oklahoma electronic health record incentive program oklahoma health care authority board retreat...
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OklahomaElectronic Health Record Incentive Program
OklahomaHealth Care Authority
Board RetreatThursday, August 26, 2010
Carol McFarland, CPA, CGFM Melody Anthony, M.S.
Performance & Reporting Manager Provider Services Director
Adolph Maren Jr., M.A.
Senior Planning Coordinator
Oklahoma EHR Incentive Program
Origin: American Recovery &Reinvestment Act of 2009
Health Information Technology provisions of the ARRA
The Health Information Technology for Economic and Clinical Health Act established programs under Medicare and Medicaid to provide incentive payments for the "meaningful use" of certified EHR technology.
"HITECH Act"• Title XIII, Division A, HIT • Title IV of Division B,
Medicare and Medicaid HIT
HITECH Legislation’s purpose:
To improve outcomes, facilitate access, simplify care, and reduce costs of health care nationwide by providing:
Major financial support to provider and States;
Learning opportunities created and leverages through technical assistance from CMS and others;
Will establish sustainable data-driven infrastructure that will create
a framework for improving healthcare quality and outcomes
Oklahoma EHR Incentive Program
Federal Partner responsibilities Centers for Medicare & Medicaid Services
incentive program and meaningful use (MU)
Final Rule for EHR Incentives & MU - July 13, 2010 www.cms.gov/EHRIncentivePrograms/
Office of the National Coordinator of Health Information Technology
certification standards program for EHR technology temporary certification program –
final rule published June 18, 2010 effective June 24, 2010
permanent certification program is expected to be published this fall
www.HealthIT.hhs.gov
Oklahoma EHR Incentive Program
Incentive to . . . Adopt (acquire and install)
Implement (commenced utilization, train staff, deploy tools, exchange data)
Upgrade (expand functionality or interoperability)
Or…
Meaningfully Use (meet specified criteria)
. . . a certified EHR System
Oklahoma’s Program begins January 2011
Oklahoma EHR Incentive Program
Oklahoma EHR Incentive Program
Provider Eligibility, Registration and Attestation
EHR Incentive Eligibility:Qualifying Eligible Professionals (EP)1 Current SoonerCare Provider Contract
2 Hospital-based EPs are NOT eligible
90% or more of services are performed in a hospital inpatient or emergency room setting.
3 Provider Type Physicians (MD,DO)
Pediatricians
Dentists
Certified Nurse Midwifes
Nurse Practitioners
Physician Assistants (PA) practicing at a FQHC/RHC so led by a PA
4 Patient Volume over a 90 day period
30% SoonerCare
20-29% SoonerCare - Pediatricians = 2/3 of incentive payment
30% Needy Individuals* Medical EPs practicing predominantly in FQHC or RHC
*Needy individuals = SoonerCare members, patients receiving uncompensated care and patients receiving services at reduced or no cost based upon ability to pay
Oklahoma EHR Incentive Program
EHR Incentive Eligibility:Qualifying Eligible Hospitals (EH)1 Current SoonerCare Provider Contract
2 Hospital Types Acute Care Hospital (includes CAHs & cancer hospitals)
Avg. length of stay < 25 days
CCN* last 4 of
0001 – 0879; 1300 – 1399
Children’s Hospital CCN* last 4 of 3300 – 3399
Not applicable to children’s wings of larger hospitals
3 Patient Volume over a 90 day period
Acute Care Hospital 10% SoonerCare
Children’s Hospitals No Requirement
* CCN - CMS Certification Number
Oklahoma EHR Incentive Program
Patient Volume Calculation
Based upon CMS final rule
A Patient Volume Documentation worksheet will be provided as part of attestation process
Provider defined 90 day period in the calendar year
Number of SoonerCare* member encounters Number of total patient encounters
Oklahoma EHR Incentive Program
* or Needy Patient encounters for EPs providing services at a FQHC/RHC
Registration
EPs and EHs are required to register with the Medicare and Medicaid registration and attestation system Name, NPI, business address, phone Tax payer ID Number (TIN) Hospitals must provide the CCN
EPs must select Medicare or Medicaid May switch once between programs before 2015
If Medicaid, must select one state May switch states annually
Oklahoma EHR Incentive Program
OHCA will:
Connect to federal repository to facilitate provider attestation
Continue verification of eligibility Disburse payment after cross-checking for potential
duplicative, inappropriate payments and verification of supporting documentation
Disburse payment to one eligible TIN Notify the national repository upon payment
Registration
Oklahoma EHR Incentive Program
Oklahoma EHR Incentive Program
Electronic Attestation Process
*Office of the National Coordinator for Health Information Technology – Authorized Testing and Certificaiton Body
Provider registers with CMS CMS directs providers to the OHCA website for
enrollment in the Oklahoma EHR incentive program
Providers fill out attestation Identify your ONC-ATCB* certified EHR system Complete patient volume worksheet Electronically sign contract ammendment and fax
requested documention to OHCA
Provider is not a hospital based professional
Provider must provide services in Oklahoma
Provider is not receiving an incentive payment from another state for that calendar year
Provider has adopted, implemented or upgraded a certified EHR
Provider inputs the certification number for the ONC-ATCB certified EHR system
Provider list number of FTE jobs created by implementing a certified product
Provider reports cash payments made for the certified EHR
Provider confirms assignment of payment to a qualified TIN
Providers percentage of SoonerCare patient volume is equal to or greater than the allowed
Provider has specified the patient volume date range of 90 days during the calendar year
Oklahoma EHR Incentive ProgramEP Electronic Attestation
Hospital is not currently receiving an incentive payment from another state for that federal fiscal year
Hospital must be located in Oklahoma
Hospitals (Medicaid only) have adopted, implemented or upgraded a certified EHR, or meaningfully used a certified EHR
ONC-ATCB EHR Certification number is included
Hospital list number of FTE jobs created by implementing a certified product
Hospital (acute care) percentage of SoonerCare discharges is at least 10%; Children's hospitals have no discharge percentage
Oklahoma EHR Incentive ProgramEH Electronic Attestation
Adopt / Implement / Upgrade
Oklahoma EHR Incentive Program
Adopted – Acquired and Installed
Implemented – Commenced Utilization
Upgraded – Expanded Upgraded to certified EHR technology or added new functionality to meet the definition of certified EHR technology
Must be certified EHR technology capable of meeting meaningful use
No EHR reporting period Only for first participation year
Oklahoma EHR Incentive Program
Meaningful Use (MU) of EHR
The Recovery Act specifies the following 3 components of Meaningful Use:
Use of certified EHR in a meaningful manner Use of certified EHR technology for electronic exchange of
health information to improve quality of health care Use of certified EHR technology to submit clinical quality
measures(CQM) and other such measures selected by the Secretary
Meaningful Use of EHR –
Health Outcome Priorities
Improve quality, safety, efficiency, and reduce health disparities
Engage patients and families in their health care Improve care coordination Improve population and public health Ensure adequate privacy and security protections for
personal health information
Oklahoma EHR Incentive Program
Meaningful Use of EHR 3 Stages currently proposed
Stage 1 EP: 20 of 25 Objectives / Measures EH: 19 of 24 Objectives / Measures To meet certain objectives/measures, 80% of patients must
have records in the certified EHR technology Reporting Period –90 days for first year; one year
subsequently Oklahoma will adopt MU measures as published.
CMS intends to propose 2 additional stages through future rulemaking.
At this time, CMS plans on transitioning the Stage 12 menu set into the Stage 2 core set.
Oklahoma EHR Incentive Program
Oklahoma EHR Incentive Program
Eligible Professionals –15 Core Objectives1. Computerized Physician Order Entry (CPOE)
2. E-Prescribing (eRx)
3. Report ambulatory clinical quality measures to CMS/States
4. Implement one clinical decision support rule
5. Provide patients with an electronic copy of their health information, upon request
6. Provide clinical summaries for patients for each office visit
7. Drug-drug and drug-allergy interaction checks
8. Record demographics
9. Maintain an up-to-date problem list of current and active diagnoses
10. Maintain active medication list
11. Maintain active medication allergy list
12. Record and chart changes in vital signs
13. Record smoking status for patients 13 years or older
14. Capability to exchange key clinical information among providers of care and patient-authorized entities electronically
15. Protect electronic health information
Oklahoma EHR Incentive Program
Eligible Hospitals –14 Core Objectives
1. CPOE
2. Drug-drug and drug-allergy interaction checks
3. Record demographics
4. Implement one clinical decision support rule
5. Maintain up-to-date problem list of current and active diagnoses
6. Maintain active medication list
7. Maintain active medication allergy list
8. Record and chart changes in vital signs
9. Record smoking status for patients 13 years or older
10. Report hospital clinical quality measures to CMS or States
11. Provide patients with an electronic copy of their health information, upon request
12. Provide patients with an electronic copy of their discharge instructions at time of discharge, upon request
13. Capability to exchange key clinical information among providers of care and patient-authorized entities electronically
14. Protect electronic health information
Oklahoma EHR Incentive Program
Eligible Professionals –10 Menu Set Objectives1. Drug-formulary checks
2. Incorporate clinical lab test results as structured data
3. Generate lists of patients by specific conditions
4. Send reminders to patients per patient preference for preventive/follow up care
5. Provide patients with timely electronic access to their health information
6. Use certified EHR technology to identify patient-specific education resources and provide to patient, if appropriate
7. Medication reconciliation
8. Summary of care record for each transition of care/referrals
9. *Capability to submit electronic data to immunization registries/systems
10. *Capability to provide electronic syndromic surveillance data to public health agencies
*At least 1 public health objective must be selected
Oklahoma EHR Incentive Program
Eligible Hospitals –10 Menu Set Objectives1. Drug-formulary checks
2. Record advanced directives for patients 65 years or older
3. Incorporate clinical lab test results as structured data
4. Generate lists of patients by specific conditions
5. Use certified EHR technology to identify patient-specific education resources and provide to patient, if appropriate
6. Medication reconciliation
7. Summary of care record for each transition of care/referrals
8. *Capability to submit electronic data to immunization registries/systems
9. *Capability to provide electronic submission of reportable lab results to public health agencies
10. *Capability to provide electronic syndromic surveillance data to public health agencies
*At least 1 public health objective must be selected
Incentive
Payments
Oklahoma EHR Incentive Program
Eligible Professional Payments
Paid in alignment with the Calendar year
First year amount consistent regardless of stage (AIU or MU) Maximum incentives are $63,750 over 6 years Incentives are same regardless of start year The first year maximum payment is $21,250 Must begin by 2016 to receive incentive payments No requirement for “consecutive years” participation Incentives available through 2021 Only 1 incentive payment per year
Oklahoma EHR Incentive Program
Eligible Hospital Payments
Paid in alignment with the Federal Fiscal year (FFY) First year amount consistent regardless of stage (AIU or MU) $2M base + per discharge amount (based on Medicare/
Medicaid share) Medicare Meaningful Use requirements may be deemed
eligible for Medicaid payments Payment is calculated, then disbursed over 3-6 years; we
have proposed 3 year disbursement No annual payment may exceed 50% of the total calculation;
no 2-year payment may exceed 90%; we have proposed 50% / 40% / 10%
Hospitals cannot initiate payments after 2016 and payment years must be consecutive after 2016
States must use auditable data sources in calculating the hospital incentive (e.g., cost report)
Payments through 2021
Oklahoma EHR Incentive Program
Eligible Hospitals
Calculate total incentive in base year
Calculated on a 4 year payment basis
Payment over 3 years Year 1: 50% Year 2: 40% Year 3: 10%
Oklahoma EHR Incentive Program
Eligible Hospitals
(Overall EHR Amount) * (Medicaid Share)
Defined as
{Sum over 4 year of [(Base Amount)+ Discharge Related Amount Applicable for Each Year) * Transition Factor Applicable for Each Year]}
. . . multiplied by . . .
[Medicaid inpatient-bed-days / {(Total inpatient-bed-days) * (estimated total charges – charity care
charges) / (estimated total charges)}]
Oklahoma EHR Incentive Program
Monitoring,
Oversight
&
Audit
Oklahoma EHR Incentive Program
Monitoring / Oversight / AuditMonitoring / Oversight / Audit
Attest to specific requirements
Provide required documentation
Keep supporting documentation on file
Random sample and targeted sample reviews will be conducted
Oklahoma EHR Incentive Program
[email protected] [email protected] [email protected]
www.okhca.org/EHR-incentive
Oklahoma EHR Incentive Program
Thank You!