Transcript Texas Medicaid EHR Stimulus Funding

Making Meaning of
“Meaningful Use”- EHR,
Medicare and Texas
Medicaid Funding
Presented by Pamela McNutt
Sr. VP & CIO
Methodist Health System
1
Medicaid EHR Incentives – Eligibility

Acute care and critical access hospitals

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Includes children’s hospitals
Excludes Psychiatric, Rehab, Long Term Care and Cancer
hospitals
Must have at least 10% Medicaid volume
May seek both Medicare or Medicaid incentives
Eligible Providers

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Physicians, pediatricians, dentists, certified nurse midwives
nurse practitioners, physician assistants in special rural
programs
Cannot be hospital based (ie. radiology, lab, ED)
Must have at least 30% Medicaid volume (20% for Pediatricians)
Must choose either Medicare or Medicaid but can switch once
2
Medicaid EHR Incentives – How to Qualify

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Possess a Certified Complete EHR system
Report quality metrics
Meet Meaningful Use by demonstrating functionality in
your EHR systems split into three increasingly difficult
stages
Progression of Meaningful Use Stages by Payment Year
First Fiscal
Year
2011
2012
2013
2014
Payment Year
2011
2012
2013
2015
2015 +**
Stage 1
Stage 1
Stage 2
Stage 2
Stage 3
Stage 1
Stage 1
Stage 2
Stage 3
Stage 1
Stage 2
Stage 3
Stage 1
Stage 3
2015 +*
* Avoids payment adjustments only for EPs in the Medicare EHR Incentive Program.
** Stage 3 criteria of meaningful use or a subsequent update to the criteria if one is established through rulemaking.
Stage 3
3
Texas Medicaid EHR Incentives – How it is paid

Incentive payments for use of electronic health records
scaled over a three-year period starting in CMS FY 2011

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50%, 40%, 10% respectively
Year 1 payment is for adoption, implementation, upgrade
or adoption of Certified EHR technology and does not
require achievement of Meaningful Use
Year 2 – 3 requires demonstration of meaningful use of
certified EHR technology and reporting of quality metrics

Will be the same as the Medicare in Texas
4
Texas Medicaid EHR Incentives – Example of Payments
A 500 bed hospital with significant Medicaid and charity care volume
showing timing of payments based on achievement of Meaningful Use
(AIU = adopting, implementing or upgrading Certified EHRs)
Calendar
Year
Start in
2011
MU
Stage
Start in
2012
MU
Stage
Start in
2013
MU
Stage
2011
$2,400,000
AIU
2012
$1,920,000
2013
Start in
2014
MU
Stage
1
$2,400,000
AIU
$ 480,000
2
$ 1,920,000
2014
---------
2
2015
----------
2016
1
$2,400,000
AIU
$ 480,000
2
$ 1,920,000
2
$2,400,000
AIU
3
-----------
3
$ 490,000
3
$1,920,000
----------
3
-----------
3
-------------
3
2017
----------
3
-----------
3
-------------
2018
----------
3
-----------
3
-------------
Total
$4,800,000
$ 4,800,000
$ 4,800,000
Start in
2015
MU
Stage
3
$2,400,000
AIU
$ 490,000
3
$1,920,000
3
-------------
3
3
-------------
3
$4,800,000
Start in
2016
MU
Stage
3
$2,400,000
AIU
$490,000
3
$1,920,000
3
--------------
3
$490,000
3
$4,800,000
$4,800,000
5
Texas Medicaid EHR Incentives – Physician Payments
“Allowable Costs” has been recently re-defined to be a flat
rate rather than an accounting of actual expenses spent on
EHR technology. The EHR product’s Certification # will be
required for the attestation.
6
Texas Medicaid EHR Incentives – Important Dates

CMS registration for the stimulus programs - January 3,
2011


Must register for both Medicare and Medicare on CMS site
Registration does not mean you have to attest to meaningful use
this year
Texas registration and application for Year 1 funds –
opens February 14
 Year 1 payments start in May 2011
 Year 2 and 3 will required demonstration of Meaningful
Use
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
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90 contiguous days Year 2
Full year in Year 3
You can “sit out” a year between payment years then get
back in if needed for compliance to MU
7
Medicare Stimulus
Funding
Presented by David S. Muntz
Sr. VP & CIO
Baylor Health Care System
Attribution: Much of the material presented is available at
http://healthit.hhs.gov
8
Medicare EHR Incentives –
Eligibility

Eligible Hospitals
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Eligible Providers
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"Subsection (d) hospitals" in the 50 states or DC that are paid under the Inpatient Prospective Payment System (IPPS)
Critical Access Hospitals (CAHs)
• Qualifying CAHs may receive incentive payments for up to four payment years beginning with cost reporting periods
that begin in FY 2011. The year with a cost reporting period that begins in FY 2015 is the last payment year for
which a qualifying CAH can receive incentive payments as a meaningful EHR user.
• CAHs can qualify to receive payments from both the Medicare and Medicaid EHR Incentive Programs.
Medicare Advantage (MA-Affiliated) Hospitals
A payment year is the federal fiscal year (October 1 - September 30) starting in fiscal year 2011 (i.e. October 1, 2010)
Doctor of Medicine, Doctor of Osteopathy, Dental surgeon, Doctor of Dental Medicine, Podiatrist, Optometrist,
Chiropractor
Cannot be hospital based (e.g. radiology, lab, ED)
Must choose either Medicare or Medicaid but can switch once
A payment year is a calendar year starting in 2011
Additional incentive for eligible professionals who provide services in a Health Professional Shortage Area (HSPA)
Both
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For the first payment year, any continuous 90-day period within a calendar year
For the second, third, and fourth payment year, the calendar year
If you skip a year, you cannot make it up
To get the maximum payment, you must begin activities in 2012
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Medicare EHR Incentives –
How to Qualify

Possess a Certified Complete EHR system.
 Report quality metrics.
 Meet Meaningful Use by demonstrating
functionality in your EHR systems split into
three increasingly difficult stages.

Important! For 2015 and later, Medicare
eligible professionals, eligible hospitals, and
CAHs that do not successfully demonstrate
meaningful use will have a payment
adjustment in their Medicare reimbursement.
10
Progression of Meaningful Use Stages
by Payment Year
First Fiscal
Year
2011
2012
2013
2014
Payment Year
2011
2012
2013
2015
2015 +**
Stage 1
Stage 1
Stage 2
Stage 2
Stage 3
Stage 1
Stage 1
Stage 2
Stage 3
Stage 1
Stage 2
Stage 3
Stage 1
Stage 3
2015 +*
Stage 3
* Avoids payment adjustments only for EPs in the Medicare EHR Incentive Program.
** Stage 3 criteria of meaningful use or a subsequent update to the criteria if one is established through rulemaking.
11
Medicare EHR Incentives For Eligible Hospitals –
How it is paid
The payment formula for a hospital (payment year) is equal
to the product of the following (get your CFO involved):
1)
Initial amount – The sum of the base amount* specified plus the
discharge related** amount for a 12 month period selected by the
Secretary with respect to such payment year
2)
The Medicare share*** for the hospital for a period selected by
the Secretary with respect to such payment year
3)
The transition factor**** for the hospital for the payment year
*The base amount specified in the subparagraph is $2 million
** The discharge related amount is as follows: 1 - 1,149th discharge, $0; 1,150th through
the 23,000th discharge, $200; any discharge greater than the 23,000th, $0.
*** The Medicare share specified is equal to a fraction determined by the number
of Medicare inpatient bed days and other specific factors
**** The transition factor is determined by multiplying first payment year by:
1 for year 1; .75 for year 2; .5 for year 3; .25 for year 4; and 0 for any
following payment year
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Medicare EHR Incentives For Eligible Hospitals –
How it is paid
13
CRITICAL ACCESS HOSPITALS
(CAHs) – How it is paid

Qualifying CAHs may receive incentive payments for up to four payment
years beginning with cost reporting periods that begin in FY 2011. The
year with a cost reporting period that begins in FY 2015 is the last payment
year for which a qualifying CAH can receive incentive payments as a
meaningful EHR user.

Qualifying CAHs can receive incentive payments for the reasonable costs
incurred for the purchase of depreciable assets like computers and
associated hardware and software, necessary to administer certified EHR
technology, excluding any depreciation and interest expenses associated
with the acquisition.
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A qualifying CAH will receive an incentive payment amount equal to the
product of its reasonable costs incurred for the purchase of certified EHR
technology and its Medicare share percentage. The Medicare share
percentage equals the lesser of (1) 100 percent; or (2) the sum of the
Medicare share fraction for the CAH and 20 percentage points.
14
Medicare EHR Incentives For Eligible Providers
– How it is paid
15
Limiting Factors

A qualifying EP will receive an incentive payment equal to 75
percent of Medicare allowable charges for covered
professional services furnished by the EP in a payment year,
subject to maximum payments.

Physicians who report using an EHR that is also capable of eprescribing would be eligible for EHR incentives only, and will
no longer be eligible for the e-prescribing bonuses.

Hospital-based EPs who furnish substantially all their services
in a “hospital setting” are not eligible for incentive
payments. Hospital-based EPs are now defined as EPs who
furnish 90 percent or more of their allowed services in a
hospital inpatient setting, or hospital emergency department.
16
Penalties Based on Medicare
Reimbursement
YEAR
PENALTY REDUCTION
2015
1%
2016
2%
2017 & beyond
3%
17
Useful Information For All in
Pursuit of Meaning Use
Incentive$
18
Caveat Based on Re-Estimation of Participation
and Budget for Incentive Program
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The government may distribute less money than anticipated

CBO estimated that total federal incentive payouts could reach $34 billion

Officials have now stated that outlays are likely to range from $14.1 to $27.3 billion
Budget revisions may be reviewed after evaluating the popularity of the incentive
payment program.
Source:
Congressional Budget Office year-by-year estimate of
the economic effects of the American Recovery and
Reinvestment Act of 2009, dated March 2, 2009
Link: http://www.cbo.gov/ftpdocs/100xx/doc10008/03-02Macro_Effects_of_ARRA.pdf
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EHR Incentives – Important Dates
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October 1, 2010 – Reporting year begins for eligible hospitals and CAHs.
January 1, 2011 – Reporting year begins for eligible professionals.
January 3, 2011 – Registration for the Medicare EHR Incentive Program begins.
January 3, 2011 – For Medicaid providers, states may launch their programs if they
so choose.
April 2011 – Attestation for the Medicare EHR Incentive Program begins.
May 2011 – EHR Incentive Payments expected to begin.
July 3, 2011 – Last day for eligible hospitals to begin their 90-day reporting period to
demonstrate meaningful use for the Medicare EHR Incentive Program.
September 30, 2011 – Last day of the federal fiscal year. Reporting year ends for
eligible hospitals and CAHs.
October 1, 2011 – Last day for eligible professionals to begin their 90-day reporting
period for calendar year 2011 for the Medicare EHR Incentive Program.
November 30, 2011 – Last day for eligible hospitals and critical access hospitals to
register and attest to receive an Incentive Payment for Federal fiscal year (FY) 2011.
December 31, 2011 – Reporting year ends for eligible professionals.
February 29, 2012 – Last day for eligible professionals to register and attest to
receive an Incentive Payment for calendar year (CY) 2011.
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http://healthit.hhs.gov
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Visit the CHPL:
http://onc-chpl.force.com/ehrcert
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Regional Extension Centers
Overarching objective:
 The RECs will support and serve health care providers to help them quickly
become adept and meaningful users of electronic health records (EHRs).
RECs are designed to make sure that primary care clinicians get the help
they need to use EHRs.
RECs will:
 Provide training and support services to assist doctors and other providers
in adopting EHRs
 Offer information and guidance to help with EHR implementation
 Give technical assistance as needed
 The goal of the program is to provide outreach and support services to at
least 100,000 priority primary care providers within two years.
Under HITECH, $677 million is allocated to support a nationwide system of
RECs that cover every geographic region of the United States to ensure
plenty of support to health care providers in communities across the
country. There are 4 RECs in Texas.
26
Certification
Complications
Presented by Pamela McNutt
Sr. VP & CIO
Methodist Health System
27
Issues that have arisen with Certification

An eligible hospital or provider must possess a Certified
EHR through:

A Certified Complete EHR or
A combination of Certified Modules or

Self certification of home grown or non-certified modules
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You must own all the modules even if not using them for
“meaningful use”
There are complications with mixing and matching
systems since most major vendors certified as a
Complete EHR

Modules do not inherit the certification of a Complete EHR
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Illustration of Certification Issues
Primary Vendor A – Certified Complete EHR
Clinical
Documentation
X X X
CPOE
Emergency
Portal
Dept
Data exchange
Public Health
CCD record
Reporting
X
Quality Metrics
Vendor B – Certified Complete EHR
X
Clinical
CPOE
Documentation
X
Emergency
Dept
Vendor C – Certified Module
Emergency
Dept
Portal
Data exchange
Public Health
CCD record
Reporting
X
X
Quality Metrics
Vendor D – Certified Module
Quality Reporting
and Data
Repository
The organization would have to “possess” every component listed
on this diagram regardless of whether they are used
29
ONC’s proposed solution to certification issues


Put market pressure on your vendors to go back and
get permutations of the Complete EHRs certified as
modules
Leverage the “loop hole” that you don’t have to
implement all modules of a Certified Complete EHR
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Get vendors to agree to let you load the software but not pay
until you begin using it
Contract with vendors for the right to use, at any time and at
one’s discretion, all the software but not pay until it is used
If “mixing and matching” assure yourself that the
combination:


Has not adversely impacted the calculation of any meaningful
use measures
Includes all meaningful use measures
30