PREPARING FOR EMR PROGRAM SUCCESS IN 2016 12/10/2015. December 15, 2015. Travis Skinner, CPA Senior Managing Consultant tskinner@bkd.



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PREPARING FOR EMR PROGRAM SUCCESS IN 2016 December 15, 2015 Travis Skinner, CPA Senior Managing Consultant tskinner@bkd.com Michael Orr, CPA Director morr@bkd.com David McDonald, CPA Director dmcdonald@bkd.com Rhys Gay Sales Leader, Cerner Rhys.Gay@Cerner.com 1

TO RECEIVE CPE CREDIT Participate in entire webinar Answer polls when they are provided If you are viewing this webinar in a group Complete group attendance form with Title & date of live webinar Your company name Your printed name, signature & email address All group attendance sheets must be submitted to training@bkd.com within 24 hours of live webinar Answer polls when they are provided If all eligibility requirements are met, each participant will be emailed their CPE certificates within 15 business days of live webinar ACRONYM MEANINGS 2

TODAY S AGENDA Finalized 2015 EHR Modification Rule New Measures & Objectives Eligible Hospitals (EHs) Eligible Professionals (EPs) EHR Audits Federal OIG Pre/Post-Payment Medicaid HITECH Tentative/Final Settlements Meaningful Use Audits STAGE 3 REGULATIONS Snippets from Stage 3 Stage 3 will focus on improving health care outcomes & further advance interoperability CMS plans to propose changes to the reporting period, timelines, & 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 & reduce confusion stemming from multiple stage requirements 3

FINALIZED 2015 EHR MODIFICATION RULE Finalized rule was published on October 6 & is based on Elevating patient-centered care Improving health outcomes Supporting providers who care for patients Delay for rule was due to combining of three proposed rules Office of the National Coordinator for Health Information Technology (ONC) Rule Stage 3 Meaningful Use Rule 2015 Modification Rule 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 & after will now be calendar year Modified other aspects of programs Alternative exclusions & specifications for Stage 1 & Stage 2 4

STAGE OF MEANINGFUL USE CRITERIA BY FIRST YEAR Centers for Medicare & Medicaid Services- CMS.gov 10 OBJECTIVES FOR 2015-2017 (MODIFIED STAGE 2 - EPS) 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 5

MODIFYING OTHER ASPECTS OF PROGRAMS FOR EPS Major changes approved Secure messaging Changed from 5% to having fully enabled capability for patients to send/receive a secure electronic message with EP during 2015 EMR reporting period Health Information Exchange (old summary of care) Did away with original Measure 1 (provide a summary of care record for more than 50% of transitions & referrals) Did away with original Measure 3 (conduct one or more successful electronic exchanges or conduct one or more successful tests with CMS designated test EMR) Now must use CEHRT to create a summary of care record & electronically transmit such summary to a receiving provider for more than 10% of transitions of care & referrals Patient portal Changed second measure from 5% to at least one patient Public health reporting Immunizations registries Syndromic surveillance Specialized registries From ongoing submission to active engagement Completed registration Testing & validation Production 9 OBJECTIVES FOR 2015-2017 (MODIFIED STAGE 2 - EHS) 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 6

MODIFYING OTHER ASPECTS OF PROGRAMS FOR EHS Major changes approved Health Information Exchange (old summary of care) Did away with original Measure 1 (provide a summary of care record for more than 50% of transitions & referrals) Did away with original Measure 3 (conduct one or more successful electronic exchanges or conduct one or more successful tests with CMS designated test EMR) Now must use CEHRT to create a summary of care record & electronically transmit such summary to a receiving provider for more than 10% of transitions of care & referrals Patient portal Changed second measure from 5% to at least one patient Public health reporting Immunizations registries Syndromic surveillance Specialized registries Electronic reportable lab results From ongoing submission to active engagement Completed registration Testing & validation Production EMR AUDITS Federal OIG audits HUGE PROBLEMS nationwide Significantly more payables than receivables Coming to your state sooner than later Medicaid Pre-payment audits (Third-party EMR vendor implementing program) Post-payment audits (Third-party EMR audit contractor) 7

EMR AUDITS HITECH audits Jurisdictional Medicare Administrative Contractors (MAC) In-house, on-site or desk review Will receive audit on every cost report that settles a program year Meaningful Use audits Figliozzi & Co. ALL or NOTHING penalty Failing one year puts ALL years at RISK Medicaid payments tied to MU at RISK as well RESOURCES 12 THINGS YOU NEED TO KNOW: FINAL 2015 EMR MODIFICATION RULE FOR ELIGIBLE HOSPITALS 12 THINGS YOU NEED TO KNOW: FINAL 2015 EMR MODIFICATION RULE FOR ELIGIBLE PROFESSIONALS Archived Webinar: What Just Happened to the EMR Program? Articles It s Time to Attest to Program Year 2015 Are You Ready? The Next Round of Eligible Hospital Meaningful Use Audits Have Begun! 8

ON-TRACK IMPLEMENTATION STAGES Implementation Approach On Track Solutions for Software Implementation ON-TRACK IMPLEMENTATION STAGES STAGE 8 Post Implementation & Closing STAGE 1 Project Initiation STAGE 2 Proof of Concept STAGE 7 Cutover To Production STAGE 3 Project Definition STAGE 6 Acceptance Testing & Training STAGE 5 Delivery STAGE 4 Analysis & Design 9

Source: http://www.eostar.com/eostar/ IMPLEMENTATION MISCUES Not providing adequate training Not performing thorough testing Not validating data Not managing project or expectations Not addressing change management 10

Pieces for a Successful Selection Process People 11

Departmental Culture From: To: The way it s always been Its all about me Shift from Silo to Enterprise For the greater good How: Subject Matter Experts Super -Users Organizational Culture From: To: How: Missing Departmental Buy in Lack of a common vision Nonexistent Executive presence One Organization Quantity to Quality Care Executive Driven Project Themed Implementation Early Physician Involvement Dedicated Executive Champion 12

Questions to ask the Vendors How will you assist in Training? What are your strategies for complete staff buy in? How will you get our Physicians on board? How will you assist in augmenting/assisting our staff during the transition? Process 13

Refreshing your Policies and Procedures Do they align for an Electronic Environment? HIPAA Omnibus Rule Does the current way we do things make sense? Centralized v. Departmental Scheduling Centralized Electronic Inventory Clinician Communication Organizational Established Ordersets Realigning the Organization and Goals Allow every department a chance to give input in the evaluation Evaluate the Organization Hierarchy Treat IT as a strategic asset 14

Questions to ask the Vendors Do you have assigned strategists on our project (and are they clinical or financial)? How much guidance do you give us on your system standards versus flexibility? How many Clinicians do you employ? To what HIMSS Level will we be automated? Technology 15

Hardware Uninterrupted Connectivity Effective Application Management Best application hosting six years in a row Software Fast, easy and smart across devices Optimized for specialties 16

Warmware One truly integrated platform and a partner that can scale to match your business strategies and growth rate. Questions to ask the Vendors If hosted, do you do the hosting or do you leverage a 3 rd party? Also, will you guarantee that hosting? How much have you invested in your current platform and how much do you invest annually? Do you have an ED, Inpatient, and Clinic Product, and are they built on the same database? In what percent of the Acute facilities in the US are you the core EMR? In what percent of the Ambulatory Clinics in the US are you the EMR? How many net clients have you gained or lost in the last 12 months? How many employees do you have? How are you willing to go at risk for your product? 17

QUESTIONS? CONTINUING PROFESSIONAL EDUCATION (CPE) CREDITS BKD, LLP is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.learningmarket.org. The information in BKD webinars is presented by BKD professionals, but applying specific information to your situation requires careful consideration of facts & circumstances. Consult your BKD advisor before acting on any matters covered in these webinars. 18

CPE CREDIT CPE credit may be awarded upon verification of participant attendance For questions, concerns or comments regarding CPE credit, please email the BKD Learning & Development Department at training@bkd.com THANK YOU! FOR MORE INFORMATION Travis Skinner 254.776.8244 tskinner@bkd.com Michael Orr 254.776.8244 morr@bkd.com David McDonald 816.221.6300 dmcdonald@bkd.com Rhys Gay rhys.gay@cerner.com 19

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