Meaningful Use for Eligible Professionals (EPs) Q & A

1. Meaningful Use for Eligible Professionals (EPs) Q&A VITL Staff 06-16-2011 (updated 6-17-2011) V6.0

2. Notes Not legal advice CMS and State of Vermont rules may change Check vitl.net for updates Medicaid Medicare Medicare/Medicaid Carol Kulczyk ckulczyk@vitl.net Paul Forlenza pforlenza@vitl.net

3. Medicaid: Is reimbursement still based on 85% of EHR implementation costs? • Originally CMS required that eligible professionals prove spending at least 15% of the total cost of EHR technology • CMS now assumes EPs attesting to MU have met the 15% requirement • No proof is necessary for attestation but invoices should be kept for audit purpose

4. Medicaid: If we implemented an EHR in 2010, does that mean we have met meaningful use for 2011? • Adopting, implementing or upgrading (A/I/U) to a certified EHR will qualify you to receive an incentive payment for 2011 • Does not matter when the system was originally implemented. However, incentives are only available for certified systems • Patient volume thresholds must be met in any consecutive 90-day period from the previous 12 months from the date of attestation.

5. Medicaid: How do we calculate patient volume since we see patients with primary and secondary Medicaid coverage and Catamount MVP or BC? • All Medicaid encounters will count including secondary and Catamount • Medicaid % of unique patient encounters is calculated by dividing the Medicaid related encounters by total patient encounters for the reporting period • The state of Vermont will be issuing detailed rules for calculating patient encounters.

6. Medicaid: Does an EHR implementation need to be completed in 2011 to qualify for incentive payment? • EP does not have to install certified EHR technology • acquire, purchase or secure access to certified EHR • install or commence using certified EHR • expand functionality of certified EHR • upgrade to certified EHR • Signed contract indicating that the provider has adopted or upgraded would be sufficient

7. Medicare: What determines whether or not EP gets the maximum incentive payment? • Incentive Payments based on 75% of Part B allowable charges • To receive $18,000 (maximum in year 1), EP must have $24,000 in allowable charges • Medicaid does not have this requirement

8. Medicare: Incentive Payment • When an EP has attested to MU and has $24,000 in allowable charges for a calendar year, CMS will send a payment • If $24,000 is not reached in the calendar, CMS will make payment = 75% of allowable charges after February of the next calendar year • If $12,000 in 2011 allowable charges, CMS will make payment after February 2012 calculated as $12,000 x 75% = $9,000

9. Medicare/Medicaid: What are reporting periods for EPs? • Reporting period based on calendar year • Medicare: • 1st year: any consecutive 90 days for 1st year • 2nd year: one full calendar year • Medicaid: • 1st year: no reporting period; demonstrate A/I/U • 2nd year: any consecutive 90 days • 3rd year: one full calendar year

10. Medicare/Medicaid: Important Dates • Medicare • October 3, 2011 last day to begin 90-day reporting period for 2011 • February 29, 2012 last day to register and attest for MU to receive an incentive payment for 2011 • Medicaid • October 3, 2011 State of Vermont scheduled to open Medicaid incentive program • Check www.vitl.net for updates

11. Medicare/Medicaid: Definition of exchange of key clinical information – part I • Electronic transmission and acceptance of key clinical information using the capabilities and standards of certified EHR technology • Format • if information available in structured format, must be exchanged in structured format • if available only in unstructured electronic formats (e.g., free text/scanned images), unstructured information exchange would satisfy the measure

12. Medicare/Medicaid: Definition of exchange of key clinical information – part II • Following would not utilize the certification capability of certified EHR technology to electronically transmit the information and would not meet the measure of this objective • physical media such as CD-ROM, USB, hard drive • Using the method your EHR vendor utilized to certify your EHR will meet the requirements

13. Medicare/Medicaid: How do I attest to Meaningful Use? • Medicare • Attest using the CMS web based system • Medicaid • Check www.vitl.net for future announcements • VITL will help you be prepared for meeting MU and attest

14. VITL Services • Workflow analysis • Technology assessment vendor selection • Practice culture assessment • Project management • EHR vendor selection • EHR deployment and implementation • Implementing privacy policies consistent with HIPAA • Achieving meaningful use of the EHRs

15. Meaningful Use for Eligible Professionals (EPs) Q&A VITL Staff 06-16-2011 V5.0