insights webinar - regulations recap

Regulation Recap - Meaningful Use Wednesday, November 19, 2014

Disclaimer: Nothing that we are sharing is intended as legally binding or prescriptive advice. This presentation is a synthesis of publically available information and best practices.

Jonathan Everett

I have been around the Healthcare IT arena for over 12 years

Vice President of Business Development for Quirk Healthcare

Reside in Portland, OR – it rules

Quick Introduction

• Set of standards defined by the Centers for Medicare & Medicaid Services (CMS)

• Financial incentives for using certified EHR technology (CEHRT):

– In a meaningful manner

– For electronic exchange of health information

– Submit Clinical Quality Measures (CQM)

Meaningful Use - Overview

Meaningful Use Stages

Data capture and sharing

Advanced clinical processes

Improved outcomes

Stage 1

Stage 2

Stage 3

Meaningful Use Stages

* For Medicaid providers only

Medicare Reimbursement

MU Stage 2011 2012 2013 2014 2015 2016

Year 1 $18,000 $18,000 $15,000 $12,000

Year 2 $12,000 $12,000 $12,000 $8,000

Year 3 $8,000 $8,000 $4,000 $4,000

Year 4 $4,000 $4,000 $2,000

Year 5 $2,000 $2,000

Medicaid ReimbursementMU Stage

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021

AIU (Year 1)

$21,250 $21,250 $21,250 $21,250 $21,250 $21,250 $21,250 $21,250 $21,250 $21,250 $21,250

MU1 (Year 2)

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

MU1 (Year 3)

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

MU2(Year 4)

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

MU 2 (Year 5)

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

MU 2/3 (Year 6)

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

Meaningful Use Eligibility

• Doctors of medicine or osteopathy

• Doctors of dental surgery or dental medicine

• Doctors of podiatry

• Doctors of optometry

• Chiropractors

MU1 vs MU2

MU1

•13 Core

•5/10 Menu

•Total: 18

MU2

•17 Core

•3/6 Menu

•Total: 20

MU1 2013 vs MU1 2014

• Patient Portal added as a Core Measure

• Other minor changes:

https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/stage1changestipsheet.pdf

Penalties

Data Year Penalty Year Penalty Amount

2014 2015 -1%

2015 2016 -2%

Continues at additional -1% each year

Rule UpdatesIf you were scheduled to demonstrate:

Using 2011 Edition CEHRT to do:

Using 2011 & 2014Edition CEHRT to do:

Using 2014 Edition CEHRT to do:

Stage 1 in 2014 2013 Stage 1 objectives and measures*

2013 Stage 1 objectives and measures*

OR2014 Stage 1 objectives and measures*

2014 Stage 1 objectives and measures

Stage 2 in 2014 2013 Stage 1 objectives and measures*


OR2014 Stage 1 objectives and measures*

OR Stage 2 objectives and measures*


ORStage 2 objectives and measures

To Use Any Of The Methodologies with An Asterisk

You must attest that you could not fully implement 2014 Edition CEHRT for the EHR reporting period in 2014 due to

delays in 2014 Edition CEHRT availability. This can be delays with the certification, issues caused with defects, or delay in ancillary products (like reports and HISPs).

Medicaid

Medicaid providers:

Do not need to start attesting until 2016 to receive full amount.

Can do AIU the first year for first payment.

Do not have a sequential year requirement.

…. So ignore the next several slides.

Using the Correct MU Version

If you are on a 2011 certified system, you MUST use 2013 MU 1 requirements.

If you are on a 2014 certified system, you MUST use 2014 MU 1 requirements. This means the patient portal is a core measure.

If this is your first year attesting…

You need to attest by October 1, 2014 or face penalty in 2015.

Hardship exceptions for 2015 have to be submitted by November 30th.

Keep an eye out for 2016 hardship exceptions.

If this is your second year attesting…

You must attest for a quarter by end of year.

If you are on a 2011 certified version, you attest using MU1 2013 requirements.

If you are on a 2014 certified version, you attest using MU1 2014 requirements. This requires a patient portal.

If this is your third or fourth year attesting…

You must attest for a quarter by end of year.

You may either:

If you are on a 2011 certified version, you attest using MU1 2013 requirements.

If you are on a 2014 certified version, you attest using MU1 2014 requirements. This requires a patient portal.

Or attest using Stage 2.

Some Words of Caution

Providers who are attesting for their fourth or fifth year of Meaningful Use in 2015 will have to attest for the full year (well, unless CMS changes their mind again).

For Medicaid providers, not all states will have their attestation portals ready in time. Contact your state for more details.

Q&[email protected]