Facts and Myths of Meaningful Use

Transcription

1 Facts and Myths of Meaningful Use Facts and Myths of Meaningful Use Facts and Myths of Meaningful Use on-demand webinar: To view the webinar, please go to: meaningful-use. These questions were answered by the EHR Incentive Program experts at Henry Schein together with the representatives of the Centers for Medicare and Medicaid Services. For additional information, visit and enter EHR Incentive Programs 1. Q: So what is exactly the formula for computing the 30%? Is it based on Medicaid patients encounters divided by total patient encounters in the clinic? A: Generally stated, Medicaid encounters must comprise at least 30% of the eligible professional s total encounters during a period of 90 consecutive days in the calendar year previous to the calendar year for which the provider is attesting to having met program requirements. To show that EPs are meeting the 30% Medicaid patient volume threshold (or 30% needy individual patient volume threshold if the EPs are practicing predominantly in an FQHC or RHC), States propose one or more methods of calculating patient volume to CMS, and States have to identify verifiable data sources available to the provider and/or the State. Please contact your State Medicaid Agency for more information on how your State is calculating patient volume. 2. Q: In a group where some offices have less than or no Medicaid and other offices have more than 30% can those offices with <30% apply? A: You would have to have the average of the groups be at least 30% Medicaid patient volume, or else only the eligible professionals whose individual Medicaid patient volume is at least 30% would be able to qualify for an incentive. You would have to talk to your State about how they would define a group. A group with multiple sites of practice can combine to meet the requirement. A group can use the combined average of the group to meet the 30% Medicaid threshold if they all agree to it even if, as individuals, they do not qualify for the threshold. 3. Q: A/I/U stands for what again? A: Adopt, Implement, Upgrade. According to the CMS website, Medicaid eligible professionals must adopt, implement, upgrade to or demonstrate meaningful use of certified EHR technology in the first year of participation, and successfully demonstrate meaningful use in subsequent participation years. For more information visit the Medicare and Medicaid EHR Incentive Program Basics. 4. Q: We would like also to hear something about how dental schools services are accounted? A: Dental schools themselves are not eligible for incentives under the Medicaid EHR Incentive Program. Individual dentists may be eligible based upon meeting all the eligibility criteria, including having 30% Medicaid patient volume (or 30% needy individual patient volume if they practice predominantly in an FQHC or RHC). Dentists who see Medicaid patients at dental schools can count those services/ encounters toward 30% Medicaid patient volume threshold.

2 5. Q: We are a large Indian Health Service dental clinic and have just implemented the EDR. We ve been told that in order to participate in MU, we will have to implement the EHR also. Is that your understanding? A: In Stage One, Year One, any organization simply needs to adopt, implement or upgrade to a certified EHR. That means that the organization just needs to acquire the certified EHR and demonstrate a financial or legal commitment to the EHR. In Stage One Year Two and beyond, the eligible providers at the organization do need to demonstrate meaningful use of the certified EHR in order to continue receiving incentive payments under the Medicaid EHR Incentive Program. 6. Q: How is the 30% proportion of services to Medicaid patients measured? Visits, RVUs, charges? A: The 30% Medicaid patient volume threshold is calculated using encounters. There are multiple definitions of encounter in terms of how it applies to the requirements for patient volume. Generally stated, a patient encounter is any one day where Medicaid paid for all or part of the service or Medicaid paid the co-pays, cost-sharing, or premiums for the service. In general, the same concept applies to needy individuals. Please contact your State Medicaid agency for more information on which types of encounters qualify as Medicaid/needy individual patient volume. 7. Q: And what happens if I demonstrate compliance in the first two years of Stage 1, but I do not comply in the third year of stage I? Do I have to refund the money for the first two years? A: No! The Medicaid EHR Incentive Program is a voluntary program and any participation earns you the funding that you received. You could participate in just Stage 1 and get the funding and then stop attesting. 8. Q: If a provider attested to AIU in 2012 then 90 days in 2013 they would need to then have a full year of MU in 2014 before they can attest to Stage Two which would be (then for them) 2015? A: Providers do not need to attest for each stage in consecutive years in order to qualify. They do need to follow the stages as they move through the program. That means that they could attest to A/I/U in 2012, then skip a year and attest to 90 days in 2014 and the full year in Once they have passed through all of the steps in Stage One, they can attest for Stage Two. In order to receive the full potential incentive payments, an eligible professional would need to begin the Medicaid EHR Incentive Program by Q: Is Dentrix Enterprise a certified EHR? A: No. Dentrix Enterprise is currently in the process of adding the necessary features to become a fully certified EHR. We plan to have that full certification by the middle of In the meantime, Dentrix Enterprise Meaningful Use Access is a fully certified EHR that can be purchased to enable a provider to qualify for the Stage One Year One requirement of A/I/U. 2 Meaningful Use Questions & Answers

3 10. Q: Our non-profit clinic provides care to FQHC patients under a contract with our local FQHC. Would we qualify for the FQHC rules regarding using the needy individual patient volume to qualify? A: Yes! The Social Security Act at section 1905(l)(2) defines an FQHC as an entity which, (i) is receiving a grant under section 330 of the Public Health Service Act, or (ii)(i) is receiving funding from such a grant under a contract with the recipient of such a grant and (II) meets the requirements to receive a grant under section 330 of the Public Health Service Act, (iii) based on the recommendation of the Health Resources and Services Administration within the Public Health Service, and is determined by the Secretary to meet the requirements for receiving such a grant including requirements of the Secretary that an entity may not be owned, controlled, or operated by another entity; or (iv) was treated by the Secretary, for purposes of Part B of title XVIII, as a comprehensive Federallyfunded health center as of January 1, 1990, and includes an outpatient health program or facility operated by a tribe or tribal organization under the Indian Self-Determination Act or by an urban Indian organization receiving funds under Title V of the Indian Health Care Improvement Act for the provision of primary health services. 11. Q: You stated that there are no certified dental vendors, yet the last slide indicated that Henry Schein is certified? Please explain? A: While there are a few dental vendors that provide certified EHR options for their customers (such as Henry Schein), there is no certifying standard specifically for electronic dental records. The certifying standard applies to electronic health records generally. 12. Q: Are there a minimum number of hours a Dentist needs to work to qualify as an EP for Meaningful Use (we are an FQHC)? A: No! The FQHC just needs to attest to seeing a minimum of 30% of needy individuals in order to qualify for the incentive. 13. Q: When are MU workflows anticipated to be released to providers? Will these be available with the update? A: For Dentrix Enterprise customers interested in working with us as we develop this functionality, please contact support to sign up at Q: The certification web site shows Version 7.6 of Dentrix Enterprise is certified for Meaningful Use is that correct? A: No! You ll notice that the certification website actually shows that version 7.6 of Dentrix Enterprise Meaningful Use Access is certified for Meaningful Use. This is actually a completely different product than Dentrix Enterprise and actual utilization of the product would require double entry of information. We recommend Dentrix Enterprise Meaningful Use Access to organizations who would like to attest for Stage One, Year One criteria immediately and then speak with a Henry Schein representative at to determine their long term plan for meeting subsequent stages. 15. Q: Is Dentrix completely certified as a standalone EDR or is only certified with another EDR? A: No! You ll notice that the certification website actually shows that version 7.6 of Dentrix Enterprise Meaningful Use Access is certified for Meaningful Use. This is actually Meaningful Use Questions & Answers 3

4 a completely different product than Dentrix Enterprise and actual utilization of the product would require double entry of information. We recommend Dentrix Enterprise Meaningful Use Access to organizations who would like to attest for Stage One, Year One criteria immediately and then speak with a Henry Schein representative at to determine their long term plan for meeting subsequent stages. 16. Q: Has there been any information or documentation regarding which measures dentists typically qualify for with regards to Stage One MU criteria for Y2 Medicaid incentives? A: To date, most dentists that have received incentives have done so under the Medicaid EHR Incentive Program for adopting, implementing, or upgrading to certified EHR technology (AIU), so it is difficult to assess at this point in the EHR Incentive Programs which Stage 1 Meaningful Use core and menu measures are most accessible for dentists. Even though most Stage 1 Meaningful Use measures are oriented towards acute-care rather than oral health, 13 of the 25 core and menu measures do have exclusion criteria, so it is up to the dentist to determine whether s/ he meets the exclusion criteria for each objective. 17. Q: They may not understand encounters please explain encounter = what? A: There are multiple definitions of encounter in terms of how it applies to the requirements for patient volume. Generally stated, a patient encounter is any one day where Medicaid paid for all or part of the service or Medicaid paid the co-pays, cost-sharing, or premiums for the service. In general, the same concept applies to needy individuals. Please contact your State Medicaid agency for more information on which types of encounters qualify as Medicaid/needy individual patient volume. 18. Q: 30% encounters for Medicaid patients even if a specific encounter is not covered by Medicaid but is provided to a Medicaid patient? A: As described in the Stage 1 EHR Incentive Programs final rule, a valid encounter for the purposes of calculating an eligible provider s Medicaid patient volume is one where Medicaid has payment liability for the service. So under the current rule, if a service is provided to a Medicaid patient even though Medicaid does not cover that service, then provision of that service cannot be considered a valid encounter towards an eligible provider s Medicaid patient volume threshold for the Medicaid EHR Incentive Program. But stay tuned for revisions to this definition of encounter under the Stage 2 EHR Incentive Programs rule. 19. Q: When you say access to a certified EHR system, what is access? We have a medical certified EHR system. Do the dentists need log in access, so that they can view their patient on the medical certified system, does this qualify? A: Yes. If a provider has a certified EHR in their clinic and the ability to access that record, they qualify for the Stage One, Year One incentive payment according to A/I/U. If they were to attest to meaningfully using the EHR for Year Two and beyond, they would need to log in and actually use the software. For A/I/U, the dentists would need to have a financial or legal commitment to that EHR such as a provider license to use the EHR. 4 Meaningful Use Questions & Answers

5 20. Q: Hello, I am a dental director at a FQHC. What is the definition for 30% needy? Is it based off the federal poverty guidelines? A: Needy individuals are persons meeting any of the following criteria: (1) They are receiving medical assistance from Medicaid or the Children s Health Insurance Program (CHIP); (2) they are furnished uncompensated care by the provider; or (3) they are furnished services at either no cost or reduced cost based on a sliding scale determined by the individual s ability to pay. So encounters with persons receiving care at an FQHC under any of the circumstances described above count towards the 30% needy individual patient volume of an eligible provider who is practicing predominantly at the FQHC. 21. Q: This is a lot of money pouring out of a Federal Program. Is this potentially all in jeopardy if the Supreme Court strikes down the ACA? A: The CMS feels very safe with the program. There is no indication that the federal government would reduce or eliminate this program. Please see the extended answer on the webinar recording. 22. Q: We are current Dentrix Enterprise users, would you please discuss the MU Access product and how it works? A: Dentrix Enterprise Meaningful Use Access is a fully certified EHR. An organization simply needs to meet the A/I/U standard for Stage One, Year One of the Medicaid EHR Incentive Program in order to receive the first year of funding. By obtaining Dentrix Enterprise Meaningful Use Access, an organization will meet those criteria. As we mentioned before, Dentrix Enterprise is currently working for full certification by mid Q: In an FQHC, will the 30% have to be broken down by providers or as a whole? A: Eligible professionals who practice predominantly at an FQHC may use the FQHC s patient volume as a proxy for their own under three conditions: 1) The FQHC s patient volume is appropriate as a patient volume methodology calculation for the eligible professional (for example, if an eligible professional only sees Medicare, commercial, or self-pay patients, this is not an appropriate calculation); 2) There is an auditable data source to support the FQHC s patient volume determination; and 3) So long as the FQHC and eligible professionals decide to use one methodology in each year (in other words, FQHCs could not have some of the eligible professionals using their individual patient volume for patients seen at the FQHC, while others use the FQHC-level data). The FQHC must use the entire practice s patient volume and not limit it in any way. Eligible professionals may attest to patient volume under the individual calculation or the FQHC proxy in any participation year. Furthermore, if the eligible professional works in both the FQHC and outside the FQHC (or with and outside a group practice), then the FQHC-level determination includes only those encounters associated with the FQHC. 24. Q: The Schein EHR products are listed as EHRs. What is the difference between EDR and EHR? What if DDS has an EDR that is not Schein? Is Schein interoperable? Meaningful Use Questions & Answers 5

6 A: The Meaningful Use Access products are all fully certified EHRs (electronic health records). However, in order to purchase one of these products, an organization must already have a Henry Schein practice management software. However, if the dental group that uses a Schein practice management software is part of an organization that has an existing, certified EHR, they do not need to purchase an additional product to meet Stage One, Year One criteria. 25. Q: Is Enterprise version 6 certified as a stand-alone EHR? If one uses an certified EHR for stage 1, Can you use Dentrix Enterprise Version 6 to meet stage 2 MU? A: Dentrix Enterprise 6.0 is not a certified EHR. However, Dentrix Enterprise is currently programming the upgrades necessary to be certified. We anticipate that release to be mid-2013 which is plenty of time for an eligible provider to begin the attestation process to receive the full Medicaid program payout. 26. Q: EHR can be medical or dental, correct? A: EHR stands for electronic health record so technically, it could be either medical or dental. However, the current EHR certification process is focused on general practice medicine and has no dental specific criteria. There is no certifying process for an EDR electronic dental record. 27. Q: I have read only tobacco and BP will apply to DDS MU criteria. Isn t it true that most of MD MU criteria are not part of normal DDS practice? A: It is true that many of the Stage 1 Meaningful Use core and menu measures (and the clinical quality measures) are more applicable to acute-care providers than to dentists. However, dentists and other non-acute care providers can be excluded from having to meet several of the Stage 1 Meaningful Use measures that are not applicable to their practices. 28. Q: Which Version of Dentrix Enterprise will be meeting the meaningful use criteria in order to meet the standards for phase 1, 2nd year? A: We are anticipating that Dentrix Enterprise 7.0 will meet the standard for Stage One, Year Two and beyond. 29. Q: We have had Dentrix Enterprise for well over 365 days. If the software wasn t certified during that time, would we be eligible for A: Dentrix Enterprise is not a certified EHR at this time. In order to meet the Stage One, Year One criteria, an organization must adopt, implement or upgrade to a certified EHR. Dentrix Enterprise is currently programming the requirements necessary to be fully certified and expect this to release in mid You can begin the EHR Incentive Program under the Medicaid path at any time until 2016 in order to take advantage of the full funding opportunity. 30. Q: Also, is Dentrix Enterprise working towards Complete or Modular Certification? A: Dentrix Enterprise is working toward complete certification. 6 Meaningful Use Questions & Answers

7 31. Q: Re group practice comments made by John... will those individual DDS apply as individuals and each receive a payment? A: Individual eligible professionals, rather than groups or clinics, apply for incentives under the Medicaid EHR Incentive Program. As eligible professionals, dentists can reassign their incentive payment to their employer or to an entity with which they have a contractual arrangement allowing the employer or entity to bill and receive payment for the EP s covered professional services. 32. Q: When do we expect to have Dental Specific Criteria in place? A: Under Stage 2 of the EHR Incentive Programs, CMS is planning to include several clinical quality measures that are relevant to oral health. CMS expects to release the Stage 2 EHR Incentive Programs final rule in late-summer For those providers who began participating in the EHR Incentive Programs in 2011 or 2012, Stage 2 of the programs will begin in Q: Does ownership in the practices matter? Can an associate/employee provider qualify as an EP? Or is this just for owner EP s? A: No. Any provider that meets the definition of an eligible professional can qualify for the payment. 34. Q: Does it matter if the provider is full or part time? A: No. Even a part-time provider can meet the criteria. 35. Q: If some individual dentists in the practice have >30% MCD volume, but the group average is less than 30%, can those individuals be eligible for the incentive payments? A: Yes, individual dentists that meet the 30% Medicaid patient volume requirement can qualify for an incentive under the Medicaid EHR Incentive Program based on their individual Medicaid patient volume, even if they are members of a practice or group that doesn t have a practice-wide average of 30% Medicaid patient volume. Additionally, the individual dentists would have to meet all other eligibility criteria to qualify for an incentive (e.g., adopted a certified EHR, not be hospital-based, etc). 36. Q: How do you handle a certified EHR that is integrated with Dentrix? A: If a provider already has access to a certified EHR that is integrated with Dentrix Enterprise, those providers can meet the Stage One, Year One criteria to be eligible without purchasing any additional product as long as they meet the other eligible professional requirements. 37. Q: Can you please address any available (or expected releases) of Dentrix workarounds to meet MU for the Year 2 90 day EHR reporting period (in 2012) for group/clinic providers that already attested in 2011? A: We are currently programming the necessary requirements into Dentrix Enterprise to be a fully certified EHR by the middle of If you have additional questions, please contact a Henry Schein representative at Meaningful Use Questions & Answers 7

8 38. Q: Are volunteer providers eligible to participate in the Medicaid incentive program, assuming 30% group volume reporting is met? A: Yes. Like any Medicaid eligible provider, a volunteer provider may use a clinic or group practice s patient volume as a proxy for their own under three conditions: 1) The clinic or group practice s patient volume is appropriate as a patient volume methodology calculation for the EP (for example, if an EP only sees Medicare, commercial, or self-pay patients, this is not an appropriate calculation); 2) There is an auditable data source to support the clinic s patient volume determination; and 3) So long as the practice and EPs decide to use one methodology in each year (in other words, clinics could not have some of the EPs using their individual patient volume for patients seen at the clinic, while others use the clinic-level data). The clinic or practice must use the entire practice s patient volume and not limit it in any way. EPs may attest to patient volume under the individual calculation or the group/clinic proxy in any participation year. The volunteer provider would have to meet all other eligibility criteria as well (e.g., has adopted a certified EHR, is not hospital-based, etc.) in order to qualify for an incentive under the Medicaid EHR Incentive Program. 39. Q: If a dentist worked for us during the previous calendar year but has recently moved to another practice. Are we able to secure the incentive for the previous year that he was with us? A: No. Since EHR Incentive Program payments are per doctor and not per practice, the doctor would be eligible to receive the payment. Organizations who would like to receive the payment in the doctor s stead would be required to have some kind of agreement with that doctor. Individual eligible professionals, rather than groups or clinics, can qualify for incentives under the Medicaid EHR Incentive Program. As eligible professionals, dentists can reassign their incentive payment to their employer or to an entity with which they have a contractual arrangement allowing the employer or entity to bill and receive payment for the EP s covered professional services. Another issue that this question raises concerns incentives for a previous calendar year. All State Medicaid EHR Incentive Program attestation tails for 2011 have closed, so presently an eligible professional could qualify for an incentive only for Calendar Year 2012 and future years. 40. Q: What are the measures that CMS will approve the EXCLUSIONS for? A: The CMS EHR Incentive Programs website has downloadable Stage One Meaningful Use Specification Sheets that show applicable exclusions (if any) for each meaningful use core and menu measure. The Specification Sheets can be found on the website by clicking on the CMS EHR Meaningful Use Overview tab, and scrolling down to the Downloads section of the tab Henry Schein Inc. Henry Schein Practice Solutions makes no representations or warranties with respect to the contents or use of this documentation, and specifically disclaims any express or implied warranties of title, merchantability, or fitness for any particular use. All contents are subject to change. Third party products, logos, trademarks or registered trademarks are the property of their respective owners. C-MUFAQ-q312