A Trail Guide to HITECH

1. A Trail Guide to HITECH

2. HITECH History February 17, 2009 President Obamasigns ARRA July, 2009 Formal recommendation to ONC on Meaningful Use July 13, 2010 Final Rules on Meaningful Use and Temporary Certification May, 2009 HIT Committeesappointed December, 2009 Initial rules published October 1, 2010 Incentive program forhospitals begins January 1, 2011 Incentive program for physicians begins 2

3. We are at the beginning of the single largest transformation of any industry in US history.

4. The final Rules didn’t change the important things This is still the greatest opportunity in our industry’s history Physicians still have to choose one program Medicare is still up to $44,000; Medicaid $63,750 There are still penalties for not participating And of course, there’s still Meaningful Use The provider must comply with submission of reports on clinical quality measures The EHR must be connected The EHR must be a certified product and include ePrescribing

5. If you remember just three things… The final rules provide: Greater flexibility to meet and report certain objectives for meaningful use – no longer “all or nothing”! Lowered metrics for EHR operational use in most instances Reduced number of clinical quality measures required It’s absolutely doable! 5

6. A Trail Guide

7. Acquire or Upgrade Your EHR Select your EHR. Make certain it’s sized to your practice, and has the capability to extend beyond Meaningful Use to Meaningful Value.

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11. Acquire or Upgrade Your EHR Select your EHR. Make certain it’s sized to your practice, and has the capability to extend beyond Meaningful Use to Meaningful Value. 4

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15. Meaningful Use is just “Base Camp”

16. Beyond Stage 1 Meaningful UsePursuing your vision for world class healthcare Stimulus Funds Are Only Part of the ROI Picture But in 2011,Stimulus Funds are the biggest return on your investment, so… the time is NOW! Source: Electronic Health Records: A Guide for Clinicians and Administrators, Jerome Carter, MD, FACP 16

17. What You Need To Do:General Program Details

18. HITECH - The Approach Stage 3 Stage 2 Stage 1 2011 2013 2015 Improved Outcomes Exchange of clinical data Advancement of processes Capture & Share Data

19. When do I have to be live, and for how long? First year of demonstration: Any continuous 90-day period within the payment year January 1, 2011 to April 1, 2011 March 13, 2011 to June 11, 2011 September 10, 2001 to December 9, 2011 Unallowable: November 1, 2011 to January 31, 2012 because it crosses into the next year Second payment year and beyond: The EHR reporting period will mean the entire payment year Sample dates

20. Do I have to use an EHR 100% of the time? 50% or more of your patient encounters during the EHR reporting period must be at one or more practices/locations equipped with a certified EHR Allows not only for the minimal levels of down-time expected from an EHR product, but for providers to still participate who work in multiple locations with varying adoption levels

21. Are the Medicaid & Medicare Meaningful Use requirements the same? The Medicare Rule is the minimum standard for the Medicaid incentive program States may add or modify measures related to Public Health and Registries

22. Who is eligible for the EP incentives? Medicare Doctor of medicine or osteopathy Doctor of dental surgery or medicine Doctor of podiatric medicine Doctor of optometry Chiropractor • Medicaid • Physician (MD and DO only) • Dentist • Certified nurse-midwife • Nurse practitioner • Physician Assistant (PA) practicing in a FQHC or RHC that is so led by a PA • Doctor of optometry (as allowed by the state)

23. How do I know if a PA qualifies as “lead”? • When a PA is the primary provider in a clinic • i.e. when there is a part-time physician and full-time PA, the PA would be considered the primary provider • When a PA is a clinical or medical director at a clinical site of practice • When a PA is an owner of an RHC, regardless of other providers delivering care there

24. Medicare Incentive Program

25. Schedule of payments

26. How will my incentive be calculated? Calculated by multiplying your submitted allowable charges to Medicare by 75%, up to the capped amount for the year Part B claims for the Fee for Service program Items in the Medicare Physician’s Fee Schedule Only the “professional” components, not the “technical” Only those furnished by the EP There is no minimum patient volume required

27. How will my incentive be calculated? • To collect the full incentive payment of $18,000 in 2011, you’ll need to submit allowable charges of at least $24,000 • However, you can earn an incentive with less (i.e., a payment of $12,000 for submitted allowables of $16,000) • Bonus: Physicians operating in a “health provider shortage area" (HPSA) will be eligible for an extra 10%

28. How does Medicare Advantage factor in? • Amounts paid by MAOs will be close to the amounts paid under Medicare FFS, but likely not identical • To participate in the MA program, the practitioner must: • be either employed by that MAO or furnish at least 80% of his or her services to that MAO’s enrollees • be employed by or be a partner in a group practice with an entity that furnishes at least 80% of its services to that MAO’s enrollees • furnish at least 20 hours per week of patient care services  • If you don’t hit that 80% threshold, your MA claims won’t count towards an incentive (only your Medicare FFS patient claims)

29. What about the penalties? • Must demonstrate Meaningful Use by 2014 or penalties will begin in 2015 • 1% reduction in the Medicare Physician Fee Schedule • If course isn’t corrected, additional 1% in 2016 and again in 2017 • Secretary of HHS can reduce additional 2% if nationwide EHR adoption is below 75% in 2017

30. Medicaid Incentive Program

31. How do I know if I qualify to participate in the Medicaid incentives? 30% of all patient encounters must be attributable to Medicaid over a continuous 90-day period within the most recent year Will apply a plain meaning test – no short-term outreach! Required to annually re-attest to patient volume thresholds Medicaid replacement plans count towards the threshold Medicaid patients assigned through capitation count, too Pediatricians can qualify with 20% (66% of normal requirement) Incentive paid will be $42,050 (66% of normal incentive)

32. How is the payment calculated under the Medicaid program? The incentive payments for Medicaid are flat fees intended to cover the “net average allowable” cost of purchasing, implementing and maintaining an EHR Nothing to do with claims value or volume of services rendered – no calculation involved Once you meet the threshold, it’s a flat fee payment schedule Total: $63,750 Years 2-6: $8,500/yr Year 1: $21,250

33. What if someone helps pay for my EHR? Outside funds, such as through a Stark program, that are directly attributable to payment for an EHR could be subtracted from the incentive However, the “average allowable costs” from CMS provide some flexibility Can accept as much as $29,000 in funding from other sources and still accept the maximum year one payment In following years, an eligible professional can receive as much as $10,610 in contributing funds and still accept the full payment

34. How does it work for providers in a FQHC / RHC? Must “practice predominantly” (more than 50% of the time) in a FQHC or RHC over a six month period Must have a minimum of 30% patient volume attributable to “needy individuals” over 90-days within the most recent year Needy individuals: Receive medical assistance from Medicaid or the CHIP Receive care by the provider for which they are uncompensated Receive services furnished at either no cost or reduced cost based on a sliding scale determined by the individual's ability to pay Bad debt is consistent with this definition

35. Can I switch between the programs? May switch one time from one program to the other If switching, you will continue in the new program at whichever payment year you would have attained in the first program had you not switched I.e., if two years were completed in Medicaid but you no longer met the 30% threshold of patient volume, you would be allowed to switch to the Medicare program at the level of the third year payment of that program Last year to switch is CY 2014

36. Proving Meaningful Use of an Electronic Health Record

37. What does Prove actually mean related to Meaningful Use incentives? Providing attestation through a secure mechanism (an online portal currently in development) for 2011 and 2012 Must identify the certified EHR technology in use Submit reports on product use and clinical metrics

38. What will the process be for registration? • Starting January 1, 2011, a web-based registration function will be launched • Will have to give the following information when registering: • Name, NPI, business address and business phone • Taxpayer Identification Number (TIN) to which you want the incentive payment made • Whether you elect to participate in the Medicare EHR incentive programs or the Medicaid EHR incentive program

39. How will I submit proof & required reports? • First opportunity to actually file for the incentives will be April 2011 • New web-based portal is being developed through which all required reports will be submitted • Note: Must keep records of all qualification & reports for six years following each Reporting Year (similar to HIPAA)

40. How will Meaningful Use be measured? • Two required components under HITECH statute • EHR Functional (operational) metrics • Clinical Quality Metrics • Can opt out of some metrics if they are irrelevant for your practice / patients • No longer any manual chart review required to determine if you’ve met the thresholds – everything can now be reported out of the EHR 40

41. What are the EHR Functional Metrics? • 15 Core measures • Required of everyone • 10 Menu Set measures • You choose five that best fit within your practice • Can attest that almost any of the metrics are irrelevant to your practice to remove it from the list and reduce the number of metrics you must report on

42. EHR Functional Measures (subset) • CPOE (medication orders only) was 80% 30% • ePrescribing was 75%40% • Drug screening Functionality enabled • Active medication list 80% • Active medication-allergy list 80% • Medication reconciliation 50% • Problem list in ICD-9-CM or SNOMED-CT 80% • Lab results (numeric) stored as structured data 40% • Clinical decision support was 5 One alert in use 42

43. Measures of EHR Use Recording patient vitals (height, weight & BP) 50% Record patient demographics 50% Patient information: electronic copy uponrequest in three business days 50% Patient access to electronic information (i.e. lab results) within four business days 10% Clinical summary of each visit to patient 50% Patient reminders (electronic) on request 20% * See Allscripts web site for entire list

44. Measures of EHR Use: Interoperability Tests Electronic data exchange with provider notin the same organization 1 test Submission of reportable lab data to PHD* 1 test Submission of immunization reports to PHD 1 test Submission of syndromic surveillance to PHD 1 test Can be dummy data but cannot be simulated tests *PHD = Public Health Department 44

45. High Five News! Reporting got so much easier! Numerator / Denominator concept Almost entirely from patients tracked in the EHR Drastically reduces the administrative work required to report on MU compliance

46. Standing Ovation: Flexibility IF a core measure cannot be met, attest to an acceptable reason for its “exclusion,” and your total number of required measures is reduced: you do not have to substitute another ! • Example: What if the majority of your patients live in rural areas with no access to a Pharmacy that accepts eRx – you cannot meet the threshold requirement. • Simply attest to that reason and your number of 20 Stage 1 requirements is now lowered to 19.

47. Clinical Quality Measures

48. What are Clinical Quality Measures? Essentially, the measure of the care you’re providing to your patients based on administrative or medical record data Once benchmark data is gathered, analyzing this data will allows government and the industry to identify patterns in diagnosis & treatment related to geography, insurance coverage, race, language and other segmentation Effective, Safe, Timely Care, Patient-Centered

49. Which specialties are covered by the proposed measures? Cardiology Pulmonology Endocrinology Oncology Proceduralist/Surgery Primary Care Physicians Pediatrics • Obstetrics and Gynecology • Neurology • Psychiatry • Ophthalmology • Podiatry • Radiology • Gastroenterology • Nephrology This approach is out! * See Allscripts web site for list of specialty-specific measures

50. What is the new rule about CQM? • 44 total Clinical Quality Measures included in Rule • Down from 90! • Must report on six to be compliant • Three Core • Can select Alternative Core measures depending on relevance • An additional three that you choose * See Allscripts web site for entire list