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Criteria for HIT Stimulus Funding:  Meaningful Use and Certification Requirements May 4, 2010

EHR Incentive Payments Michele Madison mmadison@mmmlaw.com. Criteria for HIT Stimulus Funding:  Meaningful Use and Certification Requirements May 4, 2010. EHR Incentives. Funding Provider Financial Incentives Meaningful Use Timing. Governmental Incentives.

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Criteria for HIT Stimulus Funding:  Meaningful Use and Certification Requirements May 4, 2010

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  1. EHR Incentive PaymentsMichele Madisonmmadison@mmmlaw.com Criteria for HIT Stimulus Funding:  Meaningful Use and Certification RequirementsMay 4, 2010

  2. EHR Incentives • Funding • Provider Financial Incentives • Meaningful Use • Timing

  3. Governmental Incentives Medicare and Medicaid EHR Programs are estimated to provide incentives in the amount of: $9.7Billion to $27.4 Billion

  4. Government Incentives • Hospitals have received $155.3 million in Medicaid Adopt/Implement/Upgrade payments • Hospitals have received $124.9 million in Medicare meaningful use payments to date. • July 66 Hospitals Attested • June 49 Hospitals Attested • The number is increasing gradually

  5. Eligible Entities

  6. Who is Eligible? • Eligible Professionals • The Final Rule finalizes that hospital based eligible professionals to exclude only those physicians that provide 90% or more of their services in either an inpatient or emergency department. • Hospitals –Acute Care Hospitals that are paid on PPS • Critical Access Hospitals –The Final Rule Includes Critical Access Hospitals in the definition of eligible hospital for Medicaid incentives. • Children's’ Hospitals are eligible under Medicaid program

  7. Eligible Professionals Medicare A physician as defined in section 1861(r) of the Social Security Act*, which includes the following five types of professionals: Doctor of medicine or osteopathy Doctor of dental surgery or medicine Doctor of podiatric medicine Doctor of optometry Chiropractor

  8. Medicaid Program • Medicaid Eligible Professionals (30% population) • Physicians • Pediatricians (20% population) • Dentists • Certified nurse-midwives • Nurse practitioners • Physician assistants who are practicing in Federally Qualified Health Centers (FQHCs) or Rural Health Clinics (RHCs) led by a physician assistant. • Hospitals -10% Medicaid Patient Volume • Childrens Hospitals

  9. Registration • Eligible Providers may Register with • CMS starting on January 3, 2011 • State of Georgia registration opens in September 2011 • http://cms.gov/EHRIncentivePrograms • EPs may only participate in one program. • The EPs may change programs one time prior to 2015. • Hospitals may participate in both Medicare and Medicaid Programs.

  10. 3 Step Process • What do I need to do to receive my Medicare EHR incentive payment? • 1. Successfully register for the Medicare EHR Incentive Program; • 2. Meet meaningful use criteria using certified EHR technology; and • 3. Successfully attest, using CMS' Web-based system, that you have met meaningful use criteria using certified EHR technology.

  11. Numbers You Need • What can you do now for the Medicare and Medicaid EHR Incentive Programs? • Make sure you have enrollment records in the appropriate systems. You’ll need: • A National Provider Identifier (NPI) • All eligible professionals, eligible hospitals, and critical access hospitals (CAHs) must have a National Provider Identifier (NPI) to participate in the Medicare and Medicaid EHR Incentive Programs. • An enrollment record in the Provider Enrollment, Chain and Ownership System (PECOS) • All eligible hospitals and Medicare eligible professionals must have an enrollment record in PECOS to participate in the EHR Incentive Programs. (Note: Eligible professionals who are only participating in the Medicaid EHR Incentive Program are not required to be enrolled in PECOS.) • If you do not have an enrollment record in PECOS, you should still register for the Medicare and Medicaid EHR Incentive Programs.

  12. Required Registration Information • Hospitals • CMS Identity and Access Management (I&A) User ID and Password. • CMS Certification Number (CCN). • National Provider Identifier (NPI). • Hospital Tax Identification Number. • NOTE: You do not have to provide information on the certified EHR technology you are using when you register. However, this information is required when you attest.

  13. Dual Eligibility • If you represent a hospital that meets all of the following qualifications, you are dually-eligible for the Medicare and Medicaid EHR Incentive Programs: • You are a subsection(d) hospital in the 50 U.S. States or the District of Columbia, or you are a Critical Access Hospital (CAH); and • You have a CMS Certification Number ending in 0001-0879 or 1300-1399; and • You have 10% of your patient volume derived from Medicaid encounters.

  14. Medicare Incentives Incentives for Adoption and Meaningful Use of Certified EHR Paid to the Eligible Professional or Facility or Employer No payments after 2016 No incentive if first adopting after 2014 HPSA EP eligible for 10% increase Payment is either single consolidated payment

  15. Hospital Payments The Medicare incentive payment is the product of three factors: 1. An Initial Amount [$2Million + (0 x (1149-1 discharges) +(200 x (23,000-1150 discharges)] 2. The Medicare Share # of IP Part A Bed Days + # of IP Part C Days ------------------------------------------------------------------------------------------------------ Total IP Bed Days x Total Charges - Charges Attributable to Charity Care Total Charges 3. A Transition Factor applicable to the payment year

  16. CAH Payments Critical Access Hospital: reasonable costs incurred for the purchase of depreciable assets like computers, hardware and software (excluding depreciation and interest) multiplied by Medicare share percentage • Paid through prompt interim payment– cost reporting period • No payment after 2015 and no payments for more than 4 consecutive years

  17. Payment Timing • Medicare EHR incentive payments to eligible hospitals and critical access hospitals (CAHs) will also be made approximately four to eight weeks after the eligible hospital or CAH successfully attests to having demonstrated meaningful use of certified EHR technology. • Eligible hospitals and CAHs will receive an initial payment and a final payment. Eligible hospitals and CAHs that attest in April can receive their initial payment as early as May 2011. Final payment will be determined at the time of settling the hospital cost report.

  18. Payment Method • How will I receive the incentive payment? • If you are eligible for an incentive payment, the payment will be made to the taxpayer identification number you selected during registration. The payment will be deposited in the first bank account on file with CMS and will be noted as “EHR Incentive Payment” by the bank. • If you receive payments for Medicare services via electronic funds transfer, you will receive your Medicare EHR incentive payment the same way. If you currently receive Medicare payments by paper check, you will also receive your first Medicare EHR incentive payment by paper check.

  19. Demonstration of Meaningful Use During the First Year Eligible Professionals and Hospitals shall file an attestation statement that they are in compliance with the meaningful use measures. During the Second Year, Eligible Professionals and Hospitals shall electronically report the information.

  20. Reporting Period • FY 2011 90 Day Reporting • FY 2012 Entire Calendar Year • FY 2013 Entire Calendar Year • FY 2014 Entire Calendar Year

  21. Medicaid Incentives www.dch.georgia.gov/ehr

  22. Georgia’s Medicaid EHR Incentives Program • The Georgia Department of Community Health is implementing the Medicaid Electronic Health Records (“EHR”) Incentive Program authorized by the American Recovery and Reinvestment Act of 2009 (“ARRA”) • Purpose: The program is designed to: • make incentive payments to Eligible Hospitals in the first payment year to adopt, implement or upgrade an ONC certified EHR system; and • for the Meaningful Use of a certified EHR system according to the requirements developed by CMS in subsequent payment years.

  23. Eligibility • Acute care and critical access hospitals must have a Medicaid (Title XIX) patient volume of at least 10% of their total volume to be eligible to receive payments. • "Patient volume" is defined by CMS as the percent of Medicaid Title XIX encounters to total hospital encounters for the same 90-day period. • Eligible acute care and critical access hospitals may receive payments from both the Medicare and Medicaid Incentive Programs.

  24. Defining “Patient Encounters” • Services rendered to an individual per inpatient discharge where Medicaid (or a Medicaid demonstration project under section 1115 of the Act): • paid for part or all of the service; or • paid all or part of their premiums, co-payments, and/or cost-sharing; or • Services rendered to an individual in an emergency department on any one day where Medicaid (or a Medicaid demonstration project under section 1115 of the Act): • either paid for or all of the service; or • paid all or part of their premiums, co-payments, and/or cost sharing.

  25. Calculating Patient Volume Eligible Hospitals must meet patient volume thresholds based on a ratio where the numerator is the total number of Medicaid (Title XIX) patient encounters treated in any 90-day period in the previous calendar year and the denominator is all patient encounters during the same period. • Includes patients enrolled in Georgia’s Medicaid managed care plans. • Claims data with zero dollar payments should not be included in calculation. • Out of state patients living within 50 miles of State line may be included in patient volume. • CHIP patient volume must be excluded from the patient volume calculations.

  26. Incentive Payment Calculation and Distribution of Payments • Hospitals to use data from CMS cost reports and DSH surveys to make incentive payment calculation. • DCH is preparing a Medicaid Hospital Patient Volume and Incentive Payment Calculator to consist of the following components: an annual EHR base amount; a per-discharge amount for each year; a transition factor for each year; a Medicaid share based on inpatient, non-charity care days; and an aggregate EHR payment amount. • Payments distributed over 3 year schedule: • Year 1: 40% of Aggregate EHR Hospital Incentive Amount • Year 2: 40% of Aggregate EHR Hospital Incentive Amount • Year 3: 20% of Aggregate EHR Hospital Incentive Amount • 2016 is the last year that Eligible Hospitals may begin receiving payments from the Medicaid EHR Incentives Program.

  27. Incentive Payments • Incentive Payments • An Attestation of certified EHR usage including any applicable calculation worksheets must be submitted and approved for payment. • Once approved, allow 30 – 45 days for payment. Submissions and payments are annual. Incentive payments are expected to commence in September 2011.

  28. Meaningful Use • Eligible Hospitals do not have to demonstrate Meaningful Use in their first payment year. • During providers' first payment year, they must only demonstrate that they have adopted, implemented, or upgraded certified EHR technology. There is no reporting period for this requirement. • Meaningful Use must be demonstrated in its second participation year. For the second participation year, the EHR reporting period is 90-consecutive days within the participation year. • For all subsequent years after the second year, the EHR reporting period is the full annual period (one federal fiscal year).

  29. Medicaid Payments • First participation year only for Medicaid providers • Adopted –Acquired and Installed: Evidence of installation prior to incentive • Implemented –Commenced Utilization of: Staff training, data entry of patient demographic information into EHR • Upgraded –Expanded Upgraded to certified EHR technology or added new functionality to meet the definition of certified EHR technology • Must use certified EHR technology • (CMS Presentation July 20, 2010)

  30. Attestation Electronic Attestation Attestation Worksheet

  31. Key Dates • January 1, 2011 – Reporting year begins for eligible professionals. • January 3, 2011 – Registration for the Medicare EHR Incentive Program begins. • January 3, 2011 – For Medicaid providers, states may launch their programs if they so choose. • April 18, 2011 – Attestation for the Medicare EHR Incentive Program begins. • May 2011 – EHR Incentive Payments expected to begin. • July 3, 2011 – Last day for eligible hospitals to begin their 90-day reporting period to demonstrate meaningful use for the Medicare EHR Incentive Program.

  32. Key Dates (cont’d) • September 30, 2011 – Last day of the federal fiscal year. Reporting year ends for eligible hospitals and CAHs. • October 3, 2011 – Last day for eligible professionals to begin their 90-day reporting period for calendar year 2011 for the Medicare EHR Incentive Program. • November 30, 2011 – Last day for eligible hospitals and critical access hospitals to register and attest to receive an Incentive Payment for Federal fiscal year (FY) 2011. • December 31, 2011 – Reporting year ends for eligible professionals. • February 29, 2012 – Last day for eligible professionals to register and attest to receive an Incentive Payment for calendar year (CY) 2011.

  33. Michele Madison Partner, Healthcare mmadison@mmmlaw.com 404-504-7621 This presentation is provided as a general informational service to clients and friends of Morris, Manning & Martin LLP. It should not be construed as, and does not constitute, legal advice on any specific matter, nor does this message create an attorney-client relationship. These materials may be considered Attorney Advertising in some states. Please note, prior results discussed in the material do not guarantee similar outcomes. Thank you

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