Medicare Electronic Health Record Incentive Program

Transcription

1 Medicare Electronic Health Record Incentive Program The American Recovery and Reinvestment Act (Recovery Act) of 2009 provides for incentive payments for Medicare eligible professionals (EPs) who are meaningful users of certified electronic health record (EHR) technology. The Meaningful Use Criteria Meaningful Use is using certified EHR technology to Improve quality, safety, efficiency, and reduce health disparities Engage patients and families in their health care Improve care coordination Improve population and public health All the while maintaining privacy and security According to HITECH, an EP is considered a meaningful user of EHR if, during the specified reporting period, it: 1. Demonstrates use of certified EHR technology in a meaningful manner; 2. Demonstrates that the certified EHR technology is connected in a manner that provides for the electronic exchange of health information in order to improve the quality of health care, such as promoting care coordination; and 3. Uses certified EHR technology to submit information to the Secretary of CMS on specified clinical quality measures and other measures. While the Meaningful Use Final Rule includes the criteria for Stage 1, CMS has not yet proposed criteria for Stages 2 and 3. Although, CMS expects to update the meaningful use criteria on a biennial basis, with the Stage 2 criteria being released by the end of 2011 and the Stage 3 criteria being released by the end of

2 Stage 1 Objectives and Measures Reporting In the Final Rules, CMS lessened the burden on EPs, eligible hospitals (EHs), and critical access hospitals (CAHs) seeking to establish meaningful use by requiring a core set of 15 criteria objectives for EPs (reduced from 23 for 25 for EPs in the proposed rule) and a "menu" of 10 criteria objectives with associated measures of which providers are required to meet five of their choosing. Eligible Professionals must complete: 15 core objectives 5 objectives out of 10 from menu set 6 total Clinical Quality Measures (3 core or alternate core, and 3 out of 38 from additional set) Meaningful Use Core Objectives (15 Core Objectives) 1. Computerized provider order entry (CPOE) 2. E-Prescribing (erx) 3. Report ambulatory clinical quality measures to CMS/States 4. Implement one clinical decision support rule 5. Provide patients with an electronic copy of their health information, upon request 6. Provide clinical summaries for patients for each office visit 7. Drug-drug and drug-allergy interaction checks 8. Record demographics 9. Maintain an up-to-date problem list of current and active diagnoses 10. Maintain active medication list 11. Maintain active medication allergy list 12. Record and chart changes in vital signs 13. Record smoking status for patients 13 years or older 14. Capability to exchange key clinical information among providers of care and patient-authorized entities electronically 15. Protect electronic health information Meaningful Use 10 Menu Set Objectives (may defer 5 of 10) 1. Drug-formulary checks 2. Incorporate clinical lab test results as structured data 3. Generate lists of patients by specific conditions 4. Send reminders to patients per patient preference for preventive/follow up care 5. Provide patients with timely electronic access to their health information 6. Use certified EHR technology to identify patient-specific education resources and provide to patient, if appropriate 7. Medication reconciliation 8. Summary of care record for each transition of care/referrals 9. Capability to submit electronic data to immunization registries/systems* 10. Capability to provide electronic syndromic surveillance data to public health agencies* *At least 1 public health objective must be selected. 2

3 Clinical Quality Measures EPs will have to report data on three core quality measures in 2011 and 2012: blood-pressure level, tobacco use status, and adult weight screening and follow-up. There are alternate quality measures for providers to which the above quality measures do not apply: weight assessment and counseling for children, influenza immunization, and childhood immunization status. Notably, to meet the meaningful use requirements, EPs need only report the required clinical quality measures-they need not satisfy a minimum value for any of the clinical quality measures. Additionally, EPs also must choose three other measures from a list of 38 that it is able to incorporate into its EHRs. Eligible professionals are required to report on three (3) core clinical quality measures and select an additional three (3) clinical quality measures to report from a different set than the core list. EPs must also submit their aggregate clinical quality measure number, denominator, and exclusion data to CMS to demonstrate meaningful use. For payment year 2011, a provider need only attest to the particulars relating to each quality measure. However, starting in payment year 2012, in addition to meeting requirements for meaningful use, Medicare EPs, EHs, and CAHs will be required to electronically submit clinical quality measure results (numerators, denominators, exclusions) as calculated by certified EHR technology. Exclusions Some meaningful use objectives may not apply to certain eligible professionals and such exclusions would not count against the required fulfillment of objectives. For example, chiropractors who do not e-prescribe would not be expected to meet that objective as they would not have any eligible patients. Medicare Eligible Professionals The Medicare EHR Incentive Program for eligible professionals starts in 2011 and will continue through Depending on the first year they participate, eligible professionals can participate for up to 5 years throughout the duration of the program. The last year to begin participation in the Medicare EHR Incentive Program is Under the Medicare EHR Incentive Program, EPs include the following: Doctor of medicine or osteopathy. Doctor of dental surgery or dental medicine. Doctor of podiatry Doctor of optometry. Chiropractor. Medicare eligible professionals are eligible for incentive payments for the "meaningful use" of certified EHR technology, if all program requirements are met. To qualify for Medicare EHR incentive payments, Medicare eligible professionals must successfully demonstrate meaningful use for each year of participation in the program. The incentive payments for EPs are based on individual providers. If you are part of a practice, each EP may qualify for an incentive payment if each EP successfully demonstrates meaningful use of certified EHR technology. Each EP is only eligible for one incentive payment per year, regardless of how many practices or locations at which he or she provide services. 3

4 Hospital-based EPs are not eligible for incentive payments. An EP is considered hospitalbased if 90% or more of his or her services are performed in a hospital inpatient or emergency room setting. Incentive payments are made based on the calendar year. The reporting period for the first year of participation is any 90 continuous days during the calendar year. The reporting period for all subsequent years is the entire calendar year. For calendar years , eligible professionals who demonstrate meaningful use of certified EHR technology can receive up to $44,000 over 5 years under the Medicare EHR Incentive Program. To receive the maximum EHR incentive payment, Medicare eligible professionals must begin participation by Important! For 2015 and later, Medicare eligible professionals who do not successfully demonstrate meaningful use will have a payment adjustment to their Medicare reimbursement. The payment reduction starts at 1% and increases each year that a Medicare eligible professional does not demonstrate meaningful use, to a maximum of 5%. Medicare eligible professionals who also qualify as a Medicaid eligible professional must choose between the Medicare and Medicaid incentive programs when they register. What can you do now? Make sure you have enrollment records in the appropriate systems. National Provider Identifier (NPI) All eligible professionals, eligible hospitals, and critical access hospitals (CAHs) must have a National Provider Identifier (NPI) in order to participate in the Medicare and Medicaid EHR Incentive Programs. National Plan and Provider Enumeration System (NPPES) Most providers will need an active user account in the National Plan and Provider Enumeration System (NPPES). Please visit the link under "Related Links Inside CMS" for more information on NPPES. Provider Enrollment, Chain and Ownership System (PECOS) Act now to verify that you have an enrollment record in PECOS. All eligible hospitals and Medicare eligible professionals must have an enrollment record in PECOS to participate in the EHR Incentive Programs. (Eligible professionals who are only participating in the Medicaid EHR Incentive Program are not required to be enrolled in PECOS.) If you do not have an enrollment record in PECOS, now is the time to set up your record. The best way to submit your application is through Internet-based PECOS. Fee-for-Service Medicare Incentive Payment Incentive Participating in the EHR Incentive Program and Other Current CMS Incentive Programs EPs may not receive EHR incentive payments from both the Medicare and Medicaid programs in the same year. In the event an EP qualifies for EHR incentive payments from both the Medicare and Medicaid programs, the EP must elect to receive payments from only one program. After an EP qualifies for an EHR incentive payment under one program but before 2015, an EP may switch between the Medicare and Medicaid programs one time. Upon switching programs, the EP will be placed in the payment year the EP would have been in had the EP not switched programs. For 4

5 example, if an EP decides to switch after attesting to meaningful use of certified EHR technology for a Medicare Fee-for-Service (FFS) incentive payment for the second payment year, then the EP would be in the third payment year for purposes of the Medicaid incentive payments. The Medicare and Medicaid EHR Incentive Programs are new and separate programs from other active CMS incentive programs, such as the Physicians Quality Reporting Initiative (PQRI) and the MIPPA E-Prescribing Incentive Program. The Medicare EHR Incentive Program will begin in early Registration for the Medicare program will be available starting on January 3, An EP who participates in the Medicare EHR incentive program may also participate in the Physician Quality Reporting System. However, if an EP elects to receive an EHR incentive payment through the Medicare Program, the EP is not eligible to receive an incentive payment through the Electronic Prescribing (erx) incentive program. On the contrary, EPs who receive an EHR payment through the Medicaid Program are eligible to also receive an incentive payment through the erx incentive program provided they meet all the requirements of the erx program. Medicare eligible professionals who predominantly furnish services in an area designated as a Health Professional Shortage Area (HPSA) will receive a 10% increase in their annual EHR incentive payments. NOTE: The additional 10% HPSA incentive is not available for eligible professionals who participate in the Medicaid EHR Incentive Program. Payment - Calculation Under FFS Medicare, the payment incentive amount, subject to an annual limit, is equal to 75 percent of an EP's Medicare physician fee schedule allowed charges submitted not later than 2 months after the end of the calendar year. This means that, for 2011, the EHR incentive payment for an EP would be, subject to an annual limit, equal to 75 percent of the EP's Medicare physician fee schedule allowed charges for CY 2011, based on claims for services performed by the EP from January 1, 2011 through December 31, 2011, and submitted to the EP's Medicare contractor (MAC/carrier) no later than February 29, Incentive Payment - Time Frame EPs can begin receiving incentive payments in any calendar year (CY) from 2011 to EPs may receive Medicare incentive payments for up to five years, depending on the year in which the EP first becomes a meaningful user of certified EHR technology. Medicare EPs who successfully demonstrate meaningful use and receive a Medicare EHR incentive payment in the first or second year of the incentive program (2011 or 2012) may qualify to receive payments for the full five years. However, Medicare EPs who first successfully demonstrate meaningful use for 2013 can only receive incentive payments for four years and will receive less than the maximum possible incentive payment. Accordingly EPs who start participating in 2014 can only receive incentive payments for three years and will also receive less than the maximum incentive payment possible. An EP who first successfully demonstrates meaningful use of certified EHR technology for 2015 will not qualify for any Medicare EHR incentive payments. In addition, starting in 2015, an EP who does not successfully demonstrate meaningful use of certified EHR technology use will be subject to reduced physician fee schedule payments. 5

6 Medicare EHR incentive payments will be made on a rolling basis after CMS has ascertained that the EP met meaningful use for the reporting period and the EP has met the maximum allowable charges threshold. In the event that the EP does not meet the maximum allowed charges threshold by the end of the calendar year, payment will be made following the deadline to submit claims for the period. Incentive Program - Annual Limits EPs who successfully demonstrate meaningful use of certified EHR technology during the relevant EHR reporting period may be eligible for an incentive payment amount, subject to an annual limit, equal to 75 percent of the EP's Medicare allowed charges submitted not later than two months after the end of the calendar year. Table 1 illustrates the maximum incentive payments an EP can receive by year and the total incentive payments possible if an EP successfully demonstrates meaningful use and qualifies for an incentive payment each year. As shown, the total amount of the incentive payment an EP can receive is dependent in part on the year in which the EP successfully demonstrates meaningful use. Table 1: Maximum Incentive Payments Based on the First CY in Which an EP Participates Calendar Year Maximum Incentive Payments Based on the First CY in Which an EP Participates In the Program $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 Payment Adjustments Beginning in 2015 If an EP does not successfully demonstrate meaningful use of certified EHR technology, the EP's Medicare physician fee schedule amount for covered professional services will be adjusted by the applicable payment adjustment specified in the Recovery Act beginning in The payment adjustments will be as follows: percent of Medicare physician fee schedule covered amount percent of Medicare physician fee schedule covered amount 2017 and each subsequent year-97 percent of Medicare physician fee schedule covered amount If it is determined that for 2018 and subsequent years that less than 75 percent of EPs are meaningful users then the payment adjustment will change by one percentage point each year until the payment adjustment reaches 95 percent. The Recovery Act allows for a hardship exception, which, if applicable, could exempt certain EPs from the payment adjustment. The exemption is subject to annual renewal, but in no case will a hardship exemption be given for more than five years. Note: More information on payment adjustments and the requirements to qualify for a hardship exemption will be provided in future rulemaking prior to the 2015 effective date. 6

7 Medicare Advantage (MA) Incentive Payments Section 1853(1)(1) of the Act, as added by the Recovery Act, also provides for incentive payments to qualifying MA organizations (MAO) for their affiliated EPs who are meaningful users of certified EHR technology. Specifically an MA EP as defined by section 1853(1)(2) of the Act, as added by the Recovery Act must either: Furnish, on average, at least 20 hours/week of patient-care services and be employed by the qualifying MAO or Be employed by, or be a partner of, an entity that through contract with the qualifying MAO furnishes at least 80 percent of the entity's Medicare patient care services to enrollees of the qualifying MAO If an MA EP meets these guidelines and the MAO can attest that the MA EP is a meaningful user of certified EHR technology the MAO can receive an incentive payment in accordance with Table 1. Similar to the Medicare FFS incentive program MA organizations are not eligible for incentive payments for hospital based EPs. Section 1853(1)(3)(B) of the Act, as added by the Recovery Act, specifically states that duplicate payments may not be made for EPs eligible for both the FFS incentive payment and the MA incentive payment. Section 1853(l)(3)(B)(l) says that if an EP is eligible to receive an incentive payment from both the Medicare FFS and MA programs, the Medicare FFS payment will be made first but only if it is for the maximum amount due for that payment year. Therefore, before a payment can be made to a qualifying MAO for an EP, CMS will determine if that EP has already been paid the maximum for that year through the Medicare FFS Program. If the EP received the maximum incentive payment available for that payment year from the Medicare FFS Program then the MAO would not be eligible to receive an MA incentive payment for that EP for that payment year. If, however, the EP did not receive the maximum possible incentive payment possible for the payment year, then the MAO will receive the incentive payment solely through the MA incentive program, Payment solely under the MA program for EPs who qualify for incentive payments under both FFS and MA, but who did not earn the maximum bonus under FFS, is required by section 1853(I)(3)(B)(ll) of the Act. Certification for the Medicare EHR Incentive Programs The Medicare and Medicaid EHR Incentive Programs require the use of certified EHR technology. Standards, implementation specifications, and certification criteria for EHR technology have been adopted by the Secretary of the Department of Health and Human Services. EHR technology must be tested and certified by an Office of the National Coordinator (ONC) Authorized Testing and Certification Body (ATCB) in order for a provider to qualify for EHR incentive payments IMPORTANT: Even if you are already using EHR technology, it must be tested and certified by an ONC- ATCB specifically for the Medicare and Medicaid EHR Incentive Programs. EHR technologies that meet the certification requirements for the Medicare and Medicaid EHR Incentive Programs are listed on the ONC Web site. For more information, please visit the Centers for Medicare and Medicaid Service EHR Incentive Program website at: 7