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ARRA HITECH Meaningful Use Update

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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

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What Do Physicians Need to Do?

Choose a Certified Complete EHR

2010 2011

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

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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.

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When will it all be finalized?

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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

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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

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What Do Physicians Need to Do?

Choose a Certified Complete EHR

2010 2011

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

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Utilize Certified EHR Technology

Certified EHR Technology

Certified Complete EHRMeets all 25 measures

Certified EHR ModuleMeets 1 of 24 measures

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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.”

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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

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What Do Physicians Need to Do?

Choose a Certified Complete EHR

2010 2011

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

2 3 4 51

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New: Staged Approach to Meaningful Use

2011 2012 2013 2014 2015

2011 Stage 1 Stage 1 Stage 2 Stage 2 Stage 3

2012 Stage 1 Stage 1 Stage 2 Stage 3

2013 Stage 1 Stage 2 Stage 3

2014 Stage 1 Stage 3

2015 Stage 3Firs

t Pay

men

t Yea

r

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Proposed Meaningful Use Measures: Stage 1Stage 1 Meaningful Use Proposed Requirements Pulse EHR FunctionUse Computerized Physician Order Entry (CPOE)

MedicationsLaboratoryRadiology/imagingProvider referrals

Orders Module

Incorporate clinical lab-test results into EHR as structured data Orders Module

Implement drug-drug, drug-allergy, drug formulary checks ePrescribing

Generate and transmit permissible prescriptions electronically ePrescribing

Maintain active medication and medication allergy list ePrescribing

Electronically complete medication reconciliation of two or more medication lists (compare and merge) into a single medication list that can be electronically displayed in real-time

ePrescribing

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Proposed Meaningful Use Measures: Stage 1Stage 1 Meaningful Use Proposed Requirements Pulse EHR FunctionMaintain an up-to-date problem list of current and active diagnoses Charge capture/Orders

Implement 5 clinical decision support rules Encounter capture

Provide clinical summaries for patients for each office visit Encounter capture

Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, and outreach

Clinical reporter

Report quality measures to CMS or the States Clinical reporter

Send preventive/ follow up care reminders to patients per patient preference

Health maintenance and alerts

Record and chart changes in vital signs for at least 80% of all unique patients age 2 and over

Vitals capture

Record “smoking status” for at least 80% of all unique patients 13 years or older

Social History capture

At least 80% of all unique patients seen have demographics recorded as structured data

Patient chart

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Proposed Meaningful Use Measures: Stage 1Stage 1 Meaningful Use Proposed Requirements Pulse EHR FunctionCheck insurance eligibility electronically from public and private payers

Practice Management

Claims filed electronically to public and private payers Practice Management

Provide an electronic copy of health information to patients upon request

Pulse Patient Portal

Enable a user to provide patients with online access to their clinical information, including, at a minimum, lab test results, problem list, medication list, medication allergy list, immunizations, and procedures.

Pulse Patient Portal

Enable a user to electronically transmit a patient summary record to other providers and organizations

Interoperability standards

Capability to exchange key clinical information among providers of care and patient authorized entities electronically

Interoperability standards

Enable a user to submit electronic data to immunization registries Interoperability standards

Enable a user to provide electronic syndromic surveillance data to public health agencies

Interoperability standards

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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 CourierDepartment 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

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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

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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

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How will Meaningful Use be proven?

Attestation to CMS1. Complete EHR Certification information (supplied by Pulse)

2. Describe performance on all functional measures required for Meaningful Use

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Clinical Reporting Measures

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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 Measures1. Inquiry Regarding Tobacco Use

2. Blood pressure measurement

3. Drugs to be avoided in the elderly

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Specialty Specific Proposal Measures

Cardiology Pulmonology Endocrinology Oncology Surgery Primary Care Pediatrics

OB GYN Neurology Psychiatry Ophthalmology Podiatry Radiology Gastroenterology Nephrology

Specialty measures will be limited to a required subset of 3 to 5 measures based on the availability of electronic measure specifications and comments received

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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.

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What Do Physicians Need to Do?

Choose a Certified Complete EHR

2010 2011

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

2 3 4 51

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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

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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?

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Payment Calendars

Medicaid incentive qualification must start by 2015, no payments beyond 2021

2011 2012 2013 2014 2015 2016 Total

2011 $18,000 $12,000 $8,000 $4,000 $2,000 $0 $44,000

2012 $18,000 $12,000 $8,000 $4,000 $2,000 $44,000

2013 $15,000 $12,000 $8,000 $4,000 $39,000

2014 $12,000 $8,000 $4,000 $24,000

2015+ $0Firs

t Att

esta

tion

Year

Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Total

$21,250 $8,500 $8,500 $8,500 $8,500 $8,500 $63,750

Medicaid Calendar

Medicare Calendar

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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?

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Medicare First year (2011) requires

continuous 90-day period within the payment year which can attest to Meaningful Use

Cannot cross calendar years

Medicaid 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

What is the Timing?

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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

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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

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What Do Physicians Need to Do?

Choose a Certified Complete EHR

2010 2011

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

2 3 4 51

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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

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The time to get started is now!

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Prepare An Organized Plan to Implement Now

Choose a Certified Complete EHR

2010 2011

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

2 3 4 51

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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

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Consider Pulse EHR

Easier to buy.Easier to implement.Easier to learn.Easier to use.Easier to adopt.

An easier way to meaningful use.

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Let’s get started.

Contact me directly: browley@pulseinc.com

www.pulseinc.com1.800.444.0882