Series 1: “Meaningful Use” for Behavioral Health Providers

1. Series 1: “Meaningful Use” for Behavioral Health Providers From the CIHS Video Series “Ten Minutes at a Time” Module 7: Meeting the PBHCI Grant HIT-Related Expectations for the Meaningful Use Standard and Understanding the Eligible Professional Incentive Program 9/2013

2. Module 7 Outline • Review of the grant expectations around meeting the standards for “Meaningful Use” • Review of the Eligible Professional (EP) Incentive Program • How to meet the grant expectations for “Meaningful Use” regardless of EP Incentive Program participation

3. Grant Expectations* • SAMHSA expects PBHCI grantees to achieve Meaningful Use Standards, as defined by CMS, by the end of the grant period; to that end, applicants must propose how they will develop and demonstrate the ability to: • Submit at least 40% of prescriptions electronically (as allowable given state-specific laws regarding the use of e-prescriptions for controlled substances); • Receive structured lab results electronically; • Share a standard continuity of care record between behavioral health providers and physical health providers; and • Participate in the regional extension center program. • *Page 9 of Request for Applications (RFA), No. SM-12-008, “PBHCI”

4. “Meaningful Use Standard” (Stage 1) • Set of standards and specific criteria (15 Core and 5 of 10 Menu Objectives and Measures)* • Defined by CMS specifically for the Eligible Professional (EP) Incentive Program • Measures are calculated by each Eligible professional • Denominator = all of the patients they have seen • Numerator = all of the patients who received the “Meaningful Use” related service • Produces a percent that is compared to the Measure requirements http://www.healthit.gov/

5. What the Grant Requires for “Meaningful Use” • Grant does not require participation in the Eligible Professional Incentive Program • Grant does require that the project achieve the standards for “Meaningful Use” for patients enrolled in the PBHCI initiative and their data is entered into the certified Complete EHR

6. Eligible Professional Incentive Program • As noted in Module 1, this series refers to the standards for the Medicaid EP Incentive Program, and Stage 1 of Meaningful Use • Eligible to register*: • Physician; nurse practitioner; certified nurse (midwife); dentist; physician’s assistant, but only under specific conditions related to Federally Qualified Health Centers (FQHC) and Rural Health Centers (RHC) • 30% Medicaid patient volume OR practice predominantly in an FQHC or RHC • * https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/downloads/EHRMedicaidEP_RegistrationUserGuide.pdf

7. Incentive Payments* • Registered EP must meet measure threshold for each applicable Core and Menu Objective • Stage 1, Year 1, “Acquire, Implement, Use (AIU) • Stage 1, Year 2, 12 months continuous at full implementation • Organization attests that EP has met threshold and “receives” the incentive (usually not pocketed by the EP) • Max $63,750 per EP over 6 years (Stages 1, 2 & 3) *Please note that these are the requirements for the Medicaid track. The Medicare track has slightly different requirements http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/index.html?redirect=/ehrincentiveprograms/

8. Meeting the Meaningful Use Standard:Grantee Employs EPs Participating Incentive Program • EXAMPLE • Core Objective #5 – Active Medication List • “Meaningful Use” Standard • More than 80 percent of all unique patients seen by the EP have at least one entry (or an indication that the patient is not currently prescribed any medication) recorded as structured data. • Denominator = unique patients seen by EP, entered into the EHR. Denominator includes PBHCI enrollees. • Numerator = unique patients seen by the EP, entered into the EHR, and have at least one entry recorded as structured data.

9. Meeting the Meaningful Use Standard:Grantee Does Not Employ EPs, or EPs Not Participating • Scenario 1: “No EPs employed by the grantee,” solution • Consult with GPO • Grantee will still be required to meet the standard. • Use population-based measures • All PBHCI enrollees entered into the EHR are the denominator • PBHCI enrollees receiving the service are the numerator • The necessary data is entered into the Behavioral Health provider certified EHR • Note: If Primary Care Partner is EP in the Incentive Program • Enters PBHCI enrollee data into the PCP EHR? Does NOT meet the PBHCI grant requirements!

10. Meeting the Meaningful Use Standard:Grantee Does Employ One or More EPs, Not Participating • Scenario 2: EP or EPs are employed by grantee (either as staff or via contract) but not participating in the incentive program • Act “as if” the EPs are in the incentive program BUT • Solution A: Use the PBHCI enrollees assigned to them as the denominator. The number of PBHCI enrollees receiving the service is the numerator OR • Solution B: Consider all EPs collectively as one single EP, with all of the PBHCI enrollees in the denominator. The total number of PBHCI enrollees receiving the services is the numerator.

11. Summary • All PBHCI grantees must ensure that the services enrollees in the project receive meet the standard for “Meaningful Use.” • SAMHSA does not require grantee EPs to participate in the Eligible Professional Incentive Program • If the EP(s) employed by the grantee and seeing PBHCI enrollees is participating in the incentive program, this assures the project meets the grant requirement (as part of their participation in the incentive program) • If the PCP is not an employee of the grant recipient, or is not participating in the program, SAMHSA will accept one of three possible approaches to meeting this requirement

12. We Have Solutions for Integrating Primary and Behavioral Healthcare Contact CIHS for all types of primary and behavioral health care integration technical assistance and training needs 1701 K Street NW, Ste 400 Washington DC 20006 Web: www.integration.samhsa.gov Email: integration@thenationalcouncil.org Phone: 202-684-7457 Prepared and presented by Colleen O’Donnell, MSW, PMP, CHTS-IM for the Center for Integrated Health Solutions