Meaningful Use and EHRs

Meaningful Use and Electronic Health Records:

What You Need to Know

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Meaningful Use and EHRs

The EHR Incentive Program of Meaningful Use

• The Meaningful Use Incentive Programs are part of the Health Information Technology for Economic and Clinical Health (HITECH) Act, which is under the American Recovery and Reinvestment Act (ARRA)

• The goals of using a certified EHR in a meaningful way are to:

– Reduce medical errors– Improve health care outcomes– Ensure quality– Reduce healthcare costs

Meaningful Use and EHRs

Types of Meaningful Use Programs

• Medicare EHR Incentive Program– Eligible Professionals– Hospitals

• Medicaid EHR Incentive Program– Eligible Professionals– Hospitals* If you are an EP who is eligible for both,choose the Medicaid EHR Incentive program

Meaningful Use and EHRs

Medicaid vs. Medicare EHR Incentive Programs: A sideby side comparison

Note: Before 2015, and eligible professional may switch between the Medicare and Medicaid programs (or vice versa) one time after the first incentive payment is initiated.

Meaningful Use and EHRs

Payments across the Medicaid EHR Incentive ProgramIncentive year

2012 2013 2014 2015 2016

2012 $21,250

2013 $8,500 $21,250

2014 $8,500 $8,500 $21,250

2015 $8,500 $8,500 $8,500 $21,250

2016 $8,500 $8,500 $8,500 $8,500 $21,250

2017 $8,500 $8,500 $8,500 $8,500 $8,500

2018 $8,500 $8,500 $8,500 $8,500

2019 $8,500 $8,500 $8,500

2020 $8,500 $8,500

2021 $8,500

Total: $67,350 $67,350 $67,350 $67,350 $67,350

Meaningful Use and EHRs

Eligibility For Individual Providers – Eligible Professionals (EPs)

• Medicaid: A Medicaid eligible professional (EP) is defined as a non hospital-based

– Physician– Nurse practitioner– Certified nurse-midwife– Dentist– Physician assistant who furnish services in a

Federally Qualified Health Center or Rural Health Clinic that is led by a physician assistant.

Meaningful Use and EHRs

Definition of a non-hospital based provider

• Hospital based: defined as 90% or more of the provider's encounters taking place at an inpatient (POS 21) or emergency room (POS 23) practice location.

Meaningful Use and EHRs

Must be a Medicaid Provider in good standing

Each eligible professional must have an individual Medicaid Provider ID– If rendering providers do not have one, they will need to get one– Medicaid uses the Medicaid ID to validate patient volume and track payments– Colorado Medicaid’s Provider Enrollment will need to know that the new providers have

been providing services under an already defined group Medicaid provider ID• If your agency has more than 1 group Medicaid ID, then for every Group Medicaid

number that an agency has, the agency must work with CO Medicaid to ensure these individual Medicaid provider ID numbers get tied to the group Medicaid Provider ID numbers.

• For those rendering providers who may already have an individual Medicaid Provider ID that they were not using for services in the agency in which they will participating in the EHR Incentive program with, the agency will need to make sure those individual providers are associated with the group as well.

– Providers who do not have a Medicaid Provider number can get one by going to http://www.colorado.gov/cs/Satellite/HCPF/HCPF/1214992377067 .

**If you have questions regarding your Medicaid ID or check enrollment statuses contact ACS Provider Services at 1-800-237-0757.

Meaningful Use and EHRs

Medicaid EHR Incentive Program and A/I/U

– Adopted > acquired, purchased or secured access to

– Implemented > installed or commenced utilization of

– Upgraded to certified EHR technology

*An EP does not have to demonstrate meaningful use for stage 1 year 1 for the Medicaid EHR Incentive Program.

Meaningful Use and EHRs

Supporting documentation for A/I/U

To prove adoption of a system simply attach documentation of the EHR system during the attestation process (for example - proof of a contract, software license, or purchase order). The proof should be applicable to the type of attestation (Adoption, Implementation or Upgrade). • A screenshot of the ONC Certified HIT Product List (CHPL) site is also required. • The ONC Certification number must match what is in Step 3 of the CO R&A

Colorado Medicaid also provides an A/I/U workbook which can be found downloaded at the following link> http://co.arraincentive.com/docs/CO-EP-AIU-Attestation-Workbook.xls.

Meaningful Use and EHRs

Must meet Medicaid patient volume requirement

To qualify for an incentive payment under the Medicaid EHR Incentive Program, an eligible professional must meet one of the following criteria:

• Have a minimum 30% Medicaid patient volume• Have a minimum 20% Medicaid patient volume, and is

a pediatrician• Practice predominantly in a Federally Qualified Health

Center or Rural Health Center and have a minimum 30% patient volume attributable to needy individuals

Meaningful Use and EHRs

Patient Volume• Eligible Professionals must demonstrate 30% Medicaid patient volume for a

representative 90-day period in the previous calendar year. Pediatricians may demonstrate a minimum of 20% Medicaid patient volumes to qualify for a reduced incentive amount.

• Patient volumes are based on unique patient encounters per day for the 90 day period. In certain circumstances, you may also be able to count Medically Needy patient volumes to help you meet the eligibility requirements. You can also count patients seen in different states if you practice in multiple states.

• Your patient volume information must come from an auditable data source, so you must be able to provide documentation that supports your volumes if requested.

• When determining patient volume, must use a representative 90 consecutive day period in the previous calendar year

• Multiple procedures in the same day for the same individual rendered by the same provider would count as only one encounter.

Meaningful Use and EHRs

Additional information for calculating patient volume

• Colorado has provided a Patient Volume Workbook. The workbook can be downloaded at the following link> http://co.arraincentive.com/docs/CO-EP-Eligibility-Workbook.xlsNote: The state of Colorado requires that the EP retain a copy of this worksheet in their records for Seven years in case of audit.

• Numerator includes fee for service and Medicaid HMO encounters that were paid in part or in full by Medicaid.

– A Medicaid patient encounter is any patient encounter (as defined above) where a Medicaid (not CHIP) fee-for-service claim or managed care organization paid for all or part of the services provided, or the co-pays, cost sharing or premiums for the services provided.

• Denominator includes all encounters regardless of payment status

• Eligible professionals may see their Medicaid patients at any health care POS location/setting– Exception: eligible professionals practicing at a Federally Qualified Health Clinic (FQHC)

using the “needy individual” definition; that is applicable per the federal regulations only at FQHCs.

Meaningful Use and EHRs

Additional information for calculating patient volume

• There are no restrictions on hours worked or eligible professional employment type (e.g., contractual, permanent, temporary).

• An EP is allowed to aggregate or separate patients across practice sites and places of service; however, one location that meets the applicable payment year's EHR technology incentive payment eligibility criteria (Adopt, Implement, or Upgrade or Meaningful Use) MUST BE INCLUDED in the provider's patient volume measurement.

• An EP is allowed to aggregate patients across States.

– The eligible professional must be able to document their out-of-state patient volume.

• EPs can count patients that are dual eligible for Medicare and Medicaid as long as Medicaid was billed at least one cent ($ .01) for the provided service.

• All patient volume information entered into the Colorado EHR Incentive Program attestation system may be subject to audit that could result in payment recoupment. Be sure to assemble an audit file for everything used for attestation.

Meaningful Use and EHRs

Group by proxy conditions• Providers 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.– 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 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), then the clinic/practice level determination includes only those encounters associated with the clinic/practice.

Meaningful Use and EHRs

Group Administrators• As a group of physicians we can have an administrator do the attestation process for

us?

Yes, but each physician MUST sign the completed attestation form as knowledge of attestation individually as well as submit their attestation. Signed attestation forms can be uploaded (front and back) prior to submission. Lastly, the administrator needs to send an electronic notice to each EP to notify them to submit their attestation. The EP will need to create an individual login to the CO R&A system and submit their attestation once they have been notified by the group administrator.

• Which steps of the attestation system can be done by the administrator for a group and which must be done by the individual professional?

The administrator for a group can complete all steps of the attestation process except signing individual attestation forms and the actual submission of the attestation. Each physician must sign the attestation completion form individually to ensure compliance with all Federal and State regulations. Each physician must also create their own CO R&A account login to submit their completed attestation.

Meaningful Use and EHRs

CMS New rules for 2013• If our practice/clinic is attesting as a group for AIU and we have NOT received our

payment, can we add a recently hired, qualified EP that has seen Medicaid patients but was not present in our 90-day period from the previous year for eligibility in our group calculation?

– Yes. CMS has allowed for new EPs hired onto your practice/clinic to be “grandfathered” into your practice/clinic’s volume as long as the volume is representative of the entire practice/clinic if the EPs in your group have not yet received payment. **For RHCs/FQHCs – the new EP must be able to prove that in the previous calendar year they practiced predominately in an RHC/FQHC to be able to use the Needy Individual Patient Volume.

• If our practice/clinic has attested as a group for AIU and we have RECEIVED OUR PAYMENT, can we add a recently hired, qualified EP that has seen Medicaid patients but was not present in our 90-day period from the previous year for eligibility in our group calculation?

─ No. CMS does not allow EPs to be added to a group once a payment has been received. Any new EPs must register and attest as individuals the following year, following all current eligibility rules. **For RHCs/FQHCs – the new EP must be able to prove that in the previous calendar year they practiced predominately in an RHC/FQHC to be able to use the Needy Individual Patient Volume.

Meaningful Use and EHRs

Reassignment of incentive dollars for the CO MedicaidEHR Incentive program

• Each EP would receive an incentive payment.

• EPs can reassign their incentive payments to one entity such as his or her employer or an entity with which they have a valid employment agreement or valid contractual arrangement that allows the entity to bill for the EP's services. Applicants will attest to this relationship during the application process.

• Colorado Medicaid will allow providers to select a pay-to provider based on the current financial relationships established with CO Medicaid.

Meaningful Use and EHRs

Stage 1 EHR Meaningful Use SpecificationSheets for Eligible Professionals

CORE1. *CPOE2. Drug : drug and drug : allergy checks3. Up to date problem list4. *eRx5. Active Medication list6. Active Medication Allergy list7. Demographics8. *Vital Signs9. *Smoking Status10. Clinical Quality Measures11. Clinical Decision support rule12. *Electronic copy of Health Info upon request13. *Clinical Summaries after each visit14. Exchange Key Clinical Information15. Protect Health Information

MENU1. *Implement drug formulary checks2. *Incorporate Lab test results3. Generate patient lists4. *Patient Reminders5. *Provide patients Electronic Access6. Patient Specific Education Resources7. *Medication Reconciliation8. *Summary of Care record upon

transition9. *Submit Electronic data to immunization

registry10. *Submit syndromic surveillance data to

public health agency*MEASURES that have exclusions

Note: each EP must meet all 15 CORE measures or be eligible for an exclusion from the CORE Measures that have exclusions. They must also meet 5 of the 10 Menu measures. In stage 1, An EP can defer the 5 remaining Menu measures.

Meaningful Use and EHRs

What is the difference?• Modular EHRs– Each part of the system must be purchased

separately, i.e. billing A/R, scheduling, clinical

• Integrated EHRs:─ One system, fully integrated solution. Designed to

handle every aspect of the organization.• Client/Server site-based solutions• Web-hosted/Cloud-based solutions

Meaningful Use and EHRs

What is the difference?• Partially Certified EHRs

– An “EHR Module” certification refers to any service, component, or combination thereof that meets at least one certification criterion adopted by the Secretary.

– An “EHR Module” certified EHR could include a single capability required by one certification criterion, or it could provide all capabilities but one required by the certification criteria for a Complete EHR.

• Complete Certified EHRs – “Complete EHR is technology that has been developed to meet, at a minimum,

all applicable certification criteria adopted by the Secretary for an Ambulatory setting (45 CFR 170.302 and 45 CFR 170.304).

– Because it is certified as a “Complete EHR,” it includes the functionality that will enable an Eligible Professional to meet all of the measures for Stage 1.

Meaningful Use and EHRs

Web-hosted SaaS Solutions• Customer can access their software through

the internet from any location.• Costs over infrastructural arrangements

significantly reduced.• Provides for good data sharing between

clinical practitioners, thereby, ensuring that the quality of health care will improve appreciably and the true potential of EMR/EHRs will not fall short.

Meaningful Use and EHRs

Web-hosted SaaS Solutions• Reduces the heavy staff requirements

associated with conventional licensed and client/server solutions.

• State of the art data centers, expert information security resources and round the clock support professionals .

• Significantly reduces implementation costs

Meaningful Use and EHRs

Staying current and compliant

• System updates are performed automatically and rolled out simultaneously to all users

• Government, State, and Local regulation and reporting changes are managed and implemented in cooperation with the vendor partner for all effected organizations

• HIPPA compliance is guaranteed by the vendor– Data are safe, secure, and backed up by the

vendor

Meaningful Use and EHRs

www.MUforBH.com

• FAQso Get quick answers to the most common Meaningful Use questions

• Forumo Chat and exchange ideas with others in your community

• Play the MU Gameo A step-by-step guide to claiming your Meaningful Use dollars

• Videos and Webinarso Access past Meaningful Use presentations for additional help or join our free live webinars

• MU State Universityo Meaningful Use Education State by State

A resource for behavioral health professionals seeking advice, guidance, andinformation on meeting Meaningful Use requirements.

Meaningful Use and EHRs

DisclaimerIt is important that each individual take responsibility for understanding of the final rules and regulations of the Medicaid and Medicare EHR Incentive Programs. MUforBH.com offers these free webinars as a service and makes every effort to provide accurate information. We make no claim that our information is complete or contains no inaccuracies.

Under no circumstances shall anyone associated with MUforBH.com be liable for any incidental, indirect, consequential or special damages or loss of any kind including those resulting from the expected incentives themselves.

MUforBH.com in no way considers itself the ultimate authority or expert on the final rules and regulations of the Medicare and Medicaid EHR Incentive Programs and expects that each individual will consult the state specific Medicaid EHR Incentive Program website for their specific states rules and/or the CMS website for the EHR Incentive Program rules.

It is important that each Eligible Professional note that CMS views the EP as ultimately responsible for the numerator and denominator and their Medicaid Encounter volume as well as the data used for attestation on the measures of Meaningful Use. CMS has announced there will be audits: “There are numerous pre-payment edit checks built into the EHR Incentive Programs’ systems to detect inaccuracies in eligibility, reporting and payment. Post-payment audits will also be completed during the course of the EHR Incentive Programs.”

Meaningful Use and EHRs

Important Links• Colorado Registration & Attestation System Provider

Outreach Page• CMS EHR Incentive Programs Webinar Slides• CMS FAQs• Colorado State Specific FAQs•

Table of Contents for the Stage 1 Eligible Professional Measure Specifications

• Colorado Registration and Attestation JUMP Start page• Colorado EP eligibility workbook• Colorado A/I/U attestation workbook• www.MUforBH.com