A Guide to Understanding and Qualifying for Meaningful Use Incentives

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1 A Guide to Understanding and Qualifying for Meaningful Use Incentives A White Paper by DrFirst Copyright DrFirst All Rights Reserved. 1

2 Table of Contents Understanding and Qualifying for Meaningful Use Incentives... 3 Understanding Meaningful Use Requirements and Attestation... 3 Three Stages of Meaningful Use... 3 EHR Incentive Programs... 4 MU objectives... 5 MU core objectives... 5 MU menu objectives... 6 Performance Measures... 6 Selecting an EHR solution... 7 Conclusion... 8 About DrFirst, Inc Copyright DrFirst All Rights Reserved. 2

3 Understanding and Qualifying for Meaningful Use Incentives The Health Information Technology for Economic and Clinical Health Act (HITECH Act), which was signed into law as part of the American Recovery and Reinvestment Act of 2009 (ARRA), established a series of incentives and penalties to encourage medical practitioners to adopt electronic health records (EHRs). The HITECH Act established criteria for Meaningful Use (MU). The Centers for Medicare and Medicaid Services (CMS) was tasked with validating MU to ensure that providers and hospitals weren t just installing EHRs, but using them in a way that actually improved patient outcomes. Medicare and Medicaid eligible providers must meet a series of objectives and then attest to MU by registering with CMS and providing the necessary data. Physicians are eligible for incentive payments of up to $63,750 over a period of six years. This article will discuss the ins and outs of MU incentives with a focus on modular EHR systems, a unique way of combining best of breed EHRs that enable a provider to have the necessary functionality required for Meaningful Use that provide the least expensive and least time-consuming path to MU. Understanding Meaningful Use Requirements and Attestation The ARRA includes as much as $27 billion over ten years to support the adoption of EHRs. EHRs can improve patient care and minimize costs by reducing the occurrence of adverse drug events through clinical decision support rules, easier access to patient records, increased patient outreach, and a greater percentage of generic prescribing. Achieving these and other benefits requires that practitioners not simply move health information from paper to electronic form but also utilize productivity- and safetyenhancing EHR functions such as entering prescriptions through the computer so that the prescription can be automatically checked against the patient s allergies and for interactions with other drugs that patient is taking. Providers are required to meet progressively more stringent MU requirements over the course of the program in order to ensure that the full potential of EHRs is achieved. Three Stages of Meaningful Use CMS has divided MU into three stages. Stage 1 began January 1, 2011, and places a focus on data collection. Eligible providers will participate in no less than 2 years of Stage 1 regulations. In Stage 1, providers are expected to meet performance measures for 15 core and 5 of 10 menu objectives as well as a number of clinical quality measures. Stage 2 is scheduled to begin January 1, 2014 for those providers that have completed a minimum of two years of Stage 1 of Meaningful Use. Stage 2 places a heavy emphasis on exchange of data. Stage 3 is tentatively set to begin on January 1, No rules have been proposed yet for Stage 3 of Meaningful Use. Copyright DrFirst All Rights Reserved. 3

4 EHR Incentive Programs The HITECH Act established separate incentive programs for providers servicing Medicaid and Medicare patients. The Medicaid program offers a maximum payout of $63,750 over six years, while the Medicare program offers a maximum of $44,000 over five years. The last year to begin participation in the Medicaid program is 2016, while the last year to participate in Medicare program is To qualify for the Medicaid program, eligible providers must have a minimum of 30% Medicaid population; pediatricians can qualify with a minimum of 20% Medicaid population. Providers must demonstrate the Medicaid population over a 90 day period from the previous calendar year. To qualify for the Medicare program, providers must bill for at least one Medicare patient. Eligible providers also must have a minimum of $24,000 in total Medicare allowables to receive the maximum incentive under the Medicare plan. If the provider ends the year with less than $24,000, the provider will receive 75% of their allowables as their incentive. in in in $18, $12,000 $18, $8,000 $12,000 $15, $4,000 $8,000 $12,000 $12, $2,000 $4,000 $8,000 $8, $2,000 $4,000 $4,000 Total $44,000 $44,000 $39,000 $24,000 Disbursement schedule for Medicare MU program in in 2011 in 2012 in 2013 in 2014 in 2015 in $21, $8,500 $21, $8,500 $8,500 $21, $8,500 $8,500 $8,500 $21, $8,500 $8,500 $8,500 $8,500 $21, $8,500 $8,500 $8,500 $8,500 $8,500 $21, $8,500 $8,500 $8,500 $8,500 $8, $8,500 $8,500 $8,500 $8, $8,500 $8,500 $8, $8,500 $8, $8,500 Total $63,750 $63,750 $63,750 $63,750 $63,750 $63,750 Disbursement schedule for Medicaid MU program The Medicaid program allows the provider to receive the first year s incentive by simply adopting, upgrading or implementing a certified EHR solution. In the second year, the provider only needs to prove MU for any consecutive 90 day period. After the second year, the provide needs to prove MU for the entire year to receive the incentive. Medicare Copyright DrFirst All Rights Reserved. 4

5 providers must show MU for 90 continuous days to quality in their first year and show MU for the full year in subsequent years. Medicare providers will be subject to a 1% penalty if they do not successfully attest by October, 1, 2014, while Medicaid providers will not be subject to penalties under current law. A provider that qualifies for both programs should elect to participate in the Medicaid program because of its higher payout and relaxed MU requirements in the first two years. Providers can register for MU at the CMS website, Medicaid providers also have to register on their state Medicaid website. Providers attest to MU by entering numerators and denominators for each measure at the CMS website for Medicaid providers. The website used for Medicaid registration varies by state. Medicaid providers do not need to attest to MU during Year 1 but must submit evidence they have purchased, implemented or upgraded to a certified EHR solution. MU objectives To qualify for MU incentives, providers must use EHR technology that is certified by Office of the National Coordinator (ONC) and Authorized Testing and Certification Bodies (ATCBs). EHR products can be fully certified for all 25 MU objectives and a minimum of 9 Clinical Quality Measures, or modular, which means they are certified for a portion of the 25 objectives and 44 Clinical Quality Measures. Providers can either purchase a fully certified solution or purchase modular solutions that together meet the certification criteria. MU core objectives 1. 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. 2. Implement drug-drug and drug-allergy interaction checks. 3. Maintain an up-to-date problem list of current and active diagnoses. 4. Generate and transmit permissible prescriptions electronically (erx). 5. Maintain active medication list 6. Maintain active medication allergy list 7. Record all of the following demographics: a. Preferred language b. Gender c. Race d. Ethnicity e. Date of birth 8. Record and chart changes in the following vital signs: a. Height b. Weight c. Blood pressure d. Calculate and display body mass index (BMI) Copyright DrFirst All Rights Reserved. 5

6 e. Plot and display growth charts for children 2 20 years, including BMI. 9. Record smoking status for patients 13 years old or older. 10. Report ambulatory clinical quality measures to CMS or, in the case of Medicaid eligible providers (EPs), the States. 11. Implement one clinical decision support rule relevant to specialty or high clinical priority along with the ability to track compliance with that rule. 12. Provide patients with an electronic copy of their health information (including diagnostics test results, problem list, medication lists, medication allergies) upon request. 13. Provide clinical summaries for patients for each office visit. 14. Capability to exchange key clinical information (for example, problem list, medication list, allergies, and diagnostic test results), among providers of care and patient authorized entities electronically. 15. Protect electronic health information created or maintained by the certified EHR technology through the implementation of appropriate technical capabilities. MU menu objectives 1. Implement drug formulary checks. 2. Incorporate clinical lab-test results into EHR as structured data. 3. Generate patient lists by specific conditions to use for quality improvement, reduction of disparities, research, or outreach. 4. Send patient reminders per patient preference for preventive/follow-up care. 5. Provide patients with timely electronic access to their health information (including lab results, problem list, medication lists, and allergies) within four business days of the information being available to the EP. 6. Use certified EHR technology to identify patient-specific education resources and provide those resources to the patient if appropriate. 7. 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. 8. The EP who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care should provide summary care record for each transition of care or referral. 9. Capability to submit electronic data to immunization registries or immunization information systems and actual submission according to applicable law and practice. 10. Capability to submit electronic syndromic surveillance data to public health agencies and actual submission according to applicable law and practice. Performance Measures Some objectives require performance measures to be met. For example, one of the performance measures requires 40% of the provider s prescriptions must be sent to the pharmacy electronically. Another performance measure requires providers to enter height, weight and blood pressure measurements into the EHR for 50% of its patients. There are Copyright DrFirst All Rights Reserved. 6

7 also 44 clinical quality measures (CQM). These measures emphasize collecting further detail during the patient encounter and using that information for follow-up. For example one measure requires providers to distribute a smoking cessation plan to patients who smoke. CQMs do not have performance requirements. However, when attesting to MU, providers must submit numerators and denominators for at least six measures. Selecting an EHR solution Providers must choose between a fully certified EHR solution or an a la carte system, also known as a modular EHR. Fully certified EHR solutions have the advantage of the provider obtaining a complete solution with a single purchase. But practices may not be ready for a full EHR, because of the cost or because some modules within the EMR are too difficult to implement or use. Providers may also not have the funding or do not feel the practice is ready for a full EHR. Modular EHR systems allow providers to pick the tools and functions that make the most sense in their own practices and clinics. Modular EHRs also allow providers to leverage the benefits of best of breed technology already being used. The cost of modular EHR can be considerably lower than a fully certified solution. Additionally, modular EHRs allow the provider to implement on a smaller scale and build the experience needed for a full-scale EHR implementation. However, the sheer volume of modules available can make the selection process difficult. Providers that purchase multiple EHR solutions also have to deal with multiple vendors and may have to work through interoperability issues. DrFirst has simplified the selection of a modular EHR by providing a completely certified modular EHR that providers can immediately implement and begin earning incentive money. DrFirst Rcopia-MU SM combines DrFirst s industry leading Rcopia e-prescribing technology with WellCentive s patient registry. DrFirst handles all Tier 1 support calls while WellCentive assists with Tier 2 support issues. DrFirst s Rcopia-MU can be licensed for as low as $2,400 per year, a small fraction of the $21,250 first year Medicaid incentive or the $18,000 first year Medicaid incentive. The fee includes a license for one provider, web training and product support. Nonphysicians can use the product at no additional cost. Rcopia-MU enables the practice to earn significant ROI providing funds for a future full EHR implementation if desired. Practices can be up and running in as little as two weeks. Current Rcopia users will experience quicker implementation because half the solution is already being used. The user only requires a single log-in directly into Rcopia, a key advantage for the 30,000-plus physicians currently using Rcopia to process over 1 million prescriptions per week. Clinical data and some patient demographic information is automatically transferred between modules by DrFirst integration technology. When ready to perform registry actions, a click of the button launches the user into WellCentive without entering a new user logon or password. Copyright DrFirst All Rights Reserved. 7

8 DrFirst s AttestEasy SM service provides a proactive approach in helping providers achieve successful MU. DrFirst representatives perform frequent checks on the provider s Rcopia-MU system and flag any potential errors and MU measures that are near or below the threshold. In addition the DrFirst representatives provide assistance in correcting the errors and improving the measures. In advance of attestation day, DrFirst sets up a personalized walk-through webinar and organizes all MU data in a handy referral document to speed up the attestation process. DrFirst is the only standalone e-prescribing company to receive GoldRx TM Solution Certification 4 Years in a row! Surescripts GoldRx Certification Status acknowledges that DrFirst has gone above and beyond standard e-prescribing solutions - improving the prescribing process by dedicating resources to support the new electronic process and by investing in the development and design of a workflow that maximizes the value of an electronic link with pharmacies. The criteria for advanced certification status focuses on benchmarks that signal a vendor s commitment to interoperability, customer support and successful customer implementations. Conclusion Providers can qualify for Medicare and Medicaid incentives with the use of certified EHR technology. Providers can purchase a fully certified solution or purchase modular solutions that together make up 100% of the certification criteria. Modular EHR solutions allow providers to take a best of breed approach to MU by choosing tools and functionality that make the most sense. DrFirst s Rcopia-MU is a combination of two modularly certified EHRs that physicians can implement and begin to earn incentives immediately. Copyright DrFirst All Rights Reserved. 8

9 About DrFirst, Inc. Founded in 2000, DrFirst is the nation's leading e-prescribing and solutions platform provider to physician practices, major health plans, health systems, hospitals, and EHR vendors. Through its Open Borders Program, DrFirst solutions integrate with over 200 EHR, practice management and HIT systems. A Surescripts Gold Certified solution provider for four consecutive years with its award-winning Rcopia electronic prescription management system, DrFirst utilizes the Surescripts network for pharmacy connectivity, health plan information, and patient medication history. For more information, visit Contact Us Tel: 888-DRFIRST Tel: Fax: Online: DrFirst, Inc Key West Ave. Suite 230 Rockville, MD USA Copyright DrFirst All Rights Reserved. 9