Meaningful Use: Getting and Keeping YOUR Money!

1. Meaningful Use:Getting and KeepingYOUR Money! Veronica Fernandez, BBA, Regional Coordinator Becky Jones, MSN, RN-BC, Regional Coordinator Terry Alexander, Director, Critical Access and Rural Hospitals

2. Highlights • EHR Incentives and Payment Adjustments • Current Climate: Audits! • Supporting Your Attestation • Navigating the Security Risk Assessment

3. ePrescribing Quick Note • 2013 was the last year to earn an eRx incentive payment • 2014 is the last year to incur an eRx payment adjustment (based on the 1st 6 months of 2013)

4. EHR Incentives • Meaningful Use

5. Meaningful Use: Medicaid • Physician – MD or DO • Dentist • Nurse Practitioner • Certified Nurse-Midwife • PA – only in special circumstances • Patient Volume – 30 % or more Medicaid

6. Timeline for Medicaid Meaningful Use

7. Meaningful Use: Medicare • Doctors of medicine or osteopathy • Doctors of dental surgery or dental medicine • Doctors of podiatric medicine • Doctors of optometry • Chiropractors

8. Timeline for Medicare EHR Incentive

9. Progression of Meaningful Use

10. Penalties • Medicare eligible professionals and eligible hospitals who do not meet the requirements for meaningful use by 2015 and in each subsequent year are subject to adjustments to Medicare reimbursements that start at 1% per year, up to a maximum 5% annual adjustment. • EPs and EHs must continue to demonstrate meaningful use every year to avoid payment adjustments. • Does not apply to Medicaid payment at this time

11. Hardship Exceptions • Must apply for hardship exception • Lack of infrastructure • New EPs • Unforeseen circumstances • natural disaster • vendor issues • Lack of face-to-face or telemedicine interaction or lack of need for follow-up • Practice at multiple locations with lack of control over availability of CEHRT

12. What To Do Now • Adopt a certified EHR • Learn about Meaningful Use • EPs Demonstrate meaningful use in 2014 for a 90-day reporting period – no later than Oct 1, 2014 to avoid payment adjustments in 2015. • EHs must start 90 day attestation period no later than 7/1/2014 • Contact WTxHITREC

13. Pre-payment Review Post-payment Contractors Audits

14. About the Auditors • Medicare EHR Incentive Program • Figliozzi and Company will audit Eligible Professionals (EPs) and Eligible Hospitals (EHs) participating in the Medicare EHR Incentive Program. • Medicaid EHR Incentive Program • Texas Health and Human Services Commission (HHSC) has contracted with the CPA firm of Davila, Buschhorn & Associates, P.C. to conduct audits on behalf of the State of Texas. • Prepayment Reviews

15. What to expect if you are audited Medicare EHR Incentive Program • A request letter will be sent electronically by a CMS email address and will include the auditor’s contact information. • The email address provided during registration will be used for the initial request letter. • Providers selected for audits will have two (2) weeks to submit their documentation. Medicaid EHR Incentive Program • You will receive a notice of audit directly from Davila, Buschhorn & Associates. • You have ten (10) days to respond with all requested information.

16. Responding to an Audit • Respond to the request to confirm that you have received it. • Assemble your supporting documentation. • If you need additional time to run more reports, ask for an extension. • Data is dynamic! • If you must run new reports, understand that the numbers will be different, even for the same time period you used to attest. • You may need to ask TMHP to reset the attestation site so you can enter new information. • If entering new information, recheck all numbers to ensure they match any new material you upload.

17. What happens if I fail an audit? • If an EP or EH fails a Medicare EHR Incentive Program audit in 2013, there will be a 2015 payment adjustment. • When an EP or EH fails an audit they “lose” the program year they are participating in and the incentives for that year. • An EP or EH can appeal the final determination of their audit.

18. Supporting Your Attestation

19. Supporting Documentation • As you prepare for attestation – prepare for an audit • Assemble electronic files and paper notebook or file • Create electronic file folders that clearly indicate contents • Rename files of documents to clearly indicate what the document is: • e.g. 2013 Medicaid group volume detail

20. Supporting AIU Attestation • Certified EHR Technology • Contract or license agreement • Signatures • Practice location • Version – if different from original agreement, upload • Patient volume • Total encounters/total Medicaid encounters Include Medicaid secondary Exclude CHIP Detail of Medicaid encounters – no PHI

21. Supporting Meaningful Use • Reports from CEHRT with numerators and denominators • Meaningful Use Report • Quality Measures Report • Non-Percentage-Based Objectives • One or more screen shots from the EHR system that are dated during the EHR reporting period for all yes or no objectives

22. Public Reporting Measures • ImmTrac • Provider ImmTrac number • Email or other communication that file was received • Syndromic Surveillance • Health Department • Copy of letter or email from your Health Region • Lab Results to the Health Department • Contact the Health Department for your region

23. And More Documentation Reports from the EHR • All screen shots should include the EHR system logo and date • Do NOT include PHI And a big one… Document your Security Risk Analysis

24. Navigating The Security Risk Assessment

25. Breach Notification Fines: • Penalties start at $100 per violation that the CE did not know of or could not have known • $1,000 for violation due to reasonable cause • $10,000 due to willful neglect that is promptly corrected • $50,000 for violation due to willful neglect that is not promptly corrected • Note: In Texas, a breach of PHI (Protected Health Information) may also be classified as a felony? (Section 522.002(b), Texas Business and Commerce Code) OH NO!!!!: • CMS is taking the position that failure to have proper policies and procedures in place constitute a willful neglect..... I.E. $10,000 for each breach !!!

26. The “Basics” • You must have 1 “full blown” SRA performed • SRAs must be “reviewed and updated” annually. • SRA must be completed during the attestation period • All HIGH findings should be corrected immediately (if possible). • You must have a Corrective Action Plan in place to address ALL deficiencies

27. Required or Addressable? [According to CFR (Code of Federal Regulations)] • If it’s required….ok….it’s required. • If it is addressable, the entity can do 1 of 3 things: • implement the addressable implementation specifications; • implement one or more alternative security measures to accomplish the same purpose; • not implement either an addressable implementation specification or an alternative. The covered entity’s choice must be documented.

28. Free SRA Tools • A Security Risk Assessment Tool (and video) from the ONC: http://www.healthit.gov/providers-professionals/security-risk-assessment • An Excel spreadsheet developed by the ONC (Available from the WTxHITREC) • An Excel spreadsheet developed by: “EHR Physicians, Inc”. (Available from the WTxHITREC)

29. Once You Have Completed Your SRA • Appoint a Security Risk Officer • Form a Security Risk Committee • Meet (officially) not less monthly • Have an agenda and take minutes • Demonstrate that you are taking action on the SRA findings • Keep a list of D-I-P’s (Deliverables, Issues, Problems)

30. Other Tools Available From WTxHITREC • “D-I-P” spreadsheet (Deliverables/Issues/Problems) • Meeting Agenda/Minutes Template • Security Policies and Procedures Template • A staff of over 15 people dedicated to serving West Texas. A GREAT TOOL! (or TOOLS!)

31. Q & A Contact Information: WTxHITREC Main Number: (806) 743-7960 Director of Critical Access and Rural Hospitals: Terry Alexander: (214) 236-5327 Regional Coordinators: Becky Jones: (806) 743-7960 (Trusted Advisors) Cappi Phillips: (806) 778-3243 Sharon Rose: (806) 928-6403 Leta Cross-Gray: (325) 721-2500 Veronica Fernandez : (915) 307-1295 Jeremy Castillo: (512) 550-0770 All e-mail addresses are: <first name>.<last name>@ttuhsc.edu Example: terry.alexander@ttuhsc.edu