Medicaid EHR Incentive Program Dentists as Eligible Professionals. Kim Davis-Allen, Outreach Coordinator

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1 Medicaid EHR Incentive Program Dentists as Eligible Professionals Kim Davis-Allen, Outreach Coordinator

2 Considerations Must begin participation by Program Year 2016 Not required to participate in consecutive years No Medicaid penalty for not participating penalty is applied to Medicare Part B claims There is not a mandate that all providers must have and be utilizing certified electronic health record technology (CEHRT) by a certain date June

3 Understanding Participation Program Year Payment Year January 1 - December 31 Year in which you met program requirements Program years through 2021 Simple count Medicaid: One - Six Payment Year One: $21,250 Payment Years Two - Six: $8,500 Medicare: One - Five Payments vary based on when participation began and program year participation June

4 First Year of Program Participation EP Participation and Payments Timeline and Reporting Periods for Participation in the Medicaid EHR Incentive Program Current Year Attestation Year AIU Stage 1 90 days Stage days Stage 2 90 days Stage days Stage days Stage AIU Stage 1 90 days Stage 1 90 days Stage days Stage days Stage AIU Stage 1 90 days Stage days Stage days Stage days Stage AIU Stage 1 90 days Stage days Stage days Stage days Stage AIU Stage 1 90 days Stage days Stage days Stage days Stage AIU Stage 1 90 days Stage days Stage days Stage days Stage 3 June

5 Getting Started CMS Registration and Attestation (R&A) Locate your National Provider Identifier (NPI) and Tax Identification Number (TIN). If you don t have an NPI, visit NPPES and apply Have (or create) a NPPES web user account Register at the CMS EHR Incentive Program Registration site Use the log-in credentials for your NPPES web user account Select Florida for your payment state State Application There is a Quick Link within your individual Medicaid web portal to the application Within three days of successful registration at the R&A your application is populated with your registration information An is sent once the application is active June

6 Medicaid EP Program Requirements The following requirements should be met each participation year: Be an Eligible Provider (EP) Type Physicians Advanced Registered Nurse Practitioners (ARNPs) Certified Nurse-Midwives Dentists Physicians Assistants (PA)* *Must be working in a Federally Qualified Health Center (FQHC) or Rural Health Clinic (RHC) led by a PA Meet Medicaid Volume 30% Medicaid or 20% if Pediatrician Based on consecutive 90 day period in the calendar year prior to the program year or the 12 months prior to application A Medicaid encounter is defined as a service(s) rendered on any one day to an individual enrolled in a Medicaid program. Have CEHRT June

7 June March

8 Current Program Stages Adopt, Implement, Upgrade Stage 1 (two reporting periods) Stage 2 (two reporting periods) Stage 3 (Can Begin 1/1/2017) June

9 EP Volume Methodologies EPs can calculate patient volume one of three ways: 1. Individual Volume: EP uses individual (private practice) Medicaid encounters Total Individual Medicaid Volume Total Individual Volume 2. Group Proxy Volume: EP uses group Medicaid encounters Total Group Medicaid Volume Total Group Volume 3. Individual Volume when affiliated with a group: EP using his individual encounters from the group but all members must use this method June

10 EP Volume Volume can be individual or group Group volume is encouraged - using same methodology Have group designation with Florida Medicaid system (FLMMIS) Once group volume is determined, may be used regardless of program stage Each volume period may only be used once Volume may be based on one or multiple locations At least one volume location must have CEHRT Medicaid volume no longer based on paid claims Volume workbook available Maintain details of volume information to support application June

11 Adopt, Implement, Upgrade (AIU) Do not have to be using the system May not be a planned purchase or upgrade (e.g. in the next three months) Must have 2014 CEHRT To support AIU, need a vendor letter containing Provider or practice name 2014 Certification number Name and version of the system Date of purchase or upgrade June

12 Meaningful Use Basics Meaningful use reporting is based on all patients/encounters 50% of encounters must be at locations equipped with CEHRT 80% of unique patients seen at locations with CEHRT must have their records in CEHRT June

13 Current Stage 1 Requirements for EPs 13 Core Measures 5 Menu Measures 9 CQMS For complete information on Stage 1, visit: Guidance/Legislation/EHRIncentivePrograms/Meaningful_Use.html June

14 Computerized Provider Order Entry (CPOE) Objective Use Computerized Provider Order Entry (CPOE) for medication orders directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local, and professional guidelines Measure More than 30% of all unique patients OR total medication orders with at least one medication in their medication list seen by the EP have at least one medication order entered using CPOE Exclusion An EP who writes fewer than 100 prescriptions during the EHR reporting period As a Dental Provider Order medications through the CEHRT (e.g antibiotics for infections) June

15 Drug-Drug; Drug Allergy Objective Implement drug-drug and drug-allergy interaction checks Measure The EP has enabled this functionality for the entire EHR reporting period Exclusion None As a Dental Provider Automatic when enabled in the CEHRT June

16 Problem List Objective Maintain an up-to-date problem list of current and active diagnoses Measure More than 80% of all unique patients seen by the EP have at least one entry or an indication that no problems are known for the patient recorded as structured data Exclusion None As a Dental Provider Review prior to treatment If no active problems, document no known problems as structured data June

17 E-Prescribing Objective Generate and transmit permissible prescriptions electronically (erx) Measure More than 40% of all permissible prescriptions written by the EP are transmitted electronically using CEHRT Exclusion An EP who writes fewer than 100 prescriptions during the EHR reporting period An EP that does not have a pharmacy within their organization and there are no pharmacies that accept electronic prescriptions within 10 miles of the EP s practice at the start of his/her EHR reporting period As a Dental Provider Order/ transmit all permissible prescriptions Address workflow June

18 Active Medication List Objective Maintain active medication list Measure More than 80% of all unique patients seen by the EP have at least one entry (or an indication that the patient is not currently prescribed any medication) recorded as structured data Exclusion None As a Dental Provider Update the list with reported medications prescribed including over the counter medications If no active medications, document no active medications as structured data Not required to update this list at every contact with the patient June

19 Active Medication Allergy List Objective Maintain active medication allergy list Measure More than 80% of all unique patients seen by the EP have at least one entry (or an indication that the patient has no known medication allergies) recorded as structured data Exclusion None As a Dental Provider Review prior to treatment If no active medication allergies, document no active medication allergies as structured data June

20 Demographics Objective Record all of the following demographics: preferred language, gender, race, ethnicity, date of birth Measure More than 50% of all unique patients seen by the EP have demographics recorded as structured data Exclusion None As a Dental Provider Review and address workflows to capture this information June

21 Vital Signs Objective Record and chart changes in the following vital signs: Height (H), Weight (W), Blood Pressure (BP); calculate and display body mass index (BMI); and plot and display growth charts for children 2-20 years, including BMI Measure More than 50% of all unique patients seen by the EP during the EHR reporting period have BP (for patients age 3 and over only) and H and W (for all ages) recorded as structured data Exclusions Sees no patients three years or older is excluded from recording BP Believes three vital signs have no relevance to their practice Believes H and W are relevant, but BP is not, is excluded from recording BP Believes BP is relevant to their scope of practice, but H and W are not, is excluded from recording H and weight As a Dental Provider Take the exclusion as appropriate June

22 Smoking Status Objective Record smoking status for patients 13 years old and older Measure More than 50% of all unique patients 13 years or older seen by the EP have smoking status recorded as structured data Exclusion An EP who sees no patients 13 years or older As a Dental Provider Verify workflows to ensure status captured as structure data June

23 Clinical Decision Support Objective Implement one clinical decision support rule relevant to specialty or high clinical priority along with the ability to track compliance with that rule Measure Implement one clinical decision support rule Exclusion None As a Dental Provider Dental specific reminders are not required May be dictated by system June

24 Clinical Summaries Objective Provide clinical summaries for patients for each office visit Measure Clinical summaries provided to patients for more than 50% of all office visits within 3 business days Exclusion An EP who has no office visits during the EHR reporting period As a Dental Provider An after-visit summary that provides a patient with relevant and actionable information and instructions. Minimal data elements required. If an EP believes that substantial harm may arise from the disclosure of particular information, an EP may choose to withhold that particular information from the clinical summary Dental specific information not required June

25 View, Download, and Transmit Objective Provide patients the ability to view online, download, and transmit their health information (with four business days of the information being available to the EP) Measure More than 50% of unique patients seen by the EP during the EHR reporting period are provided timely access (available to the patient within four business days after the information is available to the EP) online access to their health information subject to the EP s discretion to withhold certain information Exclusion An EP who neither orders nor creates any of the information listed for inclusion, except for "Patient name" and "Provider's name and office contact information, may exclude the measure As a Dental Provider Not required that patient actually access but must have information necessary to access June

26 Protect Electronic Health Information Objective Protect electronic health information created or maintained by the CEHRT through the implementation of appropriate technical capabilities Measure Conduct or review a security risk analysis in accordance with the requirements under 45 CFR (a)(1) and implement security updates as necessary and correct identified security deficiencies as part of its risk management process Exclusion None As a Dental Provider The analysis is meant to be a complete review of the components specified in the federal regulation, including policies and procedures, and responsible parties Risks and deficiencies must be identified and a mitigation plan in place; including who will complete the task, how will you complete the task, and when will you complete the task June

27 Stage 1 Menu Measures No longer be permitted to count an exclusion toward the minimum required if there are other objectives that can be met Can claim exclusions for an objective if qualify for remaining menu objectives If you exclude from any menu measure, MAPIR will require you to answer all menu measures June

28 Drug Formulary Checks Objective Implement drug formulary checks Measure The EP has enabled this functionality and has access to at least one internal or external formulary for the entire EHR reporting period Exclusion An EP who writes fewer than 100 prescriptions during the EHR reporting period As a Dental Provider Automatic when enabled in the CEHRT June

29 Incorporate Lab Results Objective Incorporate clinical lab test results into EHR as structured data Measure More than 40% of all clinical lab test results ordered by the EP during the EHR reporting period who results are either in a positive/negative or numerical format are incorporated in CEHRT as structured data Exclusion An EP who orders no lab tests whose results are either in a positive/negative or numerical format during the EHR reporting period As a Dental Provider Applies to lab tests ordered by the dentist (provider) June

30 Generate Patient Lists Objective Generate lists of patients by specific conditions to use for quality improvements, reduction of disparities, research, or outreach Measure Generate at least one report listing patients of the EP with a specific condition Exclusion None As a Dental Provider Generate a list of patients with a medical condition relevant to dentist service delivery (e.g. hypertension) Generate patient list based on a dental diagnosis or condition June

31 Patient Reminders Objective Send reminders to patients per patient preference for preventive/follow-up care Measure More than 20% of all patients 65 years old or older or 5 years old or younger were sent an appropriate reminder during the EHR reporting period Exclusion An EP who has no patients 65 years old or older or 5 years old or younger with records maintained using CEHRT As a Dental Provider Can use an outside reminder system but must be captured within the CEHRT Does not have to be dental-specific June

32 Patient Education Objective Use CEHRT to identify patient-specific education resources and provide those resources to the patient if appropriate Measure More than 10% of all unique patients seen by the EP provided patient-specific education resources Exclusion None As a Dental Provider Resources identified through logic built into CEHRT which evaluates information about the patient and suggests education resources that would be of value to the patient Education resources or materials do not have to be stored within or generated by the CEHRT Understand how system captures and reports June

33 Medication Reconciliation Objective The EP who receives a patient from another setting of care or provider of care or believes an encounter is relevant should perform medication reconciliation Measure The EP performs medication reconciliation for more than 50% of transitions of care in which the patient is transitioned into the care of the EP Exclusion An EP who was not the recipient of any transitions of care during the EHR reporting period As a Dental Provider Only required for identified transitions of care June

34 Summary Care Record Objective The EP who transitions their patient to another setting of care of provider of care or refers their patient to another provider of care should provide a summary care record for each transition of care or referral Measure The EP who transitions or refers their patient to another setting of care or provider of care provides a summary of care record for more than 50% of transitions of care and referrals Exclusion An EP who neither transfers a patient to another setting nor refers a patient to another provider during the EHR reporting period As a Dental Provider Only required for identified transitions of care Can send an electronic or paper copy of the summary care record directly to the next provider or can provide it to the patient to deliver to the next provider, if the patient can reasonably expected to do so. June

35 Immunization Registry Objective Capability to submit electronic data to immunization registries or immunization information systems and actual submission according to applicable law and practice Measure Performed at least one test of CEHRT s capacity to submit electronic data to immunization registries and follow up submission if the test is successful (unless none of the immunization registries to which the EP submits such information has the capacity to receive the information electronically) Exclusion An EP who administers no immunizations during the EHR reporting period or where no immunization registry has the capacity to receive the information electronically As a Dental Provider Exclusion applies June

36 Syndromic Surveillance Objective Capability to submit electronic syndromic surveillance data to public health agencies and actual submission according to applicable law and practice Measure Performed at least one test of CEHRT s capacity to provide electronic syndromic surveillance data to public health agencies and follow-up submission if the test is successful (unless none of the public health agencies to which an EP submits such information has the capacity to receive the information electronically) Exclusion An EP who does not collect any reportable syndromic information on their patients during the EHR reporting period or does not submit such information to any public health agency that has the capacity to receive the information electronically As a Dental Provider Not an option for Florida providers June

37 2014 Clinical Quality Measures (CQM) Regardless of Stage EPs - 9 out of 64 Cover at least three of the National Quality Strategy Domains Core Sets for Adult and Children No threshold that must be met CQM Reporting Dually eligible hospitals beyond first year of Meaningful Use must electronically report CQM data EPs attesting to Medicare beyond their first year of Meaningful Use must electronically report CQM data EPs attesting to Medicaid will report to the state through the online application (MAPIR) June

38 CQM National Quality Strategy Domains Patient Safety (PS) Clinical Process and Effectiveness (CPE) Care Coordination (CC) Efficient Use of Healthcare Resources (EHR) Patient and Family Engagement (PFE) Population and Public Health (PPH) June

39 Certification Flexibility Rule Rule effective October 1, 2014 The rule grants flexibility to providers who are unable to fully implement 2014 edition CEHRT for an EHR reporting period in 2014 due to delays in 2014 CEHRT availability Implementation- a provider s ability to fully implement the functionality may be limited by the availability and timing of product installation, deployment of new processes and workflows, and employee training Providers may now use EHRs that have been certified under the 2011 edition, a combination of the 2011 and 2014 editions, or the 2014 edition for 2014 participation June

40 Attestation Options June

41 Unable To Fully Implement Due To Software development delays Missing or delayed software updates Being able to implement 2014 CEHRT for only part of the reporting period not the full reporting period Unable to train staff, test the updated system, or put new work flows in place because of delays associated with installation of 2014 CEHRT Unable to meet Stage 2 summary of care measures due to recipient of transmittals impacted by 2014 CEHRT issues June

42 Reasons That Do Not Count as Delays in 2014 Edition CEHRT Financial issues Inability to meet one or more measures Staff turnover and changes Provider waited too long to engage a vendor Refusal to purchase the requisite software updates Providers who fully implemented 2014 edition CEHRT and can report in 2014 June

43 2015 Modification Rule - Proposed Changes June

44 Goals of Proposed Provisions Align with Stage 3 proposed rule to achieve overall goals of program Synchronize reporting period objectives and measures to reduce burden Continue to support advanced use of Health IT to improve outcomes for patients June

45 2015 Proposed Rule Overview Streamlines program by removing redundant, duplicative, and topped out measures Modified patient action measures in Stage 2 objective related to patient engagement Aligned reporting with full calendar year (for eligible hospitals) Changes EHR reporting period in 2015 to 90 day period to accommodate modifications June

46 Proposed Participation Changes - Medicaid 2015: all providers 90 days o Attest to modified version of Stage 2 with alternative measures/exclusions for Stage 1 providers 2016: 1 st year 90 days; all other full year o Attest to modified version of Stage : 1 st year 90 days; all other full year o Attest to modified version of Stage 2 or Stage : 1 st year 90 days; all other full year o Attest to Stage 3 June

47 Proposed Meaningful Use Measures: Reporting Periods CPOE E-Prescribing Clinical Decision Support View, Download or Transmit Security Risk Analysis Patient Specific Education Medication Reconciliation Summary of Care Secure Messaging Public Health The complete Proposed Rule can be found at: https://www.federalregister.gov/articles/2015/04/15/ /medicare-andmedicaid-programs-electronic-health-record-incentive-program-modifications-to June

48 Proposed CPOE: Proposed Measure 1: More than 60% of medication orders created by the EP Measure 2: More than 30% of laboratory orders Measure 3: More than 30% of radiology orders created by the EP during the EHR reporting period are recorded using computerized provider order entry Proposed Alternate: If scheduled for Stage 1 in 2015 Measure 1: More than 30% of all unique patients with at least one medication in their medication list seen by the EP Exclusion for Measure 2: No equivalent Stage 1 measure Exclusion for Measure 3: No equivalent Stage 1 measure June

49 Proposed E-prescribing: Proposed Proposed Alternate: If scheduled for Stage 1 in 2015 More than 50% of all permissible prescriptions, or all prescriptions, written by the EP are queried for a drug formulary and transmitted electronically using CEHRT More than 40% of all permissible prescriptions written by the EP are transmitted electronically using CEHRT June

50 Proposed Clinical Decision Support: Proposed Measure 1: Implement five clinical decision support interventions related to four or more clinical quality measures at a relevant point in patient care for the entire EHR reporting period Measure 2: The EP has enabled and implemented the functionality for drugdrug and drug allergy interaction checks for the entire EHR reporting period Exclusion: For the second measure, any EP who writes fewer than 100 medication orders during the EHR reporting period Proposed Alternate: If scheduled for Stage 1 in 2015 Measure 1: Implement one clinical decision support rule Measure 2: The EP has enabled and implemented the functionality for drugdrug and drug allergy interaction checks for the entire EHR reporting period June

51 Proposed Patient Electronic Access: Proposed Measure 1: More than 50% of all unique patients seen by the EP during the EHR reporting period are provided timely (within four business days after the information is available to the EP) online access to their health information subject to the EP's discretion to withhold certain information Measure 2: At least one patient seen by the EP during the EHR reporting period (or their authorized representatives) views, downloads, or transmits his or her health information to a third party Proposed Alternate: If scheduled for Stage 1 in 2015 Same as proposed Exclusion for Measure 2: No equivalent Stage 1 measure June

52 Proposed Electronic Health Information Protection: Proposed Conduct or review a security risk analysis in accordance with the requirements in 45 CFR (a)(1), including addressing the security (to include encryption) of ephi data stored in CEHRT in accordance with requirements in 45 CFR (a)(2)(iv), and 45 CFR (d)(3), and implement security updates as necessary and correct identified security deficiencies as part of the EP, eligible hospital, or CAHs risk management process Proposed Alternate: If scheduled for Stage 1 in 2015 Same as proposed June

53 Proposed Patient Specific Education: Proposed Patient specific education resources identified by CEHRT are provided to patients for more than 10% of all unique patients with office visits seen by the EP during the EHR reporting period Proposed Alternate: If scheduled for Stage 1 in 2015 Same as proposed Provider may claim an exclusion for the measure of the Stage 2 Patient Specific Education objective if for an EHR reporting period in 2015 they were scheduled to demonstrate Stage 1 but did not intend to select the Stage 1 Patient Specific Education menu objective June

54 Proposed Medication Reconciliation: Proposed The EP performs medication reconciliation for more than 50% of transitions of care in which the patient is transitioned into the care of the EP Proposed Alternate: If scheduled for Stage 1 in 2015 Provider may claim an exclusion if they did not intend to select the Stage 1 Medication Reconciliation menu objective June

55 Proposed Summary of Care: Proposed The EP that transitions or refers their patient to another setting of care or provider of care (1) uses CEHRT to create a summary of care record; and (2) electronically transmits such summary to a receiving provider for more than 10% of transitions of care and referrals Proposed Alternate: If scheduled for Stage 1 in 2015 Provider may claim an exclusion if they did not intend to select the Stage 1 Summary of Care menu objective June

56 Proposed Secure Messaging: Proposed During the EHR reporting period, the capability for patients to send and receive a secure electronic message with the provider was fully enabled Proposed Alternate: If scheduled for Stage 1 in 2015 Provider may claim an exclusion since there is not an equivalent Stage 1 measure June

57 Proposed Public Health: Proposed: Choose 2 Immunization Registry Reporting Syndromic Surveillance Reporting Case Reporting Public Health Registry Reporting Clinical Data Registry Reporting Proposed Alternate: If scheduled for Stage 1 in 2015 Chose 1 public health measure to report on Same exclusions apply if an EP: Does not administer immunizations Does not collect data Does not treat condition No registry acceptable of accepting electronic data No registry has declared readiness to receive June

58 Things to Remember Grace Period for Program Year 2014 ends June 30, 2015 Proposed changes at this time comments through June 15, 2015 Stay the Course June

59 Resources for Dentists How does Meaningful Use impact health IT for oral health? pacthealthit.html ADA: Electronic Health Records June

60 Additional Contacts and Resources Online Call EHR Incentive Program Call Center: (855) Social Media June

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