HITECH* Update Meaningful Use Regulations Eligible Professionals October 2010 * Health Information Technology for Economic and Clinical Health, a component of the ARRA of 2009
McDowell Lecture December 3, 2008 Document Objectives Provide high level summary of programs and incentives Review final Meaningful Use (MU) requirements, timeframes and processes for Eligible Professionals (EPs) Outline potential opportunities for assistance DISCLAIMER This material is intended to be informational only and details have been streamlined or omitted to provide only a summary overview. How many of you already use an EMR? How many of you have know about HITECH and the incentives at a basic level? McDowell Research Center for Global IT 2
Definitions and Acronyms HITECH Health Information Technology for Economic and Clinical Health MU Meaningful Use, the term used in ARRA to describe a hospital or physician who demonstrates achievement of specific goals and therefore can earn Medicare and/or Medicaid incentive payments CPOE Computerized Provider Order Entry EHR Electronic Health Record; EMR: Electronic Medical Record EH Eligible Hospital to receive stimulus funds EP Eligible Professional one of five types of professionals legally authorized to practice their profession under state law HIE Health Information Exchange CAH Critical Access Hospital (now eligible for Medicaid funds) HIPAA Health Insurance Portability & Accountability Act ONC Office of the National Coordinator ONC ATCB Authorized Testing and Certification Bodies designated to perform testing and award certifications CCHIT Certification Commission for Health Information Technology Skip this it is in their handout
Intent of the HITECH program The program emphasizes the meaningful use of an EHR to 1. Improve quality, safety, efficiency, and reduce health disparities 2. Engage patients and families 3. Improve care coordination 4. Ensure adequate privacy and security protections for personal health information 5. Improve population and public health Oh yea, Reduce the cost of our healthcare system 4
Programs to support EHR Adoption MIPPA E Prescribing Incentive (Through 2013) Medicare and Medicaid Incentives; An EP must choose one or the other (may switch programs once) Regional Extension Centers; Provide EPs with knowledge, tools and assistance 5 Medicare Improvements for Patients and Providers Act The MIPPA authorizes a new incentive program for eligible professionals who are successful electronic prescribers
Who Qualifies? Eligible Professionals Medicare Doctor of medicine or osteopathy Doctor of dental surgery or dental medicine Doctor of podiatric medicine Doctor of optometry Chiropractor Medicaid Physicians Dentists Certified nurse midwives Nurse practitioners Physicians assistants (in rural health clinic or FQHC led by a physician assistant) Medicare EPs may not be hospital-based Requires minimum 30% Medicaid patient mix (20% for Pediatrics) Qualifying Medicaid EPs: the definition of a qualifying EP includes five types of professional: physicians; dentists; certified nurse midwives; nurse practitioners; and physician assistants (PAs) practicing in a federally qualified health center(fqhc) or rural health center (RHC) that is led by a physician assistant.cms clarifies in its response to comments the definition of physician assistant (PA) led entity. That definition can include: when a PA is the primary provider in a clinic (if there is a parttime physician and a full time PA, CMS would consider that clinic PA led); when a PA is a clinical or medical director at a clinical site of practice; or Health Policy Alternatives, Inc.July 21, 201037 whenapaisanownerofanrhc.
Medicare Incentives for EPs Maximum incentive amount is $44,000 over 5 years Must begin participation by 2012 to receive maximum incentive Incentives based on 75% of Medicare Allowed Charges for that year Starting in 2015 Penalties (reduction in Medicare reimbursements) for EPs not demonstrating Meaningful Use 7 To receive the maximum incentive payments for CY 2011, an EP would need to have at least $24,000 in Medicare allowed charges that year (that is $24,000 x.75 = $18,000). The incentive payment amount, subject to an annual limit, is equal to 75 percent of the Secretary s estimate of the Medicare allowed charges for covered professional services furnished by the EP during the relevant payment year. The Medicare EHR incentive program for Eligible professionals (EPs) starts in 2011 and continues through 2016. Eligible professionals can participate for 5 years throughout the duration of the program. The last year to begin participation is 2014. For 2015 and later, Medicare eligible professionals who do not successfully demonstrate meaningful use will have a payment reduction in their Medicare reimbursement. The payment reduction starts at 1% and increases up to 5% for every year that a Medicare eligible professional does not demonstrate meaningful use. Hospital based physicians and Medicaid eligible professionals are not subject to possible payment reductions. Medicare EPs who cannot successfully demonstrate meaningful use will have a payment reduction in their Medicare reimbursement starting in 2015, even if they never received an incentive payment or only participate in the Medicaid EHR incentive program.
Medicaid Incentives for EPs EPs may receive payments up to $63,750 over six years Incentive based on up to 85% of state calculated global average costs for EHR Start no later than 2016 Achievement of MU not required in first year No payments made after 2021 No Medicaid penalty for failure to demonstrate Meaningful Use adopting, implementing or upgrading and EHR
Stages of Meaningful Use Meaningful Use (MU) requires 3 main components: Certified clinical system Temporary program in place Health Information Exchange Relaxed for Stage 1 Clinical quality reporting Relaxed for Stage 1 Three stages have been outlined and define increasing requirements to achieve and maintain Meaningful User status Stage 1 Stage 2 Stage 3 2011-2012 2013-2014 2015 and beyond Data Capture and Sharing Electronically capture data in coded format as well as report health information for tracking key clinical conditions Advanced Clinical Processes Guide and support care processes and coordination through the exchange of information Improved Outcomes Achieve improved performance through the effective adoption and use of care processes as well as advance key health system outcomes
Stage 1 Overview Stage 1 MU regulations provide 2 sets of requirements: Core Objectives 15 basic EHR functions that must be achieved by every EP Menu Activities 10 additional functions from which providers can choose any 5 to implement in Stage1 All Core and Menu activities will be required to achieve Stage 2 status Reporting mechanism in 2011 is Attestation Methodology with selected compliance reviews In 2012, CMS plans to have an electronic reporting mechanism Specifically, CMS will require EPs, EHs and CAHs to attest through a secure mechanism, such as through claims based reporting or an online portal.
Stage 1 MU Requirements (CORE) # Objective 1 CPOE (computerized practitioner order entry) 2 Drug drug and drugallergy interaction checks Eligible Professionals Eligible Hospitals and CAHs Measurement More than 30% of unique patients with at least one medication order entered using CPOE Functionality is enabled for the entire EHR reporting period 3 E Rx N/A More than 40% of all permissible prescriptions written are transmitted electronically using certified EHR 4 Record demographics More than 50% of all unique patients have demographics recorded as structured data: Preferred language, Insurance type., Gender, Race, Ethnicity, Date of birth, Date and cause of death (Hospital Only) 5 Active problem and diagnosis list More than 80% of all unique patients have at least one entry or an indication that no problems are known recorded as structured data 6 Active medication list More than 80% of all unique patients have at least one entry (or an indication that the patient is not currently prescribed any medication) recorded as structured data 7 Active medication allergy list More than 80% of all unique patients have at least one entry (or an indication that the patient has no known medication allergies) recorded as structured data
Stage 1 MU Requirements (CORE) # Objective Eligible Professionals Eligible Hospitals and CAHs Measurement 8 Record vital signs More than 50% of all unique patients age 2 and over have height, weight and blood pressure recorded as structured data: Height,Weight, Blood pressure, Calculate and display BMI, Plot and display growth charts for children 2 20 years, including BMI 9 Smoking status More than 50% of all unique patients 13 years old or have smoking status recorded as structured data 10 Clinical decision support 11 Report CMS measures 12 Patient copy of health information Implement one clinical decision support rule and ability to track compliance 6 measures from 44 (3 core, 3 selected) 15 measures from 44 2011: provide aggregate numerator, denominator, and exclusions through attestation 2012: electronically submit clinical quality measures More than 50% of all patients who request an electronic copy of their health information are provided it within 3 business days
Stage 1 MU Requirements (CORE) # Objective Eligible Professionals 13 Electronic copy of discharge instructions Eligible Hospitals and CAHs Measurement N/A More than 50% of all patients who are discharged and who request an electronic copy of their discharge instructions are provided it 14 Clinical summaries N/A Clinical summaries provided to patients for more than 50% of all office visits within 3 business days 15 Exchange patient information 16 Protect electronic health information Performed at least one test of certified EHR technology's capacity to electronically exchange key clinical information Conduct or review a security risk analysis, implement security updates as necessary, and correct identified security deficiencies as part of risk management process
Stage 1 MU Requirements (MENU) # Objective 1 Drug formulary checks 2 Advance directives* Eligible Professionals Eligible Hospitals and CAHs Measurement Function is enabled for the entire EHR reporting period N/A More than 50% of all unique patients 65 years old or older admitted have an indication of an advance directive status recorded 3 Lab test results More than 40% of all clinical lab tests results ordered for patients admitted to its inpatient or emergency department during the EHR reporting period whose results are either in a positive/negative or numerical format are incorporated in certified EHR technology as structured data 4 Patient lists i Generate at least one report listing patients of the EP, eligible hospital or CAH with a specific condition 5 Patient reminders N/A 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 6 Patient access to information N/A More than 10% of all unique patients are provided timely (available to the patient within 4 business days of being updated in the certified EHR technology) electronic access to their health information subject to the EP s discretion to withhold certain information * New in Final Rule i State has option to make required for Medicaid
Stage 1 MU Requirements (MENU) # Objective Eligible Professionals Eligible Hospitals and CAHs Measurement 7 Patient education* More than 10% of all unique patients are provided patientspecific education resources 8 Medication reconciliation Medication reconciliation is performed for more than 50% of transitions of care in which the patient is transitioned 9 Summary of care A summary of care record is provided for more than 50% of transitions of care and referrals 10 Immunization registries Performed at least one test of certified EHR technology's capacity to submit electronic data to immunization registries and follow up submission if the test is successful (unless none of the immunization registries have the capacity to receive the information electronically) 11 Public health data N/A Performed at least one test of certified EHR technology s capacity to provide electronic submission of reportable lab results to public health agencies and follow up submission if the test is successful (unless none of the public health agencies do not have the capacity to receive information electronically) 12 Syndromic surveillance data Performed at least one test of certified EHR technology's capacity to provide electronic syndromic surveillance data to public health agencies and follow up submission if the test is successful (unless the public health agencies do not have the capacity to receive information electronically) * New in Final Rule i State has option to make required for Medicaid
Stage 1 Timeline Considerations July 8 Proposed HIPAA enforcement rule by OCR October 1 (FY11) Medicare / Medicaid hospital incentive program begins April 2011 Initiate EP and EH Medicare attestation process May 2011 Medicare EHR incentives begin June 30, 2012 Many providers targeting 2012 to meet Stage 1 Meaningful Use Summer State Medicaid Programs launched Jan 2012 Permanent certification 2010 2011 July 1 ONC accepts applications for ONC-ATCB status Fall Temporary certified EHR software projected to be available & final rule on permanent process released January 1 Medicare / Medicaid incentive program for physicians begins & CMS program registration for EPs and EHs NOTE: EP incentives based on calendar years EH incentives based on Federal Fiscal Year (FFY) Stage 1 requires 90 consecutive days of MU compliance. Therefore - EHs have until June 30, 2011 - EPs have until Sept. 30, 2011 to meet and to meet and sustain MU and receive FY2011 incentive payments -
Certification Update The basis for all MU is a certified EHR The ONC has designated several Authorized Testing and Certifcation Bodies (ATCBs) ONC s list of Certified Health IT Product List http://onc chpl.force.com/ehrcert Several prominent vendors have already received certification, including: NextGen Complete Ambulatory EHR 5.6 SP1 eclinicalworks Complete Ambulatory EHR 8.0.48 17
Additional Assistance Available Regional Extension Center (REC) Program Initial government funding of assistance services (90% level) Just under $5,000 per Eligible Professional Michigan designated REC is the Michigan Center for Efficient Information Technology Adoption (M CEITA) M CEITA can provide assistance in MU Assessments EHR Selection EHR implementation EHR Monitoring EHR Optimization 18