2011 Medicaid EHR Incentive Program

Transcription

1 2011 Medicaid EHR Incentive Program Matthew Stanford VP Policy & Regulatory Affairs Associate Counsel Wisconsin Hospital Association Elise Braun Medicaid HIT Planning Team WI Department of Health Services Strategy & Operations Deloitte Consulting LLP January 21,

2 Medicaid Incentive Program: Key Issues to Think About The Medicare and Medicaid EHR Incentive Programs have key differences No penalties under the Medicaid Program for not meeting meaningful use. CAHs and PPS hospitals have the same payment methodology. Entirely different payment scheme for the Medicaid Program. Maximum of 3 payment years. Before FFY 2016, a hospital does not lose a payment year if it has a gap between participation years. A hospital can start as late as FFY 2016 and still receive the full Medicaid incentive payments through FFY Must meet a 10% Title XIX Medicaid volume threshold or be a children s hospital to be eligible for the Medicaid EHR Incentive Program. 2

3 Medicaid Incentive Program: Key Issues to Think About Key Difference with Medicare: MU not required in first payment year In the first fiscal year that a provider applies and is eligible for the Medicaid incentive program, that provider can receive payment merely by showing adoption, implementation, or upgrade of certified EHR. Adoption = Acquired and installed Implement = Commenced utilization Upgrade = Expanded EHR to meet meaningful use (including certification) In subsequent payment years, the provider must meet meaningful use. 3

4 Medicaid Incentive Program: Key Issues to Think About Maximizing your Medicare and Medicaid Incentive payments Considerations: Must demonstrate MU in FFY 2013 to receive the full Medicare EHR Incentive. Hospitals that begin participation in FFY 2014 or later receive a lower Medicare incentive. 4 Stage 1 MU applies for the hospital s first two years of participation in the Medicare EHR Incentive Program. Current rules indicate that Stage 2 MU will apply on the hospital s 3rd year of demonstrating MU. Rules for Stage 2 MU are still in development; not likely finalized until December Under current rules, hospitals that receive payment in FFY 2011 for Medicare MU will have to show 1 year of meeting Stage 2 MU beginning on Oct. 1, 2012.

5 Medicaid Incentive Program: Key Issues to Think About Maximizing your Medicare and Medicaid Incentive payments It may be most advantageous for hospitals to: Seek 1st Medicaid payment in FFY 2011 or Merely need to demonstrate adoption, implementation or upgrading of certified EHR. Seek 2nd Medicaid payment in FFY 2013 (show 90 days of Stage 1 MU). Seek 1st Medicare payment in FFY 2013 (show 90 days of Stage 1 MU). Seek 3rd Medicaid payment in FFY 2014 (show 1 year of Stage 1 MU). Seek 2nd Medicare payment in FFY 2014 (show 1 year of Stage 1 MU). 5

6 WHA Resources WHA Toolkit WHA Education Primary WHA contact: Matthew Stanford 6

7 January 21, 2011

8 Medicaid EHR Incentive Program Overview Eligibility Requirements Patient Volume Calculation Meaningful Use Incentive Payment Calculation Participating in the Medicaid EHR Incentive Program Registration and Receiving Payments Timeline and Next Steps for Hospitals Resources Questions 8

9 Section 4201 of the American Recovery and Reinvestment Act (ARRA) of 2009 established a program for incentive payments to certain classes of eligible Medicaid professionals and hospitals who adopt and become meaningful users of certified EHR technology Medicaid Eligible Hospitals, as defined in the Statute and the Medicare and Medicaid Programs; Electronic Health Record Incentive Program Final Rule, include: Acute Care Hospitals (including CAHs and Cancer Hospitals)* Average length of patient stay is 25 days or fewer and with a CCN that has the last four digits in the series or Children's Hospitals with a CCN that has the last four digits in the series Hospitals are eligible as determined by unique CMS certification numbers (CCN) Hospital Medicaid EHR Incentive Program Participation Years are based on the Federal Fiscal Year (FFY) *Also eligible for the Medicare EHR Incentive Program 9

10 1st Participation Year Adopt, Implement, or Upgrade certified EHR technology or demonstrate meaningful use of certified EHR technology 2nd 3rd Participation Year Demonstrate meaningful use of certified EHR technology EHR Reporting Period * 90 consecutive days within the FFY for 1st year of demonstrating Meaningful Use (MU) 1 year for subsequent years of demonstrating MU All Participation Years Acute Care Hospitals: Have an Average Length of Stay (ALOS) of 25 days or fewer Have a minimum 10% Title XIX Medicaid Patient Volume Have a CCN that has the last 4 digits in the series or Children s Hospitals: Separately certified as a children s hospital, either freestanding or hospitalwithin hospital Have a CCN that has the last 4 digits in the series No Patient Volume Requirements 10

11 Medicaid Patient Volume Equation Total Title XIX Medicaid Patient Encounters for a 90-day period in the preceding Federal Fiscal Year Total Patient Encounters in that same 90-day period *100 Title XIX Medicaid Patient Encounter Services rendered to an individual per inpatient discharges where Medicaid or a Medicaid demonstration project under section 1115 paid for part or all of the service; Services rendered to an individual per inpatient discharge where Medicaid or a Medicaid demonstration project under section 1115 of the Act paid all or part of their premiums, co-payments, and/or cost-sharing; Services rendered to an individual in an emergency department on any one day where Medicaid or a Medicaid demonstration project under section 1115 of the Act either paid for part or all of the service; or Services rendered to an individual in an emergency department on any one day where Medicaid or a Medicaid demonstration project under section 1115 of the Act paid all or part of their premiums, co-payments, and/or cost-sharing. 11

12 WHA and DHS have been working collectively to determine Medicaid Patient Volume for Hospitals DHS is developing a report that will list Hospital Medicaid Patient Volume eligibility by Federal Fiscal Year (FFY) Quarter. Information for FFY 2010 will be available on the following dates: 2010 FFY Q1 (10/01/09 12/31/09): January 31, FFY Q2 (1/01/10 3/31/10): March 7, FFY Q3 (4/01/10 6/30/10): March 7, FFY Q4 (7/01/10 9/30/10): May 31, 2011 It is anticipated that DHS will publish a list of all hospitals that meet the volume threshold and are potentially eligible to receive a Medicaid EHR Incentive Payment in FFY 2011 on the Medicaid EHR Incentive Program website ( If Hospitals have questions about their Patient Volume calculation they should requests for information to the Medicaid EHR Incentive Program Inbox: dhsehrincentiveprogram@wi.gov 12

13 MU measures are the same for the Medicare and Medicaid EHR Incentive Programs Hospitals must report on 19 of 24 MU objectives 14 must be core objectives 5 objectives may be chosen from the list of 10 menu set objectives At least one objective must be a population or public health measure Some MU objectives are not applicable to every Hospital, in these cases the Hospital would be excluded from having to meet that measure Exclusions do not count against the 5 deferred menu set objectives EHR Reporting Period 1st year of demonstrating MU is 90 days within the participation year (FFY), all subsequent years of demonstrating MU it is the full participation year (FFY) Reporting MU Criteria Dually Eligible Hospitals Report to CMS Hospitals deemed eligible by CMS will automatically be deemed eligible by Medicaid Medicaid Only Hospitals Report to Wisconsin Medicaid Agency 13

14 Aggregate EHR Hospital Incentive Amount will be calculated by the State in Participation Year 1 per CCN Adjustments to the aggregate incentive payment may be needed based upon updates to cost report data States had the option to disburse the Aggregate EHR Hospital Incentive Amount over 3 6 years The Wisconsin Medicaid Agency will distribute payments over 3 years according to the following percentages: Participation Year 1: 50% of Aggregate EHR Hospital Incentive Amount Participation Year 2: 40% of Aggregate EHR Hospital Incentive Amount Participation Year 3: 10% of Aggregate EHR Hospital Incentive Amount The # of years payments are distributed over does not impact the Aggregate EHR Hospital Incentive Amount For Dually Eligible Hospitals - Medicaid EHR Incentive Payments are in addition to the Medicare EHR Incentive Payments The two have no impact one another 14

15 In order to receive an EHR incentive payment after 2016 the Hospital must have received a payment in the previous year Hospitals receiving a Medicaid EHR incentive payment must receive payments on a consecutive, annual basis after the year 2016 Prior to 2016, Medicaid incentive payments to hospitals can be made on a nonconsecutive, annual basis Data elements used to calculate the Aggregate EHR Hospital Incentive Amount will come from the most recently submitted Hospital Cost Report period (the individual Hospital s Fiscal Year) With one exception the average annual growth rate will be calculated using the most recent three years of available discharge data 15

16 Aggregate EHR Hospital Incentive Amount= (Overall EHR Amount) * (Medicaid Share) 16

17 Overall EHR Amount = Sum over 4 years of [(Base Amount + Discharge Related Amount Applicable for Each Year) * Transition Factor Applicable for Each Year]} Data Input Name Description Source of Data Base Amount $2,000,000 Statute Defined Discharge Related Amount $200*(the 1,150th through the 23,000th discharge for year 1, for subsequent years use discharges adjusted for the provider's average annual rate of growth for the most recent 3 years for which data are available per year.) Transition factor Year 1 = 1 Year 2 = 0.75 Year 3 = 0.50 Year 4 = 0.25 Hospital (WHA will be able to provide assistance to Hospitals in determining this information) Statute Defined 17

18 Data Provided: Discharges Hospital Fiscal Year 2010: 2,000 Base Year (BY) Hospital Fiscal Year 2009: 1,900 BY (-1) Hospital Fiscal Year 2008: 1,720 BY (-2) Hospital Fiscal Year 2007: 1,500 BY (-3) Formula Calculation Annual Growth Rate (BY (-2) BY (-3))/ BY (-3) (1,720-1,500)/1, (BY (-1) BY (-2))/ BY (-2) (1,900-1,720)/1, (BY BY (-1))/ BY (-1) (2,000-1,900)/1, Average Annual Growth Rate = ( ) / 3 =

19 Discharges Per Calculation Y1 = 2,000 (Base Year) Y2 = Y1 * = 2,204 Y3 = Y2 * = 2,429 Y4 = Y3 * = 2,677 Discharge Related Amount Y1 = 200* (2,000 1,149) = 170,200 Y2 = 200* (2,204 1,149) = 211,000 Y3 = 200* (2,429 1,149) = 256,000 Y4 = 200* (2,677 1,149) = 305,600 Overall EHR Amount Y1 = (2,000, ,200) * 1 = 2,170,200 Y2 = (2,000, ,000) * 0.75 = 1,658,250 Y3 = (2,000, ,000) * 0.50 = 1,128,000 Y4 = (2,000, ,600) * 0.25 = 576,400 Discharges increase each year by the average annual growth rate from the amount calculated in the previous year Discharges that count in this formula are the 1,150 23,000 discharge Overall EHR Amount = SUM OF ALL 4 Years = $5,532,850 19

20 Medicaid Share = {(Estimated Medicaid Inpatient Bed Days + Estimated Medicaid Managed Care Inpatient Bed Days)/ [(Estimated Total Inpatient Bed Days)*(Estimated Total Charges - Charity Care Charges)/(Estimated Total Charges)]} Data Input Name Description Source of Data Estimated Medicaid Inpatient Bed Days * Estimated Medicaid Managed Care Inpatient Bed Days* Estimated Total Inpatient Bed Days Medicaid Title XIX Fee for Service Inpatient Bed Days for the Hospital s cost reporting period (provided by Wisconsin Medicaid) Medicaid Title XIX Manage Care Inpatient Bed Days for the Hospital s cost reporting period (provided by Wisconsin Medicaid) Medicare Cost Report Worksheet S-3, Part 1, Column 6, line 12 State of Wisconsin Medicaid Agency State of Wisconsin Medicaid Agency Hospital Estimated Total Charges Medicare Cost Report Worksheet C, Part 1, Column 8, line 103 Charity Care Charges Medicare Cost Report , Worksheet S- 10, line 30 Hospital Hospital *Dual Eligible Numerator - For purposes of calculating the Medicaid share, a patient cannot be counted in the numerator if they would count for purposes of calculating the Medicare share. 20

21 Data Provided: Medicaid Inpatient Bed Days (FFS) = 5,000 Medicaid MCO Inpatient Bed Days = 2,000 Total Inpatient Bed Days = 21,000 Total Charges = $10,000,000 Charity Charges = $1,300,000 Medicaid Share = (5, ,000) /{21,000*[(10,000,000 1,300,000)/10,000,000]} Medicaid Share =

22 Aggregate EHR Hospital Incentive Amount= (Overall EHR Amount) * (Medicaid Share) Aggregate EHR Hospital Incentive Amount = $5,532,850 * 0.38 = $2,102,483 Participation Year Aggregate EHR Amount Percentage Payment Amount Year 1 $2,102,483 50% $1,051, Year 2 $2,102,483 40% $840, Year 3 $2,102,483 10% $210,

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24 All Hospitals must register via the CMS s National Level Repository (NLR) Information Hospitals will need: CMS Identity and Access Management (I&A) User ID and Password CMS Certification Number (CCN) National Provider Identifier (NPI) Hospital Tax Identification Number For information on what will be required during registration go to: sp Registration Types Medicaid Only Medicare Only Medicare and Medicaid (Dually Eligible Hospitals) If at any time plan to participate in both programs then Hospital should register for both a the time of initial registration This is true even if for the first year the Hospital only plans to do A, I, U for Medicaid 24

25 Targeted to be ready Summer 2011 To access the portal Hospitals must: Be a certified Wisconsin Medicaid Provider (no sanctions, currently licensed) Have a ForwardHealth Provider Portal Account 25

26 In Participation Year 1 Hospitals can AIU certified EHR technology or demonstrate MU for Medicaid Medicaid Only Hospital Report all information (both AIU and MU) to the Wisconsin Medicaid Agency through the ForwardHealth Portal Dually Eligible Hospital Adopt, Implement, or Upgrade Report all information to Wisconsin Medicaid Agency through the ForwardHealth Portal Meaningful Use Medicaid Attestations Report to the Wisconsin Medicaid Agency through the ForwardHealth Portal Hospital Payment Calculation Data - Report to the Wisconsin Medicaid Agency through the ForwardHealth Meaningful Use Criteria - Report to CMS through the NLR Dually Eligible Hospitals demonstrating MU will need to submit to Medicare prior to requesting payment from the Wisconsin Medicaid Agency Hospitals deemed eligible by CMS will automatically be deemed eligible by the Wisconsin Medicaid Agency 26

27 Information will be evaluated by Medicaid, if Hospital meets the criteria the Hospital will be approved for a Medicaid EHR incentive payment Medicaid will inform the NLR of the payment made to the Hospital to update the Hospital s NLR record Payments will be processed and distributed through Electronic Fund Transfer (EFT) If Hospital does not currently have EFT established, one will need to be established before requesting payment 27

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29 Certified EHR technology available and listed on ONC website APRIL 2011 Attestation for the Medicare EHR Incentive Program begins Registration and attestation for Wisconsin Medicaid EHR Incentive Program begins NOVEMBER 30, 2011 Last day for eligible hospitals and CAHs to register and attest to receive an Incentive Payment for FFY 2011 Last year to initiate participation in the Medicare EHR Incentive Program Last year to receive a Medicare EHR Incentive Payment Last year to initiate participation in Medicaid EHR Incentive Program FALL 2010 WINTER 2010/2011 SPRING 2011 SUMMER 2011 FALL 2011 WINTER 2011/ JANUARY 3, 2011 Registration for the Medicare EHR Incentive Program begins MAY 2011 Medicare EHR Incentive Payments begin Wisconsin Medicaid EHR Incentive Payments begin Medicare payment adjustments begin for EPs and eligible hospitals that are not meaningful users of EHR technology Last year a Hospital can receive a Medicaid EHR Incentive Payment from Wisconsin 29

30 Questions? Medicaid EHR Incentive Program NLR Registration ONC list of Certified EHR Technology ListServe Register your to subscribe to updates on the Medicaid EHR Incentive Program: Wisconsin Health Information Technology Extension Center 30

31 Questions? 31