Transcript CMS EHR Incentive Program

CMS EHR Incentive Program
Are you leaving substantial financial
incentives on the table?
Meaningful Use
ARRA specifies 3 components of Meaningful Use
Use of certified EHR in a meaningful way
Use of a certified EHR technology for electronic exchange
of health information to improve the quality of health care
Use of certified EHR technology to submit clinical quality
measures
Carrots and Sticks
The Medicare Carrot
Year
Adopt
2011
Max
Allowable
Charges
Adopt
2012
Adopt
2013
Adopt
2014
Adopt
2015+
2011
$18,000
$24,000
-
-
-
-
2012
$12,000
$16,000
$18,000
-
-
-
2013
$8,000
$10,666
$12,000
$15,000
-
-
2014
$4,000
$5,333
$8,000
$12,000
$12,000
-
2015
$2,000
$2,666
$4,000
$8,000
$8,000
-
2016
-
$2,000
$4,000
$4,000
-
2017
-
-
$0
$0
-
Total
$44,000
$44,000
$39,000
$24,000
$0
Health
Shortage
Area
+10%
+10%
+10%
+10%
$58,665
 Forfeit incentive for skipped year(s)
 Actual Payment based on 75% of allowable charges for each year to maximum
The Medicare Stick
99%
98%
97%
96%*
% Regular
Fee
Schedule
95%*
*If for 2018 and subsequent years, the proportion of eligible providers who are meaningful users is less than 75%, the
secretary of Health and Human Services may cut payment up to, but no more than 5%.
Significant hardship exceptions, granted on a case-by-case basis, may exempt an eligible provider who is not a meaningful
EHR user from payment adjustment for the year. Exemption is subject to annual renewal and will not be granted for more
than 5 years.
The EP Medicaid Carrot
•
•
•
•
Year
Adopt
2011
Adopt 2012
Adopt
2013
Adopt
2014
Adopt
2015
Adopt 2016
Adoption Year
Payment
$21,250
$21,250
$21,250
$21,250
$21,250
$21,250
Subsequent
Year Payment
Thru 2016
$8500 x 5
Thru 2017
$8500 x 5
Thru 2018
$8500 x 5
Thru 2019
$8500 x 5
Thru 2020
$8500 x 5
Thru 2021
$8500 x 5
Total Max
Payment
$63,750
$63,750
$63,750
$63,750
$63,750
$63,750
Actual Payments capped at 85% of EHR Expenditures Costs/yr
NO payment for Medicaid volume <30% in reporting period (90 days in 2011)
unless pediatrician, then 2/3 max payment for 20-30% Medicaid volume.
No requirement for consecutive year reporting until 2017.
No forfeiture for skipped years.
The Stick
The Rest of the Story
 Market Impact: ONC/CMS will publish lists of MC
Meaningful Users (providers and hospitals)
 Multiple private insurers have declared that future
contracting will reflect demonstrated Meaningful Use
 Board certification, MOC, state licensing may include
Meaningful Use status in the future
 But wait, there’s more….
Meaningful EHR Use supporting other programs?
Accountable
Care
Organization
Personal
Health
Record
Platforms
Chronic Care
Programs
Meaningful
Use of EHR
Systems
Patient
Centered
Medical
Home
Health
Information
Exchange
Payer Disease
/ Care
Management
Who is eligible?
Who is an Eligible Provider?
Medicare
Medicaid
MD, DO, DDS, DPS, OD,
DC/DCM
Same
Excludes all NP’s
Nurse Practitioners
Excludes all CNM’s
Certified Nurse Midwives
Excludes all PA’s
PA in FHCQ or in PA led RHC
– Both programs exclude hospital based providers.
• The determination of whether an Eligible Provider (EP) is a hospital-based provider is
determined individually for each EP is made on basis of the billed site of service code on
claims submitted to CMS.
• The rule defines hospital based providers as those who submit >90% services billed during
the CMS fiscal year(Oct – Sept) with place of service codes 21 (inpatient hospital) and/or 23
(emergency room).
– An NP might qualify for Medicaid Program, while physician in same practice qualifies for Medicare
incentive.
– Providers who already have EHRs are eligible
– One program switch allowed during program
– PQRI participation ok, Medicare eRx
Medicaid Volume Calculations
Medicaid Volume Calculations
•
Patient volume is calculated by dividing the number of Medicaid encounters
during any representative and continuous 90‐day period in the preceding calendar
year by the total number of encounters in that same period. In other words,
patient volume is a percentage derived from a fraction with a numerator of
Medicaid encounters and a denominator of total encounters.
•
CMS also indicates that determining patient volume is not an exact science:
– “We expect providers and States to make estimation in accordance with the methodologies we
established here. The estimation would need to be made with reasonable effort, using
verifiable data sources by the provider and the State.”
•
Retaining an audit trail: All patient volume data and calculations should be
supported and documented, for two reasons: first, to be fully prepared for an
audit, and second, to identify the specific data sources and record the processes
by which patient volume was determined.
•
Patient volume thresholds must be established each year of participation.
Meaningful Use Criteria
Criteria for Demonstration of Meaningful Use
Applies to both Medicare and Medicaid
Stage 1 Meaningful Use Criteria
Report on EHR
Functionality and
Interoperability Objectives
Report on 15 Core
Functionality and
Interoperability Measures
Report on 5/10 Menu
Functionality and
Interoperability Measures
Report on Clinical
Quality Measures
Report on 3 Core Clinical
Quality Measures (0r 3
Alternative Core Measures)
Report on 3/38 Menu
Clinical Quality Measures
The Medicaid EHR EP Incentive
What’s Different from Medicare?
 Easier qualification: NPs included; First year requirement only
“Adoption, Implementation, Upgrade” of certified EHR
technology; only 90 day attestation in second year for
demonstration of Meaningful Use
 Tougher eligibility: based on Medicaid patient volume: 30%
Medicaid minimum unless pediatrician, then 20%
 More complex registration: federal and state
 Better funding:
• Total of $64k maximum
• No financial loss for “late” EHR application, nor for skipping
report years, up to last payment year of 2021
• No reimbursement penalty for failure to adopt (vs 1% in 2015,
increasing to 5% in 2019 for Medicare Part B)
Medicaid High Level EP Process
Year 1
Eligible
Professional
registers with
CMS for the
EHR Incentive
Program
Medicaid
Validates
Eligible
Professional
Eligibility
EP Adopts,
Implements, or
Upgrades
certified EHR
system
Year 2-6
EP
demonstrates
meaningful
use of the
certified EHR
System
Medicaid
Certifies
Eligible
Professional
meets CMS
requirements
and distributes
incentive $$
Year 1: $21,250
Year 2-6: $8,500
per year qualified
Medicaid Program Year 1:
What does it mean to Adopt, Implement, or Upgrade
Adopt: To “acquire, purchase, or secure access to certified EHR technology.”
There is evidence that a provider demonstrated actual installation prior to the incentive, rather than
‘‘efforts’’ to install. We stated that this evidence would serve to differentiate between activities that
may not result in installation (for example, researching EHRs or interviewing EHR vendors) and actual
purchase/acquisition or installation. Acquisition or purchase does not necessarily mean the certified
EHR technology is installed and functioning.
Implementation: To “install or commence utilization of certified EHR technology.”
The provider has installed certified EHR technology and has started using the certified EHR technology
in his or her clinical practice. Implementation activities would include staff training in the certified EHR
technology, the data entry of their patients’ demographic data into the EHR, or establishing data
exchange agreements and relationships between the provider’s certified EHR technology and other
providers, such as laboratories and pharmacies.
Upgrade: To “expand the available functionality of certified EHR technology.”
The provider has added clinical decision support, e-prescribing functionality, or other enhancements
that facilitate the meaningful use of certified EHR technology. An example of upgrading that would
qualify for the EHR incentive payment would be upgrading from an existing EHR to a newer version that
is certified per the EHR certification criteria promulgated by the Office of the National Coordinator
(ONC) related to meaningful use. Upgrading may also mean expanding the functionality of an EHR in
order to render it certifiable per the ONC EHR certification criteria ( http://onc-chpl.force.com/ehrcert ).
It’s not just about the EHR and a list of
objectives and measures, it’s about
better care!
How do I find out more?
Don’t risk leaving substantial financial
incentives on the table!
Contact us at [email protected] for more
information on the CMS EHR Incentive Program
and how you can take meet the requirements
for Meaningful Use!