EHR Incentives for Professionals and Hospitals Paul Forlenza, VP - PowerPoint PPT Presentation

EHR Incentives for Professionals and Hospitals Paul Forlenza, VP Policy, VITL updated October 1, 2010 – v.8.1

Disclaimer • Not legal analysis or advice • Analysis based on reviewing Centers for Medicare and Medicaid Services (CMS) Final Rule (800+ pages) and analysis by other health care policy organizations Contact: Paul Forlenza, VP Policy Vermont Information Technology Leaders, Inc. 802-223-4100 x103 pforlenza@vitl.net 2 10/1/2010 VITL - V.8.1

Topics • Health Outcome Priorities • Stages for Implementing Meaningful Use • Eligible Professionals – Eligibility – Requirements to Achieve Meaningful Use – Clinical Quality Measures – Medicare and Medicaid Incentive Payments – Timeline and Next Steps • Eligible Hospitals • Appendix - Details about MU subjects 3 10/1/2010 VITL - V.8.1

EHR INCENTIVES FOR PROFESSIONALS 4 10/1/2010 VITL - V.8.1

Health Outcome Priorities 1. Improve quality, safety, efficiency and reduce health disparities 2. Engage patients and families in their health care 3. Improve Care Coordination 4. Protect privacy and security of personal health information 5. Improve population and public health 5 10/1/2010 VITL - V.8.1

Which program am I eligible for? Medicare Medicaid • Doctors (PFS *): • Patient Volume Thresholds – Medicine and Osteopathy – Physicians – Dental Surgery or Medicine – Pediatricians – Doctor of Podiatric Medicine – Nurse practitioners – Doctor of Optometry – Certified Nurse Midwives – Chiropractors – Physician Assistants at FQHC/RHC led by PA • Incentive for practicing in a Health Professional – Dentists Shortage Area (10%) * Physician Fee Schedule 6 10/1/2010 VITL - V.8.1

Who is not eligible for incentives? • Professionals that perform substantially (90%) all of their services in an inpatient hospital setting or emergency room are not eligible Place of Service Eligible? Professionals Codes Hospitalists ER Physicians NO POS 21 and 23 Radiologists Anesthesiologists Professionals in YES POS 22 outpatient setting 7 10/1/2010 VITL - V.8.1

Do I qualify for the Medicaid Program? 1 st YR 90-day Eligible Professionals Comments Patient Volume * Threshold for Physicians 30% Eligible Professionals , Pediatricians 20% predominantly Nurse Practitioner 30% practicing in FQHC/RHC, PAs at FQHC/RHC 30% must have a 30% Certified Nurse "needy 30% Midwives individual" patient volume Dentists 30% * Second year requires a full year of patient volume 8 10/1/2010 VITL - V.8.1

Patient Volume • Eligible professional: calculate using patient encounters or patient panel • Alternative: use practice/clinic volume • CMS also allows states to develop alternative methods to calculate patient volume 9 10/1/2010 VITL - V.8.1

Calculating Patient Volume Patient Encounter Method Total Medicaid patient encounters in any 90-day period in the Preceding calendar year = % x 100 Total patient encounters in that same 90-day period 10 10/1/2010 VITL - V.8.1

Patient Volume Example Patient Encounter Method 100 Medicaid patient encounters = 33% x 100 Physician 300 Total patient encounters qualifies for Medicaid Program 11 10/1/2010 VITL - V.8.1

Calculating Patient Volume Patient Panel Approach Total Medicaid patients assigned to EP’s panel in any representative, continuous 90 days in the preceding calendar year x 100 = % Total patients assigned to a EP in same 90 day period with at least one encounter with patient during year prior to 90 day period 12 10/1/2010 VITL - V.8.1

Stages for implementing Meaningful Use Stage 3: 2015 Stage 2: 2013 Improved Stage 1: outcomes Advanced clinical 2011 processes and robust health information Capture data in exchange structured form and limited sharing 13 10/1/2010 VITL - V.8.1

How do I achieve Meaningful Use? A. Use certified Electronic Health Record (EHR) in a meaningful manner B. Electronically exchange health information to improve quality of care C. Report Clinical Quality Measures to CMS 14 10/1/2010 VITL - V.8.1

What is a certified EHR? • Previously EHRs certified by Certification Commission for Health Information Technology (CCHIT) • ONC now selecting “Authorized Testing and Certification Bodies”(9 -23-10) – Certification Commission for HIT (CCHIT) – Drummond Group, Inc. (DGI) – InfoGard Laboratories, Inc. • Certified EHRs to be post on ONC website 15 10/1/2010 VITL - V.8.1

A. How do I use a certified EHR in a meaningful manner? • EPs: 15 Core Objectives (EHs: 14) – use certain functions of EHR like e-Prescribing – maintain active problem lists – Report clinical quality measures (CQMs) • EPs and EHs 5 of 10 Menu Set Objectives – generate lists of patients by specific conditions – capture clinical lab results in structured format – Implement drug-formulary checks 16 10/1/2010 VITL - V.8.1

B. How do I exchange health information? • Must be with an unaffiliated organization – Connect to the VT Health Information Exchange – Connect directly (point to point) • Examples – Accept lab results as structured data into EHR – use e-Rx (generate and transmit electronically) • Robust bi-directional exchange delayed 17 10/1/2010 VITL - V.8.1

C. What clinical quality measures must I report? • Clinical Quality Measurers based on PQRI/NQF * – 3 core CQMs – Or 3 alternate core – Plus 3 additional from list of 38 CQMs *PQRI: Physician Quality Reporting Initiative; NQF: National Quality Forum 18 10/1/2010 VITL - V.8.1

Maximum Medicaid incentives ? 1,2 Payment Year Total Incentive 2015 2016 2017-21 Payments 2011 2012 2013 2014 Stage 1 Stage 1 Stage 2 Stage 2 Stage 3 Stage 3 $63,750 $21,250 $8,500 $8,500 $8,500 $8,500 $8,500 Stage 1 Stage 1 Stage 2 Stage 3 Stage 3 Stage 3 $63,750 $21,250 $8,500 $8,500 $8,500 $8,500 $8,500 Stage 1 Stage 2 Stage 3 Stage 3 Stage 3 $63,750 $21,500 $8,500 $8,500 $8,500 $8.5k*2 Stage 1 Stage 3 Stage 3 Stage 3 $63,750 $21,500 $8,500 $8,500 $8.5k*3 Stage 3 Stage 3 Stage 3 $63,750 $21,500 $8,500 $8.5k*4 1. Flat fee payment based on 85% of EHR “net allowable costs” 2. Max. incentive for Pediatrician, with 20% patient threshold, $42,500 19 10/1/2010 VITL - V.8.1

First year A/I/U option for Medicaid • No EHR prior to Incentive Program – A dopt (acquired and installed) – I mplement (started use of EHR) • Existing EHR – U pgrade (expanded/upgraded to certified EHR technology or added new functionality) 20 10/1/2010 VITL - V.8.1

What are maximum Medicare incentives? Payment Year Total Incentive 2015 2016 2013 2014 Payments 2011 2012 Stage 2 Stage 2 Stage 3 Stage 1* Stage 1 $44,000 $8,000 $4,000 $2,000 $18,000 $12,000 Stage 1 Stage 2 Stage 3 Stage 3 Stage 1 $44,000 $12,000 $8,000 $4,000 $2,000 $18,000 Stage 1 Stage 2 Stage 3 Stage 3 $39,000 $15,000 $12,000 $8,000 $4,000 Stage 1 Stage 3 Stage 3 $24,000 $12,000 $8,000 $4,000 Payment Adjustments -1% -2% -3% 1. No Medicare early adoption option 2. Payment based on 75% of PFS 21 10/1/2010 VITL - V.8.1

How do I get my Medicare/Medicaid incentive payments? Medicare Core 2011 Attest to MU & report CMS aggregate data for 90 days Measures 2012 Attest & report for 1 year Menu Set Measures Medicaid 2011 Adopt/Implement/Upgrade Clinical State 2012 Attest; report 90 days data Quality Medicaid 2013 Attest; report data for 1 yr Measures Office Register using CMS web-based portal. Single, annual, consolidated payment. Tied to NPI but can be transferred to practice/clinic. 22 10/1/2010 VITL - V.8.1

Other Considerations for EPs • Medicare or Medicaid; not both; switch once • Meaningful use for professional; not practice • Calculate thresholds by provider or practice • FQHC/RHC “Needy Individuals” threshold – Medicaid patients – Uncompensated care – No cost or sliding scale fee patients – Children Health Insurance Program (CHIP) enrollees 23 10/1/2010 VITL - V.8.1

Stage 1: Reporting Requirements Hypertension Tobacco use Adult weight 15 Core Objectives Alternate: Children Weight Flu Immunization > 50 yrs Children Immunization State can move 4 public health CMS or or 3 alternate measures from State menu to core 38 Clinical Quality Measures 10 Menu Set 1 must be public health Objectives measure 24 10/1/2010 VITL - V.8.1

What are the differences between the EHR Incentive Programs? Medicare Medicaid No patient thresholds Patient volume thresholds No mid-levels Mid-levels included • $44,000 maximum $63,750 maximum • 10% HPSA bonus based on 85% of EHR • • 75% allowable PFS charges “net allowable costs” • Payments over 5 yrs Payments over 6 yrs ( 2011-2016) (2011-2021) Can not skip a year Can skip a year 1 st yr must demonstrate Adopt, implement or upgrade Meaningful Use option for 1st yr Penalties starting 2015 No penalties 25 10/1/2010 VITL - V.8.1

Timeline for EHR incentives • Jan. 2011: – Medicare/Medicaid registration begins – Earliest date for States to launch program • April 2011: – Attestation for Medicare begins – State sets date for Medicaid attestation • May 2011: Medicare incentive payments begin • Feb. 2012: Last day for EPs to register and attest to receive CY2011incentive payment 26 10/1/2010 VITL - V.8.1