Transcript Payment Adjustments

Stage 2 Meaningful Use and 2013 PQRS
Updates Webinar
Barbara Connors, D.O., M.P.H.
Patrick Hamilton
Centers for Medicare & Medicaid Services
Philadelphia Regional Office
January 15, 2013
1
Physician Quality Reporting
System (PQRS)
2
PQRS – Who is an Eligible Professional?
EPs include:
• Physicians
• MD, DO, Doctor of Podiatric Medicine, Doctor of Optometry, Doctor
of Dental Surgery, Doctor of Dental Medicine, Doctor of Chiropractic
• Practitioners
• PA, NP, Clinical Nurse Specialist, CRNA, Certified Nurse Midwife,
Clinical SW, Clinical Psychologist, RD, Nutrition Professional,
audiologists
• Therapists:
• PT, OT, Qualified Speech-Language Therapist
3
PQRS Goals
• Align with other Medicare quality reporting
programs that have quality reporting
requirements
• Encourage eligible professionals into reporting for
the PQRS payment adjustment by providing
alternative means to avoiding the 2015 and 2016
payment adjustments
• Emphasize PQRS facilitates the overall
improvement in quality of care
4
CMS Quality and Reporting Program Alignment
• PQRS and the EHR Incentive Program Extension of
the PQRS-Medicare EHR Incentive Pilot to 2013
• Satisfactory reporting criteria for the 2014 PQRS
Incentive via the EHR-based reporting mechanism
and the criteria for meeting the CQM component
of meaningful use under the EHR Incentive
Program
• Requirement of Certified Electronic Health Record
Technology (CEHRT)
5
PQRS Group Practice Reporting Option (GPRO) & Medicare Shared Savings Program
• PQRS GPRO measures aligned with measures
under MSSP
• Under the Medicare Shared Savings Program,
ACOs successfully reporting measures under the
Medicare Shared Savings Program via the GPRO
Web Interface will not be subject to the PQRS
payment adjustments as long as the ACO
satisfactorily reports at least 1 measure
6
PQRS and the Value-based Payment Modifier
• The Value-based Payment Modifier and meeting the
criteria for satisfactory reporting for the 2013 PQRS
incentive and 2015 PQRS payment adjustment
– Group practices consisting of 100+ eligible
professionals, beginning in 2013 will be subject to
the Value-based Payment Modifier
Note: The 2015 and 2016 Value-based payment modifier
does not apply to ACOs
7
PQRS Reporting Periods
2015 PQRS payment adjustment:
• 6-month and 12-month reporting periods that coincide with
the 2013 PQRS incentive reporting periods
2016 PQRS payment adjustment
• 6-month and 12-month reporting periods that coincide with
the 2014 PQRS incentive reporting periods
2017 and subsequent PQRS payment adjustments
• 12-month reporting periods only
8
Incentive and Payment Adjustment Amounts
2013: 0.5% Incentive
2014: 0.5% Incentive
2015: 1.5% Payment Adjustment will be applied in
2015 based on reporting in 2013
2016: 2.0% Payment Adjustment will be applied in
2016 based on reporting in 2014
9
Reporting Mechanisms
Registry
• Expand use of the registry-based reporting mechanism to group practices
participating in the GPRO
EHR
• Beginning in 2014:
• All direct EHR products and EHR data submission vendor’s products must
be certified by the Office of the National Coordinator as CEHRT.
• Expand use of the EHR-based reporting mechanism to group practices
participating in the GPRO in 2014
GPRO Web Interface
• Adoption of the Medicare Shared Savings Program method of assignment
and sampling
10
Reporting Mechanisms
Administrative Claims
• A reporting mechanism under which an eligible professional
or group practice elects to have CMS analyze claims data to
determine which measures an eligible professional or group
practice reports
• For the 2015 PQRS payment adjustment only
• Under this reporting mechanism, eligible professionals or
group practices need to complete this election by the October
15, 2013 deadline
11
Benefits of Participating as an Individual Eligible Professional
There is no requirement to register to participate as an
individual
Exception: If an individual eligible professional wishes to elect the
administrative claims-based reporting mechanism to avoid the 2015 PQRS
payment adjustment, the eligible professional must affirmatively elect to be
analyzed under this reporting mechanism
• For eligible professionals in solo practices, participating
in PQRS as an individual is the only option for you
• Eligible professionals within your group practice may
freely choose which PQRS measures to report
12
How to Participate as an Individual
Choose a reporting period, reporting mechanism, and reporting
criterion
• Reporting Periods: 6-month, 12-month
• Reporting Mechanisms: Claims, Registry, EHR (EHR direct product and EHR
data submission vendor), and Administrative Claims (to avoid the 2015
PQRS payment adjustment only)
Choose the individual measures or measures groups you wish to
report
• Note: For help on choosing measures, please see the “How to Get
Started” section of the CMS PQRS website and contact the QualityNet
Help Desk if you still have questions
Start Reporting!
13
PQRS Payment Adjustment
For 2015 and subsequent years, a payment adjustment
with respect to covered professional services furnished
by an eligible professional will be applied if the eligible
professional does not satisfactorily submit data on
quality measures for covered professional services for
the quality reporting period for the year
Applicable adjustment amount:
 2015: 1.5%
 2016 and subsequent years: 2.0%
14
How to Avoid the Payment Adjustment in 2015
There are 3 ways an individual eligible professional may meet the criteria for
satisfactory reporting for the 2015 PQRS payment adjustment:
1.
2.
3.
Meet the criteria for satisfactory reporting for the 2013 PQRS Incentive
Report 1 valid measure or measures group using the claims, registry, or EHRbased reporting mechanisms
Elect to be analyzed under the administrative claims-based reporting
mechanism
Note: If participating in PQRS through another CMS program (such as the
Medicare Shared Savings Program), please check the program’s requirements for
information on how to simultaneously report under PQRS and the respective
program.
15
How to Avoid the Payment Adjustment in 2016
There is 1 way an eligible professional may meet the
criteria for satisfactory reporting for the 2016 PQRS
payment adjustment:
• Meet the criteria for satisfactory reporting for the 2014
PQRS Incentive
Note: We may establish additional ways to meet the
criteria for satisfactory reporting for the 2016 PQRS
payment adjustment in future rulemaking.
16
Definition of a PQRS Group Practice
• Group Practice = A single Tax Identification Number (TIN) with 2
or more eligible professionals, as identified by their individual
National Provider (NPI), who have reassigned their Medicare
billing rights to the TIN
• We have changed the definition of group practice to include
groups of 2-24 eligible professionals.
• Beginning in 2013, all group practices can participate in the PQRS
group practice reporting option (GPRO)
17
GPRO Reporting
Benefits of Participating as a Group
Practice:
Billing and reporting staff may report one set of quality
measures data on behalf of all eligible professionals within
a group practice, reducing the need to keep track of
eligible professionals’ reporting efforts separately
18
How to Participate as GPRO
1. Self-Nominate to Participate in
the PQRS Group Practice Reporting
Option (GPRO)
•
•
Group practices will submit a self-nomination statement via a CMS developed website
Deadline to Self-Nominate: October 15, 2013
2. Choose a Reporting Mechanism and Reporting Criterion Available
Reporting Mechanisms in 2013
•
GPRO Web Interface, Registry, and Administrative Claims
3. Beginning in 2014, the EHR-based reporting mechanism will also
be available for use under the GPRO
Start Reporting!
19
GPRO Payment Adjustment
For 2015 and subsequent years, a payment adjustment
with respect to covered professional services furnished by
an eligible professional will be applied if the eligible
professional does not satisfactorily submit data on quality
measures for covered professional services for the quality
reporting period for the year
• Applicable adjustment amount:
• 2015: 1.5%
• 2016 and subsequent years: 2.0%
20
How to Avoid the Payment Adjustment in 2016
There is 1 way a group practice may meet the criteria for
satisfactory reporting for the 2016 PQRS payment
adjustment:
Meet the criteria for satisfactory reporting for the 2014
PQRS Incentive under the GPRO
• Note: We may establish additional ways to meet the
criteria for satisfactory reporting for the 2016 PQRS
payment adjustment in future rulemaking
21
PQRS Measures
Total # of Individual PQRS Measures:
2013 there are 259 measures
2014 there are 288 measures
Consider Million Hearts measure
GPRO Measures:
18 measures, including 2 composites, for a total of 22 measures (same as the
measures available for reporting under the Medicare Shared Savings Program)
• Note: For help on selecting measures on which to report, please see the “How
to Get Started” section of the CMS PQRS website and contact the QualityNet
Help Desk if you still have questions
22
e-Prescribing Initiative
23
The eRx Incentive Program: Updates
• Most of the requirements for the remainder of the eRx Incentive
Program were established in the CY 2012 Medicare PFS final rule.
Please note that, although the self-nomination deadline to
participate in the PQRS GPRO was extended to October 15, the
self-nomination deadline to participate in the eRx GPRO remains
January 31.
Updates to the eRx Incentive Program:
• New Criteria for the eRx group practice reporting option (eRx
GPRO)
– Since, accordingly with PQRS, we expanded definition of group practice to include
groups of 2-24 eligible professionals, we finalized new criteria for becoming a
successful electronic prescriber under the eRx GPRO:
– Report the electronic prescribing measure for at least 75 instances during the applicable
2013 eRx incentive or 2014 eRx payment adjustment reporting period
24
eRx Incentives for 2012 and 2013
•
# of Eligible
Professionals
Most of
2012 Incentive (1.0% of MPFS)
2013 Incentive (0.5% of MPFS)
the requirements for the remainder of the eRx Incentive
Individual
(Reporting viawere
Report
the eRx measure’s
at
Report the eRx measure’s
numerator
for at
Program
established
innumerator
the CYfor2012
Medicare
PFS final
rule.
Claims, Registry, or Direct
least 25 unique denominator-eligible visits
least 25 unique denominator-eligible visits
Please
note that,
the
self-nomination
EHR & EHR
data
betweenalthough
January 1, 2012
and December
31,
between deadline
January 1, 2013to
and December
submission vendor)
31, 2013
participate in2012
the PQRS GPRO was extended
to October 15, the
self-nomination deadline to participate in the eRx GPRO remains
2-24 EPs (Reporting via
N/A
Report the eRx measure’s numerator for at
January
31.
Claims, Registry,
or Direct
least 75 unique denominator-eligible visits
EHR & EHR data
between January 1, 2013 and December
Updates
to
the
eRx
Incentive
Program:
submission vendor)
31, 2013
• New Criteria for the eRx group practice reporting option (eRx
25-99 EPs
(Reporting via
Report the eRx measure’s numerator for at
Report the eRx measure’s numerator for at
GPRO)
Claims, Registry, or Direct
least 625 unique denominator-eligible visits
least 625 unique denominator-eligible visits
Since, accordingly
with
PQRS,
we and
expanded
of group
practice
to include
EHR & EHR–data
between
January
1, 2012
Decemberdefinition
31,
between
January
1, 2013 and
December
submission vendor)
2012
31, 2013
groups of 2-24
eligible professionals, we finalized new
criteria for becoming a
successful electronic prescriber under the eRx GPRO:
– Reportviathe electronic
prescribing
measure
for atforleast
the applicable
100+ EPs (Reporting
Report the
eRx measure’s
numerator
at 75 instances
Report theduring
eRx measure’s
numerator for at
2013
eRx
incentive
or
2014
eRx
payment
adjustment
reporting
period
Claims, Registry, or Direct
least 2500 unique denominator-eligible visits
least 2500 unique denominator-eligible
EHR & EHR data
between January 1, 2012 and December 31,
visits between January 1, 2013 and
submission vendor)
2012
December 31, 2013
25
eRx Payment Adjustments for 2014 (-2.0% of MFPS)
Reporting
Individual EPs
2-24 EPs
• Most of the requirements for the
Period
25-99 EPs
100+ EPs
remainder of the eRx Incentive
Program
were established in the CYReport
2012theMedicare
PFS final rule.
12 month
Reports on the 2011 eRx N/A
eRx
Report the eRx
(Reporting
measure’s
measure’s numerator
measure’s
Please
notenumerator
that, although the self-nomination
deadline
tonumerator at
via Claims, code at least 25 times
at least 625 times for least 2500 times for
participate
in
the
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GPRO
was
extended
to October 15, the
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encounters associated encounters associated
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least
with atin
least
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the
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the denominator
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codes between
between January 1,
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January 1, 2012 and
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to the
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December 31, 2012
2012 (same criteria for
the 2012 eRx
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the 2012(eRx
eRx incentive)
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successful
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least between
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and
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times
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1, 2013period
and
2013 and June 30, 2013
2013
incentive
2014 eRx
payment
adjustment
reporting
January 1, 2013 June 30, 2013
and June 30,
2013
26
Hardship Exemptions for eRx Payment Adjustments
Significant Hardship Exemption Category
Method of
Submission
Deadline for
2013
Exemption
Deadline for
2014
Exemption
• Most of the requirements for the remainder of the eRx Incentive
Program were established in the CY 2012
MedicareExtended
PFS final
rule.
The eligible professional or group practice practices in a rural area with
Web-based
to
June 30,
limited high
speed internet
Communication
January 31,to 2013
Please
noteaccess
that, although the self-nomination
deadline
Support Page
2013
participate in the PQRS GPRO was extended
to October
15, the
The eligible professional or group practice practices in an area with
Web-based
Extended to
June 30,
limited available
pharmacies for electronic
prescribing
2013
self-nomination
deadline
to participateCommunication
in the eRx January
GPRO31,remains
Support Page
2013
January 31.
The eligible professional or group practice is unable to electronically
Web-based
Extended to
June 30,
prescribe due to local, state, or Federal law or regulation
January 31,
2013
Updates to the eRx Incentive Program: Communication
Support Page
2013
The•eligible
professional
or group
limited
prescribing
Extended to(eRx
June 30,
New
Criteria
forpractice
thehas
eRx
group
practiceWeb-based
reporting option
activity, as defined by an eligible professional generating fewer than 100 Communication January 31,
2013
GPRO)
prescriptions
during a 6-month reporting period
Support Page
2013
2013 Adjustment:
Eligible
professionals
or group
practices
who
EHR Incentive
31, to include
June 30,
– Since,
accordingly
with
PQRS,
we expanded
definition
of groupJanuary
practice
achieve meaningful use during the 2013 12- and 6-month eRx payment
Program’s
2013
groups of 2-24 eligible professionals, we finalized
new criteria for
becoming 2013
a
adjustment reporting periods (that is, January 1, 2011 – June 30, 2012); Registration/
successful
electronicorprescriber
under
eRx GPRO:
2014 Adjustment:
Eligible professionals
group practices
who the
achieve
Attestation Page
meaningful
duringthe
the 2014
12- andprescribing
6-month eRx
paymentfor at least 75 instances during the applicable
– useReport
electronic
measure
adjustment reporting
periods
(that is,
1, 2012
– June adjustment
30, 2013)
2013 eRx
incentive
orJanuary
2014 eRx
payment
reporting period
Eligible professionals or group practices who
demonstrate intent to participate in the EHR Incentive Program and
adoption of Certified EHR Technology
EHR Incentive
Program’s
Registration/
Attestation Page
January 31,
2013
June 30,
2013
27
eRx Informal Review Process
• Implementation of an eRx Informal Review process
• How to Request an eRx Informal Review for the 2012 or 2013
eRx Incentives:
– Informal Review Request Method: email
– Deadline: 90 days following the receipt of the applicable full year eRx
feedback reports
• How to Request an eRx Informal Review for the 2013 or 2014
eRx Payment Adjustments:
• Informal Review Request Method: email
• Deadline:
– For the 2013 eRx payment adjustment: February 28, 2013
– For the 2014 eRx payment adjustment: February 28, 2014
28
HITECH Meaningful Use:
Stage 2 & Payment
Adjustments
29
HITECH Meaningful Use Stage 2 Final Rule
• Changes to Stage 1 of meaningful use
• Stage 2 of meaningful use
• New clinical quality measures
• New clinical quality measure reporting mechanisms
• Payment adjustments and hardships
• Medicare Advantage program changes
• Medicaid program changes
30
Changes to Stage 1: CPOE
Current Stage 1 Measure
Denominator=
Unique patient
with at least
one medication
in their
medication list
New Stage 1 Option
Denominator=
Number of
orders during
the EHR
Reporting
Period
This optional CPOE denominator is available in 2013 and beyond for Stage 1
31
Changes to Stage 1: Vital Signs
Current Stage 1 Measure
Age Limits=
Age 2 for
Blood Pressure
& Height/
Weight
Exclusion=
All three
elements not
relevant to
scope of
practice
New Stage 1 Measure
Age Limits=
Age 3 for Blood
Pressure, No age
limit for Height/
Weight
Exclusion=
Blood
pressure to be
separated
from height
/weight
The vital signs changes are optional in 2013, but required starting in 2014
32
Changes to Stage 1: Testing of HIE
Current Stage 1 Measure
One test of
electronic
transmission of
key clinical
information
Stage 1 Measure Removed
Requirement
removed
effective 2013
The removal of this measure is effective starting in 2013
33
Changes to Stage 1: E-Copy & Online Access
Current Stage 1 Objective
Objective=
Provide patients
with e-copy of
health
information upon
request
Provide electronic
access to health
information
New Stage 1 Objective
Objective=
Provide patients
the ability to
view online,
download and
transmit their
health
information
• The measure of the new objective is 50% of patients have accessed their
information; there is no requirement that 5% of patients do access their
information for Stage 1.
• The change in objective takes effect in 2014 to coincide with the 2014
certification and standards criteria
34
Changes to Stage 1: Public Health Objectives
Current Stage 1 Objectives
New Stage 1 Addition
Immunizations
Reportable Labs
Addition of
“except where
prohibited” to
all three
objectives
Syndromic
Surveillance
This addition is for clarity purposes and does not change the Stage 1 measure for these
objectives.
35
Stages of Meaningful Use
Advanced
clinical
processes
Data
capturing
and sharing
Improved
outcomes
Stage 3
Stage 2
Stage 1
36
Meaningful Use: Changes from Stage 1 to Stage 2
Stage 1
Stage 2
Eligible Professionals
Eligible Professionals
15 core objectives
17 core objectives
5 of 10 menu objectives
3 of 6 menu objectives
20 total objectives
20 total objectives
Eligible Hospitals &
CAHs
Eligible Hospitals &
CAHs
14 core objectives
16 core objectives
5 of 10 menu objectives
3 of 6 menu objectives
19 total objectives
19 total objectives
37
2014 Changes
1. EHRs Meeting ONC 2014 Standards – starting in 2014, all EHR
Incentive Programs participants will have to adopt certified EHR
technology that meets ONC’s Standards & Certification Criteria
2014 Final Rule
2. Reporting Period Reduced to Three Months – to allow
providers time to adopt 2014 certified EHR technology and
prepare for Stage 2, all participants will have a three-month
reporting period in 2014.
38
Stage 2 EP Core Objectives
EPs must meet all 17 core objectives:
Core Objective
Measure
1. CPOE
Use CPOE for more than 60% of medication, 30% of laboratory, and
30% of radiology
2. E-Rx
E-Rx for more than 50%
3. Demographics
Record demographics for more than 80%
4. Vital Signs
Record vital signs for more than 80%
5. Smoking Status
Record smoking status for more than 80%
6. Interventions
Implement 5 clinical decision support interventions + drug/drug and
drug/allergy
7. Labs
Incorporate lab results for more than 55%
8. Patient List
Generate patient list by specific condition
9. Preventive Reminders
Use EHR to identify and provide reminders for preventive/follow-up
care for more than 10% of patients with two or more office visits in
the last 2 years
39
Stage 2 EP Core Objectives
EPs must meet all 17 core objectives:
Core Objective
Measure
10. Patient Access
Provide online access to health information for more than 50% with
more than 5% actually accessing
11. Visit Summaries
Provide office visit summaries for more than 50% of office visits
12. Education Resources
Use EHR to identify and provide education resources more than 10%
13. Secure Messages
More than 5% of patients send secure messages to their EP
14. Rx Reconciliation
Medication reconciliation at more than 50% of transitions of care
15. Summary of Care
Provide summary of care document for more than 50% of transitions
of care and referrals with 10% sent electronically and at least one
sent to a recipient with a different EHR vendor or successfully
testing with CMS test EHR
16. Immunizations
Successful ongoing transmission of immunization data
17. Security Analysis
Conduct or review security analysis and incorporate in risk
management process
40
Stage 2 EP Menu Objectives
EPs must select 3 out of the 6:
Menu Objective
Measure
1. Imaging Results
More than 10% of imaging results are accessible through Certified
EHR Technology
2. Family History
Record family health history for more than 20%
3. Syndromic Surveillance
Successful ongoing transmission of syndromic surveillance data
4. Cancer
Successful ongoing transmission of cancer case information
5. Specialized Registry
Successful ongoing transmission of data to a specialized registry
6. Progress Notes
Enter an electronic progress note for more than 30% of unique
patients
41
Aligning CQMs Across Programs
• CMS’s commitment to alignment includes finalizing the same
CQMs used in multiple quality reporting programs for reporting
beginning in 2014
• Other programs include Hospital IQR Program, PQRS, CHIPRA,
and Medicare SSP and Pioneer ACOs
Hospital
Inpatient
Quality
Reporting
Program
Physician
Quality
Reporting
System
Children’s Health
Insurance
Program
Reauthorization
Act
Medicare
Shared
Savings
Program and
Pioneer ACOs
42
Clinical Quality Measures
• CQM reporting will remain the same through 2013.
•
44 EP CQMs
•
•
•
3 core or alternate core (if reporting zeroes in the core) plus 3 additional CQMs
Report minimum of 6 CQMs (up to 9 CQMs if any core CQMs were zeroes)
15 Eligible Hospital and CAH CQMs
•
Report all 15 CQMs
• In 2012 and continued in 2013, there are two reporting methods available for
reporting the Stage 1 measures:
•
•
Attestation
eReporting pilots
•
Physician Quality Reporting System EHR Incentive Program Pilot for EPs
•
eReporting Pilot for eligible hospitals and CAHs
• Medicaid providers submit CQMs according to their state-based submission
requirements.
43
Electronic Submission of CQMs Beginning in 2014
• Beginning in 2014, all
Medicare-eligible providers
in their second year and
beyond of demonstrating
meaningful use must
electronically report their
CQM data to CMS.
• Medicaid providers will
report their CQM data to
their state, which may
include electronic
reporting.
44
CQM Selection and HHS Priorities
All providers must select CQMs from at least 3 of the 6 HHS
National Quality Strategy domains:
 Patient and Family Engagement
 Patient Safety
 Care Coordination
 Population and Public Health
 Efficient Use of Healthcare Resources
 Clinical Processes/Effectiveness
45
Changes to CQMs Reporting
Beginning in 2014
Prior to 2014
Report 9 out of 64 CQMs
Report 6 out of
44 CQMs
EPs
Eligible
Hospitals
and CAHs
• 3 core or alt.
core
• 3 menu
Report 15 out
of 15 CQMs
EPs
Eligible
Hospitals
and CAHs
Selected CQMs must cover at
least 3 of the 6 NQS domains
Recommended core CQMs:
9 for adult populations
9 for pediatric populations
Report 16 out of 29 CQMs
Selected CQMs must cover at
least 3 of the 6 NQS domains
46
Payment Adjustments
• The HITECH Act stipulates that for Medicare EP, subsection (d)
hospitals and CAHs a payment adjustment applies if they are
not a meaningful EHR user.
• An EP, subsection (d) hospital or CAH becomes a meaningful EHR
user when they successfully attest to meaningful use under
either the Medicare or Medicaid EHR Incentive Program
Adopt, implement and upgrade ≠ meaningful use
A provider receiving a Medicaid incentive for AIU would still be
subject to the Medicare payment adjustment.
47
Payment Adjustments
% Adjustment shown below assumes less than 75% of EPs are meaningful users for CY
2018 and subsequent years
2015
2016
2017
2018
2019
2020+
EP is not subject to the payment adjustment for eRx in 2014
99%
98%
97%
96%
95%
95%
EP is subject to the payment adjustment for e-Rx in
2014
98%
98%
97%
96%
95%
95%
% Adjustment shown below assumes more than 75% of EPs are meaningful users for
CY 2018 and subsequent years
2015
2016
2017
2018
2019
2020+
EP is not subject to the payment adjustment for eRx in 2014
99%
98%
97%
97%
97%
97%
EP is subject to the payment adjustment for e-Rx in
2014
98%
98%
97%
97%
97%
97%
48
EP EHR Reporting Period
Payment adjustments are based on prior years’ reporting periods. The length of
the reporting period depends upon the first year of participation.
•For an EP who has demonstrated meaningful use in 2011 or 2012:
Payment Adjustment Year
2015
2016
2017
2018
2019
2020
Based on Full Year EHR Reporting Period
2013
2014*
2015
2016
2017
2018
* Special 3 month EHR reporting period
To Avoid Payment Adjustments:
EPs must continue to demonstrate meaningful use every year to avoid payment
adjustments in subsequent years.
49
EP EHR Reporting Period
• For an EP who demonstrates meaningful use in 2013 for the first time:
Payment Adjustment Year
2015
Based on 90 day EHR Reporting Period
2013
Based on Full Year EHR Reporting Period
2016
2017
2018
2019
2020
2014*
2015
2016
2017
2018
* Special 3 month EHR reporting period
To Avoid Payment Adjustments:
EPs must continue to demonstrate meaningful use every year to avoid payment
adjustments in subsequent years.
50
EP EHR Reporting Period
EP who demonstrates meaningful use in 2014 for the first time:
Payment Adjustment Year
2015
Based on 90 day EHR Reporting Period
2014*
Based on Full Year EHR Reporting Period
* Special 3 month EHR reporting period
2016
2017
2018
2019
2020
2015
2016
2017
2018
2014
*In order to avoid the 2015 payment adjustment the EP must attest no later than
October 1, 2014, which means they must begin their 90 day EHR reporting period no
later than July 1, 2014.
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Payment Adjustments for Providers Eligible for Both Programs
Eligible for both programs?
If you are eligible to participate in both the Medicare and Medicaid EHR
Incentive Programs, you MUST demonstrate meaningful use according to the
timelines in the previous slides to avoid the payment adjustments. You may
demonstrate meaningful use under either Medicare or Medicaid.
Note: Congress mandated that an EP must be a meaningful user in order to
avoid the payment adjustment; therefore receiving a Medicaid EHR incentive
payment for adopting, implementing, or upgrading your certified EHR
Technology would not exempt you from the payment adjustments.
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EP Hardship Exceptions
EPs can apply for hardship exceptions in the following categories:
1.
2.
3.
Infrastructure
EPs must demonstrate that they are in an area
without sufficient internet access or face
insurmountable barriers to obtaining
infrastructure (e.g., lack of broadband).
New EPs
Newly practicing EPs who would not have had
time to become meaningful users can apply for a
2-year limited exception to payment adjustments.
4. EPs must demonstrate that they meet the
following criteria:
•
Lack of face-to-face or telemedicine interaction
with patients
•
Lack of follow-up need with patients
5.
EPs who practice at multiple locations must
demonstrate that they:
Lack of control over availability of CEHRT for more
than 50% of patient encounters
•
Unforeseen Circumstances
Examples may include a natural disaster or other
unforeseeable barrier.
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EP Hardship Exceptions
EPs whose primary specialties are anesthesiology, radiology or
pathology:
As of July 1st of the year preceding the payment adjustment year,
EPs in these specialties will receive a hardship exception based
on the 4th criteria for EPs
EPs must demonstrate that they meet the following criteria:
• Lack of face-to-face or telemedicine interaction with patients
• Lack of follow-up need with patients
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Applying for Hardship Exceptions
 Applying: EPs, eligible hospitals, and CAHs must apply for hardship exceptions to avoid the
payment adjustments.
 Granting Exceptions: Hardship exceptions will be granted only if CMS determines that
providers have demonstrated that those circumstances pose a significant barrier to their
achieving meaningful use.
 Deadlines: Applications need to be submitted no later than April 1 for hospitals, and July 1
for EPs of the year before the payment adjustment year; however, CMS encourages earlier
submission
•For More Info: Details on how to apply for a hardship exception will be posted on the CMS EHR
Incentive Programs website in the future:
•www.cms.gov/EHRIncentivePrograms
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Medicaid-Specific Changes
• Proposed expanded definition of a Medicaid
encounter:
• Include any encounter with an individual receiving
medical assistance under 1905(b), including
Medicaid expansion populations and zero pay
Medicaid claims
• Permit inclusion of patients on panels seen within 24
months instead of just 12
• Permit patient volume to be calculated using last 12
months, instead of on the CY
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Stage 2 Resources
• CMS Stage 2 Webpage:
• http://www.cms.gov/Regulations-andGuidance/Legislation/EHRIncentivePrograms/Stage_2.html
Links to the Federal Register
Tipsheets:
– Stage 2 Overview
– 2014 Clinical Quality Measures
– Payment Adjustments & Hardship Exceptions (EPs & Hospitals)
– Stage 1 Changes
– Stage 1 vs. Stage 2 Tables (EPs & Hospitals)
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Contact Info
Barbara Connors, D.O., M.P.H.
Chief Medical Officer, Region III
Centers for Medicare & Medicaid Services
Philadelphia Regional Office
Phone: (215) 861-4218
E-mail: [email protected]
Patrick Hamilton
Health Insurance Specialist
Centers for Medicare & Medicaid
Services
Philadelphia Regional Office
Phone: (215) 861-4097
E-mail: [email protected]
CMS is now on Twitter!!
Follow us at @CMSGOV
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