WHAT S NEW ON THE EHR FRONT?

Transcription

1 WHAT S NEW ON THE EHR FRONT? Mike Orr, Director Travis Skinner, Senior Managing Consultant

2 TODAYS AGENDA Finalized 2015 EHR Modification Rule (EHs & EPs) New Measures & Objectives EHR Tentative Settlement Letters HITECH Payment Audits Medicaid EHR Audits Meaningful Use Audits / SRA guidance / Flexibility Rule

3 Stage III Regulations Snippets from the Stage III public notice: Stage 3 will focus on improving health care outcomes and further advance interoperability. CMS plans to propose changes to the reporting period, timelines, and structure of the [EHR Incentive Program], including providing a single definition of meaningful use CMS intends to provide a flexible, yet, clearer framework to ensure future sustainability of the EHR program and reduce confusion stemming from multiple stage requirements.

4 Finalized 2015 EHR Modification Rule The Finalized rule was published on October 6th and is based on: Elevating patient-centered care Improving health outcomes Supporting the providers who care for patients The delay for the rule was due to the combining of the three proposed rules; the ONC Rule, Stage III Meaningful Use Rule, & the 2015 Modification Rule.

5 Finalized 2015 EHR Modification Rule Major Changes approved: Program year 2015 is now any continuous 90 day reporting period Program year 2015 will be 15 months 10/01/2014 to 12/31/2015 Attestation window for Program year 2015 is 01/04/2016 to 2/29/2016 Program year 2016 and after will now be a calendar year Modified other aspects of the programs Alternative Exclusions & Specifications for Stage 1 & Stage 2

6 1 st Year Stage of Meaningful Use TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD

7 NPRM FROM 2014 CMS Flexibility & ONC Rule Schedule

8 8 // experience ideas

9 Modifying other aspects of the programs for EPs Major Changes approved For Stage 1: Previous Stage 1 EP Objectives: 13 Core Objectives 5 of 9 Menu Objectives EP Objectives for (Modified Stage 2) 10 Core Objectives

10 Modifying other aspects of the programs for EPs Major Changes approved For Stage 2: Previous Stage 2 EP Objectives: 17 Core Objectives 3 of 6 Menu Objectives EP Objectives for (Modified Stage 2) 10 Core Objectives

11 10 Objectives for (Modified Stage 2) Security Risk Analysis Clinical Decision Support CPOE eprescribing Health Information Exchange (Summary of Care) Patient Specific Education Medication Reconciliation Patient Electronic Access (VDT) Secure Messaging Public Health Reporting

12 Modifying other aspects of the programs for EPs Major Changes approved: Secure Messaging Changed from 5% to having fully enabled the capability for patients to send/receive a secure electronic message with the EP during 2015 EMR reporting period Patient Portal Changed the second measure from 5% to at least one patient Public Health Reporting Immunizations Registries Syndromic Surveillance Specialized Registries From On-going Submission to Active Engagement Completed Registration Testing & Validation Production

13

14 14 // experience ideas

15 15 // experience ideas

16 PQRS Penalty: PQRS & value based modifier penalties Didn t meet PQRS in % Medicare Fee Schedule penalty in 2015 Didn t meet PQRS in % Medicare Fee Schedule penalty in 2016 Didn t meet PQRS in % Medicare Fee Schedule penalty in // experience ideas

17 17 // experience ideas EP EHR Penalties STOP in 2018!!! Merit-Based Incentive Payment System!

18 Modifying other aspects of the programs for EHs Major Changes approved For Stage 1: Previous Stage 1 EH Objectives: 11 Core Objectives 5 of 10 Menu Objectives EH Objectives for (Modified Stage 2) 9 Core Objectives

19 Modifying other aspects of the programs for EHs Major Changes approved For Stage 2: Previous Stage 2 EH Objectives: 16 Core Objectives 3 of 6 Menu Objectives EH Objectives for (Modified Stage 2) 9 Core Objectives

20 9 Objectives for (Modified Stage 2) Security Risk Analysis Clinical Decision Support CPOE eprescribing Health Information Exchange (Summary of Care) Patient Specific Education Medication Reconciliation Patient Electronic Access (VDT) Public Health Reporting

21 Modifying other aspects of the programs for EHs Major Changes approved: Patient Portal Changed the second measure from 5% to at least one patient Public Health Reporting Immunizations Registries Syndromic Surveillance Specialized Registries Electronic Reportable Lab Results From On-going Submission to Active Engagement Completed Registration Testing & Validation Production

22 PPS PENALTIES

23 CAH PENALTIES

24 EHR TENTATIVE SETTLEMENTS

25

26 HITECH PAYMENT AUDITS (MAC) For every Medicare EHR incentive payment, every facility that receives an EHR incentive payment will have one of three audits on their cost report: Desk review In-House Audit On-Site Audit

27 HITECH PAYMENT AUDITS (MAC) Positive Adjustment Opportunities Part C Days Total Days Charity Care Presumptive Charity Care Policy Review

28 Pre/Post Payment Medicaid EHR Audits OIG has these EHR post-payment audits as a high priority through 2018 Positive Adjustment Opportunities Potential missing Medicaid days Incorrect reporting period used for payment calculation Total Days (including hospice days, employee days, Part B days, etc.) Be alerted to potential overpayments for things like unpaid days and bad debts being included with Charity care

29 EHR MEANINGFUL USE AUDITS (FIGLIOZZI) Worked on program years 2011, 2012 and and /or Stage II audits have yet to begin The audit protocol for Stage II audits has yet to be released Still auditing a minimum of 5% of the nations Meaningful Users ALL or NOTHING penalty Including Medicare & Medicaid incentive payments

30 Flexibility Final rule Allowed facilities to attest to a lower level of criteria than the facility was scheduled to attest for Program Year 2014 No upfront checking of qualifications for appropriate use of the rule Check the radial button, put in an ONC certification number consistent with the lower level of criteria, and click a button saying you will maintain documentation supporting the facility s use of the Flexibility Rule for at least 6 years that s all that s required Documentation, Documentation, Documentation is the key

31

32 EHR MEANINGFUL USE AUDITS (FIGLIOZZI) Working with Figliozzi is easier than with CMS if facility fails. Can appeal Figliozzi failure with CMS One Bite at the Apple Submit only NEW evidence

33 33 // experience ideas KEY TAKE AWAYS FROM THIS PRESENTATION Program year 2015 is 15 months long ending 12/31/2015 with an any continuous 90 day reporting period, open window starts on 01/4/2016! Every participant that receives an interim payment will experience a HITECH audit! Medicaid recoupments are REAL and can be significant, don t go down without a fight! Use of the Flexibility Final Rule needs to be DOCUMENTED! MU Audit penalty is very REAL and the key is your documentation!

34 THANK YOU! // visit bkd.com or contact: FOR MORE INFORMATION Mike Orr // Director // ext Travis Skinner // Senior Managing Consultant // ext