ge healthcare meaningful use part 1: overview of the ... · meaningful use part 1: overview of the...

1 /CHUG ARRA Overview /

04/06/2010

GE Healthcare

Meaningful Use Part 1: Overview of the Regulations and Their Implications

Mark Segal, PhD and Joann Kern, RN

Centricity Healthcare User Group

April 30 , 2010


04/06/2010

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04/06/2010

The HITECH Act and Meaningful Use

HITECH Act•

Part of American Recovery and Reinvestment Act of 2009 (ARRA) –

February 2009

•

$36+B for HIT Infrastructure and EHR Adoption/Use

Meaningful Use•

Eligible Professionals (EP) and Hospitals demonstrate Meaningful Use of Certified EHR to receive Medicare and Medicaid EHR incentives

Major Policy Issues

Certification & Standards

Quality Reporting

Meaningful Use

HIT Policy/ Standards

Committees

HIT Policy/ Standards

Committees

GE, EHRA, eHI, HIMSS, Customers

http://www.hhs.gov/

http://www.hhs.gov/

http://www.hhs.gov/


04/06/2010

Briefing on the ONC AgendaBriefing on the ONC AgendaDavid Blumenthal, MD, MPPDavid Blumenthal, MD, MPPNational Coordinator for Health Information Technology , December 15, 2009

Meaningful Use and Other Medicare and Medicaid Incentive Policies: NPRM


04/06/2010

Three Regulations•

CMS: Meaningful Use and Payment Policies–

Notice of Proposed Rulemaking (NPRM)–

60-day comment period from January 13, 2010: March 15, 2010–

Final Rule expected by June 2010

•

ONC: Standards and Certification–

Interim Final Rule (IFR)–

Effective 30 days after publication date (January 13 +30)–

60-day comment period from January 13, 2010: March 15, 2010–


•

ONC: Testing and Certification Program–

NPRM published March 10, 2010–

Temporary and Permanent certification programs–

30 (Temporary) and 60-day (Permanent) comment periods–

Multiple certifying bodies: ONC rules/criteria and NIST testing methods–



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Evolution of Meaningful Use


04/06/2010

Meaningful Use Criteria and Reporting

Objectives/MeasuresOverall•

Few changes

from Policy Committee•

Each objective has a measure•

Must meet all objectives & measures

Eligible Professionals (EP)•

25 Objectives/Measures•

By NPI and TIN

EHR Use•

EP MU: 50%+ encounters in period must be at location(s) w/ certified EHR

Reporting2011•

Attestation

2012•

Attestation•

Quality: Direct submit via “EHR technology” to CMS/state directly or via HIE/registry

Medicare and Medicaid•

Common definition•

Minimum for Medicaid but criteria for HHS to accept state requirements

•

Additional state requirement cannot require additional EHR functionality

Meaningful Use Grid –

Page 1

Medicare and Medicaid Programs; Electronic Health Record Incentive Program; Proposed Rule, January `3, 2010, Federal Register, pp. 1844-2011


04/06/2010

Clinical Quality Measure Reporting

•

HHS not ready to accept quality data electronically•

2011: One time attestation to CMS–

CMS portal or claims as for MU generally–

Submit summary calculated measures–

Attest EHR used to capture data elements and calculate results

•

2012: Submit quality measures electronically–

Whether 2012 is first or second payment year

•

If HHS cannot accept in 2012, stay with attestation•

Quality measures for Medicare apply to Medicaid–

Alternative Medicaid measures for hospitals


04/06/2010

Clinical Quality Measure Reporting: EP

•

HHS proposes extensive

list (90) of EP core and specialty-specific measures for 2011-12–

Many from PQRI

–

Only some electronic specifications–

Numbers likely to be reduced

•

2011-12: each EP submits two groups–

Core measures group

–

Specialty group: subset of clinical measures–

Some specialties exempt from non-core


04/06/2010

Clinical Quality Measure Reporting: EP



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Demonstrating Meaningful Use

•

Common for Medicare and Medicaid–

States can apply to add to base definition

•

Stage 1: Attestation–

One-time

secure attestation per reporting period

–

Via claims submission or CMS portal–

Specifics TBD

–

Indicate certified EHR technology used–

Use same method for quality for 2011

•

CMS/States to pilot EHR-based submission


04/06/2010

When Can/Must 2011 MU be Shown to Receive Full Medicare Payment?

For First Payment Year

(2011+) in which MU shown, reporting period

is 90 continuous days

in payment year

2011

First Start

Last Start

Eligible Professionals

1/1/2011 10/1/2011

Hospitals

10/1/2010 7/1/2011

Note: Above monthly

timing applies to all post-2011 first payment years

to get full payment for that year


04/06/2010

The Path to 2015: Stages by Start Year Stage Timing Compressed for Post-2011 Starts

First Payment

Year

2011 2012 2013 2014 2015 and later**

2011 Stage 1 Stage 1 Stage 2 Stage 2 Stage 32012 Stage 1 Stage 1 Stage 2 Stage 32013 Stage 1 Stage 2 Stage 32014 Stage 1 Stage 32015 and later*

Stage 3

*Avoids payment adjustments only for EPs in Medicare EHR Incentive Program

**Stage 3 criteria of meaningful use or a subsequent update to criteria if one is established


Medicare Incentive Policies: EPCalendar

Year

First CY in which the EP Receives an Incentive Payment

2011 2012 2013 2014 2015 and

subsequent

years

2011 $18,000

2012 $12,000 $18,000

2013 $8,000 $12,000 $15,000

2014 $4,000 $8,000 $12,000 $12,000

2015 $2,000 $4,000 $8,000 $8,000 $0

2016 $2,000 $4,000 $4,000 $0

TOTAL $44,000 $44,000 $39,000 $24,000 $0

Medicare Penalties: % of allowed charges: 2015 (1%), 2016 (2%), 2017+ (3%)



04/06/2010

Medicare Incentive Policies: EP

•

EP: MD/DO, DDS/M, DPM, DO, DC •

Payment year: calendar year (CY)

•

Incentives for up to five years, starting CY 2011•

Payment schedule per start year (not actual year)

•

Medicare maximum: $44,000 (HPSA = $48,000)•

Incentive: 75% Medicare allowable charges in year–

Annual caps (e.g., $18K in first payment year: 2011-12)

•

Qualifying EP: Show MU for “EHR reporting period”


04/06/2010

Medicare Incentive Policies: EP

•

Must meet all objectives and measures•

Hospital-based EPs ineligible–

EP furnishing 90%+ Medicare covered services in hospital inpatient, outpatient, and ED (place of service 21, 22, or 23)

–

27% of Medicare physicians

•

Single annual incentive payment for EPs -

electronic•

Payments by Medicare Carrier to TIN given by EP

•

Payments on rolling basis•

Can reassign entire incentive to one employer/entity


04/06/2010

Medicaid Incentive Policies: EPs

•

State Medicaid programs administer•

Must select between Medicare or Medicaid

•

Enroll via single provider election repository•

EPs in multiple states must choose one

•

One TIN for EP incentive payments per EP•

MU shown by HHS-approved state method


04/06/2010


•

EPs–

Physicians, dentists, NP, CNMs

–

PAs practicing predominantly in PA-directed FQHC/RHC

–

Cannot be hospital-based (FQHC/RHC exempt)

–

Medicaid managed care EPs eligible for Medicaid incentives

•

Must annually

meet patient volume thresholds–

30% of encounters for 90 days in prior year

–

20% for pediatricians


04/06/2010


•

Up to $63,750 over six years and must start by 2016–

Pediatricians with Medicaid volume of 20-29%: $42,500

•

Maximum of $21,250 in first payment year–

Adopt, implement or upgrade certified EHR or MU

•

In later years, annual max of $8,500 for most EPs•

Up to $29K from others as initial contribution to EHR –

Up to $10.6K per year in later years

–

Without incentive reduction

–

No cap for State or local government contributions

•

Can assign to employers or state-designated entities


04/06/2010


•

State Medicaid programs administers•

Must select between Medicare or Medicaid

•

Enroll via single provider election repository•

Medicaid EPs in multiple states must choose 1

•

One TIN for EP incentive payments per EP•

MU demonstrated by State method (HHS to ok)


04/06/2010


•

EPs–

Physicians, dentists, NP, CNMs

–

PAs practicing predominantly in PA-directed FQHC/RHC

–

Cannot be hospital-based (FQHC/RHC exempt)

–

Medicaid managed care EPs eligible for Medicaid incentives

•

Must annually

meet patient volume thresholds–

30% of encounters for 90 days in prior year

–

20% for pediatricians


04/06/2010


•

Up to $63,750 over six years and must start by 2016–

Pediatricians with Medicaid volume of 20-29% -$42,500

•

Maximum of $21,250 in first payment year–

Adopt, implement or upgrade certified EHR or MU

•

In later years, annual max of $8,500 for most EPs•

Up to $29K from others as initial contribution to EHR –

Up to $10.6K per year in later years

–

Without incentive reduction

–

No cap for State or local government contributions

•

Can assign to employers or state-designated entities

Standards and Certification Criteria: Interim Final Rule


04/06/2010

Standards and Certification Criteria•

Interim Final Rule (IFR) effective 2/12/2010–

60-day comment period

•

Final Rule likely by June 2010•

Certification

criteria: minimum capabilities and

standards for certified EHRs to support Stage 1 MU •

Standards, certification criteria basis for testing and certification of “complete EHRs” and “EHR Modules”–

Process proposed in 3/10/2010 NPRM

–

Multiple certifying organizations likely

–

Note: Modules

address 1+ certification criteria

–

NIST: ONC consults, define test methods and processes


04/06/2010

Certification Criteria


GE Comments


04/06/2010

GE ARRA Regulation Comments

•

Earlier timing for Stage 2 NPRMs: by end of 2010•

Greater clarity for providers and vendors

•

Reduce "opportunities for providers to fail“•

Refine “all or nothing approach”

•

Reduce # of quality measures/focus on EMR specifications•

Eliminate (RCM) or scale back (lower/no %) MU criteria

•

Refine certification criteria•

Provide more robust approaches to HIE

•

Refine/strengthen standards proposals

Certification Process: Notice of Proposed Rule Making


04/06/2010

• One NPRM – Two Final Rules– Two Proposed Programs

• Temporary Certification Program– Operational for Meaningful Use Stage 1– Anticipate publishing final rule synchronously with final rules for

meaningful use and standards and certification criteria• Permanent Certification Program

– Operational for Meaningful Use Stage 2– Anticipated final rule early fall

• Two Comment periods:– 30 days for temporary certification program proposals– 60 days for permanent certification program proposals

9

Beginning of Proposed Meaningful Use Stage Stage 1 Stage 2

Quarter Q2/10

Q3/10

Q4/10

Q1/11

Q2/11

Q3/11

Q4/11

Q1/12

Q2/12

Q3/12

Q4/12

Q1/13+

Certification Program

TemporaryPermanent

ONC Certification NPRM

Source: HIMSS 2010 ONC HIMSS Town Hall Presentation


04/06/2010

NPRM: Temporary Certification

•

Application to ONC•

Organizations capable of testing and certification

•

Organizations able to test and certify Complete EHRs, EHR Modules, or both

•

Stage 1 focus•

Use NIST testing methods

•

Certification only valid for two years–

If start Stage 1 in 2013 will need Stage 2 certified EHRs

33


04/06/2010

NPRM: Permanent Certification

•

Testing and certification separated–

Per HIT Policy Committee and NIST

•

Testing: EHR (Module) can meet specific, predefined, measurable, quantitative requirements

•

Certification: Complete EHR or Module has met all applicable HHS certification criteria

•

Accreditation required–

ONC to approve accreditor for certification bodies

–

NVLAP (NIST) would accredit testing labs

•

Can certify Complete EHRs, EHR Modules, or both

34


04/06/2010

Authorized Testing/Certification Methods

•

Primary: Must have capacity to [test] and certify Complete EHRs and/or EHR Modules at their facility

•

Secondary: Must also have capacity to [test] and certify Complete EHRs and/or Modules via secondary means/location –

Site (i.e., location) where Complete EHR or EHR Module has been developed (e.g., at Complete EHR developer’s facility); or

–

Site where Complete EHR or EHR Module resides (e.g., hospital where HIT installed); or

–

Remotely (i.e., through other means, such as secure electronic transmissions and automated web tools, or location other than certifying body facilities)

35


04/06/2010

Temporary Certification Program

36

Testing:Tools/Data/Scripts

TestReport

Complete EHR/EHR Module Submitted

CertificationApplication and Agreement

Reports Certified Product Info

Publishes

Authorizes

NIST

ONC-Authorized Testing & Certification Bodies

Vendors/Self-Developers

Technical Requirements

12 3

4

5 Certified HIT Products List

National Coordinator



04/06/2010

Permanent Certification Program

37

Technical Requirements

Testing:Tools/Data/Scripts

TestReport

Complete EHR/EHR Module Submitted

CertificationApplication and Agreement

Reports Certified Product Info

Publishes

Authorizes

NIST National Coordinator

ONC-Authorized Certification Bodies

Vendors/Self-Developers

1 2 3

4

5 Certified HIT Products List

NVLAP-Accredited Testing

Laboratories

NVLAP

ONC-AA

Approves

Accredits

Accredits



04/06/2010

NIST Will Provide Test Methods

Source: NIST -

http://xw2k.nist.gov/healthcare/use_testing/index.htm


04/06/2010


Source: NIST -



04/06/2010

For More Information …

•

HHS Office of the National Coordinator for Health Information Technology

www.hhs.gov/healthit/

http://www.hhs.gov/healthit/


04/06/2010

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