Meaningful Use: Is Your Practice Ready? E L I Z A B E T H W O O D C O C K

Meaningful Use: Is Your Practice Ready? E L I Z A B E T H W O O D C O C K

Is Your Practice Ready? Elizabeth W. Woodcock, MBA, FACMPE, CPC

Elizabeth W. Woodcock, MBA, FACMPE, CPC Speaker, Author, Trainer www.elizabethwoodcock.com MBA, Wharton School of Business, University of Pennsylvania BA, Duke University Fellow, American College of Medical Practice Executives Certified Professional Coder Author, 12 textbooks and more than 500 Articles Founder and Principal, Woodcock & Associates Former Consultant, Medical Group Management Association; Group Practice Services Administrator, University of Virginia Health Services Foundation ; Former Senior Associate, Health Care Advisory Board 3

Background Stage Two Medicare Payment Adjustments Q&A Session To all participants: Please note that this presentation is focused on eligible professionals, not eligible hospitals or critical access hospitals. 4

EHR Incentive Program February 2009 American Recovery and Reinvestment Act TITLE XIII HEALTH INFORMATION TECHNOLOGY HITECH Act Eligible professionals will be paid for demonstrating use of a qualified electronic health record in a meaningful manner. 5

Medicare Doctors of medicine or osteopathy Doctors of dental surgery or medicine Doctors of podiatric medicine Doctors of optometry Chiropractors Medicaid 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 6

Hospital-Based Physicians Must fund the acquisition, implementation, maintenance of CEHRT Must not be reimbursed by a hospital Application process CEHRT = certified electronic health record technology 7

Medicaid Patient Volume in Medicaid 20% if you are a pediatrician, but only eligible for two-thirds of the bonus payment! 8

* Medicaid Patient Volume Inclusion of Title XXI-funded Medicaid expansion encounters (CHIP) Inclusion of all encounters in which Medicaid is a payer (but doesn t necessarily pay) Reporting period of 90 days during 12 months prior to attestation CHIP: children s health insurance program 9

Medicaid Adopting, Implementing or Upgrading (A/I/U) is acceptable for initial year bonus (!!) A/I/U is not Meaningful Use, however. Participants will be subject to the Medicare penalties. 10

Stage One Stage Two Meaningful Use Stage Three September 4, 2012 Federal Register 21050 Final Rule: Medicare and Medicaid Programs; Electronic Health Record Incentive Program Stage 2 11

1st Year Stage of Meaningful Use December 6, 2013 Stage 2 extended through 2016 Stage 3 begins in 2017 for EPs who have completed two years of Stage 2 2011 2012 2013 2015 2016 2017 2011 1 1 1 2 2 2 3 2012 1 1 2 2 2 3 2013 1 1 2 2 3 1 1 2 2 2015 1 1 2 2016 1 1 2017 Year One: 90 Days 1 Subsequent Years: 365 Days 12

If you attested to MU in 2011 or 2012 13

1st Meaningful Use Annual Incentive Payments Year 2011 2012 2013 2015 2016 [.] TOTAL 2011 MCR $18,000 $12,000 $8,000 $4,000 $2,000 $0 $0 $44,000 MCD $21,250 $8,500 $8,500 $8,500 $8,500 $8,500 $0 $63,750 2012 MCR $18,000 $12,000 $8,000 $4,000 $2,000 $0 $44,000 MCD $21,250 $8,500 $8,500 $8,500 $8,500 $8,500 $63,750 2013 MCR $15,000 $12,000 $8,000 $4,000 $0 $39,000 MCD $21,250 $8,500 $8,500 $8,500 $17,000 $63,750 MCR $12,000 $8,000 $4,000 $0 $24,000 MCD $21,250 $8,500 $8,500 $25,500 $63,750 2015 MCR $0 $0 $0 $0 MCD $21,250 $8,500 $34,000 $63,750 2016 MCR $0 $0 $0 MCD $21,250 $ 42,500 $63,750 MCR = Medicare; MCD = Medicaid. MCD participants must begin participation by 2016. 14

Key Points about the Payment Process Reduced by 2% for sequestration (now through 2024) Taxable Paid 6 to 8 weeks after attestation, after you meet the cap (75% of total allowed charges) For example, if you are due $12,000, you must have total allowed Medicare Part B charges of $16,000 Subject to pre- and post-payment audit, conducted by NJbased Figliozzi and Company May also be sent from EHR Meaningful Use Audit Team More about audits 15

Key Points about the Audit Process [ aka Mistakes to Avoid ] Transmitted via e-mail Review the audit request complete? limited (to one measure)? Retain documentation for 6 years Confirm that the system is tracking what you re doing If you plan to declare an exclusion, don t use the element even once during the reporting period Start tracking before you plan to report (if 90 days) Track MU reports every week www.cms.gov/regulations-and- Guidance/Legislation/EHRIncentivePrograms/Downloads/EHR _SupportingDocumentation_Audits.pdf 16

Key Points about the Audit Process Make and retain screen shots Print and store reports with date Capture physician signature, where required, on attestation Perform and document security risk analysis Maintain confirmation that your state can t accept submissions (for registries, if applicable) http://www.healthit.gov/providersprofessionals/security-risk-assessment 17

Computerized Provider Order Entry Medical Assistants can perform the ordering process but CMS: Any licensed healthcare professional can enter orders... If a staff member is appropriately credentialed... Whether a staff member carries the title of medical assistant or another job title, he or she must be credentialed to perform the medical assistant services by an organization other than the employing organization. Sources: CMS EHR Incentive Program - FAQ7693, FAQ10134, FAQ7709 17

3-month reporting period First-time Stage Two First-year Stage One Second-year Stage One 19

Medicare Quarter 1 January 1 March 31 Quarter 2 April 1 June 30 Quarter 3 July 1 September 31 Quarter 4 October 1 December 31 20

Maintain core-menu structure 17 core objectives 3 of 6 menu Retain exclusions, but can t use them to disqualify 9 clinical quality measures (CQMs) No longer one of the criteria Considered part and parcel of MU 21

Meaningful Use: Stage 1 15 Core Measures 5 Menu Measures 6 MU CQMs* Meaningful Use: Stage 2 Meaningful Use 17 Core Measures 3 Menu Measures 9 MU CQMs Meaningful Use *One of the core measures ; CQM: clinical quality measure 22

Criteria Old (MU1) Threshold New (MU2) Threshold CPOE 30% (med) 60% (med); 30% (lab/rad) erx 40% 50% Demographic info 50% 80% Vitals 50% 80% Smoking status 50% 80% Clinical summaries 50% (3 days) 50% (1 day) Patient education 10% (menu) 10% (core) CPOE: Computerized Provider Order Entry 23

In addition to higher measure thresholds Completely new criteria Stage One menu-based criteria now core Multi-layer criteria Appendix: List of 17 Core and 6 Menu-based Criteria 24

http://www.cms.gov/regulations-and- Guidance/Legislation/EHRIncentivePrograms/Download s/stage2_toolkit_ehr_0313.pdf 25

Sample Core Criterion Objective: Provide patients the ability to view online, download, and transmit their health information within 4 business days of the information being available to the EP 26

Objective: Provide patients the ability to view online, download and transmit their health information within 4 business days of the information being available to the EP Sample Core Criterion Measure: (1) >50% of all unique patients are provided timely online access (4 business days) to their health information; and (2) >5% of all unique patients (or authorized representative) view, download, or transmit to a third party their health information* *for both measures, only patients seen by the eligible professional (EP) during the reporting period 27

Sample Core Criterion Objective: Use electronic messaging to communicate with patients on relevant health information 28

Sample Core Criterion Objective: Use electronic messaging to communicate with patients on relevant health information Measure: A secure message was sent using the electronic messaging function of CEHRT by >5% of unique patients (or their authorized representatives) seen by the EP during the EHR reporting period CEHRT: certified electronic health record technology 29

Sample Core Criterion Patient-driven No definition of relevant health information Can t count requests for general information or appointments Staff could also respond to the patient No requirements for a response, but quality of care and risk management dictate 30

Sample Core Criterion Many commenters voiced objections to the concept of providers being held accountable for patient actions we believe that EPs are in a unique position to strongly influence the technologies patients use to improve their own care -CMS 31

Clinical quality measures 9 measures out of 64 None are required but some are recommended Electronic submission available Alignment with existing quality programs PQRS Shared Savings Program (ACOs) NCQA Patient-Centered Medical Home Recognition PQRS: Physician Quality Reporting System; ACO: accountable care organization; NCQA: National Committee for Quality Assurance CMS: Centers for Medicare & Medicaid Services 32

CQM Domains Patient and family engagement Patient safety Care coordination Population and public health Efficient use of healthcare resources Clinical processes/effectiveness 9 required measures must come from at least three different domains 33

Payment Adjustments (based on Medicare reimbursement) Year Penalty 2015 1% 2016 2% 2017 3% Beyond 4% to 5% Note: Exceptions will be made on a case-by-case basis for significant hardships (e.g., rural practices without sufficient Internet access) or 33

Payment Adjustments (based on Medicare reimbursement) Year Penalty 2015 1% 2016 2% 2017 3% Beyond 4% to 5% Note: Exceptions will be made on a case-by-case basis for significant hardships (e.g., rural practices without sufficient Internet access) No Medicaid Adjustments 34

Criteria for Exclusion Infrastructure: Lack Internet/broadband access New eligible professional (2 years) Unforeseen circumstances (e.g., natural disasters) Scope of practice; limited interaction with patients Lack of control of EHR access Unforeseen Circumstances = EHR Loses Certification Source: 8/15/13 CMS Provider Call, Speaker Travis Broome, Team Lead, CMS Policy & Oversight of HIT Initiatives March 10, Guidance - http://www.cms.gov/regulations-and- Guidance/Legislation/EHRIncentivePrograms/Downloads/CEHRT_HEGuidance_EPs.pdf Ineligible Appendix 35

Important The impact is to eligible professionals individually, not the practice Adjustments will be applied to all Medicare reimbursement Medicaid participants need to demonstrate meaningful use to avoid Medicare adjustments Eligible professionals must continue to demonstrate meaningful use 36

Year erx PQRS EHR VBM Sequestration Total 2012-1.0% - - - -1.0% 2013-1.5% - - - -2.0%+ -3.5% -2.0% - - - -2.0% -4.0% 2015 - -1.5% -1.0% -1.0%^ -2.0% -5.5% 2016 - -2.0% -2.0% -2.0%^ -2.0% -8.0% 2017 - -2.0% -3.0% -2.0%* -2.0% -9.0% 2018 - -2.0% up to -5% -2.0%* -2.0% up to -11% 2019 - -2.0% up to -5% -2.0%* -2.0% up to -11% +As of April 1, 2013. ^Only groups with 100+ eligible professionals in 2015; CMS is proposing to add groups of 10 to 99 EPs in 2016 although they would not be subject to the payment adjustment of -2.0%. *Assumed by speaker based on 2015 final rule and 2016 proposal by CMS as published in the July 19 2013 Federal Register. Applied to all Medicare reimbursement 38

39

September 4, 2012 Federal Register 21050 Final Rule: Medicare and Medicaid Programs; Electronic Health Record Incentive Program Stage 2 http://www.gpo.gov/fdsys/pkg/fr-2012-09- 04/pdf/2012-21050.pdf 40

Elizabeth W. Woodcock, MBA, FACMPE, CPC Woodcock & Associates Speaker, Trainer, Author Atlanta, Georgia 404.373.6195 elizabeth@elizabethwoodcock.com www.elizabethwoodcock.com These handouts may not be reproduced without the written consent of the speaker. 41