health information technology
DESCRIPTION
Health Information Technology. EHR Meaningful Use Milestones for HIT Funding Michele Madison [email protected]. Presentation Overview. Purpose and Function of Stimulus Package Provider Financial Incentives Meaningful Use Certification Standards. Governmental Incentives. - PowerPoint PPT PresentationTRANSCRIPT
Health Information Technology
EHR Meaningful Use
Milestones for HIT Funding
Michele Madison
Presentation Overview
Purpose and Function of Stimulus Package
Provider Financial Incentives
Meaningful Use
Certification Standards
Governmental Incentives
American Recovery and Reinvestment Act of 2009 (ARRA)
Medicare Incentives for Eligible Professionals
Medicaid Incentives for Eligible Professionals
Direct Provider Funding
WHO: DHHS – CMS
WHEN: 2011 ----
HOW: Financial Incentive Payments
TO WHOM: Eligible Professional and Hospitals
GENERAL RULE
“Eligible Professionals” who adopt and “meaningfully use”
“certified” electronic health records
are eligible for Medicare and Medicaid Financial Incentives
Eligible Professionals
Medicare Incentives may be paid to “Eligible Professionals”
– Physicians
– Does not Apply to Hospital Based Physicians
• Emergency Room
• Anesthesia
• Pathologists
• (Determined based upon Site of Service)
Eligible Professionals
Medicare
A physician as defined in section 1861(r) of the Social Security Act*, which includes the following five types of professionals:
– Doctor of medicine or osteopathy
– Doctor of dental surgery or medicine
– Doctor of podiatric medicine
– Doctor of optometry
– Chiropractor
Medicaid
Physicians
Dentists
Certified nurse-midwives
Nurse practitioners
Physician assistants who are practicing in Federally Qualified Health Centers (FQHCs) or Rural Health Clinics (RHCs) led by a physician assistant.
Medicare Incentives
Incentives for Adoption and Meaningful Use of Certified EHR
• Paid to the Eligible Professional or Facility or Employer
• No payments after 2016
• No incentive if first adopting after 2014
Payment is either single consolidated payment or periodic installment payments
Meaningful Use Incentives by Adoption Year
9
Meaningful User 2009 2010 2011 2012 2013 2014 2015 2016 Total Incentive
2011 $ 18,000 $ 12,000 $ 8,000 $ 4,000 $ 2,000 $ 44,000
2012 18,000 $ 12,000 $ 8,000 $ 4,000 $ 2,000 $ 44,000
2013 15,000 $ 12,000 $ 8,000 $ 4,000 $39,000
2014 12,000 $ 8,000 $ 4,000 $ 24,000
2015 + $ Penalties
Medicare Dis-Incentive
Failure to Meaningfully Use Certified EHR
Starting in 2015 reduce reimbursement to 99%
– 2016 – 98%. . .
– 2017-- 97%. . .
– 2018 -- 96% . . .
– Not less than 95%
Unless Significant Hardship applies (5 year Limitation)
Hospital Payments
Hospital Specific Calculation:
[$2Million + (0 x (1149-1 discharges) +(200 x (23,000-1150 discharges) + (>23000 x 0)] x [Medicare Share] x [Transition Factor].
If the adoption is after 2013 the payment will reduce based upon modified Transition Factor
Critical Access Hospital:
Paid through prompt interim payment– cost reporting period
No payment after 2015 and no payments for more than 4 consecutive years
Development of Meaningful Use
ARRA –February 17, 2009
Meaningful Use Proposed Definition
– Health IT Policy Committee
– June 16, 2009
– Provided a Matrix to Define Terms
– Comments received until June 26, 2009
Meaningful Use under ARRA
Use of E-prescribing
Use Certified EHR to report on clinical quality measures selected by DHHS
DHHS may set alternative requirements for a group practice
DHHS shall seek to improve the use of electronic health records and health care quality over time by requiring more stringent measures of meaningful use
Information exchange - ARRA
EHR technology is connected in a manner that provides, in accordance with law and standards applicable to the exchange of information, for the electronic exchange of health information to improve the quality of health care, such as promoting care coordination.
Meaningful Use
Meaningful Use Criteria must be selected and approved by DHHS
The Measures must be published for public comment
Must be measures that DHHS can accept for reporting
Demonstration of Meaningful Use
Demonstrate Use
(1) attestation;
(2) submit claims;
(3) survey; or
(4) reporting
Meaningful Users will be identified on CMS website
HIT Policy Committee Recommendations
Established “Health Outcome Policy Priorities”
Care Goals
2011, 2013 and 2015 Objectives
2011, 2013 and 2015 Measures
Ultimate Goal of HIT Policy Committee
The ultimate goal of meaningful use of an Electronic Health Record is to enable significant and measurable improvements in population health through a transformed health care delivery system. The ultimate vision is one in which all patients are fully engaged in their healthcare, providers have real-time access to all medical information and tools to help ensure the quality and safety of the care provided while also affording improved access and elimination of health care disparities.
Health Outcome Policy Priorities
Improve Quality, Safety, Efficiencies and Reduce Health Disparities
Engage Patients and Families
Improve Care Coordination
Improve Population and Public Health
Ensure Adequate Privacy and Security Protections for Personal Health Information
HIT Policy Committee
July 16, 2009 Revised Meaningful Use Objectives and Measures
August 14, 2009—Final Meaningful Use Objectives and Measures
Final Matrix for Review
http://healthit.hhs.gov/portal/server.pt/gateway/PTARGS_0_10741_888532_0_0_18/FINAL%20MU%20RECOMMENDATIONS%20TABLE.pdf
HIT Standards Committee
August 20, 2009
Meaningful Use Measures and Data Grid
Clinical Operations Workgroup
Privacy and Security Workgroup
Meaningful Use WorkgroupStandards Committee
Standard Categories
Quality Data Types
HITEP Definitions
Data Elements
Standards
http://healthit.hhs.gov/portal/server.pt/gateway/PTARGS_0_10741_880493_0_0_18/MU%20Grid%20Data%20Element%20Standards_08202009.pdf
Measure Process Workflow
Clinical Operations
Subject Area
Recommended for 2011 and 2013 Implementation
Recommended Directional Statement for 2013 and 2015
http://healthit.hhs.gov/portal/server.pt/gateway/PTARGS_0_10741_880490_0_0_18/Ferguson_Clinical%20Operations%20WG%20Recommendations%20Revised%20Summary.pdf
Privacy and Security Standards
Source
Standards
Services Supported
Recommended Implementation Time Frame
http://healthit.hhs.gov/portal/server.pt/gateway/PTARGS_0_10741_880497_0_0_18/PRIVACY%20AND%20SECURITY%20STANDARDS%20APPLICABLE%20TO%20ARRA%20REQUIREMENTS.pdf
Certification Process
• Once a certification process is proposed, HHS in consultation with other relevant federal agencies, will review the recommendations and propose adoption of the standards, implementation specifications and certification criteria and jointly determine adoption
• Adoption pursuant to the formal rulemaking process
• Refusal to adopt requires notice to ONC and the Standards Committee with rationale
• Voluntary use of standards and implementation specifications by private entities
• Certification of private technologies will be voluntary.
• Federal agencies will require by contract that healthcare providers, health plans or health insurance issuers upgrade to IT Systems that meet the standards – catalyst to adopt.
Certification Process
• ONC will keep or recognize programs to certify technology that is in compliance with applicable certification criteria.
• Certification criteria means criteria to establish the technology meets with the standards and implementation specifications.
• The National Coordinator will consult with the Director of the National Institute of Standards and Technology in creating the certification programs.
• Implications of certification standards that do not support or require “interoperable” health network
Providers
Focus on Certification and Standards Foundation:
Functionality - ensuring that the systems can support the activities and perform the functions for which they are intended;
Security - ensuring that systems can protect and maintain the confidentiality of data entrusted to them; and
Interoperability - ensuring that systems implement the recognized standards and can exchange information and work with other systems.
Providers
Evaluate current Technology
Determine if the Technology is being programmed to address
Objectives 2011
Measures 2011
Focus on Interoperability, Functionality and Security
Evaluate Current Operations
Evaluate New Technology
Take Pro-active Steps
Monitor Objectives and Measures
Monitor Technology Compliance
Evaluate Disparate Programs
Take steps to ensure compliance with measures
Reporting mechanisms
Thank you
Michele MadisonPartner, Healthcare Practice
This presentation is provided as a general informational service to clients and friends of Morris, Manning & Martin LLP. It should not be construed as, and does not constitute, legal advice on any specific matter, nor does this message create an attorney-client relationship. These materials may be considered Attorney Advertising in some states. Please note, prior results discussed in the material do not guarantee similar outcomes.