HITECH Act American Recovery and Reinvestment Act (ARRA) Stimulus Package. HITECH Act Meaningful Use (MU)

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1 Presents Presents: Speaker: Elizabeth Woodcock, MBA, FACMPE, CPC Speaker: Elizabeth Woodcock, MBA, FACMPE, CPC HITECH Act Meaningful Use (MU) Definition Stages CMS Final Rule Criteria: Core, Menu and Clinical Quality Action Plan HITECH Act American Recovery and Reinvestment Act (ARRA) Stimulus Package What is it? An incentive program for health care providers to implement an electronic health record system that begins Jan 1, 2011 What it s not? Mandatory, but penalties begin in 2015 Exclusively for new implementations 3 4

2 Medicare Meaningful User Certified System Doctors of medicine or osteopathy Doctors of dental surgery or medicine Doctors of podiatric medicine Doctors of optometry Doctors of chiropractic medicine Medicaid Centers for Medicare and Medicaid Office of the National Coordinator of Health Care Services (CMS) Information Technology (ONC) Physicians Dentists Certified nurse midwives Nurse practitioners Physician assistants who are practicing in federally qualified health centers (FQHCs) or rural health clinics (RHCs) led by a physician assistant 5 6 Hospital based physicians are not eligible Test? Substantially all 90% or more of your services (not charges) in place of service codes 21 (inpatient hospital) or 23 (emergency department) Medicare $44,000, over 5 years Must be a participating i Medicare physician i Tied to 75% of total Medicare allowed charges $8 $18,000 year one bonus; $24,000 in allowed charges CMS revealed ld that t they will determine hospitalbased status according to claims history 7 8

3 Medicaid $63,750, over 6 years, tied to net average allowable cost 30% (20% for pediatricians) or more in Medicaid patient volume, measured over any representative 90 day period in previous year Clarifications from CMS, 7/13/ Can include MCD from primary or secondary: Services rendered on any one day to an individual where Medicaid or a Medicaid demonstration project under section 1115 of the Act paid for part or all of the service Can include Medicaid enrollee on a panel Can include multiple states, but only participate p with one Can skip a year, and return; not for Medicare 9 Medicaid No need to attest to meaningful use during first year adopting, implementing, or upgrading to certified EHR technology 10 Payment Attest through a web based portal for MCR and MCD, as proposed by CMS Single, annual, consolidated payment Tied to NPI, but can transfer to practice ARRA Defined Meaningful Use (MU) Use of certified EHR in a meaningful manner (e.g., e prescribing) Use of certified EHR technology for electronic exchange of health information to improve quality of health care Use of certified EHR technology to submit clinical quality measures(cqm) and other such measures selected by the Secretary MCR = Medicare; MCD = Medicaid; CMS = Centers for Medicare and Medicaid Services; NPI = National Provider Identifier 11 12

4 First Payment Year Payment Year ** 2011 Stage 1 Stage 1 Stage 2 Stage 2 Stage Stage 1 Stage 1 Stage 2 Stage 3 90 days 2013 Stage 1 Stage 2 Stage Stage 1 Stage * Stage 3 Centers for Medicare & Medicaid dservices December 30: Notice of Proposed Rulemaking July 13: FINAL RULE: Medicare and Medicaid Programs; Electronic Health Record Incentive Program _PI.pdf Rl Released on July 13, published on July 28 in Federal Register (at which time link will be moved) *avoids payment adjustments only for EPs in the Medicare EHR Incentive program. **Stage 3 criteria of MU or a subsequent update to the criteria if one is established through rulemaking. 13 Stage One Meaningful Use 14 Closely l links with the Certification and Standards d Final Rule Office of the National Coordinator (ONC) Final Rule, also released on July 13 Health Information Technology (HIT): Initial Set of Standards and Certification Criteria for EHR Technology Final Rule Eliminated the all or nothing approach Requires 15 core criteria; choose 5 others from a menu of 10 Reduced the criteria in number (25 to 20) Decreased the thresholds of the measures Increased the flexibility through stated exclusions (13 of 25) Eliminated the Specialty Group measures Removed the criteria that requires manual chart review to calculate l thresholdh Rejected the inclusion of administrative transactions (claims and eligibility) 15 16

5 1. Use computerized physician order entry (CPOE) 2. Implement drug drug and drug allergy interaction checks 3. Generate and transmit permissible prescriptions electronically 4. Record demographics 5. Maintain an up to date problem list of current and active diagnoses 6. Maintain active medication list 7. Maintain active medication allergy list 8. Record and chart changes in vital signs Record smoking status for patients 13 years old or older 10. Implement one clinical decision support rule relevant to specialty or high clinical priority along with the ability to track compliance with that rule 11. Report ambulatory clinical quality measures 12. Provide patients with an electronic copy of their health information, upon request 13. Provide clinical summaries for patients for each office visit 14. Capability to exchange key clinical information 15. Protect electronic health information created or maintained by the certified EHR technology 18 1 Objective Provide patients with an electronic copy of their health information, upon request 2 Measure More than 50% of all patients of the EP who request an electronic copy of their health hinformation are provided it within 3 business days 3 Exclusion Any EP that has no requests from patients or their agents for an electronic copy of patient health information during the EHR reporting period 19 How should it be delivered? Any electronic form: patient portal, personal health record (PHR), CD, USB fob, etc. Can you charge? Defers to HIPAA Privacy Rule, reasonable, cost based fee, but considers costs to be minimal Clarification to be issued in future rulemaking 20

6 How is 3 business days defined? Monday through Friday, excluding holidays If mailing physical electronic media, can mail on the 3 rd day How is the denominator the number of requests defined? Includes cudesonly ypatients ts and dtheir agents, not third party requests Certified systems must be able to automate the counting 21 What information? Defer to federal and state laws regarding disclosure Only information that exists electronically in or accessible from the EHR May withhold certain information, in accordance with HIPAA Privacy Rule Pages _PI.pdf Implement drug formulary checks 2. Incorporate clinical lab test results as structured data 3. Generate lists of patients by specific conditions 4. Send reminders to patients t for preventive/follow up care 5. Provide patients with timely electronic access to their health information 6. Use certified EHR technology to identify patient specific education resources 7. Perform medication reconciliation 8. Provide summary care record for each transition of care and referral Capability to submit electronic data to immunization registries 10. Capability to submit electronic syndromic surveillance data Must choose one of the public health initiatives 9) 9.) or 10.) as one of your menu criteria CMS is granting states to the right to transfer up to four menu criteria to the core 24

7 Required clinical quality criteria 1. Hypertension: Blood Pressure Management 2. Tobacco Use Assessment and Cessation Intervention 3. Adult Weight Screening and Follow up Alternate core criteria 1. Influenza Immunization for Patients 50 Years Old 2. Weight Assessment and Counseling for Children and Adolescents 3. Childhood Immunization Status PLUS: Three additional measures from a list of Narrow the list What exclusions apply to our practice? Determine current status What are we already doing? Can we report the numerator and denominator? Recognize system capabilities What can t we do? What can t we do, but is necessary? Next step: meet with vendor Note: to be certified, the system must be capable to allow MU! Understand the operational implications Divide and conquer 26 Exclusion Difficulty System Applies Index Constraints? Stake Person Action Criteria Measure Objective (Y or N)? (1 10) (Y or N) holders Responsible Plan etc. QUESTIONS & ANSWERS Elizabeth W. Woodcock, MBA, FACMPE, CPC Principal, Woodcock & Associates Atlanta, GA com elizabeth@elizabethwoodcock.com 27 28