EHR Meaningful Use Incentives

Transcription

1 EHR Meaningful Use Incentives April 28, 2010 Andie Martinez Associate Director of Policy California Primary Care Association 1 Meaningful Use Incentives General Overview Between $36-48 billion for Medicare/Medicaid EHR Incentive Funds CMS developing rules and regulations, final rule expected in June Eligible professional must choose Medicare or Medicaid incentive program (before CY 2014) Medicare incentives must start October 1, 2010, but no date in statute for when Medicaid incentives must start (expected January 2011) $1.5 billion expected in Medicaid EHR funding coming to California eligible professionals 2 1

2 Meaningful Use Incentives General Overview Medicaid funds will flow through DHCS and they must distribute 100% to providers DHCS (state Medicaid office) received $2.5 million (90/10 match) for administrative preparation for the program Created Office of Health Information Technology (OHIT) HITECH Advisory Group CPCA and Dr. Moore, Medical Director for Clinic Ole/ RCHC participating DHCS will get to set some parameters for how the funding is distributed, reporting, and measures 3 Eligible Professionals Who are Eligible Professionals? Non-hospital based Physicians, Dentists, Certified nurse-midwives, Nurse practitioners, and (?) Physician assistants who are practicing in a Federally Qualified Health Centers (FQHCs) or Rural Health Clinics (RHCs) led by a physician i assistant. What is a physician? a doctor of medicine or osteopathy a doctor of dental surgery or of dental medicine a doctor of podiatric medicine a doctor of optometry, a chiropractor 4 2

3 Eligible Professionals Who are Eligible Professionals? Who have at least 30% of their patient volume (encounters) attributable to Medi-Cal, or Who is a pediatrician and who has at least 20% of their patient volume (encounters) attributable to Medi-Cal, or Who practices predominantly at an FQHC or RHC and has at least 30% of their patient volume (encounters) attributable to needy individuals. Needy patients receive medical assistance from Medi-Cal or Healthy Families, are furnished uncompensated care by the provider, or are furnished services at either no cost or reduced cost based on a sliding scale determined by the individual s ability to pay. Over any continuous 90-day period within the most recent calendar year prior to reporting. Practices Predominantly- An EP practices predominantly at an FQHC or an RHC when the clinical location for over 50 percent of his/her patient encounters over a period of 6 months occurs at an FQHC or RHC. 5 Latest News Recent change to hospital-based physician eligibility EHR Incentive Provision in the Unemployment Benefits Law The law includes a provision that would expand eligibility for the EHR incentive payments to include certain physicians working in hospital-based outpatient clinics. The law removes the word "outpatient" from the description of a hospital-based "setting (whether inpatient or outpatient)" and replaces it with "inpatient or emergency room setting." Previously, P i l physicians i working in hospital settings could not qualify for the EHR incentive payments because the health IT provisions of the stimulus package asserted that such physicians rely significantly on a hospital's resources, including its EHR system 6 3

4 Incentive Payments for Adoption and Meaningful Use of Certified EHR $21,250 = 85% of $25,000 $8,500 = 85% of $10, Total 2011 $21,250 $8,500 $8,500 $8,500 $8,500 $8,500 $0 $0 $0 $0 $0 $63, $21,250 $8,500 $8,500 $8,500 $8,500 $8,500 $0 $0 $0 $0 $63, $21,25 0 $8,500 $8,500 $8,500 $8,500 $8,500 $0 $0 $0 $63, $21,250 $8,500 $8,500 $8,500 $8,500 $8,500 $0 $0 $63, $21,250 $8,500 $8,500 $8,500 $8,500 $8,500 $0 $63, $21,250 $8,500 $8,500 $8,500 $8,500 $8,500 $63,750 7 Meaningful Use Incentives What did the proposed rule say? Average allowable cost for the first payment year is $54,000 Average allowable cost for following five payment years is $20,610 Federal funds received for the purchase of an EHR must be deducted from the EHR incentive funds receivable. To receive the maximum amount an EP may have received up to $29,000 for the purchase of an EHR, and up to $10,610 for maintenance. Incentive funds are directed at providers Payments by calendar year What did the proposed rule NOT say? No language in the Proposed Rule on FTE But CMS estimated their costs based on a FTE study 8 4

5 Meaningful Use Incentives What did the proposed rule say? To get the first year of funding, a provider has to report on a 90-day period in that calendar year. Must attest to Adopting: purchase and installation of an EHR Implementing: installed and using an EHR, includes activities like staff training, data entry of patient demographic data, establishing data exchange agreements with labs, pharmacies, etc. Upgrading: expansion of functionality of EHR, such as clinical decision support, erx, CPOE, etc It will be up to the state s to determine what attestation means and what is required Every year following, providers must report on full calendar year 9 Meaningful Use Stages Stages of Meaningful Use Stage 1 Electronically capturing health information in a coded format, Using that information to track key clinical conditions and communication for care coordination purposes reporting clinical quality measures and public health information. Stage 2 Health information exchange in the most structured format possible, Example: computerized provider order entry (CPOE) and the electronic transmission of diagnostic test results (such as blood tests, microbiology, urinalysis) Stage 3 Patient access to self management tools and improving population health 10 5

6 Meaningful Use Stages 11 Calculating Incentives How do I calculate what my clinic will receive? Example: FQHC entity receives the funds (CMS changes rules) 10 Physicians 2 Pediatricians (Can receive up to 100% of incentive if they can reach the 30% figure) 3 Dentists 8 Nurse Practitioners 4 Certified Nurse Mid-wives All have worked at the FQHC for six months prior to applying AND the FQHC serves 30% needy = * 21,250 = $573,

7 Calculating Incentives How do I calculate what my clinic will receive? Example: Providers at FQHC, providers receive the funds (Rules stay the same) 10 Physicians 2 Pediatricians 3 Dentists 8 Nurse Practitioners 4 Certified Nurse Mid-wives All have worked at the FQHC for six months prior to applying AND each can attest that their patient panel is comprised of 30% needy AND they have agreed to sign over their incentive funds to the FQHC = * 21,250 = $573, Calculating Incentives What about part time providers? The rule stipulates that if the provider can reach the 30% Medicaid patient threshold then they are eligible to receive the maximum allowable in incentives It is up to them how they distribute their funds Even if they see 20% of their Medicaid patients at the clinic and only 10% at their private practice, they can choose to take the incentive i money and dinvest it in their practice 14 7

8 Meaningful Use Incentives What is CPCA doing? EHR Meaningful Use Workgroup Electronic Dental Record Workgroup HIE Workgroup CIO Taskforce Close communication with NACHC Participate on the HITECH Advisory Group with California s Medi-Cal Office 15 CPCA Submitted Comments CPCA has Payments should be at the entity-level per service location or asked for physical site FQHC site and Community clinic site these, but 30% criteria should apply to sites, not providers CMS has not yet agreed PAs at FQHCs should be eligible For FQHCs, uncompensated care should include funds from episodic programs like Ryan White and EAPC Any programs that utilize Medicaid funds should count towards the Medicaid idrequirement, i.e. F-PACT and EPSDT Adjustment for uncompensated care should apply to community clinics as well Awards be given on FTE basis, i.e. part-time provider working 10 hours would be eligible for 25% of incentive award 16 8

9 CPCA Submitted Comments CPCA has Net average allowable costs- hold harmless until January 1, asked for 2011 these, but Participation should not have to be in consecutive years as CMS has not yet agreed long as you finish by 2021 Full meaningful use by 2015 is too extreme, allow entities two years in each stage 17 Next Steps What can I do when I get back to my clinic/health center? Make sure your CEO/ED and providers understand the rule as it stands right now Make sure your contracts with your providers are written so that the incentives are transferred to the clinic/health center. This will alleviate the providers of the tax responsibility associated with receiving the incentives Start talking to your providers who are not full time about the incentives and determine if they are willing to share the incentives with your clinic/health center Send Andie Martinez your concerns and thoughts so that CPCA can assist you as you prepare for the incentives Amartinez@cpca.org or