Wondering about the meaning of Meaningful use? Pulse offers a brief overview of the forthcoming Meaningful Use requirements and what you need to do as a physician to be eligible to receive ARRA Stimulus money when it becomes available.
2. What Does it All Mean to You? Two programs with substantial incentive payment programs Medicare offers up to $44,000 per physician Medicaid offers up to $63,750 per physician Non-participation leads to reimbursement penalties 1% penalty in 2015 2% penalty in 2016 3% penalty in 2017 5% penalty in 2019 Qualification requires: Certified Complete EHR Meaningful Use
3. What Do Physicians Need to Do? 2010 2011 2 3 4 5 1 Choose a Certified Complete EHR Utilize all meaningful use measures for at least 90 consecutive days Choose Medicare or Medicaid incentive program Attest to meaningful use and name of Certified Complete EHR Implement and train usage to all meaningful use measures Receive first payment
4. Lots of Questions How will I prove I’m meeting Meaningful Use measures? How long do I have to prove Meaningful Use measures? How will I prove I’m using a Certified Complete EHR? Will the incentive payments be made to physicians or practices? How often will payments be made? Which incentive program is best for me…Medicare or Medicaid? What if my local HIE isn’t live yet? Many questions are ready to be answered today, this presentation will address many of the most common questions encountered.
6. Where Is It All Leading? 2015 2013 2011 Enable significant and measurable improvements in population health through a transformed delivery system. Adapted from Health Information Technology Meaningful EHR Use Workgroup, June 16, 2009
7. Building An Electronic Healthcare Network Personal Health Records Health Vault/Google Health Electronic Health Records Certified Complete EHR $20 billion Incentive payments available Health Information Exchanges/Regional Health Information Organizations – Connecting Patient Data within Medical Trade Areas $564 million grants issued Feb. 12th, in all 50 states National Health Information Network – A network of networks HIE grants earmarked with NHIN funding SureScripts™ - National clearing-house for prescriptions Regional Centers – Consulting with Primary Care Practices $250 million in grants issued Feb. 12th in 39 regions Community College Consortia to Educate Information Technology Professionals in Health Care $70 million to be awarded March ‘10
8. What Do Physicians Need to Do? 2010 2011 2 3 4 5 1 Choose a Certified Complete EHR Utilize all meaningful use measures for at least 90 consecutive days Choose Medicare or Medicaid incentive program Attest to meaningful use and name of Certified Complete EHR Implement and train usage to all meaningful use measures Receive first payment
10. HHS Certification Process Rules expected in February to define process for how certifying bodies will be named, certified and issue certifications CCHIT will almost certainly be a certifying body Already aligned certification criteria with proposed MU measures Dr. Mark Leavitt, CCHIT Chair: “Unless they pass a law saying that certifying bodies cannot start with the letter C, we will be a certifying body.”
11. What is a Certified Complete EHR? CCHIT mapped latest proposed requirements to 2011 Comprehensive Certification Pulse EHR first to fully certify for CCHIT 2011 Ambulatory Comprehensive Certification without any restrictions
12. What Do Physicians Need to Do? 2010 2011 2 3 4 5 1 Choose a Certified Complete EHR Utilize all meaningful use measures for at least 90 consecutive days Choose Medicare or Medicaid incentive program Attest to meaningful use and name of Certified Complete EHR Implement and train usage to all meaningful use measures Receive first payment
17. Comments? You Have Until March 15th Federal eRulemaking Portal: http:// www.regulations.gov Identified by RIN 0991-AB58 Regular, Express, Overnight Mail, Hand Delivery or Courier Department of Health and Human Services Office of the National Coordinator for Health Information Technology Attention: HITECH Initial Set Interim Final Rule Hubert H. Humphrey Building, Suite 729D 200 Independence Ave., SW. Washington, DC 20201 All comments received before the close of the comment period will be available for public inspection at http://www.regulations.gov
18. Comment Sample…Health IT Policy Committee Allow providers to defer up to five proposed measures from 2011-13 Providers could not defer all measures from a single priority area No deferrals in the privacy and security priority area Certain meaningful use measures should remain mandatory, such as: Using computerized physician order entry systems Providing patients with electronic copies of discharge instructions Recording patient demographics as structured data Transmitting certain prescriptions electronically
19. Stage 2 Preview HHS anticipates redefining objectives to include not only the capturing of data in electronic format but also the exchange of that data in increasingly structured formats Stage 2 meaningful use criteria preview: “CPOE use” will include not only the percentage of orders entered directly by providers through CPOEs but also the electronic transmission of those orders “Incorporate clinical lab-test results into EHR as structured data” will be expanded, where feasible Measures that currently require the performance of a capability test will be revised to require the actual submission of that data Measures that currently allow the provision and exchange of unstructured data will require the provision and exchange of electronic and structured data, where feasible
20. How will Meaningful Use be proven? Attestation to CMS Complete EHR Certification information (supplied by Pulse) Describe performance on all functional measures required for Meaningful Use
22. Core Clinical Reporting Measures Reports on patient care from administration and medical record data Allows identification of patterns in diagnosis and treatment All reporting must use a Certified Complete EHR to capture and calculate results All Physicians are required to report information on Core measures Proposed Required Core Clinical Reporting Measures Inquiry Regarding Tobacco Use Blood pressure measurement Drugs to be avoided in the elderly
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24. How will Clinical Quality Measures be Submitted? For 2011, an attestation methodology will be used to submit summary information to CMS on clinical quality measures as a condition of demonstrating meaningful use of Certified EHR Technology HHS and State CMS Technology is expected to be ready to receive data electronically starting in 2012 Many Health Information Exchanges are considering offering physicians the service of packaging and submitting meaningful use data.
25. What Do Physicians Need to Do? 2010 2011 2 3 4 5 1 Choose a Certified Complete EHR Utilize all meaningful use measures for at least 90 consecutive days Choose Medicare or Medicaid incentive program Attest to meaningful use and name of Certified Complete EHR Implement and train usage to all meaningful use measures Receive first payment
26. Who Qualifies? Medicare Eligible Providers (EP) Doctor of medicine or osteopathy Doctor of dental surgery of medicine Doctor of podiatric medicine Doctor of optometry Chiropractor Medicaid Eligible Providers (EP) Physicians Dentists Certified nurse – midwives Nurse practitioners Physicians assistants in FQHC or RHC led by a Physician assistant
27. Medicare Up to $44,000 over 5 years 75% of submitted allowable charges to Medicare, up to the capped amount for that year Part B claims for the Fee for Service program Items in the Medicare Physician’s Fee Schedule “Professional” components only, no “Technical” components Medicaid Up to $63,750 over 6 years Flat fees to cover 85% cost of purchasing, implementing and maintaining an EHR Average allowable cost for EHR purchase, including implementation and hardware is $54,000 Average allowable annual cost for maintenance is $20,610 How are the Incentives Calculated?
28. Payment Calendars Medicare Calendar First Attestation Year Medicaid Calendar Medicaid incentive qualification must start by 2015, no payments beyond 2021
29. Medicare Full incentive payment in 2011 requires allowable charges of $24,000 Lower allowable charges result in lower incentive payments Eligible Providers in a Health provider shortage area (HPSA) can claim an additional 10% incentive payment bonus Medicaid 30% of all patient encounters must be attributable to Medicaid over any continuous 90-day period within a calendar year Short-term outreach programs not applicable Must re-attest annually 20% requirement for Pediatricians 33% lower available incentive How are the Incentives Calculated?
30. What is the Timing? Medicare Medicaid First year (2011) requires continuous 90-day period within the payment year which can attest to Meaningful Use Cannot cross calendar years Can begin as early as 2010 if the state has filed an indication of readiness to capture electronic information 90-day attestation period would apply to both 1st and 2nd years in states approved for 2010 incentive Cannot cross calendar years Physician must demonstrate actual full installation to qualify in 2010 If you have already implemented and are ready to prove Meaningful Use, the program will begin in 2011
31. Other Unique Medicaid Differences Outside funds, other than State or local funds, such as through a Stark program, that are directly tied to payment for an EHR will be subtracted Average Allowable Costs in Medicaid program allow ability to accept up to $29,000 in first year and $10,610 in following years without impacting Physicians must choose only one state to apply for Medicaid payments State choice may be changed annually at re-attestation
32. Switching Incentive Programs Physicians may switch between programs only once during the shared program periods (last year to switch is 2014) After switching, the EP continues at the next ‘program year’ Example: After 2 years in Medicare program, an EP would start in year 3 in Medicaid program
33. What Do Physicians Need to Do? 2010 2011 2 3 4 5 1 Choose a Certified Complete EHR Utilize all meaningful use measures for at least 90 consecutive days Choose Medicare or Medicaid incentive program Attest to meaningful use and name of Certified Complete EHR Implement and train usage to all meaningful use measures Receive first payment
34. Getting Paid Tracking will be done by NPI (National Provider Identifier) A single annual payment Medicare will pay via CMS Medicaid will pay from State Medicaid or designated organization Payments will be made on a rolling basis as Meaningful Use is reported End of reporting period and/or threshold for maximum payment is reached Payments can be reassigned to any entity with a valid employment agreement with the EP Cannot split re-assignment across multiple entities A single database will track participation for both programs Application for each program will include: Identify Medicare or Medicaid program participation Name, NPI, business address and business phone Taxpayer ID Number of payment destination
36. Prepare An Organized Plan to Implement Now 2010 2011 2 3 4 5 1 Choose a Certified Complete EHR Utilize all meaningful use measures for at least 90 consecutive days Choose Medicare or Medicaid incentive program Attest to meaningful use and name of Certified Complete EHR Implement and train usage to all meaningful use measures Receive first payment
37. Get Started Now If you are not using EHR currently, consider only CCHIT 2011 Comprehensive Certified solutions Pulse EHR is fully CCHIT 2011 Comprehensive Certified Currently installed version meets and exceeds all proposed HHS Complete EHR Certification requirements If you are using an EHR today, perform practice usage gap analysis against proposed measures Expand CPOE usage Discreet data capture Coded systems are key to interoperability use Evaluate which incentive program is best for you Develop a plan for re-assignment of incentive payments
38. Consider Pulse EHR Easier to buy. Easier to implement. Easier to learn. Easier to use. Easier to adopt. An easier way to meaningful use.