WHAT JUST HAPPENED TO THE EMR PROGRAM?

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1 WHAT JUST HAPPENED TO THE EMR PROGRAM? November 5, 2015 Michael Orr Director ext Travis Skinner Senior Managing Consultant ext

2 TO RECEIVE CPE CREDIT Participate in entire webinar Answer polls when they are provided If you are viewing this webinar in a group Complete group attendance form with Title & date of live webinar Your company name Your printed name, signature & address All group attendance sheets must be submitted to training@bkd.com within 24 hours of live webinar Answer polls when they are provided If all eligibility requirements are met, each participant will be ed their CPE certificates within 15 business days of live webinar Acronym Meanings Acronym EMR EHR SRA CMS ONC EP CPOE PQRS EH CAH HITECH CEHRT Meaning Electronic Medical Records Electronic Health Records Security Risk Analysis Centers for Medicare & Medicaid Services Office of the National Coordinator Eligible Professional Computerized Physician Order Entry Physician Quality Reporting System Eligible Hospital Critical Access Hospital Health Information Technology Certified Electronic Health Records Technology 2

3 Today s Agenda Finalized 2015 EHR Modification Rule Eligible Hospitals (EHs) & Eligible Professionals (EPs) New Measures & Objectives EHR Tentative Settlement Letters HITECH Payment Audits Medicaid EHR Audits Meaningful Use Audits / SRA Guidance / Flexibility Rule Stage 3 Regulations Snippets from Stage 3 public notice: Stage 3 will focus on improving health care outcomes & further advance interoperability CMS plans to propose changes to the reporting period, timelines, & structure of the [EHR Incentive Program], including providing a single definition of meaningful use CMS intends to provide a flexible, yet, clearer framework to ensure future sustainability of the EHR program & reduce confusion stemming from multiple stage requirements 3

4 Finalized 2015 EHR Modification Rule Finalized rule was published on October 6th & is based on: Elevating patient-centered care Improving health outcomes Supporting providers who care for patients Delay for rule was due to the combining of the three proposed rules ONC Rule Stage 3 Meaningful Use Rule 2015 Modification Rule Finalized 2015 EHR Modification Rule Major Changes approved: Program year 2015 is now any continuous 90 day reporting period Program year 2015 will be 15 months 10/01/2014 to 12/31/2015 Attestation window for program year 2015 is 01/04/2016 to 2/29/2016 Program year 2016 & after will now be a calendar year Modified other aspects of programs Alternative Exclusions & Specifications for Stage 1 & Stage 2 4

5 1 st Year Stage of Meaningful Use TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD Centers for Medicare & Medicaid Services - CMS.gov 2014 Flexibility Rule Schedule Centers for Medicare & Medicaid Services - CMS.gov 5

6 Stage of Meaningful Use Criteria By First Year Centers for Medicare & Medicaid Services - CMS.gov 11 // experience ideas Modifying Other Aspects of Programs For EPs Major changes approved for Stage 1: Previous Stage 1 EP objectives: 13 Core Objectives 5 of 9 Menu Objectives EP objectives for (Modified Stage 2) 10 Core Objectives 6

7 Modifying Other Aspects of Programs For EPs Major Changes approved For Stage 2: Previous Stage 2 EP Objectives: 17 Core Objectives 3 of 6 Menu Objectives EP Objectives for (Modified Stage 2) 10 Core Objectives 10 Objectives for (Modified Stage 2) Security Risk Analysis Clinical Decision Support CPOE eprescribing Health Information Exchange (Summary of Care) Patient Specific Education Medication Reconciliation Patient Electronic Access (VDT) Secure Messaging Public Health Reporting 7

8 Modifying Other Aspects of Programs for EPs Major changes approved: Secure Messaging Changed from 5% to having fully enabled capability for patients to send/receive a secure electronic message with EP during 2015 EMR reporting period Patient Portal Changed the second measure from 5% to at least one patient Public Health Reporting Immunizations Registries Syndromic Surveillance Specialized Registries From Ongoing Submission to Active Engagement Completed Registration Testing & Validation Production Payment Adjustments: <75% Centers for Medicare & Medicaid Services - CMS.gov 8

9 Payment Adjustments: >75% Centers for Medicare & Medicaid Services - CMS.gov 17 // experience ideas Centers for Medicare & Medicaid Services - CMS.gov 18 // experience ideas 9

10 PQRS & Value Based Modifier Penalties PQRS Penalty: Didn t meet PQRS in % Medicare Fee Schedule penalty in 2015 Didn t meet PQRS in % Medicare Fee Schedule penalty in 2016 Didn t meet PQRS in % Medicare Fee Schedule penalty in // experience ideas EP EHR Penalties STOP in 2018!!! Merit-Based Incentive Payment System! 20 // experience ideas 10

11 Modifying Other Aspects of Programs for EHs Major changes approved for Stage 1: Previous Stage 1 EH Objectives: 11 Core Objectives 5 of 10 Menu Objectives EH Objectives for (Modified Stage 2) 9 Core Objectives Modifying Other Aspects of Programs For EHs Major Changes approved For Stage 2: Previous Stage 2 EH Objectives: 16 Core Objectives 3 of 6 Menu Objectives EH Objectives for (Modified Stage 2) 9 Core Objectives 11

12 9 Objectives for (Modified Stage 2) Security Risk Analysis Clinical Decision Support CPOE eprescribing Health Information Exchange (Summary of Care) Patient Specific Education Medication Reconciliation Patient Electronic Access (VDT) Public Health Reporting Modifying Other Aspects of Programs for EHs Major changes approved Patient Portal Changed the second measure from 5% to at least one patient Public Health Reporting Immunizations Registries Syndromic Surveillance Specialized Registries Electronic Reportable Lab Results From Ongoing Submission to Active Engagement Completed Registration Testing & Validation Production 12

13 PPS Penalties Centers for Medicare & Medicaid Services - CMS.gov CAH Penalties Centers for Medicare & Medicaid Services - CMS.gov 13

14 EHR Tentative Settlements 14

15 HITECH Payment Audits (MAC) For every Medicare EHR incentive payment, every facility that receives an EHR incentive payment will have one of three audits on its cost report: Desk Review In-House Audit On-Site Audit HITECH Payment Audits (MAC) Positive Adjustment Opportunities Part C Days Total Days Charity Care Presumptive Charity Care Policy Review 15

16 Pre/Post Payment Medicaid EHR Audits OIG has EHR post-payment audits as a high priority through 2018 Positive adjustment opportunities Potential missing Medicaid days Incorrect reporting period used for payment calculation Total days (including hospice days, employee days, Part B days, etc.) Be alerted to potential overpayments for things such as unpaid days & bad debts being included with Charity Care EHR Meaningful Use Audits (FIGLIOZZI) Worked on program years 2011, 2012 & &/or Stage 2 audits have yet to begin Audit protocol for Stage 2 audits has yet to be released Still auditing a minimum of 5% of the nation meaningful users All or nothing penalty Including Medicare & Medicaid incentive payments 16

17 Flexibility Final Rule Allowed facilities to attest to a lower level of criteria than facility was scheduled to attest for Program Year 2014 No upfront checking of qualifications for appropriate use of rule Check radial button, put in an ONC certification number consistent with lower level of criteria & click a button saying you will maintain documentation supporting facility s use of Flexibility Rule for at least 6 years that s all that s required Documentation, documentation, documentation is key Centers for Medicare & Medicaid Services - CMS.gov 17

18 EHR Meaningful Use Audits (FIGLIOZZI) Working with Figliozzi is easier than with CMS if facility fails Can appeal Figliozzi failure with CMS One Bite at the Apple Submit only new evidence Key Take-aways from This Presentation Program year 2015 is 15 months long ending 12/31/2015 with an any continuous 90 day reporting period, open window starts on 01/4/2016! Every participant that receives an interim payment will experience a HITECH audit! Medicaid recoupments are real & can be significant, don t go down without a fight! Use of Flexibility Final Rule needs to be documented! MU Audit penalty is very real & key is your documentation! 36 // experience ideas 18

19 QUESTIONS? Continuing Professional Education (CPE) Credits BKD, LLP is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: The information in BKD webinars is presented by BKD professionals, but applying specific information to your situation requires careful consideration of facts & circumstances. Consult your BKD advisor before acting on any matters covered in these webinars. 19

20 CPE Credit CPE credit may be awarded upon verification of participant attendance For questions, concerns or comments regarding CPE credit, please the BKD Learning & Development Department at THANK YOU! FOR MORE INFORMATION Michael Orr Director Travis Skinner Senior Managing Consultant 20

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