Welcome“Meaningful Use – What does it mean?

Panel DiscussionMay 19, 2010

Meaningful Use – What Does it Mean?Panel Discussion

Moderator:Paula M. Zalucki, FACHE

President, Salus Strategy Group

Panelists:Susan Walker

Regional Director, Beacon Partners, Inc.

Denise Webb GlassPartner, Fulbright & Jaworski, LLP

Patricia Johnston, MS, FHIMSS

Vice President, Electronic Health Record, Ambulatory and Acute Care Texas Health Resources

“Meaningful Use” •Cheat Sheet from Healthcare Executive magazine

•Certification criteria and standards for achieving “meaningful use” of certified health IT products

•Established through the American Recovery and Reinvestment Act of 2009

(aka the Stimulus Bill)

•Notice of Proposed Rule Making establishing the Electronic Health Record Incentive Program was finally released in late December 2009

Susan WalkerRegional Director,

Beacon Partners, Inc.

Meaningful Use, It’s Not Just an IT Project

A Roadmap to Organizational Readiness

Presented by: Susan WalkerRegional Director

Date: 05/19/2010

Beacon Partners

• Leader in Healthcare Consulting– Boston – San Francisco – Toronto

• Privately Held• Consulting Services

– IT Strategy, ARRA, Physician Alignment– Implementation, Clinical and Operations services

• Modern Healthcare Top 20 healthcare consulting firms

Beacon Partners’ PositionMeaningful Use

This is part of an evolutionary path

This is not an I.T project- it’s about Organizational Readiness

It’s about

Developing a patient care, quality and safety strategy supported by I.T. and doing it right

the first time.

Key Components

• Governance and Communication• Physician Alignment• Information Technology Considerations• Vendor Sustainability• Patient Flow• Quality• HIPAA /HITECH

Governance and Communication

C-Suite Support of IT

Common Vision

• Must be created together to align organizational and IT objectives.

• Should point back to strategic planning documents

• Communicate timelines and milestones toward meaningful use within organization

• Create “One Voice” to organization

Challenges

• Political– Champions – Supportive environment

• Organizational– Governance– Shared goals and objectives– Operating rules– Physician Alignment

• Financial– Access to capital– Sustainable model

• Technical Considerations– Integration with legacy systems– Security and privacy– Data management– Staffing skills assessment

Meaningful Use Check List“Starter Kit”

Full Version Available in PDF

Vision

• Have you discussed your IT strategy with your governing body?

• Have you developed a strategic plan and roadmap?• Have you assessed your facility’s meaningful use?• Have you positioned champions for project success?• Has your vendor provided you with a sustainability plan

that ensures CCHIT certification beyond the initial rule?• Physician alignment: Who should we be aligned with to

move our vision, mission and values forward?

Change Management

• Develop a robust change management plan– Just because incentives are available does not mean

physicians will fall in line.

• Have you completed a clinical workflow analysis• Do you have clinicians as team members and

champions? • Plan monthly meetings with executive committee,

clinicians and IT for communication and governance.

Clinical IT Adoption Process

Have your organizational goals and expected results for the clinical IT project been identified in the planning stage?

Design system from clinicians perspective.

Successful Go-Live means TRAINING

Measurement

• Have you completed your ARRA financial incentives estimator?

• Have you matched quality efforts and reporting to federal guidelines?

• Have you determined your up front ability to fund the EHR project?

• Have you audited your Security and Privacy policies?• Have you assessed future penalties for not adopting?

Lessons Learned

• Start the process early• Lay the foundation with

planning• Educate the entire team on

“One Voice”• Understand vendor

solutions early on• Utilize physician and

clinician champions• Communicate

Reference Documents

• MU Analysis and Recommendations Report• MU Starter Kit

– Roadmap– Check List

• Stark Talking PointsContact Susan Walker for electronic copies

swalker@beaconpartners.com

Questions & AnswersThank You

Susan WalkerSwalker@BeaconPartners.com

Denise Webb GlassPartner, Fulbright & Jaworski, LLP

When You Think HEALTH CARE,Think Fulbright.TM

Denise Webb Glass

Women’s Healthcare Executive NetworkMay 19, 2010

Legal Issues Associated with Meaningful Use Standards

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EHR Incentive Program Rules• CMS issued proposed rule on the EHR incentive programs on

December 30, 2009, published in the federal Register on January 13, 2010 with 60 day comment period.

• The comment period for the proposed rule closed on March 15, 2010.

• Next steps for CMS:– CMS reviews comments– Draft final regulation– Obtain clearance from HHS/OMB– Final rule publication—estimated to be Spring

2010

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Current Status

• On March 30, 2010, Senate Finance and HELP Committee leaders urged changes be made to proposed meaningful use rule:– Abandon all-or-nothing approach, requiring

providers to meet all Stage 1 criteria to be eligible for incentives.

– Change rule to allow hospital-based physicians to be eligible for incentive payments (even if legislation passed to allow incentives).

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Medicare Payment Incentives for Eligible Professionals (EPs)

• Start January 2011 • Equal to 75% of Medicare allowable charges for covered services

furnished by the EP in a year, subject to maximum payment in the first, second, third, fourth, and fifth years of $15,000; $12,000; $8,000; $4000; and $2,000, respectively. – Max payment for early adopters (2011 or 2012) is $18,000 in 1st year. – 10% increase in incentive payment for EPs who predominantly furnish

services in a HPSA.• No payments for meaningful EHR use after 2016 and no payments to EPs

who first become meaningful EHR users in 2015 • Payment Adjustments: Medicare fee schedule amount for professional

services provided by an EP who was not a meaningful EHR user for the year reduced by 1% in 2015; 2% in 2016, 3% in 2017 and between 3 to 5 percent in subsequent years.

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Medicare Payment Incentives for Hospitals

• Start October 2010• Up to four years of incentive payments, beginning with FY

2011 • No payments to hospitals that become meaningful EHR users

after 2015• No payments after 2016• Incentive payment calculated based on the product of (a) $2

million base, (b) the Medicare share (fraction based on the number of discharges, and (c) a transition factor to phase down payments over the 4 year period.

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Medicaid Payment Incentives• Must meet minimum Medicaid patient volume percentages, and must

waive rights to duplicative Medicare EHR incentive payments. • EPs may receive up to 85% of the net average allowable costs for certified

EHR technology, including support and training, up to a maximum level, and incentive payments are available for no more than a 6-year period.

• May receive incentive payments associated with the initial adoption, implementation or upgrade of EHR technology

• Medicare definition = minimum definition of meaningful use for Medicaid; state can change (with approval by CMS), but: – must ensure that populations with unique needs, such as children, are

addressed. – may also require providers to report clinical quality measures– EHR technology may need to be compatible with State or Federal

administrative management systems.• EPs may not receive an incentive under both Medicare and Medicaid in a

given year (but hospitals can)

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Components to be Eligible for Incentive Payments

• Eligible professional or eligible hospital• Meaningful Use• Certified EHR Technology (yet to be fully

defined)– Interim final rules also published on January 13,

2010

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Eligible Providers--Medicare• Eligible Professionals (EPs)

– Doctor of Medicine or Osteopathy– Doctor of Dental Surgery or Dental Medicine– Doctor of Podiatric Medicine– Doctor of Optometry– Chiropractor

• Eligible Hospitals– Acute Care Hospitals– Critical Access Hospitals (CAHs)

• Hospital-based EPs do not qualify for Medicare EHR incentive payments

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Eligible Providers--Medicaid

• Eligible Professionals (EPs)– Physicians (Pediatricians have special eligibility &

payment rules)– Nurse Practitioners – Certified Nurse-Midwives – Dentists– Physician Assistants who lead/direct an FQHC or RHC

• Eligible Hospitals– Acute Care Hospitals– Children’s Hospitals

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Meaningful Use—3 components

• Use of certified EHR in a meaningful manner (ex: e-prescribing)

• Use of certified EHR for electronic exchange of health information to improve quality of health care

• Use of certified EHR to submit clinical quality and other measures

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Meaningful Use--Defined in 3 Stages

• Stage 1 –2011• Stage 2 –2013*

– Expand upon the Stage 1 criteria in the areas of disease management, clinical decision support, medication management, support for patient access to their health information, transitions in care, quality measurement and research, and bi-directional communication with public health agencies.

– CMS may consider applying the criteria more broadly to IP and OP hospital settings.

• Stage 3 –2015*– Focus on achieving improvements in quality, safety and efficiency,

focusing on decision support for national high priority conditions, patient access to self management tools, access to comprehensive patient data, and improving population health outcomes.

* to be defined by CMS in future rulemaking

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Stage 1 Meaningful Use in a Nutshell

• EPs– 25 Objectives and Measures– 8 Measures require ‘Yes’ or ‘No’ as structured data– 17 Measures require numerator and denominator

• Eligible Hospitals and CAHs– 23 Objectives and Measures– 10 Measures require ‘Yes’ or ‘No’ as structured data– 13 Measures require numerator and denominator

• Reporting Period –90 days for first year (must be continuous); one year subsequently

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Meaningful Use Standards

• Use computerized physician order entry (CPOE)• Implement drug-drug, drug-allergy, drug-formulary checks• Maintain an up-to-date problem list of current and active

diagnoses• Maintain active medication list• Maintain active medication allergy list• Record demographics • Record and chart changes in vital signs • Record smoking status for patients 13 years and older

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Meaningful Use Standards• Incorporate clinical lab-test results into EHR as structured

data• Generate lists of patients by specific conditions to use for

quality improvement, reduction of disparities, and outreach• Report ambulatory quality measures to CMS or the States• Implement 5 clinical decision support rules relevant to

specialty or high clinical priority, including diagnostic test ordering, along with the ability to track compliance with those rules

• Check insurance eligibility electronically from public and private payers

• Submit claims electronically to public and private payers

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Meaningful Use Standards• Provide patients with an electronic copy of their health information upon

request• Capability to electronically exchange key clinical information among

providers of care and patient-authorized entities• Perform medication reconciliation at relevant encounters and each

transition of care• Provide summary care record for each transition of care and referral• Capability to submit electronic data to immunization registries and actual

submission where required and accepted• Capability to provide electronic syndromic surveillance data to public

health agencies and actual transmission according to applicable law and practice

• Protect electronic health information created or maintained by the certified EHR technology through the implementation of appropriate technical capabilities

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Legal Issues Arising from Meaningful Use Criteria

• Meeting 80% threshold for electronic claims submission and electronic eligibility verification from public and private payers– Dependent on payor capabilities– Effect if outsource billing & collection or business office functions

• Calculating incentive payments in the event of a merger or acquisition

• Physician reassignment of incentive payments• Donating EHR software to medical staff

– Stark exception/Anti-Kickback Statute safe harbor

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Patricia Johnston, MS, FHIMSS

Vice President, Electronic Health Record, Ambulatory and Acute Care

Preparing for Meaningful Use:A Provider’s Perspective

May 19, 2010

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Odessa

Amarillo

Lubbock

Austin

San AntonioHouston

Fort Worth/Dallas

Texas Health Resources

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One of the largest faith-based, non-profit health care delivery systems in the US…– 18,000 Employees– 3,600 Active Staff Physicians – 14 Hospitals– 6 JV Hospitals– 30 Ambulatory Healthcare Sites– 3500 Licensed Hospital Beds– 16 Counties (6.2M people)

National PerspectiveLevel of Concern in Meeting Deadline

Very Concerned

Worried

Somewhat

A Little Worried

Not at all Worried

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CHIME Survey/Dec 09 n=178

National PerspectiveTop Concerns in Implementing Standards

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CHIME Survey/Dec 09 n=178

ENTITY 2010 2011 2012 2013 2014 TOTAL

DENTON $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx

THHEB $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx

THFW $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx

THNW $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx

THSW $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx

THC $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx

THEC $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx

THAM $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx

THK $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx

THP $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx

THA $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx

THD $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx

Total $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ x,xxx,xxx $ 53,649,710

What is on the Table for THR ?

Organizing for Action

Infrastructure Development

Capacity Building

Proposal Development

Number & $ Amount of

Grants (ROI)

“Meaningful User” Definition

for THR

Data Collection

Strategy Development

Use of Consultants

Stakeholder Development

Preparation/Planning

Assessment

Advancing Physician

Engagement

Organizational Visibility

THR Stimulus Taskforce

Community Collaborations

Activities/Tactics OutcomesInputs

Timing

Staffing

HIE

PI’s

TREI

Grant Writers

Agility

Imperatives

Stakeholders

Enhanced Services

& Systems

Improved Health Outcomes

Processes Organizational Capacity

Community Health Comparative Effectiveness

Prioritize Projects/Efforts

ID Funding Opportunities

Review for Capacity

THR’s Funding Focus

ITS Finance THR Org. Phys.

Nursing Adv. & CB

Dependencies

Enhance Research Mission

for TREI

Cost-Effective System

Provider & Coordinator of

Care

Execute Plan

Health Information Technology

Comprehensive View of Quality

Transformational Themes

Impacts

Diversity

Strengthening Our Culture

C4L

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Establishing Goals By Base Camp 2* and for each subsequent year,

Texas Health entities** will meet or exceed criteria for demonstrating meaningful use in order to achieve the maximum available incentive of the HITECH provision of ARRA

*Target = 2011, Par = 2012, Threshold = 2013

** All wholly owned entities (incl. THDN) and THPG practices

Creating AccountabilityGoals Primary Secondary

Improve quality, safety, & efficiency; reduce disparities

Velasco Benson

Engage patients & their families

Marx Johnston

Improve care coordination Johnston Velasco

Improve population and public health

Tesmer Marx

Ensure privacy and security protections

Gerson/Myles Tesmer

Tracking Progress

Self Assessment Score

Requirements Fully Implemented Life Cycle Score

Process Group Overall 2011 2013 2015Overal

l 2011 2013 2015

Clin Doc 0% 0% 0% NA 80% 80% 80% NA

Decision Support 0% 0% 0% 0% 65% 80% 80% 20%

Discharge Process 0% NA 0% NA 40% NA 40% NA

Financial Mgmt 0% 0% NA NA 80% 80% NA NA

Health Mgmt 0% 0% 0% 0% 42% 70% 30% 28%

Meds Mgmt 0% 0% 0% NA 66% 75% 53% NA

Orders Mgmt 0% 0% 0% NA 80% 80% 80% NA

Patient Mgmt 0% NA 0% 0% 30% NA 60% 0%

Registration 0% 0% NA NA 80% 80% NA NA

Reporting 0% 0% 0% 0% 35% 56% 20% 15%

Regulatory Compliance 0% 0% NA 0% 40% 80% NA 0%

Total 0% 0% 0% 0% 52% 73% 53% 17%

Reporting Results

Challenges and Opportunities• Primary benefit is improving

quality, safety, efficiency, for our patients, such as:– Reporting quality metrics– ePrescribing– Health reminders– Health Information

exchange– Patient access to electronic

data– Online reporting to public

health agencies

• Challenges for early compliance include:– Understanding the metrics– Reporting capabilities of

our key software packages– Implementing new

workflows– Compliance with data

capture

Bottom Line

• We will be rewarded for doing the right thing!

Discussion and Q&A

• PatriciaJohnston PatriciaJohnston@Texashealth.org

Questions for the Panelists