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Overview of Meaningful Use August 30, 2010 IHS Office of Information Technology

Overview of Meaningful Use August 30, 2010 IHS Office of Information Technology. Today’s Session. This training will cover the following topics: EHR Incentive Programs – a Background Who Is Eligible to Participate How Much are the Incentives What are the Requirements/Meaningful Use

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Overview of Meaningful Use August 30, 2010 IHS Office of Information Technology

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  1. Overview of Meaningful UseAugust 30, 2010IHS Office of Information Technology

  2. Today’s Session This training will cover the following topics: • EHR Incentive Programs – a Background • Who Is Eligible to Participate • How Much are the Incentives • What are the Requirements/Meaningful Use • What You Need to Participate • Timeline of the Programs • Meaningful Use and IHS • Contacts and Resources

  3. EHR Incentive Programs – A Background

  4. Establishment of the EHRIncentive Programs “The American Recovery and Reinvestment Act of 2009 (ARRA) is an unprecedented effort to jumpstart our economy, create or save millions of jobs, and put a down payment on addressing long-neglected challenges so our country can thrive in the 21st century… preserve and improve affordable health care…” http://www.recovery.gov Included in ARRA is the Health Information Technology for Economic and Clinical Health (HITECH) Act, which: “Seeks to improve American health care delivery and patient care through an unprecedented investment in health information technology.”

  5. Establishment of the EHRIncentive Programs (cont’d) HITECH Act Programs Electronic Health Record (EHR) Incentive Program Authorizes the Centers for Medicare and Medicaid Services (CMS) to make incentive payments to eligible hospitals to promote the adoption and meaningful use of interoperable certified EHR technology One of several HITECH Programs created by ARRA Examples of other programs include: Regional Extension Centers: Assist providers seeking to adopt and become meaningful users of health IT Beacon Communities: Provides communities with funding to build and strengthen health IT infrastructure and exchange capabilities

  6. What is the EHRIncentive Program? • EHR Incentive Programs were established by law (ARRA) • This program is voluntary. However, Medicare penalties start in 2015 for hospitals and eligible professionals (EPs) that do not demonstrate Meaningful Use. There are no Medicaid penalties. • Programs for Medicare and Medicaid (they are different) • Programs for hospitals and EPs • EPs must choose between the Medicare and Medicaid programs; they are not eligible for both • Hospitals may participate in both programs if meet eligibility requirements • Must use certified EHR technology AND demonstrate adoption, implementation, upgrading or meaningful use • Medicare incentive program is federally run by CMS; Medicaid incentive program is run by States and is voluntary Slide content adapted from CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  7. EHR Incentive Programs – Eligible Professionals

  8. EP Eligibility – General • Eligible Professionals (EPs) • Must choose the Medicare OR Medicaid incentive program; not eligible for both • Eligibility determined by law • Hospital-based EPs are NOT eligible for incentives • DEFINITION: 90% or more of their covered professional services in either an inpatient or emergency room (Place of Service codes 21 or 23) of a hospital • Definition of hospital-based determined by law • Incentives are based on the individual, not the practice Slide content adapted from CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  9. EP Eligibility – Medicare • Medicare Eligible Professionals include: • Doctors of medicine or osteopathy • Doctors of dental surgery or dental medicine • Doctors of podiatric medicine • Doctors of optometry • Chiropractors • Specialties are eligible if meet one of above criteria Slide content provided by CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  10. EP Eligibility –Medicaid • Medicaid Eligible Professionals include: • Physicians • Nurse practitioners • Certified nurse-midwives • Dentists • Physician assistants working in a Federally Qualified Health Center (FQHC) or rural health clinic (RHC) that is so led by a physician assistant Slide content provided by CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  11. EP Eligibility – Medicaid (cont’d) • Medicaid Eligible Professionals must also meet one of the three patient volume thresholds: • Have a minimum of 30% Medicaid patient volume • Pediatricians ONLY: Have a minimum of 20% Medicaid patient volume • Working in FQHC or RHC ONLY: Have a minimum of 30% patient volume attributed to needy individuals Slide content adapted from CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  12. Participation with Other Incentive Programs Participation in EHR incentive program and other Medicare incentive programs Slide content provided by CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  13. How Much are theIncentives for Medicare? • Medicare Incentive Payments Overview • Incentive amounts based on Fee-for-Service allowable charges • Maximum incentives are $44,000 over 5 years • Incentives decrease if starting after 2012 • Must begin by 2014 to receive incentive payments • Last payment year is 2016 • Extra 10% bonus amount available for practicing predominantly in a Health Professional Shortage Area (HPSA) (identifies, by zip code or county, areas lacking sufficient clinicians to meet primary care needs) • Only one (1) incentive payment per year Slide content provided by CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  14. How Much are the Incentives – Medicare? (cont’d) Medicare Incentive Payments Detail Slide content adapted from CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  15. How Much are the Incentivesfor Medicaid? • Medicaid Incentive Payments Overview • Maximum incentives are $63,750 over 6 years • Incentives are same regardless of start year • The first year payment is $21,250 • Must begin by 2016 to receive incentive payments • No extra bonus for health professional shortage areas available • Incentives available through 2021 • Only one (1) incentive payment per year Slide content provided by CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  16. How Much are the Incentives – Medicaid? (cont’d) Medicaid Incentive Payments Detail Slide content adapted from CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  17. EHR Incentive Programs – Hospitals

  18. Who is Eligible toParticipate? • IHS hospitals are eligible to participate in both the Medicare and Medicaid incentive programs • Eligibility determined by law • Medicare Eligible Hospitals include: • Acute Care Hospitals • Subsection (d) hospitals that are paid under the PPS and are located in the 50 States or Washington, DC (including Maryland) • Critical Access Hospitals (CAHs) Slide content adapted from CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  19. Who is Eligible toParticipate? (cont’d) • Medicaid Eligible Hospitals include: • Acute Care Hospitals (now including CAHs) • Medicaid included critical access hospitals in its definition of “acute care hospital” (but incentive calculation is like other acute care hospitals; does not follow the Medicare CAH formula) • Children’s Hospitals • Acute care hospitals must meet a 10% Medicaid patient volume threshold Slide content adapted from CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  20. How Much are the Incentives? • $2M base + per discharge amount (based on Medicare/Medicaid share which effectively lowers the incentive amount) • Hospitals with larger Medicare/Medicaid populations will receive larger incentive payments • Medicare Critical Access Hospitals calculation does not start with a $2M base; uses EHR costs and Medicare share • Medicare’s calculation derives a yearly payment amount, while Medicaid’s calculation derives a total amount that States may pay eligible hospitals Slide content provided by CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  21. How Much are the Incentives? (cont’d) • Payment adjustments for Medicare begin in 2015 • No Federal Medicaid payment adjustments • Medicare hospitals: No payments after 2016 Slide content provided by CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  22. How Much arethe Incentives? (cont’d) • Medicaid Hospital specifics • Similar to Medicare hospital methodology • Payment is calculated, then disbursed over 3-6 years • No annual payment may exceed 50% of the total calculation; no 2-year payment may exceed 90% • 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 Slide content provided by CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  23. How Much are the Incentives? Medicare Subsection D Calculation • Medicare Subsection D Hospital Calculation (Base Amount + Discharge Related Amount Applicable for Each Year)* [(Medicare inpatient-bed-days + MedicareAdvantage inpatient-bed-days) / {(total inpatient-bed days) * (estimated total charges – charity care charges)/(estimated total charges)}] * Transition Factor Applicable for Each Year Slide content adapted from CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  24. How Much are the Incentives? Medicare CAH Calculation Medicare Critical Access Hospital Calculation [ (Reasonable costs incurred in that cost reporting period) + (Similarly incurred costs from previous cost reporting periods to the extent they have not been fully depreciated as of the cost reporting period involved) ] x [CAH’s Medicare Share + 20 percentage points] NOTE: Medicare Share is calculated the same way as shown previously for Subsection D hospitals. When the 20 percentage points are added, the total cannot be more than 100%.

  25. How Much Are the Incentives? Medicaid Hospital Calculation • Medicaid Acute Care (including CAH) Calculation (Overall EHR Amount) * (Medicaid Share) Where: Overall EHR Amount = {Sum over 4 year of [(Base Amount)+ Discharge Related Amount Applicable for Each Year) * Transition Factor Applicable for Each Year]} * Medicaid Share = [(Medicaid inpatient-bed-days + Medicaid managed care inpatient-bed-days) / {(total inpatient-bed days) * (estimated total charges – charity care charges)/(estimated total charges)}] Slide content adapted from CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  26. IncentivesSummary

  27. Meaningful Use Requirements

  28. What are the Requirements/ Meaningful Use? As mandated by law, to receive the incentives EPs and hospitals must adopt and demonstrate meaningful use of certified EHR technology Exception: The provider/hospital’s first year of the Medicaid incentives only require adopting, implementing, or upgrading to certified EHR technology and do not require the achievement of meaningful use. All other years require demonstration of meaningful use.

  29. What are the Requirements/ Adopt/Implement/Upgrade? • MEDICAID – only for first participation year • Adopted – Acquired and Installed • Eg: Evidence of installation prior to incentive • Implemented – Commenced Utilization of • Eg: Staff training, data entry of patient demographic information into EHR • Upgraded – Expanded • Upgraded to certified EHR technology or added new functionality to meet the definition of certified EHR technology • The EHR technology must be certified and capable of meeting meaningful use • No EHR reporting period Slide content provided by CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  30. What are the Requirements/ Meaningful Use? (cont’d) • Meaningful Use is using certified EHR technology to: • Improve quality, safety, efficiency, and reduce health disparities • Engage patients and families in their health care • Improve care coordination • Improve population and public health • All the while maintaining privacy and security Slide content provided by CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  31. What are the Requirements/ Meaningful Use? (cont’d) • ARRA specifies the following 3 components of Meaningful Use: • Use of certified EHR in a meaningful manner (e.g., e-prescribing) • 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 Slide content adapted from CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  32. What are the Requirements/ Meaningful Use? (cont’d) • EHR Certification and MU are not the same thing • Certification is what the EHR can do – responsibility of OIT • MU is how the EHR is used – responsibility of providers and hospitals with assistance from national staff • EHR Deployment Team is responsible for deploying (implementing) the EHR at sites that do not have it • It is the responsibility of the facility staff to ensure they know the MU requirements and use the EHR as needed to meet MU

  33. Real Life Example of MU

  34. What are the Requirements/ Meaningful Use? (cont’d) • RPMS sites must be using the EHR to meet MU • Sites only using RPMS roll-and-scroll will not meet MU • Commercial vendors of EHRs are subject to same MU requirements, standards, process and schedule as RPMS EHR

  35. What are the Requirements/ Meaningful Use? (cont’d) Stage 3 2015+ Stage 2 2013-2014 Stage 1 2011-2012 Rule making was open to public comment Listened to many comments received Established 3 stages of meaningful use: 2011, 2013 and 2015 Slide content adapted from CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  36. What are the Requirements/ Meaningful Use? (cont’d) • Basic Overview of Stage 1 Meaningful Use: • Payments based on calendar year for providers and federal fiscal year for hospitals • Reporting period is any consecutive 90 days for first year and 1 year subsequently • Reporting through attestation • Objectives and Clinical Quality Measures • Reporting may be yes/no or numerator/denominator attestation • To meet certain objectives/measures, 80% of patients must have records in the certified EHR technology Slide content provided by CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  37. What are the Requirements/ Meaningful Use? (cont’d) Stage 1 Objectives and Measures Reporting Slide content adapted from CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  38. What are the Requirements/ Meaningful Use? (cont’d) • Some MU objectives not applicable to every provider’s clinical practice, thus they would not have any eligible patients or actions for the measure denominator • In these cases, the eligible professional, eligible hospital or CAH would be excluded from having to meet that measure • E.g.: Dentists who do not perform immunizations; Chiropractors do not e-prescribe • Exclusions do not count against the 5 deferred measures Slide content provided by CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  39. What are the Requirements/ Meaningful Use? (cont’d) • Core Objectives: 15 for EPs and 14 for Hospitals • Computerized physician order entry (CPOE) • E-Prescribing (e-Rx) – EPs only • Drug-drug and drug-allergy interaction checks • Record demographics • Implement one clinical decision support rule • Maintain an up-to-date problem list of current and active diagnoses • Maintain active medication list • Maintain active medication allergy list • Record and chart changes in vital signs • Record smoking status for patients 13 years or older Slide content adapted from CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  40. What are the Requirements/ Meaningful Use? (cont’d) • Core Objectives (cont’d) • Report clinical quality measures to CMS/States (EPs report ambulatory; hospitals report inpatient measures) • Provide patients with an electronic copy of their health information, upon request • Provide patients with an electronic copy of their discharge instructions at time of discharge, upon request - hospitals only • Provide clinical summaries for patients for each office visit – EPs only • Capability to exchange key clinical information among providers of care and patient-authorized entities electronically • Protect electronic health information Slide content adapted from CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  41. What are the Requirements/ Meaningful Use? (cont’d) • Menu Objectives: EPs and hospitals choose 5 of 10 and must include at least 1 public health objective (marked with asterisk) • Drug-formulary checks • Record advanced directives for patients 65 years or older – hospitals only • Incorporate clinical lab test results as structured data • Generate lists of patients by specific conditions • Use certified EHR technology to identify patient-specific education resources and provide to patient, if appropriate • Medication reconciliation • Summary of care record for each transition of care/referrals Slide content adapted from CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  42. What are the Requirements/ Meaningful Use? (cont’d) • Menu Objectives (cont’d) • Capability to submit electronic data to immunization registries/systems* • Capability to provide electronic submission of reportable lab results to public health agencies* - hospitals only • Capability to provide electronic syndromic surveillance data to public health agencies* • Send reminders to patients per patient preference for preventive/follow up care – EPs only • Provide patients with timely electronic access to their health information – EPs only Slide content adapted from CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  43. What are the Requirements/ Meaningful Use? (cont’d) • An Eligible Professional who works at multiple locations, but does not have certified EHR technology available at all of them would: • Have to have 50% of their total patient encounters at locations where certified EHR technology is available • Would base all meaningful use measures only on encounters that occurred at locations where certified EHR technology is available Slide content provided by CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  44. What are the Requirements/ Meaningful Use? (cont’d) • States can seek CMS prior approval to require the following 4 MU objectives to be core for their Medicaid providers: • Generate lists of patients by specific conditions for quality improvement, reduction of disparities, research, or outreach (can specify particular conditions) • Reporting to immunization registries, reportable lab results, and syndromic surveillance (can specify for their providers how to test the data submission and to which specific destination) Slide content provided by CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  45. What are the Requirements/ Meaningful Use? (cont’d) • Meaningful Use for hospitals that qualify for both Medicare & Medicaid payments • Attest/Report on Meaningful Use to CMS for the Medicare EHR Incentive Program • Will be deemed meaningful users for Medicaid (even if the State has CMS approval for the MU flexibility around public health objectives) Slide content adapted from CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  46. What are the Requirements/ Meaningful Use? (cont’d) A Medicare hospital or Eligible Professional who does NOT demonstrate meaningful use by 2015 will be subject to payment reductions in their Medicare reimbursement schedule Medicaid-only EPs and hospitals that are not eligible for the Medicare incentive are not subject to the Medicare payment reductions Payment reductions may apply for any EP who accepts Medicare, even if you only participate in the Medicaid EHR incentive program Slide content adapted from CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  47. What are the Requirements/ Meaningful Use? (cont’d) • Future Stages of Meaningful Use • Intend to propose 2 additional Stages through future rulemaking. Future Stages will expand upon Stage 1 criteria. • Stage 1 menu set will be transitioned into core set for Stage 2. • Administrative transactions will be added. • CPOE measurement will increase to 60%. • Will reevaluate other measures – possibly higher thresholds. • Stage 3 will be further defined in next rulemaking. Slide content provided by CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  48. Clinical Quality Measuresfor EPs Clinical Quality Measures – Core Set for Eligible Professionals Slide content provided by CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  49. Clinical Quality Measures for EPs (cont’d) Clinical Quality Measures – Alternate Core Set for Eligible Professionals Slide content provided by CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

  50. Clinical Quality Measures for EPs (cont’d) • Additional set CQM for EPs– must report 3 of 38 • Diabetes: Hemoglobin A1c Poor Control • Diabetes: Low Density Lipoprotein (LDL) Management and Control • Diabetes: Blood Pressure Management • Heart Failure (HF): Angiotensin-Converting Enzyme (ACE) Inhibitor or Angiotensin Receptor Blocker (ARB) Therapy for Left Ventricular Systolic Dysfunction (LVSD) • Coronary Artery Disease (CAD): Beta-Blocker Therapy for CAD Patients with Prior Myocardial Infarction (MI) • Pneumonia Vaccination Status for Older Adults • Breast Cancer Screening Slide content adapted from CMS (EHR_Incentive_Program_EP_Training_Final ONC changes 8 10 10.pptx)

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