Presentation Transcript

1. Meaningful Use: A Review of the EHR Program & the Exceptions for Radiologists

   February 20, 2013
2. Learning Objectives Explain Program requirements for Stage 1 meaningful use Differentiate core & menu set objectives, measures & applicable exclusions & clinical quality measures Describe program criteria for qualifying as an eligible professional (“EP”) & the registration process for program incentives Describe the Stage 2 requirements & exceptions for radiologists Assess the Program’s future based on regulatory & legislative activity
3. A Provision of the ARRA
4. What is a Meaningful User?
5. Expected Outcomes To improve quality, safety & efficiency of care while reducing disparities To engage patients and families in their care To improve care coordination To promote population and public health; and To ensure privacy and security protections for personal health information
6. Three Stages of MU “Government should slow down meaningful use implementation so providers get it right,” Jan 29, 2013 http://medcitynews.com/2013/01/government-should-slow-down-meaningful-use-implementation-so-providers-get-it-right/
7. Who is Eligible? M.D. D.O. Doctor of Dental Medicine or Surgery Medicaid OnlyEPs Medicare OnlyEPs Doctor of Optometry Doctor of PodiatricMedicine Chiropractor Nurse Practitioner Certified Nurse Midwife Physician Assistant Eligible for Both CMS ID #9844, #9845
8. Determining Eligibility CMS ID#2777, #3061, FAQ10464
9. POS 22 Analysis
10. Medicaid vs Medicare CMS ID#2707
11. Payment Incentives (CMS ID #2803) $1.5 billion available in incentive payments for eligible diagnostic imaging professionals Up to $44,000/EP if MU implemented by 10.3.2012 $39,000 if MU implemented by 10.2.2013
12. Incentive Payments & Federal Income Tax Are payments subject to federal income tax? “We note that nothing in the Act excludes such payments from taxation or as tax-free income. Therefore, it is our belief that incentive payments would be treated like any other income. Providers should consult with a tax advisor or the Internal Revenue Service regarding how to properly report this income on their filings.” CMS ID #2859
13. Payment “Adjustments” Carrot now . . . Stick later CMS ID#2797 *Stays @ -3% if >75% are meaningful users
14. Deferred Penalties
15. Program Registration Are radiologists eligible professionals? (“EPs”) Any healthcare professional who provides more than 10% of professional services outside inpatient &/or emergency room settings is eligible CMS notifies EPs of ineligibility (hospital-based status) via online registration EPs must be enrolled in PECOS Registration is online through CMS Do not have to be using CEHRT to register CMS ID #2633, 2861, #2791
16. Meaningful Use Stage 1 CMS ID #2793
17. CQMs CMS ID#2773
18. Core CQMs
19. Alternate Core CQMs
20. Additional CQMs
21. 15 Core Objectives 1. Computerized provider order entry (CPOE) 2. Drug-drug and drug-allergy checks 3. Maintain an up-to-date problem list of current and active diagnoses 4. E-Prescribing (eRx) 5. Maintain active medication list 6. Maintain active medication allergy list 7. Record demographics 8. Record and chart changes in vital signs 9. Record smoking status for patients 13 years or older 10. Report ambulatory clinical quality measures to CMS/States 11. Implement clinical decision support 12. Provide patients with an electronic copy of their health information, upon request 13.Provide clinical summaries for patients for each office visit 14. Capability to exchange key clinical information 15. Protect electronic health information CMS FAQ 10151
22. 10 Menu Objectives 1.Submit electronic data to immunization registries 2. Submit electronic syndromic surveillance data to public health agencies 3. Drug formulary checks 4. Incorporate clinical lab-test results 5.Generate lists of patients by specific conditions 6. Send reminders to patients for preventive/follow-up care 7.Patient-specific education resources 8. Electronic access to health information for patients 9. Medication reconciliation 10. Summary of care record for transitions of care
23. Menu Objectives: What if None are Relevant? It’s possible that none of the menu objectives are applicable to your scope of practice If you qualify for all of the exclusions then you can select 5 menu objectives & claim the exclusion for each CMS ID#2903
24. Multiple Locations EPs who work in more than one practice or at several locations but do not have access to certified EHRs at each facility must: Have at least 50% of their total patient encounters take place at locations with certified EHR technology; and Base all of their meaningful use objectives only on patient encounters that take place at locations with certified EHRs Per Jessica Kahn, technical director for health IT, CMS Include all patient encounters except POS 21 & 23 CMS ID#3065
25. Attestation A legal statement Attest to meeting objectives & thresholds Attestation program opened April 18, 2011 Meaningful Use Attestation Calculator http://www.cms.gov/apps/ehr/ Attestation website: https://ehrincentives.cms.gov CMS FAQ 10068, ID #3059, #3209
26. Radiologist Attestation (Feb 28, 2012) 213 diagnostic 37 interventional 44 rad onc 294 total
27. Radiologist Attestation(Feb 28, 2012)
28. Do I Have to Contribute to my CEHRT? No general requirement for providers to contribute a minimum dollar amount toward the CEHRT they use However . . . Physicians must comply with Physician Self-Referral Law, commonly referred to as the “Stark Law” Under the EHR exception to the Stark Law, physicians who receive a donation of EHR items & services from a DHS entity must satisfy each element of the exception at 42 CFR 411.357(w), which includes paying 15 percent of the donor’s cost for the items and services CMS ID#3603
29. Stage 2 Final Rule (CMS)
30. Stage 1 vs Stage 2 CMS ID#7529
31. Stage 2 Effective 2014 All EPs enter Program under Stage 1 requirements, regardless of year Spend two years in each Stage before proceeding to next Stage Maintain “core-menu” set format for objectives CMS ID#7529
32. Stage 2 Core Objectives
33. Stage 2 Core Objectives
34. Stage 2 Menu Objectives
35. CQMs CMS has finalized 64 CQMs CMS has aligned the EHR CQMs with other quality reporting programs to avoid redundancy or duplicative reporting EPs who submit PQRS measures using CEHRT will satisfy their CQM reporting requirement As in Stage 1, if no CQMs are applicable, EPs must report zeros on all 9 CQMs
36. Group Reporting Options CMS finalized “batch reporting” for core & menu objectives Batch file process requires objectives & measures to be assessed at the individual EP level 2+ EPs under one TIN considered an “EHR Incentive Group” Two options for CQM reporting EPs in SSP & Pioneer ACO model EPs reporting PQRS CQMs using CEHRT
37. Exceptions Stage 2 Final Rule finalized exceptions for EPs meeting certain criteria: Lack of face-to-face or telemedicine interaction with patients, thereby making compliance with MU criteria more difficult . . . and . . . Lack of follow up with patients Lack of control over the availability of Certified EHR Technology at their practice locations Last date to apply: July 1, 2014 Must be enrolled in PECOS as Radiology Radiology, pathology, anesthesiology “automatically” fall within the exception – Rob Anthony, CMS Webinar, August 24th Included Medicare Specialty Codes are diagnostic radiology (30), nuclear medicine (36), interventional radiology (94), anesthesiology (05), and pathology (22) EPs defined as “hospital-based” may participate in the Program if they can demonstrate they fund the acquisition, implementation, and maintenance of CEHRT including supporting hardware and any interfaces needed without reimbursement from an EH or CAH and uses the CEHRT in the IP and ER departments of a hospital. FAQ7731
38. RBMA Next Steps Mini-survey conducted to assess participation levels Data being compiled now Assumption: hospital-based radiologists are not participating unless . . . Hospital provides technology & includes radiologists GOAL: Meet with CMS to redefine “hospital-based” EP
39. Meaningful Use Audits CMS has hired Figliozzi & Co. (Garden City, NY) to audit providers who have attested to having achieved MU 3-year contract, $3.13 million Audited providers will receive a letter from Figliozzi & Co. EPs asked to supply supporting documentation with regard to EP’s attestation substantiating the encounters resulting in the calculation Looking for non-compliance CMS ID#7361
40. Congress of the United States Chairmen Dave Camp, Fred Upton, Wally Herger, Joe Pitts House Ways & Means, Energy & Commerce Believe EHR Incentive Program is weak & ineffective “Result will be a less efficient system that squanders taxpayer dollars & does little, if anything, to improve outcomes for Medicare.” “In 2009 Congress warned that failure to set a date certain for interoperable standards would put as much as $35 billion in taxpayer funds in the hands of providers who purchase & use EHR systems that are not interoperable.” “More than four and one half years & two final MU rules later, it is safe to say that we are no closer to interoperability in spite of the nearly $10 billion spent.” Recommendations: Immediately suspend distribution of incentive payments until universal interoperable standards are promulgated Commensurate delay in penalties Increase MU thresholds Eliminate subsidizing business practices that block exchange of information among providers http://waysandmeans.house.gov/uploadedfiles/hhs_ehr_mu2_final.pdf
41. EHR Program Under Attack?
42. Case Study 21 radiologists; imaging-center based only Select a CEHRT vendor Opted for complete CEHRT through its PACS vendor Seamless transition of demographics Obtain “buy-in” IT & imaging center personnel Developed a Steering Committee Educate personnel about group’s goals & objectives for meaningful use
43. Case Study (cont.) Explain how the group expects to meet Program requirements & assign tasks Educate how CEHRT integrates into PACS Test CEHRT prior to “go live” Attestation CMS desk difficult to work with Could not answer specific questions Process ultimately took four weeks Attestation instructions unclear
44. Case Study (cont.) Patient’s perspective Expectations about “cloud” technology exceed actual capabilities Why don’t their other physicians have access to data submitted to the radiology group’s “cloud?” Concern about security
45. Case Study (cont.) Current status: Monitoring results Generating reports through PACS dashboard showing a “snapshot’ of each radiologist’s status on any given day Red flag if compliance threshold for a specific objective is not met Specific patients identified if data elements are missing Group is concerned about the value of participation No information collected is used for clinical evaluation How does this data collection & reporting benefit the patient? Concerned ongoing expenses will be cost prohibitive once incentives cease
46. MSN’s Client Covenant