TennCare/Medicaid EHR Provider Incentive Program 2011 Quick History The HITECH Act (creating the EHR Incentive Program) is a part of the American Re-Investment and Recovery Act (ARRA) NOT the Affordable Care Act (ACA) of 2010. The EHR Incentive Program supports the adoption of Electronic Heath Records (EHRs) by Eligible Professionals (EPs) & Eligible Hospitals (EHs) by providing financial incentives to providers that implement and demonstrate meaningful use of certified EHR technology. Medicaid agencies like TennCare administer the distribution of the federally-funded Medicaid incentive payments to qualifying EPs & EHs that adopt federally-certified EHR technology (either complete systems or module(s)). 1 1
Quick History Medicare incentive payments will run from 2011-2016. 2014 is the last year for an EP to enter the program. 2015 is the last year for an EH to enter the program. TennCare s EHR Incentive Program will run from 2011 2021. 2016 is the last year to enter the program. 2 HITECH EHR Adoption: Goals and Objectives 1 2 3 4 5 Improve Quality, Safety, and Efficiency Engage Patients and Families Improve Care Coordination Improve Population and Public Health Ensure Privacy and Security Protections 3 2
TennCare/Medicaid and Medicare Incentives Available to Eligible Health Care Professionals & Hospitals For eligible professionals: TennCare/Medicaid : Pays up to $63,750 per eligible professional over 6 years (2011 2021) Medicare: Pays up to $44,000 per eligible professional over 5 years (2011-2016) Eligible professionals must choose between receiving TennCare/Medicaid or Medicare incentive payments. For eligible hospitals: Under both TennCare/Medicaid and Medicare, payments to eligible hospitals will be derived from a base payment of $2 million which is adjusted for total discharges and the applicable TennCare/Medicaid or Medicare share of case mix. Eligible hospitals may participate in both the TennCare/Medicaid and Medicare provider incentive programs. 4 Payments for Eligible Professionals TennCare/Medicaid Incentive Payments Medicare Incentive Payment Yearly Amount 5 3
What providers are eligible for TennCare/Medicaid incentive payments? An eligible professional for the TennCare/Medicaid incentive program must not be hospital-based and be one of the following provider types: Physician Dentist Certified Nurse-Midwife Nurse Practitioner Physician Assistant practicing in an FQHC or RHC led by a physician assistant In addition, to be eligible for the TennCare/Medicaid incentive, 30% of the eligible professional s patient encounters must be TennCare/Medicaid (20%, if the eligible professional is a pediatrician) or the eligible professional must practice predominantly in a Federally Qualified Health Center (FQHC) or Rural Health Center (RHC) and have a minimum of 30% patient encounters attributable to needy individuals. Information on health care professional eligibility for the Medicare incentive program can be found at www.cms.gov/ehrincentiveprograms. 6 What providers are eligible for TennCare/Medicaid incentive payments? For Hospitals: An eligible hospital for the TennCare/Medicaid incentive program must be: An Acute Care Hospital (which includes Critical Access Hospitals) with at least 10% Medicaid patient volume A Children s Hospital (which does not have a minimum Medicaid population requirement) Information on hospital eligibility for the Medicare incentive program can be found at www.cms.gov/ehrincentiveprograms. 7 4
EHR Adoption and Meaningful Use Requirements Adopt, implement, or upgrade certified EHR technology (Year One) In order to receive a first year payment in 2011 through the TennCare /Medicaid EHR Provider Incentive Program, EPs & EHs must demonstrate that they have adopted, implemented, and/or upgraded certified EHR technology. Information on certification and certified EHR technology can be found at the Office of the National Coordinator for Health IT website (http://healthit.hhs.gov) or through the Bureau s EHR Provider Incentive page - http://www.tn.gov/tenncare/pipregistration.html Meet meaningful use criteria (Years 2-6) In subsequent payment years in the TennCare/Medicaid incentive program, EPs & EHs must prove they are using the EHR system in a meaningful way by meeting federally-designated meaningful use criteria Stage 1 Rules have been promulgated by CMS - Capture data electronically in a structured format - Implement decision support tools - Engage patients in their care - Public Health and Quality Reporting Stages 2 & 3 Rules to be promulgated by CMS at a later date - Enhanced focus on health information exchange (HIE) - Demonstrated improvements in quality of care and patient access 8 Applying for the EHR Incentive Program The first step in applying for an EHR Incentive Payment as either an Eligible Professional or an Eligible Hospital is to officially register on the CMS Medicare & Medicaid EHR Incentive Program Registration and Attestation website http://www.cms.gov/ehrincentiveprograms/10_pathtopayment.asp At the conclusion of the registration process, you will be given a registration number. Either print that page or write down the number or both! If you need to go back to the Medicare & Medicaid EHR Incentive Program Registration and Attestation website to make a change, you will need that registration number to access your profile. If you need to make changes to your Medicare & Medicaid EHR Incentive Program Registration and Attestation website registration, make sure to go all the way through the process until you reach the Submit button. Failure to click on the Submit button may result in your change not being accepted and forwarded to TennCare. 9 5
What happens after I enroll on the Medicare & Medicaid EHR Incentive Program Registration and Attestation site? CMS will forward your registration information to the Bureau of TennCare. Once received, TennCare will review your information and check To make sure that you are alive! That you have a Healthcare Professional License That you have a Tennessee Medicaid Provider ID Number That you do not have any sanctions against you preventing you from participating in the Medicare/Medicaid programs. Following TennCare s review, you will receive a notice Of acceptance of your registration; or Of denial and why your registration was denied. Some problems can only be corrected by going back to the Medicare and Medicaid Incentive Program Registration and Attestation System website. We may be able to help with other problems. TennCare will also notify CMS of the outcome of our review (usually within 24 48 hours) 10 If Your Registration is Accepted The acceptance notice you receive will tell you that we expect to have our Provider Attestation Portal open by the end of March. When it opens, you will be able to use the portal to provide on-line attestation to adopting, implementing, or upgrading to certified EHR technology. You will be requested to provide information on your Medicaid and total patient volume. Or if applying through an FQHC/RHC, the Needy Individual volume is used rather than Medicaid. For additional information, go to http://www.tn.gov/tenncare/pipregistration.html Want to keep up with the latest information? Enroll to receive TennCare s E-Blast newsletter. To subscribe to this free service, go to http://www.tn.gov/tenncare/medicaidhitemail.html 11 6
TennCare/Medicaid Electronic Health Record (EHR) Provider Incentive Program For more information about TennCare s EHR Provider Incentive Program, visit www.tn.gov/tenncare/hitech On this website you can learn more about the EHR Provider Incentive Program and register to receive additional information as it becomes available. 12 TennCare/Medicaid Electronic Health Record (EHR) Provider Incentive Program Already registered? Additional information can be found on this website: http://www.tn.gov/tenncare/pipregistration.html 13 7
Brief Introduction to Application & Attestation Section 1 Basic Provider Information Section 2 Certified Electronic Health Record Technology Section 3 Attestation of Medicaid Patient Volume for an Individual Provider Section 4 Attestation of Medicaid Patient Volume for a Group Practice or Clinic Section 5 Substitute W-9 Section 6 Automated Clearing House Direct Payment to You 14 EHR Provider Incentive Program Overview 1 Providers or Hospital Registers for Incentive Program with CMS. 2 CMS sends Registration to TennCare. 3 4 5 6 7 8 9 TennCare reviews registration and notifies EP or EH of their Eligibility Status. EP or EH will receive Notification on how to Attest. EP or EH will submit how they want to Attest (Individual, Group, Hospital) via TennCare s EHR Incentive website. http://www.tn.gov/tenncare/pipregistration.html TennCare emails the EP or EH the appropriate Attestation form. EP or EH completes and returns Attestation form. Also, sign and return by U.S Mail the two signature pages, Substitute W-9 & the Automated Clearing House forms. TennCare reviews and Attestation form and notifies EP or EH that the form has been received. TennCare distributes payment to EP or EH within 45 days. 15 8
Attestation Individual EP attestation is based on the individual paid encounters for that EP. If you practice in multiple locations, you must include the volume for all locations. However, you can only claim an EHR Incentive Payment for one location. Group practice or clinic attestation is based on the paid encounters for all professionals of the group practice. If a group practice makes the decision to use the encounter data of the group, then all members of the group practice applying for the EHR Incentive Payment through the group practice must follow that decision. CMS has the following Q&A as an example of how patient volume is determined for a group practice. Question: If an EP in the Medicaid EHR Incentive Program wants to leverage a clinic or group practice s patient volume as a proxy for the individual EP, how should a clinic or group practice account for EPs practicing with us part-time and/or applying for the incentive through a different location (e.g., where an EP is practicing both inside and outside the clinic/group practice, such as part-time in two clinics)? 16 EPs may use a clinic or group practice s patient volume as a proxy for their own under three conditions: 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); There is an auditable data source to support the clinic s patient volume determination; and 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 may 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. Furthermore, if the EP works in both the clinic and outside the clinic (or with and outside a group practice), the clinic/practice level determination includes only those encounters associated with the clinic/practice. 17 9
If Clinic A uses the clinic s patient volume as a proxy for all EPs practicing in Clinic A, this would not preclude the part-time EP from using the patient volume associated with Clinic B and claiming the incentive for the work performed in Clinic B. In other words, such an EP would not be required to use the patient volume of Clinic A simply because Clinic A chose to invoke the option to use the proxy patient volume. However, such an EP s Clinic A patient encounters are still counted in Clinic A s overall patient volume calculation. In addition, the EP could not use his or her patient encounters from Clinic A in calculating his or her individual patient volume. 18 CLINIC A (with a fictional EP and provider type) o EP #1 (physician): individually had 40% Medicaid encounters (80/200) o EP #2 (nurse practitioner): individually had 50% Medicaid encounters (50/100) o Practitioner at the clinic, but not an EP (registered nurse): individually had 75% Medicaid encounters (150/200) o Practitioner at the clinic, but not an EP (pharmacist): individually had 80% Medicaid encounters (80/100) o EP #3 (physician): individually had 10% Medicaid encounters (30/300) o EP #4 (dentist): individually had 5% Medicaid encounters (5/100) o EP #5 (dentist): individually had 10% Medicaid encounters (20/200) Totals: 1,200 encounters in the selected 90-day period for Clinic A 415 encounters attributable to Medicaid 35% of the clinic s volume This means that 5 of the 7 professionals would meet the Medicaid patient volume under the rules of the EHR Incentive Program. Two of the professionals are not eligible for the program on their own, but their clinical encounters at Clinic A should be included. 19 10
What Has Been Happening Since January 3, 2011? January 3, 2011 CMS opens the Medicare & Medicaid EHR Incentive Program Registration and Attestation System website to accept EP/EH registration applications. January 4, 2011 - The Bureau of TennCare receives the first file of EPs applying for the EHR Incentive Program 92 professionals. As of March 2011: Acute Care Hospitals 36 Certified Nurse Midwives 21 Dentists 16 Nurse Practitioners 312 Physicians 513 Physician s Assistants 23 Tennessee is second in number of EPs/EHS who have applied to participate in the EHR Incentive Program. We are FIRST in terms of the number who have been verified for participation. 20 Notable Differences between the Medicare and Medicaid EHR Incentive Programs Medicare Federal Government will implement (will be option nationally) Payment reductions begin in 2015 for providers that do not demonstrate Meaningful Use Must demonstrate MU in Year 1 Maximum incentive is $44,000 for EPs (10% bonus for EPs in HPSAs) MU definition is common for Medicare Medicaid Voluntary for States to implement (may not be an option in every State) No Medicaid payment reductions A/I/U option for 1 st year Maximum incentive is $63,750 for EPs States can adopt certain additional requirements for MU 21 11
Notable Differences between the Medicare and Medicaid EHR Incentive Programs (continued) Medicare Medicaid Last year a provider may initiate program is 2014; Last year to register is 2016; Payment adjustments begin in 2015 Last year a provider may initiate program is 2016; Last year to register is 2016 Only physicians, subsection (d) hospitals and CAHs may participate 5 types of EPs, acute care hospitals (including CAHs) and children s hospitals Acronym Translations A/I/U Adopt, Implement, or Upgrade CAH Critical Access Hospital EHR Electronic Health Record EH Eligible Hospital EP Eligible Professional HPSA Health Professional Shortage Area MU Meaningful Use 22 Medicare EP Medicaid EP Acute Care Hospital Children s Hospital Patient volume requirements None 30% of total paid encounters must be Medicaid; 20% for pediatricians. Medicare None Medicaid 10% of patient encounters must be Medicaid None Additional requirements Must have adopted, implemented or upgraded an EHR system. Must have adopted, implemented or upgraded an EHR system. Average length of stay is 25 days or less. Must have adopted, implemented or upgraded an EHR system. Cannot be a wing of a longer hospital. Must have adopted, implemented or upgraded an EHR system. Types of professional who qualify Doctor of Medicine or Osteopathy, Doctor of Dental Surgery or Dental Medicine, Doctor of Optometry, Chiropractor Physician, Dentist, Certified Nurse Midwife, Nurse Practitioner, Physician s Assistant (PA if leading FQHC or RHC) NA NA Total maximum payment $44,000 $63,750 (Pediatricians who have less than 30% Medicaid volume will receive 2/3rds) NA NA Payment years 2011-2016 2011-2021 Medicare: 2011-2016 Medicaid: 2011-2013 2011-2013 How many years payments are spread out 5 (Maximum payment is reduced if entering program after 2012) 6 Medicare 4 Medicaid 3 3 23 Last year to enter program Must meet meaningful use criteria 2014 2016 2016 (both Medicare & Medicaid payments) Yes Yes (but not required in first payment year) Yes (but not required in the first year for Medicaid only) 2016 Yes (but not required in first payment year) 12
Need More Information? Contacts? Monitor our websites for the latest information about what is going on in Tennessee: www.tn.gov/tenncare/hitech http://www.tn.gov/tenncare/pipregistration.html Sign up for our free E-Blast newsletter: http://www.tn.gov/tenncare/medicaidhitemail.html Questions can be sent to TennCare.EHRIncentive@tn.gov 24 13