CMS Medicare and Medicaid Programs; Electronic Health Record Incentive Program; Final Rule Overview 1 On demand webinars are best heard through a headset or earphones (ipod for example) that can be plugged into your laptop or desktop. Download the handouts that accompany this presentation. Other related links and documents found in Final Rules section in the subscribers library. 2 Bill Oravecz is Managing Partner of WTO Associates LLC. His engagement teams help various healthcare and life science organizations by enhancing their effectiveness and productivity through their 5-Point Analysis Approach. WTO s Healthcare IT Practice helps clients with the Adoption of EHR Systems, Meaningful Use, Privacy & Security of patient records and compliance issues. Bill has 26 years of healthcare technology and IT solutions delivery experience through various senior management positions with major IT services and healthcare technology firms. He holds a MBA from University of Connecticut and a SM in Radiology from The Pritzker School of Medicine at the University of Chicago. You can reach him at: woravecz@wto-associates.com 3
What is in the Final Rule Defines Meaningful Use (MU) for Stage 1 Identifies Clinical Quality Measures (CQM) for Stage 1 Defines Eligible Professional (EP) and Eligible Hospital/Critical Access Hospital (CAH) Defines Hospitalbased EP Details Medicare Fee-For-Service (FFS) EHR Incentive Program Details Medicare Advantage (MA) EHR Incentive Program Details Medicaid EHR Incentive Program Collection of Information Analysis (Paperwork Reduction Act) Regulatory Impact Analysis 4 What the Final Rule Does Synchronizes MU criteria across CMS programs as much as possible Works in tandem with the ONC Certification and Standards final rules Architected from HIT Policy Committee recommendations, National Committee on Vital and Health Statistics (NCVHS) hearings, Office of Management and Budget (OMB) comments, and Public Comments Coordinates with existing CMS quality initiatives Provides a foundation for a stages of EHR implementation 5 February, 2009 President signs the American Recovery & Reinvestment Act (ARRA) which includes the HITECH Act May 2009 HIT Policy committee formed and charged with developing recommendation s for meaningful use December 2009 CMS releases Notice of Proposed Rulemaking January, 2010 Notice of Proposed Rulemaking published in Federal Register March, 2010 Comment period ends for Notice of Proposed Rulemaking 6
Use certified EHR technology in a meaningful manner Use certified EHR technology connected in a manner that provides for health information exchange to improve the quality of care Using certified EHR technology, the provider submits information on clinical quality measures 7 Certified EHR is a qualified EHR approved by an ONC- recognized certifying body A qualified EHR is an electronic record of health-related information on an individual that includes patient demographic and clinical health information, such as medical history and problem lists and has the capacity to: Provide clinical decision support Support physician order entry Capture and query information relevant to healthcare quality Exchange electronic health information with, and integrate such information from, other sources 8 Physicians Chiropractors Osteopathic Physicians Eligible for Incentives Optometrists Dentists Podiatrists 9
Must furnish, on average, at least 20 hours/week of patient-care services and be employed by the qualifying MA organization OR Must be employed by, or be a partner of, an entity that through contract with the qualifying MA organization furnishes at least 80 percent of the entity s Medicare patient care services to enrollees of the qualifying MA organization 10 Physicians Physician Assistants operating at an FQHC/RHC Pediatricians, Eligible for Incentives Nurse Practitioners Dentists Certified Nurse Midwives 11 Hospital -based physicians are NOT eligible for any of the incentive programs. A hospital-based physician furnishes 90% or more of their services in either the inpatient or emergency department of a hospital. 12
2011 2013 2015 13 Meet certain objectives/measures, 80% of patients must have records in the certified EHR technology EPs must report on 20 of 25 MU objectives Reporting Period 90 days for first year; one year subsequently 14 1. Improving quality, safety, efficiency and reducing health disparities. 2. Engage patients and families in their healthcare 3. Ensure adequate privacy and security protections for personal health information. 4. Improve care coordination. 5. Improving population and public health. 15
15 Core Objectives - all must be met 10 Menu Objectives - choose 5 16 1. Denominator is all patients seen during the EHR reporting period regardless if medical records are kept using certified EHRs 2. Denominator is actions or subsets of patients seen during the EHR reporting period and records are kept using certified EHRs 17 Some objectives are not applicable to every provider s practice Practices would not have any eligible patients or actions to measure denominators Exclusions do not count against deferred Menu choices 18
50% of total patient encounters at certified EHR locations Base all MU measures on encounters at certified EHR locations 19 2011 demonstrate MU by submiting aggregate CQM numerator, denominator, and exclusion data to CMS or the States by attestation. 2012 - demonstrate MU by electronically submiting aggregate CQM numerator, denominator, and exclusion data to CMS or the States. 20 Medicare FFS Medicare Advantage Medicaid 21
Register via the EHR Incentive Program website Have a National Provider Identifier (NPI) Medicaid providers may adopt, implement, or upgrade in their first year Enroll in Medicare FFS, MA, or Medicaid Program, may only switch once after initial election Use certified EHR technology to demonstrate Meaningful Use All Medicare providers and Medicaid eligible hospitals must be enrolled in PECOS 22 States will verify provider eligibility through CMS States will ask providers for additional information: Patient Volume, Licensure, A/I/U or Meaningful Use, Certified EHR Technology 23 January 2011 Medicaid providers, States may Jan. 2011 launch their Registration programs if for EHR they so Incentive Programs choose begins April 2011 Attestation for the Medicare EHR Incentive Program begins May 2011 EHR incentive payments begin February 29, 2012 Last day for EPs to register and attest to receive an incentive payment for CY 2011 24
2015 Medicare payment adjustments begin for EPs and EHs that are not meaningful users of EHR technology 2016 Last year to receive a Medicare EHR incentive payment; Last year to initiate participation in Medicaid EHR Incentive Program 2021 Last year to receive Medicaid EHR incentive payment 25 Thank you for joining us! 26