Medicare & Medicaid EHR Incentive Programs

1. Medicare & MedicaidEHR Incentive Programs Robert Anthony Health Insurance Specialist HIT Initiatives Group Office of e-Health Standards and Services SAMHSA August 11, 2011

2. Who is Eligible to Participate Cont’d? • Eligibility determined in law • Medicare Eligible Professionals (EPs) • Doctor of Medicine or osteopathy • Doctor of dental surgery or dental medicine • Doctor of podiatry • Doctor of optometry • Chiropractors

3. Who is Eligible to Participate: Medicaid EPs • Physicians • Nurse practitioner • Certified nurse-midwife • Dentist • Physician assistant who furnishes services in a Federally Qualified Health Center or Rural Health Clinic that is led by a physician assistant. • Have a minimum 30% Medicaid patient volume* or • Have a minimum 20% Medicaid patient volume, and is a pediatrician* or • Practice predominantly in a Federally Qualified Health Center or Rural Health Center and have a minimum 30% patient volume attributable to needy individuals

4. Who is Eligible to Participate • Are mental health practitioners eligible to participate? • Yes, if you are: • Eligible in one of the Medicare/Medicaid EP categories • Not hospital-based (90% or more in POS 21/23) • Setting generally doesn’t matter (e.g., state mental health facility, long-term care facility, etc.)

5. So how’s it going so far? • Active Registrations as of July 2011 • 1,829 Hospitals (Medicare only, Medcaid only, and Medicare/Medicaid) • 77,549 Medicare + Medicaid EPs • Medicaid • 21 States launched their Medicaid EHR Incentive Program • 15 making payments

6. Medicare and Medicaid Payments • As of July 2011 • $248,014,670 in Medicaid payments (including $157 million to acute care hospitals and $20 million to children’s hospitals) • $149,351,883 in Medicare payments (including over $18.4 million to 566 eligible professionals) • $397,366,554 TOTAL PAYMENTS

7. Meaningful use

8. Medicaid: Adopt/Implement/Upgrade • Adopted – Acquired access to certified EHR technology in a legally and/or financially committed manner • Implemented – Began using certified EHR technology • Upgraded – Demonstrated having upgraded access to EHR technology newly certified in a legally and/or financially committed manner

9. Basic Stage 1 Overview • EP Payments based on Calendar Year • MU reporting period is 90 days for first year and 1 year subsequently • Reporting through attestation • 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

10. Stage 1 Measures • Eligible Professionals must complete: • 15 core objectives • 5 objectives out of 10 from menu set • 6 total Clinical Quality Measures (3 core or alternate core, and 3 out of 38 from menu set)

11. Exclusions • If an EP meets criteria for exclusion, then EP can claim exclusion during attestation. • If no exclusion is provided, or if EP doesn’t meet criteria for exclusion, then EP must meet measure in order to successfully demonstrate meaningful use and receive an EHR incentive payment.

12. EP Core Objectives/Measures • 15 Core Objectives • Computerized physician order entry (CPOE) • E-Prescribing (eRx) • Report ambulatory clinical quality measures to CMS/States • Implement one clinical decision support rule • Provide patients with an electronic copy of their health information, upon request • Provide clinical summaries for patients for each office visit • Drug-drug and drug-allergy interaction checks • Record demographics • 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 • Capability to exchange key clinical information among providers of care and patient-authorized entities electronically • Protect electronic health information

13. EP Menu Objectives/ Measures • 5 of 10 Menu Objectives • Drug-formulary checks • Incorporate clinical lab test results as structured data • Generate lists of patients by specific conditions • Send reminders to patients per patient preference for preventive/follow up care • Provide patients with timely electronic access to their health information • 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 • Capability to submit electronic data to immunization registries/systems* • Capability to provide electronic syndromic surveillance data to public health agencies* * At least 1 public health menu objective + 4 others

14. Clinical Quality Measures • 3 Core CQMs • 3 Alternate Core CQMs • Select 3 out of 38 Additional CQMs • No Thresholds – 0 is acceptable value • CQM reporting is currently through attestation • Future plans to accept CQM directly from providers’ EHRs (or through an intermediary) TBD

15. Registration and attestation overview

16. What You Need to Register • All providers must: • Register via the EHR Incentive Program website • Be enrolled in Medicare FFS, MA, or Medicaid (FFS or managed care) • Have a National Provider Identifier (NPI) • Use certified EHR technology • Medicaid providers may adopt, implement, or upgrade in their first year • All Medicare providers and Medicaid eligible hospitals must be enrolled in PECOS • http://www.cms.gov/EHRIncentivePrograms

17. Post-Registration Next Steps: Medicaid • States interface with the CMS EHR Incentive Program registration website • States ask providers to provide and/or attest to additional information in order to make accurate and timely payments, such as: • Patient Volume • Licensure • AIU or Meaningful Use • Certified EHR Technology

18. Certified EHR Technology • Required in order to achieve AIU and meaningful use • List of certified EHRs and EHR modules posted on ONC web site • Visit http://healthit.hhs.gov/certification for more information • Email ONC.Certification@hhs.gov with questions

19. Medicaid Attestation • Occurs at the State’s website (except for MU for dually-eligible EHs) • Includes eligibility elements (e.g. patient volume) and confirmation of having adopted, implemented or upgraded certified EHR technology, etc. • For the 2012 payment year, MU will be an option • Will communicate to the provider if attestation was successful or not • Provider follows up with the State if questions, to track attestation/payment status

20. Register & Attest for the EHR Incentive Programs • Visit the CMS EHR Incentive Programs website to: • Register for the EHR Incentive Programs • Attest for the Medicare EHR Incentive Programs • http://www.cms.gov/EHRIncentivePrograms/

21. EHR Incentive ProgramsWebsite

22. EHR Incentive Program Registration & Attestation Login Enter the Identity & Access management system User ID and Password User ID and Password are case sensitive

23. There are five tabs to help you navigate the registration and attestation module

26. There are five attestation actions Choose ATTEST to begin the attestation process A HELP tab is at the top of the screen for helpful tips navigating the system

27. In order to complete your attestation you must complete ALL of the topics Select START ATTESTATION to begin

28. Meaningful Use Core Measures

29. Meaningful Use Core Measures

30. Meaningful Use Core Measures EPs can be excluded from meeting an objective if they meet the requirements of the exclusion

31. Public Health Measures Select One Public Health

32. Additional Measures Submit additional menu measure objectives until a total of five menu measures have been selected Only the five chosen measures will present in the next five screens

33. Menu Measure

34. Clinical Quality Measures Denominator is entered before numerator for clinical quality measures Enter the exclusion number, if applicable

35. Clinical Quality Measures

36. Summary of Measures(Rejected Attestation)

37. User Guides and Other Resources • http://www.cms.gov/EHRIncentivePrograms/32_Attestation.asp

38. Audits • CMS will audit Medicare EPs for meaningful use • States will audit Medicaid EPs for A/I/U • All attestation elements are subject to audit. • Documentation should be retained for 6 years • Save supporting electronic/paper documentation • Save documentation to support your Clinical Quality Measures (CQMs) • If, based on an audit, a provider is found to not be eligible for an EHR incentive payment, the payment will be recouped. • CMS and the States will be implementing an appeals process for EPs, eligible hospitals and CAHs that participate in the EHR Incentive Programs.

39. Next Steps

40. Next Steps: What’s on the Horizon? • NPRM for Stage 2 (ETA: January 2012) • Proposed definition of Stage 2 meaningful use • Proposal on the payment adjustments and significant hardship exceptions • Other policies • Public Comment Period • Final Rule for Stage 2 (ETA: June 2012)

41. Stage 2 of Meaningful Use • HITPC submitted its recommendations to HHS • We will consider them for the NPRM in January 2012 • CMS/States have received significant communication expressing concerns about the Stage 2 implementation timing • Dr. Mostashari indicated his agreement with the HITPC’s request to delay Stage 2 for 12 months. • The NPRM public comment period is the time to weigh in and submit comments!

42. Resources for Information

43. Helpful Resources • CMS EHR Incentive Programs website: http://www.cms.gov/EHRIncentivePrograms • Frequently Asked Questions (FAQs) • Final Rule • Meaningful Use Specification Sheets • Meaningful Use Attestation Calculator • Registration & Attestation User Guides • Listserv • HHS Office of the National Coordinator of Health website: http://www.healthit.hhs.gov