stage 2 meaningful use - pahcom• starting with the 2014 meaningful use reporting period all eps,...
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Stage 2 Meaningful Use
• Overview
• 2014 Reporting Changes
• Medicaid Provider Eligibility
• Measures Overview
• Core Objectives Comparison
• Menu Objectives Comparison
• Clinical Quality Measures
2
Stage 2 Topics
• Does everyone move to Stage 2 in 2014? – No, everyone must do TWO years of Stage 1 before they move to
Stage 2
– If you have not completed a second year of attesting for Stage 1, you do not need to worry about most these changes until you complete the second year of stage 2
• Which Meaningful Use stage do providers need to demonstrate in 2014? – If you demonstrated MU Stage 1 for the first time in 2011 or 2012,
then you must demonstrate Stage 2 in 2014
– If you demonstrated MU Stage 1 for the first time in 2013 (or have never demonstrated MU) , then you must demonstrate Stage 1 in 2014
3
High Level Overview (1 of 2)
• How long is the attestation period in 2014? – All providers, regardless of their stage of MU, are only required to
demonstrate MU for a three-month EHR reporting period in 2014:
• Medicare Providers - three-month reporting period is fixed to the quarter of calendar year for EPs
• Medicaid Providers - three-month reporting period is not fixed
• Which Certified EHR Technology Do I Need to Use in 2014? – Regardless of the Meaningful Use Stage, if you are demonstrating in
2014 you must use 2014 Certified EHR Technology
– All 2011 certifications “expire” on 12/31/13
High Level Overview (2 of 2)
Triple Aim for Meeting Meaningful Use
Stage 1: Data Capture and
Patient Access
Stage 2: Information Exchange and Care
Coordination
Stage 3: Improved
Patient Outcomes
Better Patient Care
More Affordable Patient Care
Better Health for Populations
5
Stage 1 Stage 2
6
Core Measures Comparison
• Overview
• 2014 Reporting Changes
• Medicaid Provider Eligibility
• Measures Overview
• Core Objectives Comparison
• Menu Objectives Comparison
• Clinical Quality Measures
7
Stage 2 Topics
• Reporting Period Reduced to Three Months – Allows providers time to adopt 2014 certified EHR technology and
prepare for Stage 2
– All participants will have a three-month reporting period in 2014
• Stage 2 rule allows for batch reporting – Starting in 2014, groups will be allowed to submit attestation
information for all of their individual EPs in one file for upload to the Attestation System, rather than having each EP individually enter data
8
2014 Reporting Changes
• Starting with the 2014 meaningful use reporting period all EPs, EHs, and CAHs need to upgrade to 2014 Edition EHR technology only – regardless of the meaningful use stage they need to meet – The 2014 Edition EHR certification criteria support both revised MU
Stage 1 and new Stage 2 requirements
– 2011 Edition will no longer be acceptable for the purposes of meeting the “Certified EHR Technology” definition and from a regulatory perspective 2011 Edition certifications will “expire” come the 2014 MU reporting period
All EPs, EHs, and CAHs: Upgrade to 2014 Edition certified EHR
2014 has a Special MU Reporting Period Length
Medicare
• For non-first time Medicare EPs, EHs, and CAHs – One calendar quarter during
the reporting year
– (e.g., April 1, 2014 through June 30, 2014 would be a Medicare EP’s 2nd quarter and an EH/CAH’s 3rd quarter)
• All new EPs, EHs, and CAHs continue to have an “any continuous 90-day” reporting period
Medicaid
• All Medicaid EPs, EHs, and CAHs (as determined by their state) will have an “any continuous 90-day” or 3-month reporting period during 2014
Penalties Add Up for Medicare Providers!
Year eRX EHR PQRS Penalty
Total
2012 1.0% No
penalty No
penalty 1.0%
2013 1.5% No
penalty No
penalty 1.5%
2014 2.0% No
penalty No
penalty 2.0%
2015 No
penalty 1.0% 1.5% 2.5%
2016 No
penalty 2.0% 2.0% 4.0%
2017 No
penalty 3.0% 2.0% 5.0%
11
• Medicaid EHR Incentive Program policy is different in two respects: 1. The Medicaid program does not have payment adjustments, so
hardship exceptions are unnecessary
2. Medicaid providers are not required to participate in consecutive years of the Medicaid EHR Incentive Program
• For example, if a Medicaid EP skips 2014 (which would otherwise be their “Stage 1, Year 2”) and also skips 2015 but comes back to the Medicaid program in 2016, they would be required to demonstrate “Stage 1, Year 2” in 2016 as if they never left the Medicaid program for those two years
Medicaid Differences
• As stated in the Health Information Technology for Economic and Clinical Health (HITECH) Act, no incentives can be paid to Medicare EPs that begin MU after 2014
• EPs that start MU in 2014 could still earn as much as $24,000 in incentives if they demonstrate MU from 2014 through 2016
2014 is the Last Year Medicare EPs Can Start MU to Get Incentive Payments
• For EPs this potentially means a -2% reduction to the Medicare physician fee schedule (PFS) amount for covered professional services furnished by the EP during 2016
• The payment adjustment calculation for EHs and CAHs is a little more complicated and different for each. Here’s a link to CMS’ EH/CAH tip sheet.
2014 is the basis 2016 Medicare Payment Adjustment
• Overview
• 2014 Reporting Changes
• Medicaid Provider Eligibility
• Measures Overview
• Core Objectives Comparison
• Menu Objectives Comparison
• Clinical Quality Measures
15
Stage 2 Topics
• Patient Encounters – The definition of what constitutes a Medicaid patient encounter has
changed. The rule includes encounters for anyone enrolled in a Medicaid program, including Medicaid expansion encounters (except stand-alone Title 21), and those with zero-pay claims
– The rule adds flexibility in the look-back period for overall patient volume
16
Medicaid Provider Eligibility Expansion
Medicaid Patient Volume Calculation
• Medicaid Encounters Previously under Stage 1 Rule prior to 2013 – Service rendered on any one day
where Medicaid paid for all or part of the service or Medicaid paid the co-pays, cost-sharing, or premiums
• Changed in Stage 2 Rule (applicable to all stages) – Service rendered on any one day to
a Medicaid-enrolled individual, regardless of payment liability
– Includes zero-pay claims and encounters with patients in Title 21-funded Medicaid expansions (but not separate CHIPs)
– Zero-pay claims include • Claim denied - Medicaid
beneficiary has maxed out the service limit
• Claim denied - service wasn’t covered under the State’s Medicaid program
• Claim paid at $0 - another payer’s payment exceeded the Medicaid payment
• Claim denied - claim wasn’t submitted timely
17
Medicaid Patient Volume Calculation Using Children’s Health Insurance Program Encounters
• Stage 1 rule – Only CHIP encounters for
patients in Title 19 Medicaid expansion programs
• Stage 2 rule – CHIP encounters for patients
in Title 19 and Title 21 Medicaid expansion programs
– As before, encounters with patients in stand-alone CHIP programs cannot be included in Medicaid patient volume calculation
18
Medicaid Provider Eligibility Patient Volume Calculation
• Under Stage 1 rule prior to 2013 – Medicaid patient volume for
providers calculated across 90-day period in last calendar year
• Under Stage 2 rule (applicable to all stages) – States also have option to
allow providers to calculate Medicaid patient volume across 90-day period in last 12 months preceding provider’s attestation
• Also applies to needy individual patient volume
• Applies to patient panel methodology, too
• With at least one Medicaid encounter taking place in the 24 months prior to 90-day period (expanded from 12 months prior)
19
• Overview
• Medicaid Provider Eligibility
• 2014 Reporting Changes
• Measures Overview
• Core Objectives Comparison
• Menu Objectives Comparison
• Clinical Quality Measures
20
Stage 2 Topics
Stages of Meaningful Use
Meaningful Use Stage 2 Objectives
Stage 1 Objectives
• 15 Core Objective
• 5 out of 10 Menu Objectives
• 6 out of 44 CQMs – 3 Core or 3 Alt Core
– 3 Additional CQMs
Stage 2 Objectives
• 17 Core Objectives
• 3 out of 6 Menu Objectives
• 9 out of 64 CQMs – 1 from at least 3 NQS
domains
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Core Objectives - Minor Changes
Measures Using A Patient Portal
Interoperability: Provider to Provider
Other Core Measures
Menu Measures
• Must be submitted electronically – Unless 2014 is Year 1 for you
• PQRS???? – Plan is to have aligned and co-reported with CQM’s
Clinical Quality Measures
• Overview
• 2014 Reporting Changes
• Medicaid Provider Eligibility
• Measures Overview
• Core Objectives Comparison
• Menu Objectives Comparison
• Clinical Quality Measures
29
Stage 2 Topics
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure
Use CPOE for medication orders directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local and professional guidelines
More than 30% of unique patients with at least one medication in their medication list seen by the EP have at least one medication order entered using CPOE
Use CPOE for medication, laboratory and radiology orders directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local and professional guidelines
More than 60% of medication, 30% of laboratory, and 30% of radiology orders created by the EP during the EHR reporting period are recorded using CPOE
30
Core Objective 1 Comparison
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure
Generate and transmit permissible prescriptions electronically (eRx)
More than 40% of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technology
Objective not changed
More than 50% of all permissible prescriptions written by the EP are compared to at least one drug formulary and transmitted electronically using Certified EHR Technology
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Core Objective 2 Comparison
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure
Record demographics Preferred language Gender Race Ethnicity Date of birth
More than 50% of all unique patients seen by the EP have demographics recorded as structured data
Objective not changed
More than 80% of all unique patients seen by the EP have demographics recorded as structured data
32
Core Objective 3 Comparison
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure
Record and chart changes in vital signs: Height Weight Blood pressure Calculate and display BMI Plot and display growth charts for children 2-20 years, including BMI
For more than 50% of all unique patients age 2 and over seen by the EP, blood pressure, height and weight are recorded as structured data
Record and chart changes in vital signs: Height Weight Blood pressure (age 3 and over) Calculate and display BMI Plot and display growth charts for patients 0-20 years, including BMI
More than 80% of all unique patients seen by the EP have blood pressure (for patients age 3 and over only) and height and weight (for all ages) recorded as structured data
33
Core Objective 4 Comparison
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure
Record smoking status for patients 13 years old or older
More than 50% of all unique patients 13 years old or older seen by the EP have smoking status recorded as structured data
Objective not changed
More than 80% of all unique patients 13 years old or older seen by the EP have smoking status recorded as structured data
34
Core Objective 5 Comparison
Stage 1 Objective
Stage 1 Measure
Stage 2 Objective
Stage 2 Measure
Implement 1 clinical decision support rule relevant to specialty or high clinical priority along with the ability to track compliance that rule
Implement one clinical decision support rule
Use clinical decision support to improve performance on high-priority health conditions
1. Implement 5 clinical decision support interventions related to 4 or more clinical quality measures, if applicable, at a relevant point in patient care for the entire EHR reporting period. 2. The EP has enabled the functionality for drug-drug and drug-allergy interaction checks for the entire EHR reporting period
35
Core Objective 6 Comparison
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure
Incorporate clinical lab-test results into certified EHR technology as structured data (Menu Item)
More than 40% of all clinical lab tests results ordered by the EP during the EHR reporting period whose results are either in a positive/negative or numerical format are incorporated in certified EHR technology as structured data
Objective not changed
More than 55% of all clinical lab tests results ordered by the EP during the EHR reporting period whose results are either in a positive/negative or numerical format are incorporated in Certified EHR Technology as structured data
36
Core Objective 7 Comparison
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure
Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research or outreach (Menu Item)
Generate at least one report listing patients of the EP with a specific condition
Objective not changed
Measure not changed
37
Core Objective 8 Comparison
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure
Send reminders to patients per patient preference for preventive/ follow up care (Menu Item)
More than 20% of all unique patients 65 years or older or 5 years old or younger were sent an appropriate reminder during the EHR reporting period
Use clinically relevant information to identify patients who should receive reminders for preventive/follow-up care
Use EHR to identify and provide reminders for preventive/follow-up care for more than 10% of patients with two or more office visits in the last 2 years
38
Core Objective 9 Comparison
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure
Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, medication allergies), upon request
More than 50% of all patients of the EP who request an electronic copy of their health information are provided it within 3 business days
Provide patients the ability to view online, download and transmit their health information within 4 business days of the information being available to the EP
1. More than 50% of all unique patients seen by the EP during the EHR reporting period are provided timely (available to the patient within 4 business days after the information is available to the EP) online access to their health information
39
Core Objective 10 Comparison (1 of 2)
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure
Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, medication allergies), upon request
More than 50% of all patients of the EP who request an electronic copy of their health information are provided it within 3 business days
Provide patients the ability to view online, download and transmit their health information within 4 business days of the information being available to the EP
2. More than 5% of all unique patients seen by the EP during the EHR reporting period (or their authorized representatives) view, download, or transmit to a third party their health information
40
Core Objective 10 Comparison (2 of 2)
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure
Provide clinical summaries for patients for each office visit
Clinical summaries provided to patients for more than 50% of all office visits within 3 business days
Objective not changed
Clinical summaries provided to patients within 1 business day for more than 50% of office visits
41
Core Objective 11 Comparison
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure
Use CEHRT to identify patient-specific education resources and provide those resources to the patient if appropriate (Menu Item)
More than 10% of all unique patients seen by the EP are provided patient-specific education resources
Objective not changed
Patient-specific education resources identified by CEHRT are provided to patients for more than 10% of all unique patients
42
Core Objective 12 Comparison
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure
NEW
NEW Use secure electronic messaging to communicate with patients on relevant health information
A secure message was sent using the electronic messaging function of CEHRT by more than 5% of unique patients seen during the EHR reporting period
43
Core Objective 13 Comparison
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure
The EP who receives a patient from another setting of care or provider of care or believes an encounter is relevant should perform medication reconciliation (Menu item)
The EP performs medication reconciliation for more than 50% of transitions of care in which the patient is transitioned into the care of the EP
Objective not changed
Measure not changed
44
Core Objective 14 Comparison
Stage 1 Objective Stage 1 Measure
The EP who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care should provide summary of care record for each transition of care or referral (Menu)
The EP who transitions or refers their patient to another setting of care or provider of care provides a summary of care record for more than 50% of transitions of care and referrals
45
Core Objective 15 Comparison (1 of 2)
Stage 2 Objective Stage 2 Measure
The EP who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care should provide summary of care record for each transition of care or referral
1. EP provides a summary of care record for more than 50% of transitions of care and referrals
2. EP provides a summary of care record either a) electronically transmitted to a recipient using CEHRT or b) where the recipient receives the summary of care record via exchange facilitated by an organization that is a NwHIN Exchange participant or is validated through an ONC established governance mechanism to facilitate exchange for 10% of transitions and referrals
3. EP provider of care must either a) conduct one or more successful electronic exchanges of a summary of care record with a recipient using technology that was designed by a different EHR developer than the sender's, or b) conduct one or more successful tests with the CMS-designated test EHR during the EHR reporting period
46
Core Objective 15 Comparison (2 of 2)
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure
Capability to submit electronic data to immunization registries or Immunization Information Systems and actual submission except where prohibited and in accordance with applicable law and practice (Menu)
Performed at least one test of certified EHR technology's capacity to submit electronic data to immunization registries and follow up submission if the test is successful
Objective not changed
Successful ongoing submission of electronic immunization data from Certified EHR Technology to an immunization registry or immunization information system for the entire EHR reporting period
47
Core Objective 16 Comparison
Stage 1 Objective
Stage 1 Measure
Stage 2 Objective
Stage 2 Measure
Protect electronic health information created or maintained by the Certified EHR Technology through the implementation of appropriate technical capabilities
Conduct or review a security risk analysis per 45 CFR 164.308 (a)(1) and implement security updates as necessary and correct identified security deficiencies as part of its risk management process
Objective not changed
Conduct or review a security risk analysis in accordance per 45 CFR 164.308 (a)(1), including addressing the encryption/security of data at rest and implement security updates as necessary and correct identified security deficiencies as part of its risk management process
48
Core Objective 17 Comparison
• Overview
• 2014 Reporting Changes
• Medicaid Provider Eligibility
• Measures Overview
• Core Objectives Comparison
• Menu Objectives Comparison
• Clinical Quality Measures
49
Stage 2 Topics
Stage 1 Stage 2
50
Menu Measures Comparison
51
Menu Measures Comparison
• Stage 1 required providers to select 5 out of 10 Menu Measures – 7 of the 10 Stage 1 Menu Measures are now Core Measures
• Stage 2 requires providers to select 3 out of 6 Menu Measures – 5 of the 6 Stage 2 Menu Measures are brand new
52
Menu Objective 1 Comparison
Stage 1 Objective
Stage 1 Measure
Stage 2 Objective Stage 2 Measure
NEW
NEW
Imaging results consisting of the image itself and any explanation or other accompanying information are accessible through CEHR
More than 10% of all scans and tests whose result is an image ordered by the EP for patients seen during the EHR reporting period are incorporated into or accessible through CEHR Technology
53
Menu Objective 2 Comparison
Stage 1 Objective
Stage 1 Measure
Stage 2 Objective Stage 2 Measure
NEW NEW
Record patient family health history as structured data
More than 20% of all unique patients seen by the EP during the EHR reporting period have a structured data entry for one or more first-degree relatives or an indication that family health history has been reviewed
54
Menu Objective 3 Comparison
Stage 1 Objective
Stage 1 Measure
Stage 2 Objective
Stage 2 Measure
NEW
NEW
Capability to identify and report cancer cases to a State cancer registry, except where prohibited, and in accordance with applicable law and practice
Successful ongoing submission of cancer case information from Certified EHR Technology to a cancer registry for the entire EHR reporting period
55
Menu Objective 4 Comparison
Stage 1 Objective
Stage 1 Measure
Stage 2 Objective Stage 2 Measure
NEW NEW
Capability to identify and report specific cases to a specialized registry (other than a cancer registry), except where prohibited, and in accordance with applicable law and practice
Successful ongoing submission of specific case information from Certified EHR Technology to a specialized registry for the entire EHR reporting period
56
Menu Objective 5 Comparison
Stage 1 Objective
Stage 1 Measure
Stage 2 Objective Stage 2 Measure
NEW NEW Record electronic notes in patient records
Enter at least one electronic progress note created, edited and signed by an EP for more than 30% of unique patients
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Menu Objective 6 Comparison
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure
Capability to submit electronic syndromic surveillance data to public health agencies and actual submission except where prohibited and in accordance with applicable law and practice
Performed at least one test of certified EHR technology's capacity to provide electronic syndromic surveillance data to public health agencies and follow-up submission if the test is successful
Objective not changed
Successful ongoing submission of electronic syndromic surveillance data from Certified EHR Technology to a public health agency for the entire EHR reporting period
• Overview
• 2014 Reporting Changes
• Medicaid Provider Eligibility
• Measures Overview
• Core Objectives Comparison
• Menu Objectives Comparison
• Clinical Quality Measures
58
Stage 2 Topics
• All providers must select CQMs from at least 3 of the 6 HHS National Quality Strategy (NQS) domains
– Patient and Family Engagement
– Patient Safety
– Care Coordination
– Population and Public Health
– Efficient Use of Healthcare Resources
– Clinical Processes/Effectiveness
• Medicaid providers will electronically report their CQM data to their state
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Topic 5 - Clinical Quality Measures
Provider Prior to 2014 2014 and Beyond
EPs
Complete 6 out of 44 •3 core or 3 alt. core •3 menu
Complete 9 out of 64 Choose at least 1 measure in 3 NQS domains Recommended core CQMs include: •9 CQMs for the adult population •9 CQMs for the pediatric population •Prioritize NQS domains
Questions?
QUESTIONS?
60
Thank You!
THANK YOU, If you have any questions, contact Len at:
lberkstr@health.usf.edu
(813) 455-8949
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Or, Becky at:
rkane1@health.usf.edu
(813) 455-8950
Appendix
• Meaningful Use is when a provider uses an Electronic Health Record (EHR) “meaningfully”
• According to CMS a provider uses their EHR “meaningfully” when they: – Improve quality, safety, efficiency, and reduce health disparities
– Engage patients and families in their healthcare
– Improve care coordination
– Improve population and public health
– Ensure adequate privacy and security protections for personal health information
What is Meaningful Use?
63
• Incentive payments for eligible professionals are based on individual practitioners – If you are part of a practice, each eligible professional may qualify
for an incentive payment if each eligible professional successfully demonstrates meaningful use of certified EHR technology
– Hospital-based eligible professionals are not eligible for incentive payments
• An eligible professional is considered hospital-based if 90% or more of his or her services are performed in a hospital inpatient (Place Of Service code 21) or emergency room (Place Of Service code 23) setting.
• Each eligible professional is only eligible for one incentive payment per year, regardless of how many practices or locations at which he or she provide services
64
Overall Eligibility Requirements for Professionals
Meaningful Use Eligibility
Medicare Eligible Professional
• Doctor of medicine or osteopathy
• Doctor of dental surgery or dental medicine
• Doctor of podiatry
• Doctor of optometry
• Chiropractor
• Cannot be hospital based (90% of services furnished inpatient or ED)
Medicaid Eligible Professional • Physician (MD/DO) • Nurse practitioner • Certified nurse-midwife • Dentist • Physician assistants who work at a PA-led
FQHC or RHC • Cannot be hospital based • 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 FQHC or RHC and have a minimum 30% patient volume attributable to needy individuals
• If you are eligible for both the Medicare and the Medicaid incentive programs, you can only participate in one program not both – You may change incentives once over the incentive program duration
• If you practice in multiple locations, at least 50% of patients must be treated in locations that have certified EHRs that you use meaningfully
65
Can I Implement and Satisfy Requirements in the Same Year? (Yes, but watch dates!)
Medicare
• For the first payment year, the certified EHR reporting period is a continuous 90 day period within a calendar year
• In subsequent years, the EHR reporting period for eligible professionals will be the entire calendar year*
Medicaid • For the first participation year,
eligible professionals only have to demonstrate that they have adopted, implemented or upgraded (AIU) certified EHR technology and meet the minimum volume threshold requirements for a 90 day period within the last 12 months – There is no reporting period for
this requirement; you simply have to have your EHR in use when you attest this fact to the state
• In subsequent years, the EHR reporting period for eligible professionals will be 90 days and then the entire calendar year*
66
* In 2014, everyone will report 90 days regardless of year
Notable Differences Between Medicare and Medicaid EHR Incentive Program
Medicare
Federal government will implement
Medicare fee schedule reductions begin in 2015 for physicians who are not meaningful users
Meaningful use (attesting) begins in year 1
Maximum incentives for Eligible Professionals (EPs) is $44,000 ($39,000 if start in 2013, and $24,000 if start in 2014)
Program sunsets in 2016; fee schedule reductions begin in 2015
Payments are proportional to Medicare allowed charges (75% of total allowed charges billed up to a cap each year)
Payments after April 1, 2013 are subject to 2% sequestration
Medicaid
Voluntary for states to implement
No Medicaid fee schedule reductions
Adopt/Implement/Upgrade (AIU) for year 1
Maximum incentive for Eligible Professionals (EPs) is $63,750
Program sunsets in 2021; last year a provider may initiate program is in 2016
Payments are fixed and not proportional to Medicaid billings
Payments are not subject to the 2% federal sequestration
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Eligible for Both Programs?
• If eligible for both the Medicare and the Medicaid EHR incentive programs: – Select one as you cannot receive incentive payments from both
programs at the same time
– Medicare penalties will be incurred if Medicaid EHR incentive program is selected but you have not attested for 90 days of Meaningful Use before 2015
Adopt on or before
2011 2012 2013 2014 2015
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 -1%
2016 $0 $2,000 $4,000 $4,000 -2%
2017 $0 $0 $0 $0 -3%
Total $44,000 $44,000 $39,000 $24,000 Negative Revenue
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Meaningful Use Payment Medicare
Medicare Penalties – Based on What Year?
If you start the program in… …you must do….
…to avoid payment adjustment in 2015!
2011 365 days in 2013
2012 365 days in 2013
2013 90 days in 2013
2014 90 days by October 1, 2014
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• Source: http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/PaymentAdj_HardshipExcepTipSheetforEP.pdf
Penalties Add Up for Medicare Providers!
Year eRX EHR PQRS Penalty
Total
2012 1.0% No
penalty No
penalty 1.0%
2013 1.5% No
penalty No
penalty 1.5%
2014 2.0% No
penalty No
penalty 2.0%
2015 No
penalty 1.0% 1.5% 2.5%
2016 No
penalty 2.0% 2.0% 4.0%
2017 No
penalty 3.0% 2.0% 5.0%
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• EPs are eligible for payments: – Equal to 75% of total Medicare allowable billings up to cap
– For total incentives over program duration of up to $44,000
– For all payments made after April 1, 2013, 2% will be taken out due to federal sequestration
• Payments are based solely on achieving meaningful use – There are no “up front” payments for adopting, implementing or
upgrading EHRs
• Payments are paid over 5 years, up to 5 payments – If you adopt later or achieve meaningful use later, both the number
of payments and the amount per payment drops
– If you skip a year after you have begun the program, the payment for that year will be lost
– If meaningful use is not achieved one year after you begin, the payment for that year will be lost
Medicare Incentive Payments
Calendar Year
CY 2011 CY 2012 CY 2013 CY 2014 CY 2015 CY 2016
2011 $21,250
2012 $8,500 $21,250
2013 $8,500 $8,500 $21,250
2014 $8,500 $8,500 $8,500 $21,250
2015 $8,500 $8,500 $8,500 $8,500 $21,250
2016 $8,500 $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 $63,750 $63,750 $63,750 $63,750 $63,750 $63,750
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Meaningful Use Payment Medicaid
• Providers must demonstrate that they have adopted, implemented or upgraded certified EHR Technology
• There is no reporting period for this requirement – It simply has to be accomplished before you attest that fact to the
State
– In the first year of AIU, you must prove:
• Volume (group or individual) for a 90 day period of the prior 12 months
• Verification/receipt of adopting, implementing, or upgrading certified EHR technology
• The first year a Medicaid provider demonstrates meaningful use the EHR reporting period is 90 days (starting the year after you attest to AIU)
Medicaid Payment Year 1 – AIU
Medicaid Incentive Payments
• Providers whose patient mix includes at least 30% Medicaid beneficiaries, either managed care, fee for service or secondary Medicaid are eligible for up to $63,750
• Pediatric providers whose patient mix includes at least 20% Medicaid beneficiaries, either managed care or fee-for-service are eligible for up to $42,500, two thirds of the $63,750 – (If they meet the 30% volume they
are eligible for the entire $63,750)
• There are 2 types of payments – The first payment is based on
adopting, implementing or upgrading EHR (up to $21,250 for this first payment)
– The remaining 5 payments are based on achieving meaningful use
• You may receive up to 6 payments, paid over 6 years (must start by 2016) – If you adopt /achieve meaningful
use later, the number of payments available decreases, but not the amount per payment
– If you skip a year after you have begun the program, you can wait until the next year and try again
– If meaningful use is not achieved one year after you begin, you can wait until the next year and try again
– If you are a Medicare provider participating in the Medicaid incentive you must follow the Meaningful Use timeline to avoid payment penalties
• CMS has excellent step by step instructions with screen shots on registration and attestation – For detailed directions access the following link:
http://www.cms.gov/EHRIncentivePrograms/20_RegistrationandAttestation.asp
• Prior to registering, ensure that your Eligible Professionals (EP) know the following information – National Provider Identifier (NPI)
– National Plan and Provider Enumeration System (NPPES) User ID and Password (same as PECOS log in and password)
– Payee Tax Identification Number (if you are reassigning your benefits)
– Payee National Provider Identifier (NPI)(if you are reassigning your benefits)
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How to Register and Attest
• 3rd parties can register and attest on behalf of an Eligible Professionals (EP) if they complete a 3rd Party Proxy Registration – Create an I&A account
• https://nppes.cms.hhs.gov/NPPES/IASecurityCheck.do
– Request to attest on behalf of provider(s)
• Provider authorizes request
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3rd Party Registration
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