Medicaid and Medicare Meaningful Use of Electronic Health Records Program. May 15, 2013

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1 Medicaid and Medicare Meaningful Use of Electronic Health Records Program May 15, 2013

2 Presenters Andie Patterson, Deputy Director of Regulatory Affairs California Primary Care Association DeeAnne McCallin, REC Program Manager CalHIPSO

3 Overview HITECH Act Elements of the Meaningful Use Program EHR Certification Eligibility Timeline Measures and Objectives Stage 1 Taking advantage of the REC program

4 Acronyms AIU- Adopt, Implement, or Upgrade ARRA- American Recovery and Reinvestment Act CEHRT- Certified Electronic Health Record Technology EDR- Electronic Dental Record EHR- Electronic Health Record HIE- Health Information Exchange HIPAA- Health Insurance Portability and Accountability Act HIT- Health Information Technology ONC- Office of the National Coordinator PMS- Practice Management System SLR- State Level Registry

5 HITECH: Catalyst for Transformation Paper Records HITECH Act EHRs & HIE A system plagued by inefficiencies EHR Incentive Program 62 Regional Extension Centers Widespread adoption Meaningful Use of EHRs Health care delivery transformation Pre

6

7 Path to Better Outcomes and Quality MU Stage 2 Advanced clinical processes MU Stage 3 Improved outcomes MU Stage 1 Data capture and sharing Better clinical outcomes Improved population health outcomes Increased transparency and efficiency Empowered individuals More robust research data on health system For more information on meaningful use of EHRs, visit:

8 Framework for the MU Program Stage 1 Electronically capturing health information in a coded format, Using information to track clinical conditions for care coordination Stage 2 Health information exchange in structured format Stage 3 Patient access to self-management tools; Access to comprehensive patient data through patientcentered HIE

9 Elements of MU Program Certified EHR In order to receive incentive payments the provider must use certified EHR technology (CEHRT) Certification is defined by the Office of the National Coordinator (ONC) and is required in the HITECH Act The ONC has specified the capabilities required in a certified product Stages to certification

10 Elements of MU Program Medicaid EHR Incentive Program Every state runs its own program Medicare EHR Incentive Program Run by CMS Program runs from 2011 through 2021 Program runs from 2011 through 2016 Maximum incentive amount is $63,750 (across 6 years of program participation) In the first year, providers can receive an incentive payment for AIU of a certified EHR. Medicaid (Medi-Cal) does not have any penalties Maximum incentive amount is $44,000 (across 5 years of program participation) All years must demonstrate Meaningful Use to receive an incentive. Medicare has penalties for not participating

11 Medicare MU Program $18, $12,000 $18, $8,000 $12,000 $15, $4,000 $8,000 $12,000 $12, $2,000 $4,000 $8,000 $8, $0 $2,000 $4,000 $4,000 Total: $44,000 $44,000 $39,000 $24,000

12 Medicaid MU Program Overview Eligible professionals may receive up to $63,750 over 6 years. First year of payment is for AIU of a certified EHR technology. Following five payments require reporting and achieving meaningful use objectives and thresholds. Program runs 2011 through 2021 but must start no later than Participation does not need to be in consecutive years. EPs can skip years or not participate.

13 Medicaid MU Program Eligible Providers are non-hospital based Physicians (doctors of medicine or osteopathy and optometrists), Dentists, Certified nurse-midwives, Nurse practitioners, and Eligible for Program year 2013 but cannot yet register in the SLR. Physician assistants who are practicing in a Federally Qualified Health Centers (FQHCs) or Rural Health Clinics (RHCs) led by a physician assistant Hospital based- 90% or more of the provider s services are provided in an inpatient hospital or emergency room hospital setting (POS code 21 or 23).

14 Medicaid MU Program Eligible Providers are non-hospital based Physician assistants who are practicing in a Federally Qualified Health Centers (FQHCs) or Rural Health Clinics (RHCs) led by a physician assistant Only requires currently A lead PA can be established at one site, and then all PA s across FQHC organization are eligible Lead PA must sign and date form on day they led and all other PA s must sign and date the form with the day that the lead PA was leading the FQHC A PA can be a lead if they led for only one day

15 Medicaid MU Program Eligible Providers 30% of patient encounters attributable to Medicaid; or Must practice predominantly at an FQHC/ RHC and 30% of encounters attributable to needy individuals o Needy: Medi-Cal or Healthy Families, are furnished uncompensated care, or are furnished services at either no cost or reduced cost based on a sliding fee scale o Practices Predominantly- When the clinical location for over 50% or more of their professional services were delivered in an FQHC or RHC during a 6 month period either in the previous calendar year or the 12 months prior to attestation. Pediatricians only need to have 20% Medi-Cal or Needy encounters Patient encounters counted over any continuous 90-day representative period in previous calendar year

16 Medicaid MU Program Groups CCHCs can apply as a group (site or organization) Must meet the 30% Medi-Cal or Needy requirement as a group All providers that contributed to group volumes during the representative period must be listed as group members, even if the provider is not eligible or applying for MU. Providers can use the group s eligibility to qualify for the program as long as he/she had at least one Medi-Cal or Needy encounter during the year eligibility is being determined (i.e. doesn t have to fall within the 90 day representative period) Providers that are part of groups must still have their own individual account in the SLR

17 Medicaid MU Program Receiving Payment In the first year of payment an EP may choose to attest to AIU of an EHR 1.Adopting: acquire, purchase or secure access to certified EHR technology (signed contract counts) 2.Implementing: install or commence utilization of certified EHR technology capable of meeting meaningful use requirements 3.Upgrading: expand the available functionality of certified EHR technology capable of meeting meaningful use requirements at the practice site, including staffing, maintenance, and training, or upgrade from existing EHR technology to certified EHR technology per the ONC EHR certification criteria. Eligibility is required (30% Medi-cal or Needy) but THERE IS NO REPORTING PERIOD

18 Medicaid MU Program Receiving Payment In the second year of payment an EP must achieve meaningful use of stage 1 measures for a 90 day consecutive period In the third and following years, the EP must achieve meaningful use for 365 days For stage 1- providers will have 90 days in first year of reporting and 365 days in the second year of reporting For stage 2- providers will have to achieve and report meaningful use for 365 days each year For stage 3- providers in the Medicaid MU program will only have to report 365 days of meaningful use data for one year A provider can only participate 6 years in the Medicaid MU program

19 Getting the Medi-Cal MU Incentive Program Year 1= Stage AIU $21,250 Must meet 30% Medi-Cal or Needy for the year PRIOR Must be an eligible provider Attest that you have a certified EHR Program Year 2 = Stage 1 Meaningful Use (first year) /year Must meet 30% Medi-Cal or Needy for the year PRIOR and 50% Meaningful user provision for reporting year Attest to achieving Meaningful Use over 90 days for program year i.e. if program year is 2013, 90 days of data has to be in 2013 Program Year 3 = Stage 1 Meaningful Use (second year) /year Must meet 30% Medi-Cal or Needy for the year PRIOR and 50% Meaningful user provision for reporting year Attest to achieving Meaningful Use over 365 days for program year i.e. if program year is 2014, 90 days of data has to be in 2014** For 2014 ONLY, reporting, regardless of stage is 90 days. Every other program year is 365 days of reporting

20 Getting the Medi-Cal MU Incentive Program Year 4 = Stage 2 Meaningful Use (first year) /year Must meet 30% Medi-Cal or Needy for the year PRIOR and 50% Meaningful user provision for reporting year Attest to achieving Meaningful Use over 365 days for program year i.e. if program year is 2015, 90 days of data has to be in 2015 Program Year 5 = Stage 2 Meaningful Use (second year) /year Must meet 30% Medi-Cal or Needy for the year PRIOR and 50% Meaningful user provision for reporting year Attest to achieving Meaningful Use over 365 days for program year i.e. if program year is 2016, 365 days of data has to be in 2016 Program Year 6 = Stage 3 Meaningful Use (first year) /year Must meet 30% Medi-Cal or Needy for the year PRIOR and 50% Meaningful user provision for reporting year Attest to achieving Meaningful Use over 365 days for program year i.e. if program year is 2017, 365 days of data has to be in 2017

21 Medicaid Incentive Payments for AIU and MU of Certified EHR $21,250 = 85% of $25,000 = 85% of $10, Total 2011 $21,250 $0 $0 $0 $0 $0 $63,750 AIU Stage 1 Stage 1a Stage 2 Stage 2 Stage $21,250 $0 $0 $0 $0 $63,750 AIU Stage 1a Stage 1a Stage 2 Stage 2 Stage $21,250 $0 $0 $0 $63,750 AIU Stage 1a Stage 1a Stage 2 Stage 2 Stage $21,250 $0 $0 $63,750 Stage 1a: Signifies the changes CMS made to Stage 1 in the Stage 2 rule making AIU Stage 1a 2015 $21,250 AIU Stage 1a Stage 1a 2016 $21,250 Stage 2 Stage 1a Stage 2 Stage 2 Stage 3 Stage 2 Stage 3 $0 $63,750 $63,750 AIU Stage 1a Stage 1a Stage 2 Stage 2 Stage 3

22 Medicaid MU Program Important Notes The MU program was constructed around individual providers, not clinics/health centers. Providers can choose to reassign their incentive payment to the clinic/health center. Have to use a certified electronic health record. Dentists are eligible and can achieve MU. Eligibility is by an individual provider s Medicaid encounters or by group proxy from the prior calendar year. Reporting on the MU measures and objectives is by individual provider.

23 Reporting Meaningful Use Measures Stage 1

24 Achieving Meaningful Use Patients Time! Workflow Changes Reporting System Standardization

25 Reporting 50% Meaningful User In order for an EP to be considered a meaningful EHR user, at least 50% of the EP s patient encounters during the EHR reporting period must occur at a practice/location or practices/locations equipped with CEHRT A location is considered equipped with CEHRT if CEHRT is available at the start of the reporting period. EPs who do not conduct 50% of their patient encounters in any one practice/location would have to meet the 50% threshold through a combination of practices/locations equipped with CEHRT. EPs who do not meet this criterion are not eligible to participate in the EHR Incentive Program.

26 Reporting

27 Reporting 80% Rule At each location that an EP collects numerators and denominators for the percentage-based measures, the EP must include ALL patients in the denominator for relevant measures including patients records that are maintained in paper and/or in an uncertified EHR. Because more than 80% of all unique patients seen by the EP must have at least one entry or an indication that no problems are known for the patient recorded as structured data, it is reasonable to say that more than 80% of patients records must be maintained in CEHRT to meet Meaningful Use.

28 Reporting

29 Reporting Aggregating Data EPs who also practice at hospitals do not need to include encounters that occurred in inpatient settings and emergency departments of hospitals when collecting Meaningful Use data If CERHT is available at the start of the reporting period then the EP must include the data from those sites when capturing meaningful use data, no matter how many locations

30 Reporting Menu and CQM Measures Aggregating Data The attestation system only allows the selection of 5 menu objectives. If an EP practices in multiple locations that choose to implement the same menu objectives, the EP should combine the data for menu objectives for attestation. For menu objectives that are not shared across multiple locations, the EP should attest to the menu objectives implemented at the location where they have the greatest number of their patient encounters. The attestation system only allows the selection of 6 clinical quality measures. If an EP practices in multiple locations that choose to implement the same quality measures, the EP should combine the data for quality measures for attestation. For clinical quality measures that are not shared across multiple locations, the EP should attest to the clinical quality measures implemented at the location where they have the greatest number of their patient encounters.

31 Objectives & Measures Meaningful Use = MU Core Measures (2013 Changes) Menu Measures (of 10) Clinical Quality Measures (CQMs; 3 Core/Alt and 3 Additional) Meaningful Use

32 Clinical Quality Measures (CQMs) 3 Core CQMS & 3 Alternate CQMS 38 CQMs Report on 3 Core CQMs OR select from alternate(s) when core measure does not apply to your practice or reports a zero in the denominator. Select 3 of 38 to report on. If zeros in the denominator, must have reports showing zeros in all non selected. Clinical quality measures do not have thresholds that you have to meet you simply have to report data on them.

33 Clinical Quality Measures EPs Core Set CQMs

34 Clinical Quality Measures EPs Alternate Core Set CQMs

35 Stage 1 Core Set: Must Do All Menu Set: Must Do 5 of 10 Use CPOE e-prescribing Drug-drug & drug allergy checks Medication list Allergy list Problem list Decision support Record demographics Smoking status Vital signs Clinical summaries to patient Electronic exchange Health info to patients Clinical quality measures Protect health information Change for 2013 and beyond reporting Change for 2014 and beyond reporting Incorporate clinical labs Medication reconciliation Implement drug-formulary checks Generate patient list Patient electronic access Send reminder Patient-specific education Clinical summaries to provider Submit electronic data to immunization registry* Submit electronic syndromic surveillance data* *At least 1 public health objective must be selected.

36 Stage 1 Objective: Core 1 Computerized Provider Order Entry (CPOE) *Takes effect in 2013 What it means Old Measure Denominator: Number of unique patient with at least one medication in their medication list New Measure Added a 2 ND denominator option: # of medication orders created during EHR reporting Period. You can now choose which denominator value to use. At least 30% of your patients that have a medication listed OR 30% of your medication orders created - during the EHR period have to be entered using the EHR s CPOE module.

37 Stage 1 Objective: Core 3 E-Prescribing *Takes effect in 2013 Old Measure One Exclusion = Any EP who writes fewer than 100 prescriptions during the EHR EHR reporting period would be excluded from this requirement. New Measure Two Exclusions = EP writes fewer than 100 prescriptions during the EHR reporting period OR EP does not work within a 10 mile radius of a pharmacy that accepts electronic prescriptions What it means You may now be excluded from this measure if you meet either one of the two exclusions.

38 Stage 1 Objective: Core 8 Record Vital Signs *Optional in 2013, required in 2014 Old Measure Age Limits = Record blood pressure & height and weight for ages 2 and older Exclusions: All three elements not relevant to scope of practice If the EP sees no patients 2 years old or older New Measure Age Limits = Record BP for ages 3 and older; no age limit for height/weight Exclusions: All three elements not relevant to scope of practice BP can be excluded if only H/W are relevant H/W can be excluded if only BP is relevant EP sees no patients 3 years or older What it means Separated BP from H/W in exclusion options. Raised BP age from 2 to 3 years to align with pediatric standards. Must record height and weight for ALL patients. Raised maximum age of patients exclusion from 2 to 3 years old.

39 Stage 1 Objective: Core 14 Exchanges Key Clinical Information Among Providers *Takes effect in 2013 Old Measure One test of electronic transmission of key clinical information. New Measure This requirement is REMOVED effective What it means You are no longer required to meet this measure.

40 Taking Advantage of the Regional Extension Center Program

41 284&searchType=keyword&submitSearch=1&i d=5005

42 ONC Salesforce M3 Tool Completed by the LEC or REC Staff Provide EP s CEHRT MU dashboard report

43 ONC Salesforce M3 Tool Core Measures

44 ONC Salesforce M3 Tool Menu Measures

45 Salesforce M3 Tool CQM Measures Can use to assess readiness for Meaningful Use If measures are met, can use to earn REC grant credit prior to MU attestation with Medi-Cal or Medicare

46 ONC Salesforce M3 Tool Printable form available from your LEC Great for use to aggregate data Helps to have everything ready for your Medi-Cal SLR data entry

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