CMS Medicaid Electronic Health Record (EHR) Incentive Programs 2015 Final Rule Overview Meaningful Use

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1 CMS Medicaid Electronic Health Record (EHR) Incentive Programs 2015 Final Rule Overview Meaningful Use Presenter: Sherry Wallace-Barnes, RN Envision Management Solutions, LLC 1

2 Meaningful Use 2015 Final Rule Updates Modified Stage 2 Meaningful Use Stage 3 Meaningful Use Hardship Exemptions 2

3 The material contained in the presentation is not exhaustive and is for informational purposes only. This presentation may contain references or links to statutes, regulations, or other policy materials. The information provided is only intended to be a general summary. It is not intended to take the place of either the written law or regulations. This information does not replace guidelines established by Centers for Medicare and Medicaid Services (CMS). Please refer to Federal and State guidelines for regulatory standards. Information is valid as of the date of this presentation and may change per CMS guidelines at any time. 3

4 The Medicare and Medicaid EHR Incentive Programs provide financial incentives for the meaningful use of certified EHR technology. To receive an EHR incentive payment, providers have to show that they are meaningfully using their certified EHR technology by meeting certain measurement thresholds. Stage 1-90-day period in their first year of meaningful use and a full year in their second year of meaningful use. After meeting the Stage 1 requirements for 2 years, providers will then have to meet Stage 2 requirements for two full years. 4

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8 The majority of participating providers in Mississippi just started their first year of Stage 2 Meaningful Use. Stage 1 = AIU + MU1 + MU2 Stage 2 = MU3 + MU4 Stage 3 = MU5 + MU6* Medicaid Providers will finish six years of participation in the EHR Incentive Program as they enter their first year under Stage 3. 8

9 Maximum incentives are $63,750 over 6 years Incentives are same regardless of start year The first year payment is $21,250 The subsequent years incentive payments are $8500 for 5 years Must begin by 2016 to receive incentive payments No extra bonus for health professional shortage areas Incentives available through 2021 Only 1 incentive payment per year **(grace period) 9

10 Medicaid Incentive Payments By Calendar year 10

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12 CMS recently published a final rule that specifies criteria that eligible professionals (EPs), eligible hospitals, and critical access hospitals (CAHs) must meet in order to participate in the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. (Final rule released 10/6/2015) The final rule s provisions encompass 2015 through 2017 (Modified Stage 2) as well as Stage 3 in 2018 and beyond. 12

13 All providers are required to attest to a single set of objectives and measures (Modified Stage 2). This replaces the core and menu objectives structure of previous stages. For EPs, there are 10 objectives, including one consolidated public health reporting objective. In 2015, all providers must attest to objectives and measures using EHR technology certified to the 2014 Edition. Allowing providers who were previously scheduled to be in a Stage 1 EHR reporting period for 2015 to use a lower threshold for certain measures. Allowing providers to exclude for Stage 2 measures in 2015 for which there is no Stage 1 equivalent. 13

14 Stage 2 Patient Electronic Access, Measure 2: For 2015, instead of the 5 percent threshold, this measure requires that at least 1 patient seen by the EP during the EHR reporting period (or patient authorized representative) views, downloads, or transmits to a third party his or her health information during the EHR reporting period. 14

15 Stage 2 Secure Electronic Messaging: The 5 percent threshold has been changed to the capability for patients to send and receive a secure electronic message with the EP was fully enabled during the EHR reporting period (yes/no). Public Health Reporting: The public health reporting objectives have been consolidated into one objective with three measure options for EPs. 15

16 Starting in 2015, the EHR reporting period for all providers will be based on the calendar year. In 2015 only, the EHR reporting period for all providers will be any continuous 90-day period. EPs may select an EHR reporting period of any continuous 90 day period from January 1, 2015 through December 31, Currently, Mississippi has not turned on program year 2015 in the MS State Level Registry (MS SLR). CMS has turned off Program year 2015 for all Medicare EHR attestations. Program year 2015 will be available in January

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26 Objective: The EP, eligible hospital or CAH is in active engagement with a public health agency to submit electronic public health data from CEHRT except where prohibited and in accordance with applicable law and practice. EPs must meet 2 of 3 measures; eligible hospitals/cahs must meet 3 of 4 measures: Objective 10: Public Health Reporting Measure 1 -Immunization Registry Reporting: The EP, eligible hospital, or CAH is in active engagement with a public health agency to submit immunization data. Measure 2 Syndromic Surveillance Reporting: The EP, eligible hospital, or CAH is in active engagement with a public health agency to submit syndromic surveillance data. Measure 3 Specialized Registry Reporting -The EP, eligible hospital, or CAH is in active engagement to submit data to a specialized registry. Measure 4 Electronic Reportable Laboratory Result Reporting (for Eligible Hospitals/CAHs only): The eligible hospital or CAH is in active engagement with a public health agency to submit electronic reportable laboratory (ELR) results. Alternate Specification: An EP scheduled to be in Stage 1 in 2015 may meet 1 measure and an eligible hospital or CAH scheduled to be in Stage 1 in 2015 may meet two measures. Multiple exclusions apply. 26

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29 Synchronizes on single stage and single reporting period Focuses on advanced use objectives (8) Comment period: The final rule includes a 60-day comment period on the Stage 3 portion of the rule. Seeking comments on Stage 3: Measures, Objectives, and Reporting Periods Any modifications to Stage 3 based on those comments will be proposed through notice and comment rulemaking in future regulations. 29

30 CMS: Guidance/Legislation/EHRIncentivePrograms/index.html Mississippi Division of Medicaid: = b2 30

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