicaid payments will be made through the State. Payments made to the Tax Id Number given by the provider

35 For More Information Interim Final Rule: Health Information Technology: Initial Set of Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology ID=1153&mode=2 Follow Provide public comment link Search for: CMS Public comment period ends March 15, 2010

36 For More Information Proposed Rule: Medicare and Medicaid Programs; Electronic Health Record Incentive Program ID=1153&mode=2 Follow Provide public comment link Search for: HHS-OS Public comment period ends March 15, 2010

37 Part 3: What can you do NOW to get your incentive?

38 Practices with an EHR

39 Stage 1 Strategies for 2011 Payout Starting NOW, focus on these things: Review reporting requirements and work backwards to ensure documentation supports required reports. Implement a bi-directional lab interface and e-rx w/interaction checking Create a process for medication reconciliation and HIPAA security analysis

40 Stage 1 Strategies for 2011 Payout Perform documentation gap analysis: meds, problem, and allergy lists, vitals, BMI, etc Submit electronic claims, check eligibility Create lists of patients within the EHR using clinical decision support rules and send patient reminders Create clinical summary w/basic health information

41 Stage 1 Strategies for 2011 Payout Implement a patient portal Develop a source of statewide information on community HIE and test one exchange of key health data to other providers, health dept, or immunization registry. Begin using order entry

42 Practices with NO EHR

43 EHR Implementation Strategy Pre-Work: Getting your bearings Assessment: Discovering where you are now Planning: Deciding where you want to be in the future and how to get there System Selection: Evaluating which vendor meets your needs Implementation: Effectively installing the EHR Post-Live Evaluation: Evaluating if you are where you want to be

44 Pre-work Perform financial assessment/roi calculation Assign a physician champion Select members of EHR implementation team

45 Assessment Readiness assessment Computer skills evaluation Workflow analysis Hardware and software analysis

46 Plan Define EHR goals and measurements Learn how to manage change Keep lines of communication open Draft internal project plan for implementation

47 EHR Selection Possible Help: Regional Extension Center *Check CCHIT site for certified products Contact vendors and schedule demonstrations Request RFI/RFPs if appropriate Visit vendor references sites Negotiate contract

48 EHR Implementation Receive/review vendor implementation plan Work with vendor on system customization Test system and interfaces System training Practice using EHR in exam room (without patients) System backup and testing Establish downtime procedures

49 Post-Implementation Evaluation Goals review Meaningful use review Clinical Measure Reports Planning for subsequent phases

50 Contact Me Gary Balser EHR Consultant The Carolinas Center for Medical Excellence , ext 2004 Or