Oklahoma Electronic Health Record Incentive Program Coming January 2011

1. 1 Oklahoma Electronic Health Record Incentive Program�Coming January 2011� Oklahoma Health Care Authority Tuesday, August 31, 2010 John Calabro, CIO Good Afternoon I�ve been asked to give you the basics on Oklahoma�s EHR Incentive program; I�m Adolph Maren and on the panel is: I�ll request you hold your questions till the end of my presentation. Thanks, Keep in mind that the state is only involved in the Medicaid incentives. Medicare is being operated at the federal level. Everything we talk about today will be about Oklahoma�s incentive program which will be administered by OHCA for the state. Good Afternoon I�ve been asked to give you the basics on Oklahoma�s EHR Incentive program; I�m Adolph Maren and on the panel is: I�ll request you hold your questions till the end of my presentation. Thanks, Keep in mind that the state is only involved in the Medicaid incentives. Medicare is being operated at the federal level. Everything we talk about today will be about Oklahoma�s incentive program which will be administered by OHCA for the state.

2. 2 EHR Incentive Eligibility: EP Incentive Payments are based on the individual not the practice / group or clinic. A current Contract and practicing in Oklahoma Not hospital based: inpatient setting (place of service) POS 21; emergency room POS 23 Section 1903(t)(3)(B) of the Social Security Act list these five provider types as eligible for Medicaid payments. Pediatric dentist are included in the dentist category. A pediatrician must hold a four-year undergraduate college degree, a four-year Doctor of Medicine (M.D.) or Doctor of Osteopathy (D.O.) degree, plus at least three years of residency in training. A valid, unrestricted medical license and board certification in Pediatrics through either the American Board of Pediatrics (ABP) or the American Osteopathic Board of Pediatrics (AOPB). For EPs the reporting period must be within a calendar year. two exceptions: pediatricians and EPs practicing predominantly in a FQHC or RHC Pg 266 - Practices predominantly means an EP for whom the clinical location for over 50 percent of his or her total patient encounters over a period of 6 months in the most recent calendar year occurs at a federally qualified health center or rural health clinic. This list excludes Podiatrist, Optometrist and Chiropractors. These providers can apply for incentive payments through Medicare. PA would be leading an FQHC or RHC under any of the following circumstances: (1) When a PA is the primary provider in a clinic (for example, when there is a part-time physician and full-time PA, we would consider the PA as the primary provider); (2) When a PA is a clinical or medical director at a clinical site of practice; or (3) When a PA is an owner of an RHC. We agree that FQHCs and RHCs that have PAs in these leadership roles can be considered ��PA-led.�� Furthermore, since RHCs can be practitioner owned (FQHCs cannot), we will allow ownership to be considered ��PA-led.��EP Incentive Payments are based on the individual not the practice / group or clinic. A current Contract and practicing in Oklahoma Not hospital based: inpatient setting (place of service) POS 21; emergency room POS 23 Section 1903(t)(3)(B) of the Social Security Act list these five provider types as eligible for Medicaid payments. Pediatric dentist are included in the dentist category. A pediatrician must hold a four-year undergraduate college degree, a four-year Doctor of Medicine (M.D.) or Doctor of Osteopathy (D.O.) degree, plus at least three years of residency in training. A valid, unrestricted medical license and board certification in Pediatrics through either the American Board of Pediatrics (ABP) or the American Osteopathic Board of Pediatrics (AOPB). For EPs the reporting period must be within a calendar year. two exceptions: pediatricians and EPs practicing predominantly in a FQHC or RHC Pg 266 - Practices predominantly means an EP for whom the clinical location for over 50 percent of his or her total patient encounters over a period of 6 months in the most recent calendar year occurs at a federally qualified health center or rural health clinic. This list excludes Podiatrist, Optometrist and Chiropractors. These providers can apply for incentive payments through Medicare. PA would be leading an FQHC or RHC under any of the following circumstances: (1) When a PA is the primary provider in a clinic (for example, when there is a part-time physician and full-time PA, we would consider the PA as the primary provider); (2) When a PA is a clinical or medical director at a clinical site of practice; or (3) When a PA is an owner of an RHC. We agree that FQHCs and RHCs that have PAs in these leadership roles can be considered ��PA-led.�� Furthermore, since RHCs can be practitioner owned (FQHCs cannot), we will allow ownership to be considered ��PA-led.��

3. 3 EHR Incentive Eligibility: 1903(t)(2)(B) of the Social Security Act A current Contract Section 1903(t)(2)(B) of the Social Security Act list these hospital types as eligible for Medicaid payments by CMS Certification Number. In regards to patient volume, Only Acute Care Hospitals which includes Critical access hospitals and cancer hospitals have a 10% SoonerCare patient volume requirement. Pg 172 of the PDF or 44484 of federal register / vol 75, no. 144. �Therefore, in the final rule, we are amending the definition of acute care hospital for purposes of the Medicaid EHR incentive payment program as ��those hospitals with an average patient length of stay of 25 days or fewer, and with a CCN that falls in the range 0001�0879 or 1300� 1399.�� This definition will now encompass general short-term hospitals, cancer hospitals, and critical access hospitals that meet the Medicaid patient volume criteria.�1903(t)(2)(B) of the Social Security Act A current Contract Section 1903(t)(2)(B) of the Social Security Act list these hospital types as eligible for Medicaid payments by CMS Certification Number. In regards to patient volume, Only Acute Care Hospitals which includes Critical access hospitals and cancer hospitals have a 10% SoonerCare patient volume requirement. Pg 172 of the PDF or 44484 of federal register / vol 75, no. 144. �Therefore, in the final rule, we are amending the definition of acute care hospital for purposes of the Medicaid EHR incentive payment program as ��those hospitals with an average patient length of stay of 25 days or fewer, and with a CCN that falls in the range 0001�0879 or 1300� 1399.�� This definition will now encompass general short-term hospitals, cancer hospitals, and critical access hospitals that meet the Medicaid patient volume criteria.�

4. 4 Registration 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 Everyone must register. Insure no duplicate payments and ensure CMS�s registration software is currently in development and we are told it will be ready before January 2011. OHCA starts beta testing in October. You can register at any time but when you are ready for the payment you must complete OHCA attestation. Each year providers must complete a new attestation. EPs must select Medicare or Medicaid; hospitals are able to select both NPI EPs INDIVIDUAL NPI for EPs; you can use a group TIN, however the NPI must be an individual�s Hospitals will need to input their CCN as well TIN � could be a groups or clinics TIN There is now an indication that providers must input the EHR certification number as well. Everyone must register. Insure no duplicate payments and ensure CMS�s registration software is currently in development and we are told it will be ready before January 2011. OHCA starts beta testing in October. You can register at any time but when you are ready for the payment you must complete OHCA attestation. Each year providers must complete a new attestation. EPs must select Medicare or Medicaid; hospitals are able to select both NPI EPs INDIVIDUAL NPI for EPs; you can use a group TIN, however the NPI must be an individual�s Hospitals will need to input their CCN as well TIN � could be a groups or clinics TIN There is now an indication that providers must input the EHR certification number as well.

5. 5 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 Registration Here are the responsibilities of OHCA in regards to program registration. The next step after registration is attestation.Here are the responsibilities of OHCA in regards to program registration. The next step after registration is attestation.

6. 6 It is our goal and the intent behind the incentive program for everyone to be able to qualify for the incentive payment. As I stated earlier you may register at any time at the federal level. When you do your attestation is when you will declare your patient volume. When you are ready to attest and apply for your incentive payment you will need to go to the provider secure site and attest through our electronic provider enrollment is where you will attest. Supporting documentation will need to be faxed and when verified you will receive your yearly payment in the following month. The next slides show the specific items required for attestation. It is our goal and the intent behind the incentive program for everyone to be able to qualify for the incentive payment. As I stated earlier you may register at any time at the federal level. When you do your attestation is when you will declare your patient volume. When you are ready to attest and apply for your incentive payment you will need to go to the provider secure site and attest through our electronic provider enrollment is where you will attest. Supporting documentation will need to be faxed and when verified you will receive your yearly payment in the following month. The next slides show the specific items required for attestation.

7. 7 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 For eligible professionals Office of the National Coordinator for Health Information Technology � Authorized Testing and Certification Body For eligible professionals Office of the National Coordinator for Health Information Technology � Authorized Testing and Certification Body

8. 8 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 For eligible hospitals Office of the National Coordinator for Health Information Technology � Authorized Testing and Certification Body Next I�ll discuss the adopt/implement/upgrade or meaningful use portion of the attestation. For eligible hospitals Office of the National Coordinator for Health Information Technology � Authorized Testing and Certification Body Next I�ll discuss the adopt/implement/upgrade or meaningful use portion of the attestation.

9. 9 Adopt / Implement / Upgrade Here is the definition of adopt, implement or upgrade or AIU for short. Evidence of installation will be required when adopting certified EHR. Staff training, data entry of patient demographic information into a certified EHR Here is the definition of adopt, implement or upgrade or AIU for short. Evidence of installation will be required when adopting certified EHR. Staff training, data entry of patient demographic information into a certified EHR

10. 10 Eligible Professional Payments Paid in alignment with the Calendar year First year amount consistent regardless of stage (AIU or M/U) 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 Maximum amount $63,750 EPs need not apply for payment over consecutive years. However EPs must receive their first payment by 2016. Next is some information on Eligible Hospital payments. Maximum amount $63,750 EPs need not apply for payment over consecutive years. However EPs must receive their first payment by 2016. Next is some information on Eligible Hospital payments.

11. 11 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 By the final rule, EH payments may be dispersed over a 3-6 year period; The state Medicaid HIT plan has proposed a 3 year disbursement with 50% dispersed in the first year followed by 40% then 10% of the total amount calculated. There is a pdf file on the memory stick you received which shows potential eligible hospital incentive payments for most of the eligible hospitals in Oklahoma; my thanks to the Oklahoma Hospital Association for developing that information. All the hospital specific information originates from the Healthcare Cost Report Information System (HCRIS) database provided by CMS.� It comes from annual Medicare Cost Reports (CMS-2559-96) filed by hospitals The file is also available on the OHCA EHR incentive program website in an excel file format available for download. �HOW MUCH COULD A HOSPITAL POTENTIALLY EARN?� By the final rule, EH payments may be dispersed over a 3-6 year period; The state Medicaid HIT plan has proposed a 3 year disbursement with 50% dispersed in the first year followed by 40% then 10% of the total amount calculated. There is a pdf file on the memory stick you received which shows potential eligible hospital incentive payments for most of the eligible hospitals in Oklahoma; my thanks to the Oklahoma Hospital Association for developing that information. All the hospital specific information originates from the Healthcare Cost Report Information System (HCRIS) database provided by CMS.� It comes from annual Medicare Cost Reports (CMS-2559-96) filed by hospitals The file is also available on the OHCA EHR incentive program website in an excel file format available for download. �HOW MUCH COULD A HOSPITAL POTENTIALLY EARN?�

12. 12 Monitoring / Oversight / Audit Attest to specific requirements Provide required documentation Keep supporting documentation on file Random sample and targeted sample reviews will be conducted In a nutshell, there is nothing special about this process other than the annual attestation QUESTIONS? In a nutshell, there is nothing special about this process other than the annual attestation QUESTIONS?