Meaningful Use, An Update on Healthcare Reform

Meaningful Use: An Update on Healthcare Reform

2 Confidential Services

Agenda • Healthcare reform

• CMS and ONC timelines

• Meaningful Use

• Certification landscape

• Industry reaction

• Next steps for physicians and

hospitals

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Health Reform Update

$940 billion during the next decade, while reducing the deficit by $143 billion in the first ten years (2010-2019) and by $1.2 trillion in the second ten years. Note: the CBO released a report last week claiming the overall cost of the legislation would rise $115 billion.

Many states have filed lawsuits in federal court arguing that the federal government has no right to force their citizens to buy medical insurance

32 million Americans are estimated to gain health insurance coverage

President Obama

signed final bill

Cost

Reaction

Coverage

U.S. House Representatives passed Health

Reform

March 21

President Obama signed Health Reform

into law

March 23 Senate passed Health Reform

Bill March 24 March 30

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Health Reform

• $434 billion for expansion of Medicaid and Children's Health Insurance Plans enrollment

• $196 billion in reduced Medicare scheduled payments

• $36 billion in cuts to Medicare and Medicaid Disproportionate Share (DSH) payments

• Reduce Medicare payments for excess (preventable) hospital readmissions

• Reduce annual market basket updates for inpatient hospital, home health, skilled nursing facility, hospice and other Medicare providers, and adjust for productivity

• Limits new or expanded physician-owned hospitals

• Create state-based American Health Benefit Exchanges through which individuals can purchase coverage

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Health Reform

• $466 billion for subsidies to fund insurance for individuals and families up to 400 percent of the poverty level ($18,310 for family of 3)

• $60 billion in new fees on insurance companies (2014-2018)

• Insurance companies can no longer exclude people from coverage due to pre- existing conditions

• A coverage reinsurance program will begin to aid companies in providing health coverage for early retirees between 55 and 64 (expires in 2014)

• Payments to insurers offering Medicare Advantage services are frozen at 2010 levels

• Compact with multi-states to offer policies across borders

• Premium increases highly regulated and reported annually

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Released Regulations

• Released on December 30th, 2009 by HHS, ONCHIT and CMS

– Reporting conducted during any continuous 90-day period within the payment year

– Proposed rule from CMS detailing the Medicare and Medicaid electronic health record (EHR) incentive program

– Interim final rule from ONCHIT with initial set of standards, certification criteria, and implementation specifications for Stage 1 of the EHR incentive program

• Released on March 2, 2010

– Proposed rule regarding the accreditation process for EHR certification entities.

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CMS Timeline

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ONC Timeline

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Re-Estimation of Participation and Budget for Incentive Program

• The government may distribute less money than anticipated for the incentive payment program

– CBO estimated that total federal incentive payouts could reach approximately $34 billion

– Officials have now stated that outlays are likely to range from $14.1 billion to $27.3 billion

• Budget revisions may be reviewed after evaluating the popularity of the incentive payment program.

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Health Outcome Priorities and Care Goals within Meaningful Use

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Stage 1 – Highlights

• Insurance - Check insurance eligibility electronically & file at least 80% of all claims electronically

• EHR - Provide patients with an electronic copy of their health information & implement 5 clinical decision support rules

• CPOE - in the areas of medications, laboratories, radiology/imaging, and provider referrals.

• E-Prescribing - Requires electronic generation and transmission of permissible prescriptions.

• Privacy/Security - Protect electronic health information created or maintained by the certified EHR

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Important Stage 1 Criteria and Privacy Standards

• EHR Meaningful Use – CPOE:

› 80% of all orders for Eligible Professionals (medications, laboratory, radiology/imaging, and referrals)

› 10% of all orders for Hospitals (medications, laboratory, radiology/imaging, blood bank, physical therapy, occupational therapy, respiratory therapy, rehabilitation therapy, dialysis, and discharge/transfers)

– E-Prescribing: 75% of all permissible prescriptions for EPs

– Clinical Decision Support: 5 clinical decision support rules

• Exchange of Health Information – Conduct at least one test of submitting:

› Data to immunization registries

› Lab results to public health agencies

› Syndrome surveillance data to public health agencies

• Data Management – 80% of patients must have demographics recorded as structured data

– 80% of unique patients with one coded entry for problem list, active medication list, and medication allergy list

• Privacy and Protection of Health Information – Encryption criteria and standards specifically outlined

– Disclosure protections and notification

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Demonstrating and Reporting Meaningful Use

• Eligible professionals and hospitals demonstrate that they satisfy each of the proposed meaningful use objectives

– 25 Measures; 17 yes/no attestation and 8 require specific information submitted by the provider

– Reporting through a secure mechanism (such as claims-based reporting or an online portal)

• First Payment Year

– Reporting conducted during any continuous 90-day period within the payment year

• Second Payment Year and beyond

– Reporting conducted during the entire payment year

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Form and Timing of Incentive Payments

• Physicians

– Single, consolidated annual incentive payment

– Payments made on a rolling basis after demonstrating meaningful use for the payment period

• Hospitals

– Preliminary incentive payments based on discharges for the hospital’s fiscal year that ends prior to the payment year

– Final payments determined from the discharge data from the cost reporting period of the payment year

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Phase-In of the Proposed Meaningful Use Definition

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Quality Metrics Requirements for Obtaining Meaningful Use

• MU Quality Reporting

– Hospitals must report on 35 quality measures to meet the 2011 meaningful use requirements (Table 20)

– Physicians are required to meet all core measures in Table 4 and at least one of the sets listed in Tables 5 and 19 as specialty groups. (For example, there are 10 quality measures for cardiology, eight for pulmonology, six for oncology, and 29 for primary care.

• Reporting Quality Information

– Medicare or Medicaid Incentive Reporting

– Eligible Professional or Eligible Hospital

– Requirements on how to submit quality measures will be released by July 1, 2011.

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Security and Privacy

• Breach Notification

– Passed as part of American Recovery and Reinvestment Act of 2009 (ARRA).

– Requires health care providers and other HIPAA covered entities to promptly notify affected individuals of a breach, as well as the HHS Secretary and the media in cases where a breach affects more than 500 individuals.

• Business Associate Agreements

– Regulations also require business associates of covered entities to notify the covered entity of breaches at or by the business associate.

• Office of Civil Rights (OCR)

– The regulations require the tracking and reporting of such data breaches to OCR and FTC. OCR has published separate guidance specifying the technology and methods that will render health information unusable, unreadable and undecipherable as defined under ARRA-HITECH.

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Nationwide Health Information Network

• What is Nationwide Health Information Network (NHIN), its purpose, and how it ties into Meaningful Use

– NHIN is a network of regional health information networks to enable the secure sharing of patient data.

– Congress included information exchange as an essential part of Meaningful Use to enable physicians and hospitals to have a complete picture of a patient's health and make better decisions.

• The Policy Committee's recommendations called for the NHIN to support meaningful use by providing:

– A "trust fabric" of accountability measures, business relationships and common rules;

– Directories to locate message recipients;

– Systems to verify identities of message senders and recipients; and

– Web-based transmission services.

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Incentive Payment Issues

• Medicare vs. Medicaid

• Timing

• Funding Levels

• State vs. Federal Oversight

• Other Opportunities

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Future Development of Criteria

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NPRM on Certification

• EPs and EHs required by statute to use Certified EHR Technology to qualify for incentive payments

• On March 2, David Blumenthal released the (NPRM) providing temporary certification guidance for EHRs and EHR modules

• The NPRM would establish a temporary certification program to test and certify complete EHRs and/or EHR modules to assure the availability of certified EHR technology prior to the reporting period

• Second proposal within the NPRM would establish a permanent certification program to replace the temporary certification program to establish requirements for certification bodies authorized by the national coordinator related to the surveillance of certified EHR technology

• Includes potential for certification bodies authorized by the national coordinator to certify other types of health besides complete EHRs and EHR modules

• The temporary program would end once the permanent certification program is established and at least one certification body has been authorized by the national coordinator

• The public comment period for the temporary certification program will be open for 30 days after publication

• The public comment period for the permanent certification program will be open for 60 days after publication

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Health Reform Highlights (Payers)

32 million Americans are

estimated to gain health insurance coverage

$434 billion for expansion of Medicaid and Children's Health Insurance Plans enrollment

$36 billion in cuts to Medicare and Medicaid DSH payments

$60 billion in new fees on insurance companies (2014-2018)

Insurance companies can no longer exclude people from coverage due to

pre-existing conditions

Limits new or expanded

physician-owned hospitals

Payments to insurers offering Medicare Advantage services are

frozen at 2010 levels

Compact with states to allow cross-border policies by insurance policies.

Create state-based

American Health Benefit Exchanges through which individuals can purchase coverage


Updated Definitions

• Hospital-based Eligible Professionals

Those who furnish substantially all their services in an inpatient or emergency room setting, such as a pathologist, anesthesiologist, or emergency physician, and who do so using the facility and equipment, including qualified electronic health care records, of the hospital.

• Place of Service for Hospital-based Eligible Professionals

A hospital-based eligible professional would be ineligible to receive an EHR incentive payment under either Medicare or Medicaid, regardless of the type of service provided, if more than 90% of his/her services are identified as being provided in an inpatient hospital and emergency room.


Market Readiness

• Hospitals and Providers will be challenged to meet Meaningful Use criteria

• Studies that show market readiness to meet MU criteria

– CMS estimates that 10 to 36 percent of eligible providers and 30 to 43 percent of hospitals will be eligible for incentive payments in 2011.

• CCHIT

– About 24 vendors that have already achieved certification under CCHIT’s latest programs will be offered incremental testing to close any gaps

– CCHIT has stated that the interim final rule on Meaningful Use contained “no big surprises”

– CCHIT updates certifications to go with new standards rule

– For all other EHR vendors, the updated criteria and scripts will be published soon and applications for certification will be accepted beginning Feb. 12


Industry Comments

Mixed review have come from the Healthcare industry on the proposed definition


Dell Comments on Meaningful Use

• Stage 1 requirements should be further differentiated and extended into three phases.

• Stage 2 should provide greater lead time for comment and a more purposeful glide path.

• The rule should affirm that all IT models meeting qualifications may be utilized.

• The rule should allow for the limited assistance of non-certified technology.

• The rule should not exclude providers based on their organizational models.

• The rule should delineate clear standards for providing health information electronically.

• Medicare eligible providers should have the same rights to review as Medicaid providers.

• The rule should clarify attestation of health record “exchange” can be satisfied broadly.


Next Steps for Physicians


Next Steps for Hospitals

Thank you

Meaningful Use, An Update on Healthcare Reform

Health & Medicine

Transcript of Meaningful Use, An Update on Healthcare Reform