Stage 1 CMS EHR Incentive Program

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1 Stage 1 CMS EHR Incentive Program

2 Conflict of Interest Disclosure Elizabeth Holland Travis Broome, MPH, MBA Jason McNamara Have no real or apparent conflicts of interest to report.

3 Learning Objectives 1.Updates on the Medicare & Medicaid EHR Incentive Programs 2.Understand the stage timeline and how the stages impact implementation decisions 3.Understand provider performance on Stage 1

4 Medicare & Medicaid EHR Incentives Program Created by the American Recovery and Reinvestment Act of 2009 Where are we now? Medicaid launched in January 2011, started making payments for adopting/implementing/upgrading (AIU) soon after Today 49 states and 2 territories have Medicaid EHR incentive programs in place (Puerto Rico and Mariana Islands) Medicare opened registration in Jan 2011, opened attestation in April 2011 and started paying in May 2011

5 registration

6 registration

7 As of Jan 31, 2013 Registered Eligible Hospitals 15.05% 84.95% 5,011 Total Hospitals Registered Hospitals

8 As of Jan 31, 2013 Registered Eligible Professionals 21.79% 48.08% 30.13% 527,200 Total EPs Registered Medicare EPs (253,477) Registered Medicaid EPs (114,866)

9

10 Medicare EP Summary Jan 2013

11 Payment Summary Payment Summary

12 Medicaid EHR Incentive Payments Jan 2013

13 Paid hospitals 73.18% 26.82% 5,011 Total Hospitals Hospitals Paid

14 Paid Eligible Professionals 2.11% Paid Eligible Professionals 13.89% 23.26% 60.74% 527,200 Total EPs Medicare EPs (122,632) Medicaid EPs (73,233) MAO EPs (11,117)

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16

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19 Medicare-only Eligible Professionals Medicaid-only Eligible Professionals Could be eligible for both Medicare & Medicaid incentives 19

20 Hospitals only eligible for Medicare incentive Hospitals only eligible for Medicaid incentive Could be eligible for both Medicare & Medicaid (most hospitals)

21 Advanced clinical processes Improved outcomes Data capturing and sharing Stage 3 Stage 2 Stage 1 Stages of Meaningful Use 21

22 Everyone starts in Stage 1 No one starts Stage 2 before 2014

23 When do I start Stage 2? 1 st Year of MU 2 years Stage

24 Avoiding 2015 Payment Adjustments Meaningful EHR User in 2011 Never been a Meaningful Demonstrate meaningful use to CMS or Texas by: or 2012 EHR User End EHR reporting period by End EHR reporting period by Dec 31, 2013 Sep 30, 2014 Hospitals subtract 3 months Attest by Feb 28, 2013 Attest by Oct 1, 2014 Hospitals Subtract 3 Months Apply to CMS for a hardship exemption by: July 1,

25 Impact of Certification Q: What Certified EHR Technology do I need in 2014? A: EHR Technology certified to the 2014 Criteria covering the base EHR plus all objectives I intend to attest for in Q: Does it matter if I am in Stage 1 or 2? A: No Q: Can I use 2014 Certified EHR Technology to satisfy Stage 1 in 2013? A: Yes

26 MU and Implementation Put each objective in the context of the goal Why does CPOE improve quality, safety and efficiency? Is it measurable? How can usability and workflow be better? 26

27 Always looking to the future Stage 2 moves 9 of the 10 menu measures from Stage 1 to core Of the 23 objectives in Stage 2 only 5 are completely new for Stage 2 Of the 22 objectives in Stage 2, only 8 are completely new

28 Stage 1 Eligible Professionals 15 core objectives 5 of 10 menu objectives 20 total objectives Stage 2 Eligible Professionals 17 core objectives 3 of 6 menu objectives 20 total objectives Eligible Hospitals & CAHs 14 core objectives 5 of 10 menu objectives 19 total objectives Eligible Hospitals & CAHs 16 core objectives 3 of 6 menu objectives 19 total objectives 28

29 Lab Results Patient Lists Patient Education Summary of Care Records Medication Reconciliation Immunizations Patient Reminders Online Patient Information EP Lab Results Patient Lists Patient Education Summary of Care Records Medication Reconciliation Immunizations Public health lab results Syndromic surveillance Hospital

30 Secure Messaging Family Health History Imaging Results Registry Reporting Progress Notes Online Patient Information Family Health History Imaging Results Registry Reporting Progress Notes E-Prescribing emar Electronic lab results EP Hospital

31 Current Stage 1 Measure New Stage 1 Measure Age Limits= Age 2 for Blood Pressure & Height/ Weight Age Limits= Age 3 for Blood Pressure, No age limit for Height/ Weight Exclusion= All three elements not relevant to scope of practice Exclusion= Blood pressure to be separated from height /weight The vital signs changes are optional in 2013, but required starting in

32 Current Stage 1 Measure Stage 1 Measure Removed One test of electronic transmission of key clinical information Requirement removed effective 2013 The removal of this measure is effective starting in

33 Current Stage 1 Objective New Stage 1 Objective Objective= Provide patients with e-copy of health information upon request Provide electronic access to health information Objective= Provide patients the ability to view online, download and transmit their health information The measure of the new objective is 50% of patients are provided access to their information; there is no requirement that 5% of patients do access their information for Stage 1. The change in objective takes effect in 2014 to coincide with the 2014 certification and standards criteria 33 33

34 Dealing with EPs practicing in Multiple Locations Equipped with CEHRT Equipped With CEHRT MU => 50% Not Equipped with CEHRT

35 Clinical Quality Measures CQM Requirements Stage of Meaningful Use CQM Requirements Year CQM Requirements Output of Certified EHR

36 Prior to 2014 Beginning in 2014 EPs Report 6 out of 44 CQMs 3 core or alt. core 3 menu EPs Report 9 out of 64 CQMs Selected CQMs must cover at least 3 of the 6 NQS domains Recommended core CQMs: 9 for adult populations 9 for pediatric populations Eligible Hospitals and CAHs Report 15 out of 15 CQMs Eligible Hospitals and CAHs Report 16 out of 29 CQMs Selected CQMs must cover at least 3 of the 6 NQS domains Changes to CQMs Reporting 36

37 Eligible Professionals reporting for the Medicare EHR Incentive Program Category Data Level Payer Level Submission Type Reporting Schema EPs in 1 st Year of Demonstrating MU* Aggregate All payer Attestation Submit 9 CQMs from EP measures table (includes adult and pediatric recommended core CQMs), covering at least 3 domains EPs Beyond the 1 st Year of Demonstrating Meaningful Use Option 1 Aggregate All payer Electronic Submit 9 CQMs from EP measures table (includes adult and pediatric recommended core CQMs), covering at least 3 domains Option 2 Patient Medicare Electronic Satisfy requirements of PQRS EHR Reporting Option using CEHRT Group Reporting (only EPs Beyond the 1 st Year of Demonstrating Meaningful Use)** EPs in an ACO (Medicare Shared Savings Program or Pioneer ACOs) Patient Medicare Electronic Satisfy requirements of Medicare Shared Savings Program of Pioneer ACOs using CEHRT EPs satisfactorily reporting via PQRS group reporting options Patient Medicare Electronic Satisfy requirements of PQRS group reporting options using CEHRT *Attestation is required for EPs in their 1 st year of demonstrating MU because it is the only reporting method that would allow them to meet the submission deadline of October 1 to avoid a payment adjustment. **Groups with EPs in their 1 st year of demonstrating MU can report as a group, however the individual EP(s) who are in their 1 st year must attest to their CQM results by October 1 to avoid a payment adjustment. 37

38 Eligible Hospitals reporting for the Medicare EHR Incentive Program Category Data Level Payer Level Submission Type Reporting Schema Eligible Hospitals in 1 st Year of Demonstrating MU* Aggregate All payer Attestation Submit 16 CQMs from Eligible Hospital/CAH measures table, covering at least 3 domains Eligible Hospitals/CAHs Beyond the 1 st Year of Demonstrating Meaningful Use Option 1 Aggregate All payer Electronic Submit 16 CQMs from Eligible Hospital/CAH measures table, covering at least 3 domains Option 2 Patient All payer (sample) Electronic Submit 16 CQMs from Eligible Hospital/CAH measures table, covering at least 3 domains Manner similar to the 2012 Medicare EHR Incentive Program Electronic Reporting Pilot *Attestation is required for Eligible Hospitals in their 1 st year of demonstrating MU because it is the only reporting method that would allow them to meet the submission deadline of July 1 to avoid a payment adjustment. 38

39 Resources CMS Program Website ONC Program Website Details on the Stage 1 Meaningful Use Objectives/Measures EPs: Guidance/Legislation/EHRIncentivePrograms/Downloads/EP-MU-TOC.pdf Hospitals: Guidance/Legislation/EHRIncentivePrograms/Downloads/Hosp_CAH_MU-TOC.pdf How much are the incentives? Is my EHR certified? I advise others on meaningful use for a living/i develop certified EHRs Stage 1 Final Rule: Stage 2 Final Rule: Certification Rule:

40 How are EPs doing on Stage 1 improving care? Objective Performance Threshold 50% Interval Exclusion Deferral CPOE 84% 30% 99.1% 74.3% 19% N/A Electronic 79% 40% 92.6% 68.8% 23% N/A Prescribing Maintain Problem 96% 80% 100% 94.6% N/A N/A List Maintain 97% 80% 100% 96.2% N/A N/A Medication List Maintain 96% 80% 99.8% 94.8% N/A N/A Medication Allergy List Record 91% 50% 99.6% 85.7% N/A N/A Demographics Record Vital Signs 91% 50% 98.6% 86.1% 8% N/A Record Smoking 90% 50% 98.7% 84.7% 0.5% N/A Status Drug Formulary N/A N/A N/A 14% 16% Checks Incorporate Lab 91% 40% 100% 89.1% 4% 38% Results Patient Lists N/A N/A N/A N/A 25% Send Reminders to Patients 62% 20% 90.5% 36.5% 0.5% 78%

41 How are EPs doing on Stage 1 Patient Engagement? Objective E Copy of Health Information Office Visit Summaries Performance Threshold 50% Interval Exclusion Deferral 96% 50% 100% 100% 69% N/A 78% 50% 93.8% 63.8% 2% N/A Patient Education Resources Timely Electronic Access 49% 10% 74.9% 22.1% 73% 10% 100% 44.1% N/A 50% 2% 65%

42 How are EPs doing on Stage 1 Care Coordination? Objective Performance Threshold 50% Interval Exclusion Deferral Medication Reconciliation 89% 50% 99.9% 83.5% 3% 56% Summary of Care at Transitions 89% 50% 100% 80.0% 3% 84%

43 Medicaid Eligibility Expansion Patient Encounters The definition of what constitutes a Medicaid patient encounter has changed. The rule includes encounters for anyone enrolled in a Medicaid program, including Medicaid expansion encounters (except stand-alone Title 21), and those with zero-pay claims The rule adds flexibility in the look-back period for overall patient volume

44 Patient Volume - Medicaid Encounters: Previously under Stage 1 rule: Service rendered on any one day where Medicaid paid for all or part of the service or Medicaid paid the co-pays, cost-sharing, or premiums Changed in Stage 2 rule (applicable to all stages): Service rendered on any one day to a Medicaid-enrolled individual, regardless of payment liability Includes zero-pay claims and encounters with patients in Title 21-funded Medicaid expansions (but not separate CHIPs) 44

45 Zero-pay claims include: Claim denied because the Medicaid beneficiary has maxed out the service limit Claim denied because the service wasn t covered under the State s Medicaid program Claim paid at $0 because another payer s payment exceeded the Medicaid payment Claim denied because claim wasn t submitted timely Such services can be included in provider s Medicaid patient volume calculation as long as the services were provided to a beneficiary who is enrolled in Medicaid 45

46 CHIP encounters in patient volume calculation Previously under Stage 1 rule: Only CHIP encounters for patients in Title 19 Medicaid expansion programs Under Stage 2 rule (applicable to all stages): CHIP encounters for patients in Title 19 and Title 21 Medicaid expansion programs As before, encounters with patients in stand-alone CHIP programs cannot be included in Medicaid patient volume calculation 46

47 90-day Reporting Period for Patient Volume Under Stage 1 rule, Medicaid patient volume for providers calculated across 90-day period in last calendar year (for EPs) or Federal fiscal year (for hospitals) Under Stage 2 rule (applicable to all stages), States also have option to allow providers to calculate Medicaid patient volume across 90-day period in last 12 months preceding provider s attestation Also applies to needy individual patient volume Applies to patient panel methodology With at least one Medicaid encounter taking place in the 24 months prior to 90-day period (expanded from 12 months prior) 47

48 Children s Hospitals Medicaid made approximately 12 additional children s hospitals eligible that have not been able to participate to date, despite meeting all other eligibility criteria, because they do not have a CMS Certification Number since they do not bill Medicare. 48

49 Hospital Incentive Calculation - discharge-related amount: Hospitals that began participating before FFY 2013 use discharge data from hospital fiscal year that ends during FFY prior to hospital fiscal year that services as the first payment year Hospitals that begin participating in FFY 2013 or later use discharge data from most recent continuous 12-month period for which data are available prior to payment year 49

50 Adopt, Implement, or Upgrade (AIU) - starting in 2014: To align our polices with ONC EHR Certification Standards we modified our definition of Adopt, Implement or Upgrade. Providers can no longer attest to AIU with any Certified EHR Technology. Providers who attest to AIU in 2014 are required to secure Certified EHR Technology that can bring them to Meaningful Use in the subsequent years. 50

51 CMS Program Sessions TITLE SESSION # DATE TIME ROOM SPEAKERS Stage 1: CMS EHR Incentive Programs Stage 2: CMS EHR Incentive Programs CMS Town Hall: CMS and ehealth: Building the Future ICD-10 and Administrative Simplification 23 Monday, March 4 11:00 AM - 12:00 PM New Orleans Theater C 62 Tuesday, March 5 9:45 AM - 10:45 AM New Orleans Theater C 81 Tuesday, March 5 1:00 PM - 2:00 PM New Orleans Theater C 131 Wednesday, March 6 8:30 AM - 9:30 AM Room 294 Elizabeth Holland, CMS Travis Broome, CMS Jason McNamara, CMS Elizabeth Holland, CMS Robert Anthony, CMS Jason McNamara, CMS Steven Posnack, ONC Robert Tagalicod, CMS Kate Goodrich, CMS Elizabeth Holland, CMS Christine Stahlecker, CMS Maribel Franey, CMS Christine Stahlecker, CMS Matthew Albright, CMS Kari Gaare, CMS Denesecia Green, CMS Views from the CMS Administrator 138 Wednesday, March 6 9:45 AM - 10:45 AM New Orleans Theater C Marilyn Tavenner, CMS CMS Quality Measurement 178 Thursday, March 7 11:15 AM - 12:15 PM New Orleans Theater C Maria Michaels, CMS Deborah Kraus, CMS Maria Harr, CMS

52 Talk to CMS about ehealth at Booth #2868 To learn more about CMS ehealth programs, visit

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