Oklahoma Electronic Health Record Incentive Program

1. OklahomaElectronic Health Record Incentive Program Oklahoma Health Care Authority Board Retreat Thursday, August 26, 2010 Carol McFarland, CPA, CGFM Melody Anthony, M.S. Performance & Reporting Manager Provider Services Director Adolph Maren Jr., M.A. Senior Planning Coordinator

2. Oklahoma EHR Incentive Program Origin: American Recovery & Reinvestment Act of 2009 Health Information Technology provisions of the ARRA • Title XIII, Division A, HIT • Title IV of Division B, Medicare and Medicaid HIT "HITECH Act" The Health Information Technology for Economic and Clinical Health Act established programs under Medicare and Medicaid to provide incentive payments for the "meaningful use" of certified EHR technology.

3. Oklahoma EHR Incentive Program HITECH Legislation’s purpose: To improve outcomes, facilitate access, simplify care, and reduce costs of health care nationwide by providing: • Major financial support to provider and States; • Learning opportunities created and leverages through technical assistance from CMS and others; • Will establish sustainable data-driven infrastructure that will create a framework for improving healthcare quality and outcomes  

4. Oklahoma EHR Incentive Program • Federal Partner responsibilities • Centers for Medicare & Medicaid Services • incentive program and meaningful use (MU) • Final Rule for EHR Incentives & MU - July 13, 2010 • www.cms.gov/EHRIncentivePrograms/ • Office of the National Coordinator of Health Information Technology • certification standards program for EHR technology • temporary certification program – • final rule published June 18, 2010 • effective June 24, 2010 • permanent certification program is expected to be published this fall • www.HealthIT.hhs.gov

5. Oklahoma EHR Incentive Program Incentive to . . . • Adopt (acquire and install) • Implement (commenced utilization, train staff, deploy tools, exchange data) • Upgrade (expand functionality or interoperability) Or… • Meaningfully Use (meet specified criteria) . . . a certified EHR System Oklahoma’s Program begins January 2011

6. Oklahoma EHR Incentive Program Provider Eligibility, Registration and Attestation

7. EHR Incentive Eligibility: Oklahoma EHR Incentive Program *Needy individuals = SoonerCare members, patients receiving uncompensated care and patients receiving services at reduced or no cost based upon ability to pay

8. EHR Incentive Eligibility: Oklahoma EHR Incentive Program * CCN - CMS Certification Number

9. Patient Volume Calculation Oklahoma EHR Incentive Program • Based upon CMS final rule • A Patient Volume Documentation worksheet will be provided as part of attestation process • Provider defined 90 day period in the calendar year Number of SoonerCare* member encounters Number of total patient encounters * or Needy Patient encounters for EPs providing services at a FQHC/RHC

10. Registration Oklahoma EHR Incentive Program • EPs and EHs are required to register with the Medicare and Medicaid registration and attestation system • Name, NPI, business address, phone • Tax payer ID Number (TIN) • Hospitals must provide the CCN • EPs must select Medicare or Medicaid • May switch once between programs before 2015 • If Medicaid, must select one state • May switch states annually

11. Registration Oklahoma EHR Incentive Program OHCA will: • Connect to federal repository to facilitate provider attestation • Continue verification of eligibility • Disburse payment after cross-checking for potential duplicative, inappropriate payments and verification of supporting documentation • Disburse payment to one eligible TIN • Notify the national repository upon payment

12. Oklahoma EHR Incentive Program Electronic Attestation Process • Provider registers with CMS • CMS directs providers to the OHCA website for enrollment in the Oklahoma EHR incentive program • Providers fill out attestation • Identify your ONC-ATCB* certified EHR system • Complete patient volume worksheet • Electronically sign contract ammendment and fax requested documention to OHCA *Office of the National Coordinator for Health Information Technology – Authorized Testing and Certificaiton Body

13. Oklahoma EHR Incentive Program EP Electronic Attestation • Provider is not a hospital based professional • Provider must provide services in Oklahoma • Provider is not receiving an incentive payment from another state for that calendar year • Provider has adopted, implemented or upgraded a certified EHR • Provider inputs the certification number for the ONC-ATCB certified EHR system • Provider list number of FTE jobs created by implementing a certified product • Provider reports cash payments made for the certified EHR • Provider confirms assignment of payment to a qualified TIN • Providers percentage of SoonerCare patient volume is equal to or greater than the allowed • Provider has specified the patient volume date range of 90 days during the calendar year

14. Oklahoma EHR Incentive Program EH Electronic Attestation • Hospital is not currently receiving an incentive payment from another state for that federal fiscal year • Hospital must be located in Oklahoma • Hospitals (Medicaid only) have adopted, implemented or upgraded a certified EHR, or meaningfully used a certified EHR • ONC-ATCB EHR Certification number is included • Hospital list number of FTE jobs created by implementing a certified product • Hospital (acute care) percentage of SoonerCare discharges is at least 10%; Children's hospitals have no discharge percentage

15. Oklahoma EHR Incentive Program Adopt / Implement / Upgrade • Adopted – Acquired and Installed • Implemented – Commenced Utilization • Upgraded – Expanded Upgraded to certified EHR technology or added new functionality to meet the definition of certified EHR technology • Must be certified EHR technology capable of meeting meaningful use • No EHR reporting period • Only for first participation year

16. Oklahoma EHR Incentive Program Meaningful Use (MU) of EHR The Recovery Act specifies the following 3 components of Meaningful Use: • Use of certified EHR in a meaningful manner • Use of certified EHR technology for electronic exchange of health information to improve quality of health care • Use of certified EHR technology to submit clinical quality measures(CQM) and other such measures selected by the Secretary

17. Meaningful Use of EHR – Health Outcome Priorities Improve quality, safety, efficiency, and reduce health disparities Engage patients and families in their health care Improve care coordination Improve population and public health Ensure adequate privacy and security protections for personal health information Oklahoma EHR Incentive Program

18. Oklahoma EHR Incentive Program Meaningful Use of EHR • 3 Stages currently proposed • Stage 1 • EP: 20 of 25 Objectives / Measures • EH: 19 of 24 Objectives / Measures • To meet certain objectives/measures, 80% of patients must have records in the certified EHR technology • Reporting Period –90 days for first year; one year subsequently • Oklahoma will adopt MU measures as published. • CMS intends to propose 2 additional stages through future rulemaking. • At this time, CMS plans on transitioning the Stage 12 menu set into the Stage 2 core set.

19. Oklahoma EHR Incentive Program Eligible Professionals –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

20. Oklahoma EHR Incentive Program Eligible Hospitals –14 Core Objectives • CPOE • Drug-drug and drug-allergy interaction checks • Record demographics • Implement one clinical decision support rule • Maintain 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 • Report hospital clinical quality measures to CMS or States • Provide patients with an electronic copy of their health information, upon request • Provide patients with an electronic copy of their discharge instructions at time of discharge, upon request • Capability to exchange key clinical information among providers of care and patient-authorized entities electronically • Protect electronic health information

21. Oklahoma EHR Incentive Program Eligible Professionals –10 Menu Set 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 objective must be selected

22. Oklahoma EHR Incentive Program Eligible Hospitals –10 Menu Set Objectives • Drug-formulary checks • Record advanced directives for patients 65 years or older • Incorporate clinical lab test results as structured data • Generate lists of patients by specific conditions • 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 submission of reportable lab results to public health agencies • *Capability to provide electronic syndromic surveillance data to public health agencies *At least 1 public health objective must be selected

23. Oklahoma EHR Incentive Program Incentive Payments

24. Oklahoma EHR Incentive Program Eligible Professional Payments • Paid in alignment with the Calendar year • First year amount consistent regardless of stage (AIU or MU) • Maximum incentives are $63,750 over 6 years • Incentives are same regardless of start year • The first year maximum payment is $21,250 • Must begin by 2016 to receive incentive payments • No requirement for “consecutive years” participation • Incentives available through 2021 • Only 1 incentive payment per year

25. Eligible Hospital Payments Paid in alignment with the Federal Fiscal year (FFY) First year amount consistent regardless of stage (AIU or MU) $2M base + per discharge amount (based on Medicare/ Medicaid share) Medicare Meaningful Use requirements may be deemed eligible for Medicaid payments Payment is calculated, then disbursed over 3-6 years; we have proposed 3 year disbursement No annual payment may exceed 50% of the total calculation; no 2-year payment may exceed 90%; we have proposed 50% / 40% / 10% Hospitals cannot initiate payments after 2016 and payment years must be consecutive after 2016 States must use auditable data sources in calculating the hospital incentive (e.g., cost report) Payments through 2021 Oklahoma EHR Incentive Program

26. Eligible Hospitals Calculate total incentive in base year Calculated on a 4 year payment basis Payment over 3 years Year 1: 50% Year 2: 40% Year 3: 10% Oklahoma EHR Incentive Program

27. Eligible Hospitals (Overall EHR Amount) * (Medicaid Share) Defined as {Sum over 4 year of [(Base Amount)+ Discharge Related Amount Applicable for Each Year) * Transition Factor Applicable for Each Year]} . . . multiplied by . . . [Medicaid inpatient-bed-days / {(Total inpatient-bed-days) * (estimated total charges – charity care charges) / (estimated total charges)}] Oklahoma EHR Incentive Program

28. Oklahoma EHR Incentive Program Monitoring, Oversight & Audit

29. Monitoring / Oversight / Audit Attest to specific requirements Provide required documentation Keep supporting documentation on file Random sample and targeted sample reviews will be conducted Oklahoma EHR Incentive Program

30. Oklahoma EHR Incentive Program Adolph.Maren@okhca.org Melody.Anthony@okhca.org Carol.McFarland@okhca.org www.okhca.org/EHR-incentive Thank You!