9/9/2015. Medicare/Medicaid Incentive Program. Medicare/Medicaid Incentive Program. Meaningful Use, Penalties and Audits

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1 Meaningful Use, Penalties and Audits SHERI SMITH, FACMPE STATE VOLUNTEER MUTUAL INSURANCE COMPANY Copyright 2014 State Volunteer Mutual Insurance Company Medicare/Medicaid Incentive Program Medicare/Medicaid Incentive Program Provide incentive payments to eligible professionals, and eligible hospitals as they adopt, implement, upgrade or demonstrate meaningful use of certified EHR technology. Medicare EHR Incentive Program receive up to $44,000 Medicaid EHR Incentive Program receive up to $63,750 1

2 Medicare Maximum by Start Year $44,000 $18,000 $12,000 $8,000 $4,000 $2, $44,000 $18,000 $12,000 $8,000 $4,000 $2, $39,000 $15,000 $12,000 $8,000 $4, $24,000 $12,000 $8,000 $4,000 Medicaid Qualified for First 2011 Qualified for First 2012 Qualified for First 2013 Qualified for First 2014 Qualified for First 2015 Qualified for First 2016 Amount 2011 $21,250 $0 $0 $0 $0 $0 Amount 2012 $8,500 $21,250 $0 $0 $0 $0 Amount 2013 $8,500 $8,500 $21,250 $0 $0 $0 Amount 2014 $8,500 $8,500 $8,500 $21,250 $0 $0 Amount 2015 $8,500 $8,500 $8,500 $8,500 $21,250 $0 Amount 2016 $8,500 $8,500 $8,500 $8,500 $8,500 $21,250 Amount 2017 $0 $8,500 $8,500 $8,500 $8,500 $8,500 Amount 2018 $0 $0 $8,500 $8,500 $8,500 $8,500 Amount 2019 $0 $0 $0 $8,500 $8,500 $8,500 Amount 2020 $0 $0 $0 $0 $8,500 $8,500 Amount 2021 $0 $0 $0 $0 $0 $8,500 TOTAL s $63,750 $63,750 $63,750 $63,750 $63,750 $63,750 Meaningful Use Updates 2

3 Meaningful Use Updates April 15, CMS released proposed modifications for Stage 2 Meaningful Use requirements March 30, CMS released the proposed rule for Stage 3 for the Medicare and Medicaid EHR Incentive. Meaningful Use Updates Stage 2 Stage 2 proposed rule modifications Change reporting period in 2015 to a 90-day period aligned with the calendar year, and also would align the EHR reporting period in 2016 with the calendar year Modify the patient action measures related to patient engagement (instead of 5% change to equal to or greater than 1 ) Streamline the program by removing reporting requirements on measures which have become redundant, duplicative, or topped out through advancements in EHR function and provider performance for Stage 1 and Stage 2 Meaningful Use Updates Stage 2 Stage 2 Objective Secure Electronic Messaging Change from being a percentage-based measure, to yes-no measure stating the functionality fully enabled Consolidating all public health reporting objectives into one objective with measure options following the structure of the CQM no proposed changes (9 or 16 CQMs across at least 3 domains) from the CQM requirements previously established for all providers seeking to demonstrate meaningful use in the Medicare and Medicaid EHR 3

4 Meaningful Use Updates Stage 3 Stage 3 Continue to encourage electronic submission of CQM data for all providers where feasible in 2017 Propose to require the electronic submission of CQMs where feasible in 2018, and establish requirements to transition the program to a single stage for meaningful use Change the EHR reporting period so that all providers would report under a full calendar year timeline (exception under Medicaid providers demonstrating meaningful use for the first time). Meaningful Use Updates Stage 3 Stage 3 proposed rule The first year would report on a calendar year (with the exception of Medicaid providers in their first year of demonstrating meaningful use) Meet Meaningful Use for a single set of objectives and menu measures 2017 Optional 2018 Mandatory Last Stage of Meaningful Use Stage 3 Proposed Objectives 1. Protect Electronic Health Information 2. Electronic Prescribing (erx) 3. Clinical Decision Support 4. Computerized Provider Order Entry (CPOE) 5. Patient Electronic Access to Health Information 6. Coordination of Care through Patient Engagement 7. Health Information Exchange 8. Public Health Reporting 4

5 Stage 1 and Stage 2 Stage One Eligible Professionals Stage Two Eligible Professionals 13 core objectives 17 core objectives 5 of 10 Menu objectives 3 of 6 Menu objectives 18 total objectives 20 total objectives Stage 2 Core Measures 1. CPOE Use for more than 60% of medication, 30% laboratory, and 30% radiology 2. E-Rx E-Rx for more than 50% 3. Demographics Record for more than 80% 4. Vital Signs Record for more than 80% 5. Smoking Status Record for more than 80% 6. Clinical Decision Support Rule Implement 5 clinical decision support interventions + drug/drug and drug/allergy 7. Patient Access Provide online health information for more than 50% wit 5% actually accessing 8. Visit Summaries Provide for more than 50% of office visits 9. Security Analysis Conduct or review security analysis and incorporate in risk management process 10. Labs incorporate for more than 55% 11. Patient List Generate by specific condition 12. Preventive Reminders Use EHR to identify and provide reminders for preventive/follow-up care for 10% with two or more office visits in last 2 years 13. Education Resources Use EHR to identify for more than 10% 14. Medication Reconciliation for more than 50% of transitions of care in which the patient is transitioned into the care of EP 15. Summary of Care Provide for more than 50% with 10% sent electronically at least one sent to recipient with a different EHR vendor or testing with CMS test EHR 16. Immunizations Successful ongoing transitions of immunization data 17. Secure Massages More than 5% send secure message to their EP Stage 2 Menu Objectives 1. Syndromic Surveillance Successful ongoing transmission of syndromic surveillance data 2. Electronic Notes enter for more than 30% of unique patients 3. Imaging Results more than 10% are accessible through EHR 4. Family Health History Record for more than 20% of first degree relative 5. Cancer successful ongoing transmission of cancer case information to public health center cancer registry 6. Report Specific Cases successful ongoing transmission of data to a specialized registry Important Note: there are no exclusions provided for some of the menu objectives, you cannot select a menu objective and claim the exclusion if there are other menu objectives that you can report instead. 5

6 Clinical Quality Measures (CQMS) EPs must select and report on 9 of a possible list of 64 approved CQMs for the EHR Incentive Programs New Requirements in 2014 CQM s must cover at least 3 of the 6 available National Quality Strategy (NQS) domains, which represent the Department of Health and Human Services The 6 domains are: Patient and Family Engagement Patient Safety Care Coordination Population and Public Health Efficient Use of Health Care Resources Clinical Processes/Effectiveness 2014 complete list of CQMs for the HER Incentive webpage: Guidance/Legislation/EHRIncentivePrograms/ClinicalQualityMeasures.html Penalties Penalties EPs activity in 2013 determines the penalty adjustment in 2015 for Meaningful Use and PQRS Exempt Providers: All institutional providers FQHC and CAH Medicare Part A providers Providers that do not bill Medicare Part B (e.g. pediatricians) 6

7 Meaningful Use 2015 Penalties Medicare EPs who did not meet Meaningful Use are subject to the 1% penalty effective January 1, Medicare EPs who did not meet meaningful use are subject to the 2.0% penalty effective January 1, 2016 PQRS 2015/2016 Penalties EPs who did not report data on PQRS quality measures during the 2013 program year, payment adjusts begin in % adjustment in 2015 for services rendered January 1 December 31, % adjustment in 2016 and subsequent years Total Possible 2015 Penalties Meaningful Use -1.0% Increases 1% every year to a maximum of 5% PQRS -1.5% Increases 1% to a maximum of 2% 2015 maximum -2.5% 5 years -7.0% The adjustment are for services rendered January 1 December 31,

8 Audits CMS Audits for Meaningful Use Auditors - Figliozzi and Company Initial Letter with CMS logo Followed by electronic letter from CMS address provided during registration for Incentive Program will be used for the initial request letter States have separate process for Medicaid EHR Incentive Program Preparing for an Audit Save electronic or paper documentation that supports attestation Save documentation that support the values entered in the Attestation Module for CQMs Documentation used to validate accurate attestation and submitted CQM s Audit/documentation determines if incentive payment was correct 8

9 Preparing for an Audit Security Risk Analysis Performed by the end of the reporting period Yes/No meaningful use measures Screenshots with dates viewable Drug-Drug/Drug-Allergy Interaction Checks and Clinical Decision Support Proof functionality is available, enabled and active in the system during the reporting period. Exclusions Documentation and acceptable reason for the exclusions (example: immunization) Pre- Audits September 16, 2014 CMS undertaken 5,825 pre-payments audits 3,820 or 65.6% pre-payment audits completed 2,000 pre-payment audits in process 821 or 21.5% pre-payment audits DID NOT MEET MU standards Post- Audits Over 10,000 unique audits on 265,075 attestations Over 4,600 have been completed FAILURE rate is 24% 98.9 of failing EPs did not meet measures $ $19,800 per provider $16, average return 9

10 Medicare/Medicaid Incentive Program Medicaid Incentive Program Over 150,000 EPS are in the program Audits state by state basis No data available Questions? Sheri Smith, FACMPE State Volunteer Mutual Insurance Company Senior Medical Practice Consultant fax 10

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