Medicare & Medicaid EHR Incentive Programs Elizabeth S. Holland, MPA Director, HIT Initiatives Group Office of E-Health Standards & Services, CMS

Transcription

1 Medicare & Medicaid EHR Incentive Programs Elizabeth S. Holland, MPA Director, HIT Initiatives Group Office of E-Health Standards & Services, CMS

2 Program Progress

3 Registered Eligible Hospitals 5.33% 94.67% 4,993 Total Hospitals 4,727Registered Hospitals

4 Paid Eligible Hospitals 8.65% 91.35% 4993 Total Hospitals 4,561 Hospitals Paid

5 2014 Changes 1. EHRs Meeting ONC 2014 Standards as of 2014, all EHR Incentive Programs participants have to adopt certified EHR technology that meets ONC s Standards & Certification Criteria 2014 Final Rule 2. Reporting Period Reduced to Three Months to allow providers time to adopt 2014 certified EHR technology and prepare for Stage 2, all participants have a three-month reporting period in

6 Payment Adjustments, & Hardship Exceptions

7 Payment Adjustments Medicare payment adjustment for IPPS hospitals that are not meaningful users of certified EHR technology Begins in FY 2015 Applied to the hospital update Reduced by 25% in FY15, 50% in FY16 & 75% in FY17 (and beyond) Two year look-back: 2013 for for 2016 Hospitals that first demonstrate MU in FY 2014 must complete a 90- day reporting period in the first 9 months of 2014 to avoid a penalty in 2015 (July 1 attestation deadline) 7

8 Avoiding Payment Adjustments 1.) Infrastructure: Eligible hospital must demonstrate that they are in an area without sufficient internet access or face insurmountable barriers to obtaining infrastructure (e.g., lack of broadband) 2.) New Eligible Hospitals: Eligible hospitals with new CMS Certification Numbers that would not have had time to become Meaningful Users can apply for a limited exception to the payment adjustment. Limited to one full-year cost reporting period. 3.) Unforeseen Circumstances: Examples include a natural disaster. 4.) 2014 EHR Vendor Issues: The hospital s EHR vendor was unable to obtain 2014 certification or the hospital was unable to implement MU due to 2014 EHR certification delays. 8

9 Hardship Update Applications were accepted through April 1 st for the 2015 payment adjustment year 66 eligible hospitals applied and were accepted 3 applied late 6 were dismissed 9

10 Audits EPs, Subsection (d) Hospitals and CAHs

11 Audits Findings Security risk assessments Not meeting measure thresholds

12 Security Risk Analysis Security risk analysis is frequently missed by providers Use the CMS Security Risk Assessment fact sheet to ensure you meet measure vidersprofessionals/securityrisk-assessment

13 Audit Basics Any provider that receives an EHR incentive payment for either EHR Incentive Program may be subject to an audit Pre-pay and post-pay audits CMS, and its contractor, Figliozzi and Company, will perform audits on Medicare and dually-eligible (Medicare and Medicaid) providers who are participating in the EHR Incentive Programs States, and their contractor, will perform audits on Medicaid providers participating in the Medicaid EHR Incentive Program

14 Medicare Audits Medicare EPs and Dual-Eligible Hospitals Pre- and post-payment audits are performed 5-10% of providers subject to pre/post-payment audits Random audits and risk profile of suspicious/anomalous data If a provider continues to exhibit suspicious/anomalous data, could be subject to successive audits In order to ensure robust oversight, CMS will not be making the risk profile public

15 Medicare Documentation It is the provider s responsibility to maintain documentation Documentation to support attestation data for meaningful use objectives and CQMs should be retained for six years post-attestation Save any electronic or paper documentation that supports attestation, including documentation that supports values you entered in the Attestation Module for CQMs Hospitals should also maintain documentation that supports their payment calculations Medicaid providers can contact their State Medicaid Agency for more information about audits for Medicaid EHR Incentive Program payments

16 Primary Source Documentation Primary source document is usually the report generated by the provider s certified EHR technology Report should contain the following elements: - Numerators and denominators for the measures - Time period the report covers - Evidence to support that it was generated for that provider (e.g., identified by National Provider Identifier (NPI), CMS Certification Number (CCN), provider name, practice name, etc.) Snapshot vs. rolling reports

17 Documentation Guidance Stage 1 New: Stage 2

18 Audit Resources CMS EHR Incentive Programs Webpage: Supporting Documentation for Audits Sample Audit Letter for EPs Sample Audit Letter for Eligible Hospitals & CAHs Audit Overview Fact Sheet 18

19 Appeals

20 Audits & Appeals Misconceptions FEAR

21 Audits & Appeals Misconceptions No one outside of CMS or its audit contractor has special or privileged access to the audit or appeal process No one has been asked to consult with CMS or its audit contractor on the audit or appeal process No one has any specialized knowledge

22 Appeals

23 Appeals Appeals of failed audits If you did not respond to auditor, there is nothing to appeal Must be filed within 30 days of the demand letter to be considered & must submit documentation with the appeal

24 Appeals Appeal documentation = audit documentation Everything is public at

25 2014 progress As of June 15 th 84 hospitals have attested for were new participants 9 attested to Stage 2 25

26 Flexibility proposal CMS and ONC NPRM published on May 23 proposing 2014 CEHRT flexibility and extension of Stage 2 If finalized, the NPRM would: Allow providers to meet meaningful use with EHRs certified to the 2011 or the Edition criteria, or a combination of both Editions in 2014 Require providers to report using 2014 Edition CEHRT for 2015 EHR Reporting Period Extend Stage 2 through

27 Proposed Options : Stage 1 Proposed Options: Stage 1 Proposed options for providers scheduled to meet Stage 1 in CEHRT 2013 Definition Stage 1 objectives and 2013 CQMs 2011 & 2014 CEHRT 2013 Definition Stage 1 objectives and 2013 CQMs; or 2014 Definition Stage 1 objectives and 2014 CQMs 2014 CEHRT 2014 Definition Stage 1 objectives and 2014 CQMs 27

28 Proposed Options: Stage 2 Proposed options for providers scheduled to meet Stage 2 in CEHRT 2011 & 2014 CEHRT 2014 CEHRT 2013 Definition Stage 1 objectives and 2013 CQMs 2013 Definition Stage 1 objectives and 2013 CQMs; or 2014 Definition Stage 1 objectives and 2014 CQMs; or 2014 Definition Stage 2 objectives and 2014 CQMs 2014 Definition Stage 2 objectives and 2014 CQMs; or 2014 Definition Stage 1 objectives and 2014 CQMs 28

29 NPRM Comments NPRM Comments CMS and ONC now accepting public comment: Submit online through Regulations.gov: Deadline: July 21,

30 EHR Resources 1. CMS Stage 2 Webpage: Guidance/Legislation/EHRIncentivePrograms/Stage_2.html Stage 2 Overview 2014 Stage 1 Changes Payment Adjustments & Hardship Exceptions (EPs & Hospitals) CQM Webpage: Guidance/Legislation/EHRIncentivePrograms/2014_ClinicalQualityMeasur es.html 3. Audits: Guidance/Legislation/EHRIncentivePrograms/EducationalMaterials.html

31 For questions, please contact: Elizabeth S. Holland Director, HIT Initiatives Group Centers for Medicare & Medicaid Services