The EHR Incentive Program

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1 The EHR Incentive Program Summary of the Centers for Medicare and Medicaid Services (CMS) Final Rule on Meaningful Use On July 13th, the Centers for Medicare and Medicaid Services (CMS) released its final rule outlining how eligible physicians and hospitals can qualify for specific Medicare and Medicaid incentives for the adoption and use of certified EHR technology. The final rule establishes the program requirements for participating in the EHR incentive program beginning in 2011, and provides both challenges and opportunities for dermatologist interested in adopting EHRs. Authorized under the American Recovery and Reinvestment Act (ARRA) of 2009, the EHR incentive program is expected to stimulate interest in the adoption of EHRs by eligible physicians and hospitals through payments of up to $44,000 over five years under Medicare, or up to $63,750 over six years under Medicaid. Providers will need to meet several requirements to be eligible for the incentive funds including using a certified EHR system (systems are listed at and become a meaningful user, which is outlined in the final rule. Starting in 2015, dermatologists and other physicians who do not participate in adopting certified EHR systems and becoming meaningful users of this technology will risk reduced Medicare payments. With this final rule, CMS is moving ahead to stimulate participation in achieving significant improvements in health care coordination processes and quality outcomes through EHRs. Table 1: Payment Schedule for Participation in the Medicare EHR Incentive Program* YEAR OF ADOPTION IN 2011 IN 2012 IN 2013 IN 2014 IN 2015 IN 2016 TOTAL INCENTIVE PENALTY 2011 $18,000 $12,000 $8,000 $4,000 $2,000 $0 $44,000 0% 2012 $18,000 $12,000 $8,000 $4,000 $2,000 $44,000 0% 2013 $15,000 $12,000 $8,000 $4,000 $39,000 0% 2014 $12,000 $8,000 $4,000 $24,000 0% % % 2017 and beyond 3% *Note: Payment is based on 75 percent of the physician s Medicare allowed charges or a maximum which is listed in the table above. Providers must also have at least $24,000 in Medicare Part B allowed charges per year.

2 Eligibility CMS defines eligible providers (EP) for the Medicare EHR Incentive Program as providers who are a doctor of medicine or osteopathy, doctor of dental surgery or dental medicine, doctor of podiatry, doctor of optometry or a chiropractor who is not hospital-based. A Medicaid eligible provider is defined as a physician, nurse practitioner, certified nurse-midwife, dentist, or physician assistant who furnish services in a Federally Qualified Health Center or Rural Health Clinic that is led by a physician assistant. To qualify for an EHR incentive payment, a Medicaid EP must not be hospital-based and must have a minimum of 30% of their patient volume composed of Medicaid patients, be a pediatrician and have at least 20% of their patient volume composed of Medicaid patients or practice predominantly in a Federally Qualified Health Center or Rural Health Center and have a minimum 30% patient volume attributable to needy individuals. Providers may only select one program to participate in. Final Rule Guidelines Thanks to its advocacy efforts, the American Academy of Dermatology Association (AADA), along with other national medical associations and specialty societies, voiced their concerns about the pace and scope of the original implementation requirements. As a result, we Important guidelines to remember: Providers must use an ONC ATCB certified system Providers will only need to attest in 2011 and 2012 that they completed the objectives for Stage 1. Providers must complete 15 core objectives and 5 objectives from a menu set. A total of $44,000 over a five year period is available to providers who successfully report the stated objectives for the Medicare EHR Incentive Program. A total of $63,750 over a six year period is available to providers who successfully report the stated objectives for the Medicaid EHR Incentive program. were able to convince CMS to reduce the number of meaningful use requirements and lower the reporting thresholds it had previously proposed for Stage 1 of the program. Though the program requirements remain challenging, complex and comprehensive with some 15 core criteria set that all participants must meet, dermatology practices will now have greater flexibility in determining which additional five from the menu criteria set to report. CMS has also made changes to the timeline and set all of the criteria for 2011 and 2012 as Stage 1. Upcoming years will involve Stage 2 and Stage 3 criteria which are expected to be more difficult to achieve. Table 2: Stage of Meaningful Use Criteria by Year First Payment Year Payment Year Stage 1 Stage 1 Stage 2 Stage 2 TBD 2012 Stage 1 Stage 1 Stage 2 TBD 2013 Stage 1 Stage 1 TBD 2014 Stage 1 TBD

3 The final rule retains many of the same criteria originally outlined in the earlier proposed rule; 2011 will still be the first year eligible providers can apply for the funds and providers participating in the Medicare incentive program may only be allowed to apply for five successive payment years. Thus, if you apply for the funds in 2011 and do not apply in 2012, you will only be eligible to collect your incentive in 2013, 2014 and 2015 and cannot apply for an additional year. The is still minimized to 90 days in the first year and a full reporting year in any successive year. Providers who participate in the e-prescribing incentive program the same year they apply for the EHR incentive program will still be ineligible to collect money from both programs, and providers who successfully report and receive incentive dollars Example of Incentive Payment Schedule: Question: A dermatologist applies for the Medicare EHR incentive funds in 2011, however fails to apply in She continues applying in 2013, 2014 and How much is she eligible to collect in incentive funds? Answer: She would be eligible to collect up to $32,000. She would not be able to collect any funds from 2012 as she skipped the registration process for that year. The Medicare Incentive Program only allows physicians to collect the money on a continuous basis. They may not go back and collect any funds from previous years. will have their names and addresses published on the CMS website. Providers should still continue to report in the e-prescribing incentive program to avoid any e-prescribing penalties. The major changes, however, between the proposed and final versions of the meaningful use rule are in the reporting of s. The proposed meaningful use rule would have required providers to report on 25 core criteria. The final rule reduces these core criteria to 15 s and requires providers to report on an additional 5 s from a menu set. Providers will need to attest in 2011 and 2012 on the CMS website that they performed these s in order to be eligible for the stimulus dollars. After 2012, CMS will require providers to electronically submit this data to CMS. Please note, CMS has up to ten years to audit your documentation for meaningful use, so you should keep this information safely secured. Providers must begin their participation in this program by October 1, 2012, at the latest, to quality for the full $44,000. Dermatologists may not need to report on all core and menu sets of s. Providers may attest that their denominator is zero for a particular quality if it does not apply to their specialty. Additionally, one of the core s required is the reporting of quality s. Providers must report a total of six quality s, however there is no minimum requirement for the numerator, denominator or exclusion criteria.

4 Table 3: Core Measures for Meaningful Use - Eligible Providers (EPs) Must Report All Measures Measure Numerator Denominator Frequency (Numerator/ Denominator) 1. Use CPOE (Computer Physician Order Entry) 2. Implement drug to drug and drug allergy interaction check denominator that have at least one medication order entered using CPOE 3. E-Prescribing prescriptions in the denominator generated and transmitted electronically 4. Maintain an upto-date problem list of current and active diagnoses 5. Maintain active medication list 6. Maintain active medication allergy list patients with at least one medication in their medication list seen by the EP during the EHR more than 30 N/A N/A N/A have at least one entry or an indication that no problems are known for the patient recorded as structured data in their problem list have a medication (or an indication that the patient is not currently prescribed any medication) recorded as structured data unique patients in the denominator who have at least one entry (or an indication that the patient has no known medication Number of prescriptions written for drugs requiring a prescription in order to be dispensed other than controlled substances during the EHR reporting period more than 40 more than 80 more than 80 The percentage must be more than 80 percent in order for an EP to meet this Exceptions Does not apply to EPs that write fewer than 100 prescriptions during the Does not apply to EPs that write fewer than 100 prescriptions during the.

5 7. Record the following demographics: preferred language, gender, race and ethnicity, and date of birth 8. Record the following vital signs: height, weight and blood pressure as structured data 9. Record smoking status of patients 13 years and older 10. Implement one clinical decision support rule relevant to specialty along with the ability to track compliance with that rule 11. Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, medication allergies) upon request allergies) recorded as structured data in their medication allergy list have all the elements of demographics (or a specific exclusion if the patient declined to provide one or more elements or if recording an element is contrary to state law) recorded as structured data have at least one entry of their height, weight and blood pressure are recorded as structure data. denominator with smoking status recorded as patients age 2 or over seen by the EP during the EHR. patients age 13 or older seen by the. structured data N/A N/A Once per reporting period. receive an electronic copy of their electronic health information within three business days patients of the EP who request an electronic copy of their electronic health information four business days prior to the end of the EHR reporting period collect vital signs may report this does not apply see patients 13 years and older receive any requests from patients for an electronic copy of their health information during the

6 12. Provide clinical summaries for patients for each office visit 13. Electronically exchange key clinical information 14. Protect electronic health information created or maintained by certified EHR 15. Report clinical quality s Number of patients in the denominator who are provided a clinical summary of their visit within three business days EP for an office during the EHR N/A N/A Perform at least one test whereby data is submitted to a separate legal entity with an EHR system that can accept the data N/A N/A Conduct or review a security risk analysis per 45 CFR (a)(1) of the certified EHR technology, and implement security updates and correct identified security deficiencies as part of its risk management process Please visit asp#topofpage for more information. EPs who have no office visits are exempt from reporting this EPs can report numerators or denominators of zero

7 Table 4: Menu Set of Measures for Meaningful Use Eligible Providers (EPs) Must Report Five Measures Measure Numerator Denominator Frequency (Numerator/ Denominator) 1. Implement drugformulary checks and have access to at least one internal or external drug formulary Exceptions N/A N/A N/A Does not apply to EPs who write fewer than 100 prescriptions during the 2. Incorporate clinical lab-tests results into certified EHR technology as structured data 3. Generate at least one report listing the patients of the EP with a specific condition lab test results whose results are expressed in a positive or negative affirmation or as a number which are incorporated as structured data Number of lab tests ordered during the EHR reporting period by the EP whose results are expressed in a positive or negative affirmation or as a number more than 40 N/A N/A Once per reporting period EPs who order no lab tests and don t have results in either a positive /negative or numeric format during the EHR reporting period 4. Send reminders to patients per patient preference for preventive/follow up care were sent the appropriate reminder patients 65 years old or older or 5 years older or younger more than 20 see patients 65 years and older or 5 years and younger are excluded from reporting this 5. Provide patients with timely electronic access to their health information 6. Use certified EHR to identify patient-specific have timely (available to the patient within four business days of being updated in the certified EHR technology) electronic access to their health information online Number of patients in the denominator who are provided patient education at least 10 percent in order for an EP to meet this more than 10 EPs who neither order nor create lab tests or information that would be contained in the problem list, medication list, or medication allergy list during the EHR

8 education resources and provide those resources to the patient if appropriate specific resources 7. Perform medication reconciliation for patients transitions of care in the denominator where medication reconciliation was performed Number of transitions of care during the EHR for which the EP was the receiving party of the transition receive any transitions of care would be exempt from reporting this 8. Provide summary of care record for each transition of care or referral transitions of care and referrals in the denominator where a summary of care record was provided Number of transitions of care and referrals during the EHR reporting period for which the EP was the transferring or referring provider The percentage must be more than 50 percent in order for an EP to meet this transfer a patient to another setting or refer a patient to another provider during the EHR would be exempt from reporting this 9. Capability to submit electronic data to immunization registries* 10. Capability to submit electronic syndromic surveillance data to public health agencies* N/A N/A Perform one test during the reporting period N/A N/A Performed at least one test of certified EHR technology's capacity to provide electronic syndromic surveillance data to public health agencies and followup submission if the test is successful (unless none of the public health agencies to which an EP, eligible hospital, or CAH submits such information have the capacity to receive the information administer immunizations during the reporting period would be exempt from reporting this collect reportable syndromic data on patients during the would be exempt from reporting this

9 electronically) *At least one public health objective must be selected. Timeline The first step for any provider wishing to participate in the EHR Incentive Program is to insure they select an EHR software program that is certified for meaningful use and the dermatology specific CCHIT certification (for more information on CCHIT, please visit You should conduct a practice wide readiness assessment, workflow analysis, and identify a shortlist of preferred certified vendors. Consider what certified vendors are able to deliver with regard to the best value in terms of technical capabilities, workflow impact, and financial commitment. A vendor s value should be determined by their certification status. It may also be helpful to test drive your various EHR options to see how the meaningful use criteria is formatted, presented, and recorded so to assess the end-user s degree of comfort with system usability and workflow impact. Remember vendors that become certified may have different ways of charting and documenting data. Review, test, and verify your satisfaction before investing in a system. Providers can begin registering on the CMS website for the EHR Incentive program at You must be enrolled in PECOS and have an NPPES username and password. If you choose to begin reporting in 2011, you will only need to perform the stated objectives for 90 days. Thus, a provider would need to begin using their certified EHR technology in a meaningful way by October 1, Table 5: Timeline Explaining Implementation of Medicare EHR Incentive Program Reporting Year Must Begin By First Year Payment Reporting Method 2011 October 1, 2011 $18,000 Attest all s 2012 October 1, 2012 $18,000 Attest all s 2013 October 1, 2013 $15,000 Electronically submit data directly to CMS 2014 October 1, 2014 $12,000 Electronically submit data directly to CMS Dermatologists should assess how the meaningful use requirements will affect their plans to adopt an EHR system, and how they plan to proceed in If your practice plans to apply for the EHR incentive funds in 2011, you should still report the e-prescribing for the separate e-prescribing incentive program even though CMS will not distribute payment if your receive the EHR incentive funds. You should continue reporting the since the penalty in 2012 will be assessed based on your e-prescribing performance in Your practice can continue participating in the Physician Quality Reporting System (PQRS) as this program is expected to merge with the EHR Incentive Program in the next several years. Also, it is important to note that non-physician practitioners (PAs, NPs and nurses with prescribing authority) are eligible to participate in both the PQRS and e-prescribing incentive programs.

10 Table 6: Overall CMS Incentives Available to Providers YEAR EHR INCENTIVE* E PRESCRIBING INCENTIVE* PQRS INCENTIVE MOC INCENTIVE TOTAL INCENTIVES AVAILABLE 2011 $44,000 (dispersed over a 5 year period) 2012 $44,000 (dispersed over a 5 year period) 2013 $39,000 (dispersed over a 4 year period) 2014 $24,000 (dispersed over a 3 year period) 1% 1% 0.5% 2.5% OR $44, % 1% 0.5% 0.5% 2% OR $44, % 0.5% 0.5% 0.5% 1.5% OR $39, % 0% 0.5% 0.5% 1% + $24,000 Note: Percentages based on Medicare Part B allowed charges. *EHR and e-prescribing incentive cannot be combined. Providers must select one program to participate in. Table 7: Overall CMS Penalties Applicable to Providers YEAR EHR PENALTY E PRESCRIBING PENALTY PQRS PENALTY TOTAL PENALTIES % 1% 0% 1% % 1.5% 0% 1.5% % 2% 0% 2% % 0% 1.5% 2.5% % 0% 2% 4% 2017 and beyond 3% 0% 2% 5% Note: Percentages based on Medicare Part B allowed charges. The Academy will keep members informed and up to date as CMS issues additional guidance and clarification in the future. The Academy remains fully committed to assisting its members make informed decisions and will continue to provide resources and tools that help advance this goal. Stay tuned to the Academy s website, Dermatology World or contact the Academy directly for more information:

11 American Academy of Dermatology 930 E. Woodfield Road Schaumburg, IL (866)

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