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: www.dentrix.com/ehr. 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 www.cms.gov and enter EHR Incentive Programs 1. Q: What exactly is the formula for computing the 30 percent? Is it based on Medicaid patient encounters divided by total patient encounters in the clinic? A: Generally stated, Medicaid encounters must comprise at least 30 percent of the eligible professional s (EP 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 percent Medicaid patient volume threshold or 30 percent needy individual patient volume threshold if the EPs are practicing predominantly in a Federal Qualified Health Center (FQHC) or Regional Health Center (RHC), states propose one or more methods of calculating patient volume to Centers for Medicare and Medicaid Services (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: 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 (www.cms.gov). 3. Q: We would like also to hear something about how dental school services are accounted. A: Dental schools themselves are not eligible for incentives under the Medicaid Electronic Health Record (EHR) Incentive Program. Individual dentists may be eligible if they meet all the eligibility criteria, including having 30 percent Medicaid patient volume or 30 percent 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 the 30 percent Medicaid patient volume threshold. 4. Q: We are a large Indian Health Service dental clinic and have just implemented the electronic dental record (EDR). We ve been told that to participate in Meaningful Use (MU), we will have to implement the electronic health record (EHR) also. Is that your understanding? A: In Stage 1, Year 1, any organization simply needs to adopt, implement or upgrade to a certified EHR. That means that the organization simply needs to acquire the certified EHR and demonstrate a financial or legal commitment to it. In Stage 1 Year 2 and beyond, EPs at the organization must demonstrate meaningful use of the certified EHR to continue receiving incentive payments under the Medicaid EHR Incentive Program.
5. Q: How is the 30 percent proportion of services to Medicaid patients measured? Visits, charges? A: The 30 percent 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 where Medicaid paid for all or part of the service or Medicaid paid the co-pay, cost-sharing or premium 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. 6. Q: 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 1? 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 qualified participation earns you the funding that you received. You could participate in just Stage 1, get the funding, and then stop attesting. 7. Q: If a provider attested to A/I/U in 2012, then 90 days in 2013, would the provider need to then have a full year of MU in 2014 before he or she can attest to Stage 2, which would be 2015 for the provider? A: Providers do not need to attest for each stage in consecutive years 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 2016. Once they have passed through all of the steps in Stage 1, they can attest for Stage 2. To receive the full potential incentive payments, an eligible professional would need to begin the Medicaid EHR Incentive Program by 2016. 8. 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, such as Henry Schein, that provide certified EHR options for their customers, there is no certifying standard specifically for electronic dental records. The certifying standard applies to electronic health records generally. 9. 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 percent of needy individuals to qualify for the incentive. 10. Q: The certification web site shows Version 7.6 of Dentrix 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 Meaningful Use Access is certified for Meaningful Use. Dentrix Meaningful Use Access 7.6 is a completely different product than Dentrix and actual utilization of the product would require double entry of information. We recommend Dentrix Meaningful Use Access to organizations that would like to attest for Stage 1, Year 1 criteria immediately. We encourage those organizations to speak with a Henry Schein representative at 800-983-5908 to determine the long term plan for meeting subsequent stage requirements 2 Meaningful Use Questions & Answers
11. Q: Is Dentrix completely certified as a standalone EDR or is only certified with another EDR? A: Dentrix is NOT certified as a standalone EHR. However, Dentrix Meaningful Use Access is completely certified. For organizations interested in attesting for Stage 1, Year 1, we recommend Dentrix Meaningful Use Access after a discussion with a Henry Schein representative at 800-983-5908. 12. Q: Has there been any information or documentation regarding which measures dentists typically qualify for with regards to Stage 1 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 (A/I/U) to certified EHR technology, 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. 13. Q: Please explain what you mean by encounter. 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-pay, cost-sharing or premium 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. 14. Q: If an encounter is provided for a Medicaid patient but is not covered by Medicaid, can it count toward the 30 percent threshold? A: As described in the Stage 1 EHR Incentive Program final rule, a valid encounter for the purposes of calculating an EP 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. But stay tuned for revisions to this definition of encounter under the Stage 2 EHR Incentive Program rule. 15. 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 Accountable Care Act (ACA)? A: The CMS feels very safe with the program. There is no indication that the federal government will reduce or eliminate this program. Please see the extended answer on the webinar recording. 16. Q: We are current Dentrix users. Would you please discuss the MU Access product and how it works? A: Dentrix Meaningful Use Access is a fully certified EHR. An organization simply needs to meet the A/I/U standard for Stage 1, Year 1 of the Medicaid EHR Incentive Program to receive the first year of funding. By obtaining Dentrix Meaningful Use Access, an organization will meet those criteria. Meaningful Use Questions & Answers 3
17. Q: In an FQHC, will the 30 percent 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 cannot 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 an outside group practice), then the FQHC-level determination includes only those encounters associated with the FQHC. 18. 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? A: The Meaningful Use Access products are all fully certified electronic health records. However, to purchase one of these products, an organization must already have Henry Schein practice management software. If the dental group that uses Schein practice management software is part of an organization that has an existing certified EHR, there is no need to purchase an additional product to meet Stage 1, Year 1 criteria. 19. 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 electronic dental record (EDR). 20. Q: I have read only tobacco and Blood Pressure 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 nonacute care providers can be excluded from having to meet several of the Stage 1 Meaningful Use measures that are not applicable to their practices. 21. 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 Program final rule in late summer 2012. For those providers who began participating in the EHR Incentive Programs in 2011 or 2012, Stage 2 of the programs will begin in 2014. 4 Meaningful Use Questions & Answers
22. Q: Does ownership in the practices matter? Can an associate/employee provider qualify as an Eligible Provider (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. 23. Q: Does it matter if the provider is full or part time? A: No. Even a part-time provider can meet the criteria. 24. Q: If some individual dentists in the practice have more than 30 percent Medicaid volume, but the group average is less than 30 percent, can those individuals be eligible for the incentive payments? A: Yes, individual dentists who meet the 30 percent Medicaid patient volume requirement can qualify for the 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 practicewide average of 30 percent Medicaid patient volume. Additionally, the individual dentists would have to meet all other eligibility criteria to qualify for an incentive. 25. Q: Are volunteer providers eligible to participate in the Medicaid incentive program, assuming 30 percent group volume reporting is met? A: Yes. As with any Medicaid-eligible provider, a volunteer provider may use a clinic or group practice s patient volume as a proxy 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 The practice and EPs 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 (for example, has adopted a certified EHR, is not hospital-based, etc.) to qualify for an incentive under the Medicaid EHR Incentive Program. 26. Q: If a dentist worked for us during the previous calendar year but recently moved to another practice, can we secure the incentive for the previous year in which he or she 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 that 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. However, as eligible professionals, dentists can reassign their incentive payment to their employer or to an entity with Meaningful Use Questions & Answers 5
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 attestations for 2011 have closed. An eligible professional can qualify for an incentive only for calendar year 2012 or future years 27. Q: What are the measures for which CMS will approve exclusions? A: The CMS EHR Incentive Program website (www.cms.gov) has downloadable Stage 1 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. www.dentrix.com/ehr 1.800.983.5908 2012 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-q412