18 pages-Single-spaced-Class Journal

eHealth Provider Webinar July 2, 2013

Introduction to the EHR Incentive Programs: Overview of Basic Eligibility, Payment Information, and Key Deadlines

Presentation Objectives

Assist Eligible Professionals with:

1. Eligibility requirements for EPs

2. Basic participation requirements

3. Key program deadlines

4. Payment amounts

5. Payment Adjustments & Hardship Exceptions

What are the EHR Incentive Programs?

The Medicare and Medicaid EHR Incentive Programs provide incentive payments to eligible professionals (EPs) who demonstrate meaningful use of electronic health records (EHRs)

EPs must demonstrate meaningful use and submit measures for Stage 1, Stage 2, and Stage 3

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What is meaningful use?

Meaningful use is using certified EHR technology to:

Improve quality, safety, efficiency, and reduce health disparities Engage patients and families in their health care Improve care coordination Improve population and public health All the while maintaining privacy and security

Meaningful use mandated by law to receive incentives

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How does the program work?

The EHR Incentive Programs consist of 3 stages of meaningful use

Each stage has its own set of requirements to meet in order to demonstrate meaningful use

Stage 1

Data capturing and

sharing Stage 2

Advanced clinical

processes Stage 3

Improved outcomes

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HIT can also turn data

into information

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Eligibility

Who is eligible to participate?

Eligibility determined by law

Hospital-based EPs are NOT eligible for incentives DEFINITION: 90% or more of their covered professional services in either an inpatient (POS 21) or emergency room (POS 23) of a hospital

Definition of hospital-based determined in law

Incentives are based on the individual, not the practice

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Who is eligible to participate?

Medicare EPs include:

Doctors of medicine or osteopathy Doctors of dental surgery or dental medicine Doctors of podiatric medicine Doctors of optometry Chiropractors

EPs may not be hospital-based

CAH II physicians can begin participation in calendar year (CY) 2013

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Who is eligible to participate?

EPs in Medicare Advantage must:

Furnish, on average, at least 20 hours/week of patient-care services and be employed by the qualifying MA organization

OR Furnish, on average, at least 20 hours/week of patient care services and be employed by, or be a partner of, an entity that through contract with the qualifying MA organization furnishes at least 80% of the entity’s Medicare patient care services to enrollees of the qualifying MA organization

AND 80% of professional services are provided to enrollees of the MAO

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Who is eligible to participate?

Medicaid EPs include:

Physicians Nurse practitioners Certified nurse-midwives Dentists Physicians assistants working in a Federally Qualified Health Center (FQHC) or rural health clinic (RHC) that is so led by a physicians assistant

EPs may not be hospital-based

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Who is eligible to participate?

Medicaid EPs must also meet one of the three patient volume thresholds:

1. Have a minimum of 30% Medicaid patient volume

2. Pediatricians ONLY: Have a minimum of 20% Medicaid patient volume

3. Working in FQHC or RHC ONLY: Have a minimum of 30% patient volume attributed to needy individuals

CHIP, sliding scale, free care only count toward thresholds if working in RHC or FQHC

Are you eligible?

CMS has created an eligibility tool to help EPs determine their eligibility:

Requirements

What are the requirements for 1st year Medicaid EPs?

MEDICAID – Only for first participation year:

Adopted – Acquired access to certified EHR technology in a legally and/or financially committed manner Implemented – Began using certified EHR technology Upgraded – Demonstrated having upgraded access to EHR technology newly certified in a legally and/or financially committed manner

Must be certified EHR technology capable of meeting meaningful use

No EHR reporting period in 1st year, but in 2nd year Medicaid EPs must meet the meaningful use requirements for 90 days

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What are the requirements for 1st year Medicare EPs?

For the first year they participate, Medicare EPs have to:

Meet the requirements for and report data on a continuous 90- day period during the calendar year (any 90 days from January 1st to December 31st)

For the remaining years they participate, EPs have to meet the requirements for the entire calendar year

Both of these are called the reporting periods

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What do Medicare EPs need for registration?

Before registering:

Make sure to have an enrollment record in the Provider Enrollment, Chain and Ownership System (PECOS)*

Verify that the Medicare Administrative Contractor (MAC) has the correct banking information and payee information including:

Bank account number

Bank routing number

Payee Address

Payee National Provider Identifier (NPI) and Payee Tax Identification Number (TIN) Combinations

When registering, have on-hand:

An NPI

A National Plan and Provider Enumeration System (NPPES) Identity and Access Management (I&A) ID and password for the individual provider;

A Payee TIN

A Payee NPI

EHR Certification Number

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What do Medicaid EPs need for registration?

When registering, have on-hand:

An NPI

An NPPES I&A ID and Password

A Payee TIN

A Payee NPI**

EHR Certification Number

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What are the requirements for Stage 1 of meaningful use?

EPs participating must meet the following for Stage 1:

14 required core objectives

5 objectives chosen from a list of 10 menu set objectives

In addition to meeting the thresholds for the 14 core and 5 menu objectives, all EPs have to report on clinical quality measures (CQMs)

Meaningful Use

13 Core

Measures

+ 5 Menu

Measures

+ 6 CQMs

= MU Meaningful

Use Beginning in 2014, reporting CQMs will no longer be part of the 14 core

measures, but will be still be required. The total of core measures will become 13.

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What are the core objectives for Stage 1?

EPs must meet all core objectives:

Core Objective Measure

1. CPOE Use CPOE for at least 30% of medication orders

2. Drug-drug and Drug-allergy Checks

Enable drug-drug and drug-allergy checks on EHR

3. Problem List Record patient diagnoses for more than 80%

4. E-Rx E-Rx for more than 40%

5. Medication List Record patient medications for more than 80%

6. Medication Allergy List Record patient medications for more than 80%

7. Demographics Record demographics for more than 50%

8. Vital Signs Record vital signs for more than 50%

9. Smoking Status Record smoking status for more than 50%

10. Clinical Decision Implement one clinical decision support rule

11. Electronic Copy Provide electronic copy of health information for more than 50% of patients

12. Clinical Summaries Provide clinical summaries to more than 50% of patients

13. Protect health information Conduct security risk analysis and implement security updates

What are the core objectives for Stage 1?

EPs must meet all core objectives:

Core Objective Measure

EPs must select 5 menu objectives:

Menu Objective Measure

1. Drug Formulary Checks Enable the formulary check for the entire reporting period

2. Lab Results Incorporate lab results for more than 40%

3. Patient List Generate patient list by specific condition

4. Preventive Reminders Use EHR to identify and provide reminders for preventive/follow-up care for more than 20% of patients 65 years or older or 5 years old or younger

5. Patient Access Provide online access to health information for at least 10%

6. Education Resources Use EHR to identify and provide education resources more than 10%

7. Rx Reconciliation Medication reconciliation at more than 50% of transitions of care

8. Summary of Care Provide summary of care document for more than 50% of transitions of care and referrals

9. Immunization Registries Submit at least one immunization registry electronically

10. Syndromic Surveillance Perform at least one transmission of syndromic surveillance data

What are the menu objectives for Stage 1?

What do EPs need for attestation?

Before attesting Medicare EPs should have:

Met all of the necessary measures to successfully demonstrate meaningful use and qualify for an EHR incentive payment Completed the appropriate reporting period and timeframe A successful and active Registration status in the Registration and Attestation system An EHR Certification Number

State requirements may vary for Medicaid EPs EPs should refer to their State for details about attestation

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What is required for Stage 2?

In the Stage 1 meaningful use regulations, CMS had established a timeline that required providers to progress to Stage 2 criteria after two program years under the Stage 1 criteria

CMS delayed the onset of Stage 2 criteria, therefore the earliest that the Stage 2 criteria will be effective is in calendar year 2014 for EPs

EPs must meet the following for Stage 2:

17 core objectives

3 menu objectives that they select from a total list of 6

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Deadlines

What are the important 2013 deadlines?

Date Deadline

October 3, 2013 Last day for EPs to begin 90-day reporting period for CY 2013

December 31, 2013

Reporting year ends for EPs

February 28, 2014

Last day for Medicare EPs to register and attest to receive an incentive payment for CY 2013 (deadline varies for Medicaid EPs)

January 1, 2014- Reporting period begins for EPs for CY 2014 (90

days for Medicaid and 3 months on the quarter for Medicare)

What is happening in 2014?

For 2014 only, all providers regardless of their stage of meaningful use are only required to demonstrate meaningful use for a 3-month EHR reporting period:

For Medicare EPs- 3-month reporting period is fixed to the quarter of the year in order to align with existing CMS quality measurement programs

For Medicaid EPs- 3-month reporting period is not fixed for Medicaid EPs that are only eligible to receive Medicaid EHR incentives, where providers do not have the same alignment needs

This one-time 3-month reporting period in 2014 will help all providers who must upgrade to 2014 Certified EHR Technology to have adequate time to implement their new Certified EHR systems

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Payment Amounts

How sequestration affects EHR payments

As required by law, President Obama issued a sequestration order on March 1, 2013:

Under these mandatory reductions, Medicare EHR incentive payments made to EPs and eligible hospitals will be reduced by 2%

The 2% reduction will be applied to any Medicare EHR incentive payment for a reporting period that ends on or after April 1, 2013

If the final day of the reporting period occurs before April 1, 2013, those incentive payments will not be subject to the reduction

Medicaid payments are not affected by sequestration

The Medicare payment slides do not take into account the 2% reduction for sequestration

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How much are Medicare incentive payments?

Incentive amounts based on Fee-for-Service allowable charges

Maximum incentive for EPs starting in 2013 is $39,000 over 4 years

Must begin by 2014 to receive incentive payments

Extra bonus amount available for practicing predominantly in a Health Professional Shortage Area

Only 1 incentive payment per year

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Medicare incentive payment schedule

Maximum Payment by Start

Year

2011 2012 2013 2014 2015 2016

2011 1 1 1 2 2 3

$44,000 18,000 12,000 8,000 4,000 2,000

2012 1 1 2 2 3

$44,000 18,000 12,000 8,000 4,000 2,000

2013 1 1 2 2

$39,000 15,000 12,000 8,000 4,000

2014 1 1 2

$24,000 12,000 8,000 4,000

Medicare incentive payment sequestration schedule* *This 2% reduction will be applied to any Medicare EHR incentive payment for a reporting period that ends on or after April 1, 2013. If the final day of the reporting period occurs before April 1, 2013, those incentive payments will not be subject to the reduction.

Maximum Payment by Start

Year

2011 2012 2013 2014 2015 2016

2011 1 1 1 2 2 3

$43,720 18,000 12,000 7,840 Reduction ($160)

3,920 Reduction ($80)

1,960 Reduction ($40)

2012 1 1 2 2 3

$43,480 18,000 11,760 Reduction ($240)

7,840 Reduction ($160)

3,920 Reduction ($80)

1,960 Reduction ($40)

2013 1 1 2 2

$38,220 14,700 Reduction ($300)

11,760 Reduction ($240)

7,840 Reduction ($160)

3,920 Reduction ($80)

2014 1 1 2

$23,520 11,760 Reduction ($240)

7,840 Reduction ($160)

3,920 Reduction ($80)

How much are Medicaid incentive payments?

Maximum incentives are $63,750 over 6 years

Incentives are same regardless of start year

The first year payment is $21,250

Must begin by 2016 to receive incentive payments

No extra bonus for health professional shortage areas

Incentives available through 2021

Only 1 incentive payment per year

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Medicaid incentive payments amounts

Annual Incentive Payment by Stage of Meaningful Use

Year 1 Year 2 Year 3 Year 4 Year 5 Year 6

(AIU) 1 1 2 2 3

$21,250 $8,500 $8,500 $8,500 $8,500 $8,500

Maximum incentive payment amount is $63,750. Payments are made over 6 years and do not have to be consecutive.

*2016 is the last year that Medicaid EPs can begin participation in the program.

When Do I Start Stage 2?

http://cms.gov/Regulations-and-

Guidance/Legislation/EHRIncentivePrograms/Participation-Timeline.html

Payment Adjustments & Hardship Exceptions

Medicare EPs and payment adjustments

The HITECH Act stipulates that for Medicare EPs a payment adjustment applies if they are not a meaningful EHR user

An EP becomes a meaningful EHR user when he/she successfully attest to meaningful use under either the Medicare or Medicaid EHR Incentive Program

Adopt, implement and upgrade ≠ meaningful use

A provider receiving a Medicaid incentive for AIU would still be subject to the Medicare payment adjustment.

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Avoiding the 2015 payment adjustments

Demonstrate meaningful use to CMS by:

Apply to CMS for a hardship exemption by July 1, 2014

Medicaid EPs are not subject to payment adjustments

Meaningful EHR User in 2011 or 2012 Never been a Meaningful EHR User

End EHR reporting period by December 13, 2013

End EHR reporting period by September 30, 2014

Attest by February 28, 2014 Attest by October 1, 2014

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Payment adjustments for EPs eligible for both programs

Eligible for both programs?

If you are eligible to participate in both the Medicare and Medicaid EHR Incentive Programs, you MUST demonstrate meaningful use according to the timelines in the previous slides to avoid the payment adjustments. You may demonstrate meaningful use under either Medicare or Medicaid.

Note: Congress mandated that an EP must be a meaningful user in order to avoid the payment adjustment; therefore receiving a Medicaid EHR incentive payment for adopting, implementing, or upgrading your certified EHR Technology would not exempt you from the payment adjustments.

What are the hardship exceptions for EPs?

EPs can apply for hardship exceptions in the following categories:

1. Infrastructure

EPs must demonstrate that they are in an area

without sufficient internet access or face

insurmountable barriers to obtaining

infrastructure (e.g., lack of broadband).

2. New EPs

Newly practicing EPs who would not have had

time to become meaningful users can apply for

a 2-year limited exception to payment

adjustments.

3. Unforeseen Circumstances

Examples may include a natural disaster or other

unforeseeable barrier.

4. EPs must demonstrate that they meet the

following criteria:

Lack of face-to-face or telemedicine interaction

with patients

Lack of follow-up need with patients

5. EPs who practice at multiple locations must

demonstrate that they:

Lack of control over availability of CEHRT for more than 50% of patient encounters

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What are the hardship exceptions for EPs?

EPs whose primary specialties are anesthesiology, radiology or pathology:

As of July 1st of the year preceding the payment adjustment year, EPs in these specialties will receive a hardship exception based on the 4th criteria for EPs

EPs must demonstrate that they meet the following criteria:

Lack of face-to-face or telemedicine interaction with patients Lack of follow-up need with patients

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How do EPs apply for a hardship exceptions?

Applying: EPs, eligible hospitals, and CAHs must apply for hardship exceptions to avoid the payment adjustments. Granting Exceptions: Hardship exceptions will be granted only if CMS determines that providers have demonstrated that those circumstances pose a significant barrier to their achieving meaningful use.

Deadlines: Applications need to be submitted no later than April 1 for hospitals, and July 1 for EPs of the year before the payment adjustment year; however, CMS encourages earlier submission

For More Info: Details on how to apply for a hardship exception will be posted on the CMS EHR Incentive Programs website in the future: www.cms.gov/EHRIncentivePrograms

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Resources

Resources from CMS and ONC

Get information, tip sheets and more at CMS’ official website for the EHR incentive programs: www.cms.gov/EHRIncentivePrograms

Introduction to EHR Incentive Programs Frequently Asked Questions (FAQs) Meaningful Use Attestation Calculator Registration & Attestation User Guides Listserv

Learn about certification and certified EHRs, as well as other ONC programs designed to support providers as they make the transition: www.healthit.gov/

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Questions?

The Electronic Health Record (EHR) Information Center is open to assist you

with all of your registration and attestation system inquiries.

7:30 a.m. – 6:30 p.m. (Central Time) Monday through Friday (except federal

holidays)

1-888-734-6433 (primary number) or 888-734-6563

(TTY number)

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