Meaningful Use Preparedness 07/24/2015

Transcription

1 Meaningful Use Preparedness HEALTHCARE FINANCIAL MANAGEMENT ASSOCIATION 07/24/2015

2 Agenda Incentive Payments Measures Tracking Physicians Tracking Payment Audits

3 EHR Incentive Program Meaningful Use The American Reinvestment & Recovery Act (ARRA) February 17, "Health Information Technology for Economic and Clinical Health (HITECH) Act supports the concept of electronic health records - meaningful use [EHR-Meaningful Use Effort led by Centers for Medicare & Medicaid Services (CMS ) and the Office of the National Coordinator for Health IT (ONC). Program saw many changes since 2011, the first reporting year. Incentives decrease as penalties incurred. 3

4 Stages of Meaningful Use Stage 1 Data Capture and Sharing Stage 2 Advance Clinical Processes Stage 3 Improve Outcomes Stage 3 is to be the final stage of Meaningful Use ONC is requesting granularity with Standards and Implementation Specifications

5 Meaningful Use Stages Stage 1 Stage 2 Proposed Modified Stage Proposed Stage Core Objectives 17 Core Objectives 10 Objectives 8 Objectives 5 of 10 Menu Objectives 3 of 6 Menu Objectives 0 Menu Objectives 0 Menu Objectives 5

6 Measures

7 # Measure Stage 2 Stage 2 Modified as Proposed Stage 3 as Proposed 1.1 Protect Electronic Health Information Annual No Change Annual & After Upgrades 2.1 Clinical Decision Support 5 Rules Stage 1 Reports on Stage 2 Thresholds 5 Rules 2.2 Drug-drug and Drug Allergy Interaction Checks Drug/Drug Drug/Drug No Change Drug/Allergy Drug/Allergy 3.0 Computerized Provider Order Entry 3.1 CPOE Entry Medications Orders 60% 80% Stage 1 Reports on Stage 2 Thresholds 3.2 CPOE Laboratory Orders 30% 60% 3.3 CPOE Radiology Orders 30% 60% 4.1 Electronic Prescribing 50 % EP 80% EP No Change 10% EH Menu 25% EH 5.1 Summary of Care Send Electronic Summary of Care 10% 50% Stage 1 Reports on Stage 2 Thresholds Receive Electronic Summary of Care - 40% Reconcile Electronic Summary of Care - 80% 6.1 Patient Specific Education 10% Moves to Core for Stage 1 at 10% 35% 7.1 Medication Reconciliation 50% Stage 1 Reports on Stage 2 Thresholds 8.0 Patient Electronic Access 8.1 Patient Electronic Access (Timely Access) 5% 5% Threshold replaced by 1 patient 25% 8.2 Patient Electronic Access (VDT) 50% No Change 80% 9.1 Secure Electronic Messaging 10.0 Public Health and Clinical Data Registry Reporting 5% EP 0% EH 10.1 Immunization Registry Reporting x 10.2 Syndromic Surveillance Reporting x 10.3 Case Reporting 10.4 Public Health Registry Reporting 10.5 Clinical Data Registry Reporting 10.5 Reportable Labs to Public Health (EH Only) EP 5% Threshold replaced with Capacity to send/receive EP Both Stages Report on 2 of the 5 EH Report on 3 of 6 35% EP Report on 3 of 5 EH Report on 4 of 6

8 Proposed Stage 3 Simplified 8

9 21 Measures within the 8 Objectives Key Goals in Proposed Stage 3 Patient Engagement Interoperability 9

10 Incentive Payments

11 Medicare Incentive Payments First Payment Year Annual Incentive Payment by Stage of Meaningful Use 2011* * * $44,000 $18,000 $12,000 $8,000 $4,000 $2, $44,000 $18,000 $12,000 $8,000 $4,000 $2, $39,000 $15,000 $12,000 $8,000 $4, $24,000 $12,000 $8,000 $4, $0 $0 * Start of new stage for EPs with two years in prior stage

12 Medicaid Incentive Payments First Payment Year Annual Incentive Payment by Stage of Meaningful Use 2011* * * A.I.U $63,750 $21,250 $8,500 $8,500 $8,500 $8,500 $8, A.I.U $63,750 $21,250 $8,500 $8,500 $8,500 $8,500 $8, A.I.U $63,750 $21,250 $8,500 $8,500 $8,500 $8,500 $8, $63,750 $21,250 $8,500 $8,500 $8,500 $8,500 $8, $63,750 $21,250 $8,500 $8,500 $8,500 $8,500 $8, $63,750 $21,250 $8,500 $8,500 $8,500 $8,500 $8,500 * Start of new stage for EPs with two years in prior stage

13 Payment Adjustments (Penalty Phases Begins) 0% 1% 2% 3% Meaningful User Meaningful User x Meaningful User Meaningful User Meaningful User No Penalty No Penalty No Penalty No Penalty 3% Penalty (reduction based on 2015) CMS has announced 257,000 physicians will be penalized beginning 2015 for failing to meet Meaningful Use.

14 Hardships Lack of Internet Infrastructure Available per FCC Unforeseen and/or Uncontrollable Circumstances (Fire, Tornado, Hurricane, FEMA Declared, Flood, Explosion, Practice Closure, Bankruptcy or Debt Restructuring, EHR Certification/Vendor Issues) Lack of Control over the Availability of Certified EHR Technology Lack of Face-to-Face Patient Interaction Hardships are due July 1 each year

15 Tracking Physicians

16 Tracking Physicians Eligible Professionals attest individually CMS holds physician responsible for Meaningful Use Health network can have physicians in various stages and years of MU. Need to monitor physicians progress on objectives early and often

17 Physicians in Transition Good neighbor approach in working with outside health networks in assisting EP in Meaningful Use. CMS does not offer guidelines responsibility for meeting MU and provide required reports lies with the EP Health Networks have a variety of formal and informal policy around transitioning physicians Scenarios EP joins December 2015 and has never been a Meaningful User You have 30 days to register EP, determine Stage/Year, produce/monitor reports. Request information and reports from prior employer Payment adjustments will apply on all Medicare dollars received in 2015, 2016, 2017.

18 Physicians in Transition EP joins July Never attest. What reporting period is used? Does the former employer attest on behalf of the EP? Does the current employer attest on behalf of the EP? EP leaves you mid-reporting period. EP has been a Meaningful User since 2011 Would the new employer attest on behalf of the EP? Would the former employer provider MU reports to the provider or new employer? Depending on the comfort level, the new employer could attest for the EP. Would the former employer support an audit when our data is used? For 2015 attestations cannot occur prior to January 1 There is the potential this change will make it easier for networks to attest Where ever the EP is employed on January 1 will attest.

19 Tracking Payments

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21 Tracking Payments Provide finance department with list of EP that attest Understand newly hired employees may be subject to payment adjustments with 2 year lookback Audits could result in repayment Know the Stage/Year of EP as incentive payments are based on 75% of payments with a cap that declines each year Request that CMS provide cleaner adjudications

22 Audits

23 Audits 34 Billion spent on Meaningful Use 17 Billion expected to be repaid Auditors Medicare Audits Figliozzi & Co Medicaid Audits PA State OIG audits Hospital, Physicians, Medicare, Medicaid Audit Types Prepayment/Postpayment One Year/Multiple Years

24 Preparing for an Audit #1 Reasons audits fail is the Security Risk Assessment (SRA) SRA included physical, technical, administrative safeguards ~150 pages each Security Risk Assessment Tools Auditors Figliozzi & Company State Office of Inspector General

25 Figliozzi & Company Audit Engagement letter and document request is sent Organization provided business days to fulfill request Auditor reviews and may request additional documentation Upload is through a fileshare portal. No receipt is received. Think about documenting files names and submission times

26 PA State 60 days to reply Audit multiple EPs at once (e.g. 51, 25, 29) Medicaid Patient Volume detail In addition to expected documents, PA State has requested Proof of board certification Surveys Explanation of process or methodology

27 Office of Inspector General 10 business days to reply Audits are more in depth and focused on subset of MU Medicare and Medicaid Via or Onsite Submit files through HHS/OIG Delivery Server Secure Receipt is received when auditor retrieve the files

28 Documentation Save off source documentation (MU reports from CEHRT) used during attestation (static) Request Standard Vendor Letter from EHR vendor Screenshots of Yes/No measures Include screenshot for only measures the Eligible Professional reported on machine dated from state registries Medicaid Volume and Fiscal documentation (original and updates from desk reviews) Security Risk Analysis with remediation plan. Must address data at rest. Evidence demonstrating reports were generated by the CEHRT (A screenshot of the report within the system before it was printed, logo, etc.)

29 Documentation Documentation of Transitions of Care measure 3 cross-vendor cross-organization exchange Send a clean, organized document that answers the question. Send what is asked. EHR Vendor contract -Do not send full contract Be aware of vendor proprietary information Save CMS FAQs FAQs are periodically deleted FAQs will print blank pages

30 Documentation Collect documents now. Do no wait for the audit notification. Communicate with the auditors Communicate internally - Audit request will be sent to the address on the EHR Incentive program registration Physician Credentialing Meaningful Use contact Communicate securely with auditors. Auditors are required to report security breaches that do not meet FIPS requirements. Secure Direct address Secure file upload

31 Appendix CONTAINS: STANDARD VENDOR LET TER LINKS TO SUPPORTING DOCUMENTATION

32 Standard Vendor Letter (EHR Vendor Letterhead) EHR Vendor Letter for EHR Incentive Program As of date of this letter, (Vendor name) verifies: that (Provider name): (1) was or is a customer of (Vendor name), and (2) received the Certified electronic health record technology as a product from (Vendor name). Date: Provider Name: EHR Vendor Name: CMS Certified Product Name: CMS Certified Product Version Number: CMS EHR system Certification ID number ONC-ATCB Certification ID Number (if available): EHR Vendor Signature

33 Supporting Documentation Links Link to PA State suggested documentation for Meaningful Use Link to CMS suggested documentation for Meaningful Use Guidance/Legislation/EHRIncentivePrograms/Downloads/EHR_SupportingDocumentation_Audits.pdf Link to PA State volume sample report.