Jeff Grant, President HCMA, Inc.

Transcription

1 Meaningful Use Where Should You be Now? Jeff Grant, President HCMA, Inc. com Sponsored by: Compulink Business Systems, Inc

2 Who am I?: Over 20 years Practice Management, Operations, & HIT Consulting with nearly 1,000 practices Speaker at AAO, ASCRS, Hawaiian Eye, SECO, AOA, Vision Expo, & State Associations Contributing Editor Optometric Management Magazine Articles in Primary Care Optometry News (PCON), Administrative i ti Eyecare, Ophthalmology l Management, Ophthalmology Times, Premier Surgeon, Ophthalmology Business, & Advanced Ocular Care Assisted dozens of practices with EHR selection/implementation

3 Federal EHR Incentive According to CMS, as of August 31st: More than $1.26 Billion Medicare EHR incentive payments to over 74,000 EP s Optometrists = 2,683 Ophthalmologists = 1,587 Over $1.14 Billion Medicaid EHR incentive payments to over 55,000 EP s Over $7 billion to Medicare EP s, Medicaid EP s, and hospitals over 280,000 providers have registered Medicaid Plans launched in 48 States

4 A Roadmap to Incentive Payment EHR selection (which vendor?) EHR implementation (EHR in use but not yet a meaningful user) EHR incentive selection (Medicaid vs. Medicare) EHR meaningful use (meaningfully using a certified EHR technology ) *EHR incentive registration (Medicaid A/I/U vs. Medicare / Registration doesn t have to be after implementation and beginning of meaningful use) EHR incentive attestation EHR incentive payment

5 EHR Selection Certified products, either Complete or Modular EHRs and inpatient or outpatient, are listed on a government Web page at: Certified EHR Technology Several ophthalmology-focused l vendors are certified

6 EHR Implementation Go live on the new EHR you select, or Go live on the EHR you already have but have not implemented, or You re already live on EHR but have not begun MU

7 EHR Incentive Registration The web site for registration & attestation is:

8 EHR Incentive Registration You can and SHOULD - register for the incentives even if you don't have a certified EHR software yet and even if you aren't yet a meaningful user. For those who already have a certified EHR, the portal links to the ONC's list of certified products which makes it very easy to select the correct vendor.

9 EHR Incentive Registration To register, you need: CMS Identity and Access Management (I&A) User ID and Password EP s can use the same User ID and PW they use for the NPPES (same as ID / PW used to access PECOS). Users registering i or attesting ti on behalf of an EP must have an I&A web user account (User ID/PW) and be associated to the EP's NPI. If you don t have an account: pp ritycheck.do to create one.

10 Medicaid or Medicare Incentive: There are two Federal EHR incentives available to non-hospital based physicians Medicare and Medicaid. The Medicaid incentive could pay much more than the Medicare incentive ($64,000 vs. $44,000). There are many similarities between the two programs, but also some important differences.

11 Medicaid or Medicare Incentive: First payment year with Medicaid A/I/U (no MU) Future years with Medicaid MU each year Can start Medicaid through 2016 and lose no $$

12 Medicaid Eligibility: Physicians i Pediatricians have special eligibility & payment rules Physician for Medicaid = MDs, DOs, and optometrists t t in some states t Nurse practitioners (NPs) Certified Nurse Midwives (CNMs) Dentists Physician Assistants (PAs) when practicing at an FQHC/RHC that is so led by a PA

13 Medicaid Eligibility: OD s generally not eligible (unless their States have specifically adopted the option of 1905(e) in their State plans ) Definitely not eligible in Florida Definitely eligible in KY & IL

14 Medicaid or Medicare Incentive: One of the requirements to qualify for the Medicaid incentive is that you must have 30% of your patient volume come from Medicaid patients (Title XIX). According to one of two methods: 1) (2) Having a Medicaid enrollee on the panel assigned to the EP (for example, managed care or medical homes) within that representative 90- day period. (2)

15 Medicare EHR Incentive Amounts 75% bonus, calculated on your Allowed FFS Charges Up to annual maximum Annual maximum goes down each year 2/3 of total incentive paid in the first 2 years

16 Medicare EHR Incentive Amounts

17 EHR Incentive Attestation

18 EHR Incentive Attestation Timelines EHR Reporting Period: 90 Days in your first payment year, regardless of when you start Full calendar year in subsequent years For those that attested first in 2011, must meet Stage 2 in 2014 and Stage 3 in 2016 All others will be required to demonstrate 2 Stage 1, 2 Stage 2, & 2 Stage 3 90 days for everyone in 2014 (extra flexibility to ensure Stage 2 compliance)

19 EHR Incentive Attestation Timelines EHR Reporting Period / Dates to Keep in Mind: Oct. 3, 2012 to Dec. 31, 2012 Last possible EHR Reporting Period to get full amount (if you didn t attest for 2011) Oct. 4, 2012 Lose $5,000 Attest in 2013 to prevent 1% penalty in MU reporting period begun no later than June 30, 2014 and attest by October 1, 2014 to prevent penalty in 2015.

20 EHR Incentive Attestation Timelines

21 Common EHR Incentive Attestation & MU Questions What is certified EHR technology, a payment year, and a reporting period? Certified EHR Technology - A Complete EHR that meets the requirements included d in the definition iti of a Qualified EHR and has been tested and certified in accordance with the certification program established by the National Coordinator as having met all applicable certification criteria adopted by the Secretary; or Payment Year For EP s, any CY beginning with 2011; for Hospitals, any FY beginning i with 2011 (10/1/10). EHR Reporting Period Any continuous 90 Any continuous 90-day period within the first payment year and the entire payment year for all subsequent payment years.

22 Common EHR Incentive Attestation & MU Questions What are Exclusions? An EP will be able to report if an objective/measure is inapplicable to them, because they have no patients or insufficient number of actions that would allow calculation of the meaningful use measure. This will allow an EP to qualify as a meaningful EHR user without being required to meet objectives we have specified as potentially ti inapplicable. Stage 2 Starting in 2014, Menu Set exclusions will NOT count towards menu objectives needed.

23 Common EHR Incentive Attestation & MU Questions What is a Unique Patient? If a patient is seen by an EP more than once during the EHR reporting period then, for purposes of measurement, they only count once in the denominator for the measure. Your EHR vendor is required to do these calculations for you.

24 Common EHR Incentive Attestation & MU Questions How long do we need to comply with Stage 1 of meaningful use? Thru the end of 2013 when Stage 2 rules commence. 15 Core Set Measures All must be met. Stage 2 17 / All must be met. 10 Menu Set Measures 5 must be met. Stage 2-3 of 6 must be met (1 Old & 5 New) At least one of the Menu Set Measures must be Public Health Related** Clinical Quality Measures 3 Core, 3 Alternate Core, 3 Alternate Set Stage 2 9 of 64

25 EHR Incentive Payments Who gets paid? Except as otherwise indicated, each objective must be satisfied by an individual EP as determined by unique National Provider Identifiers(NPIs).

26 EHR Incentive Payments How / When will payments by made? Payments will be made by the single payment contractor. Additionally, the Integrated Data Repository (IDR), rather than the carriers/macs will be accumulating the allowed charges for each qualified EP s NPI. Payments would be made on a rolling basis. We anticipate that it will take anywhere from 4 to 8 weeks from the time an EP successfully attests to being a meaningful user. A single, consolidated, annual incentive payment to EPs. Paid the same way yy you get paid on claims (ETF or check).

27 EHR Incentive Payments Questions about your EHR incentive payment? DON'T: Call your MAC/Carrier/FI / INSTEAD: Call the EHR Information Center 7:30 a.m. 6:30 p.m. (CST) Mon - Fri Obtain registration status Acquire attestation status Review payment information Check progress towards meeting the $24,000 threshold amount

28 EHR Incentive Payments - Reassignment Assigning payments to an employer or other entity: EPs are allowed to reassign their incentive payment to their employer or an entity which they have a valid employment agreement or contract providing for such reassignment, consistent t with all rules governing reassignments. We are proposing to preclude an EP from reassigning the incentive payment to more than one employer or entity.

29 EHR Incentive Payments - Reassignment Assigning payments to an employer or other entity: The EP can only receive the payment themselves if they have not reassigned all of their Medicare benefits to another entity in PECOS. Medicare EPs can elect to have their payment go to another entity by selecting Payee TIN Type of EIN. (Choosing this option will activate a list of entities list that the EP reassigned Medicare benefits to in PECOS).

30 EHR Incentive Payments More than one practice For an EP furnishing covered professional services in more than one practice: We propose to use the EP's Medicare enrollment information to determine whether an EP belongs to more than one practice (that is, whether the EP's National Provider Identifier (NPI) is associated with more than one practice). In cases where the EP is associated with more than one practice, we propose that EPs select one tax identification number to receive any applicable EHR incentive payment.

31 EHR Incentive Payments More than one practice An Eligible Professional who works at multiple locations, but does not have certified EHR technology available at all of them would: Have to have 50% of their total patient encounters at locations where certified EHR technology is available Would base all meaningful use measures only on encounters that occurred at locations where certified EHR technology is available

32 EHR Incentive Payments More than one practice An Eligible Professional who works at multiple locations, but does not have certified EHR technology available at all of them would: Have to have 50% of their total patient encounters at locations where certified EHR technology is available Would base all meaningful use measures only on encounters that occurred at locations where certified EHR technology is available

33 EHR Incentive Payments HPSA There is a 10% bonus on Incentive Payments for EP s practicing predominantly in a Health Care Shortage Area. For an EP to be considered as "predominantly" furnishing covered professional services in a geographic HPSA, more than 50 percent of the EP's covered professional services must be furnished in a geographic HPSA. This would be an additional lump sum payment made no later than 120 days after the end of the calendar year.

34 EHR Incentive Payments Reviews We will conduct selected compliance reviews of EPs who register for the incentive programs and of recipients of incentive payments for the meaningful use of certified EHR technology. The reviews will validate provider eligibility through their meaningful use attestations including verification of meaningful use and would also review components of the payment formulas. We will identify and recoup overpayments made under the incentive payment programs that result from incorrect or fraudulent attestations, quality measures, cost data,,p patient data, or any other submission required to establish eligibility or to qualify for a payment. The overpayment will be recouped by CMS or its agents from the EP or other entities to whom the right to payment has been assigned/reassigned. Medicare FFS EPs will need to maintain evidence of qualification to receive incentive payments for 10 years after the date they register for the incentive program.

35 EHR Incentive Payments Reviews The EHR Incentive program includes a provision i that t allows the government to audit you up to 10 years after payment has been made. CMS was announced recently that Figliozzi and Company will be performing the meaningful use audits for CMS, and EP's are already getting letters from Figliozzi and Company. If you are selected for an audit you will receive a letter from them with the CMS logo on the letterhead. Meaningful use audit questions can be directed to Peter Figliozzi at (516) x302 or by at pfigliozzi@figliozzi.com. Figliozzi and Company s website is It is IMPERATIVE to you maintain evidence that supports the information you use(d) when you attest(ed). This might be information contained in your certified EHR, reports that you used, etc.

36 PQRS with EHR Incentive PQRS Incentive is still available even if you get the EHR Incentive. Affordable Care Act (ACA ACA) (Section 10331, March 2010) Provides Physician Quality Reporting incentives through 2014 and added PFS reductions starting in Authorized incentive payment amounts for each program year: 2012, 2013, % Authorized payment adjustment to fee schedule amount beginning in 2015 for those who do not satisfactorily report % 2016 and subsequent years 98.0%

37 No E-Rx Incentive with EHR Incentive No E-Rx Incentive Payment if you accept Medicare EHR Incentive Payment: We will exclude those EPs who accept a Medicare EHR incentive payment for a given year from being eligible for the E-Prescribing Incentive Program payment for that same year. EPs receiving a Medicaid EHR incentive payment would remain eligible for the Medicare MIPAA E- Prescribing Incentive Program payment. Earn 1% Bonus in 2012 (Last year for incentive) AND Prevent 2014 penalty (2.0%) by reporting 25 erx events between 1/1/12 & 12/31/12 Prevent 2013 penalty (1.5%) by reporting 10 erx events between 1/1/12 & 6/30/12

38 Meaningful Use Final Rule Stage 2 Final Rule Affects Stage 1: Changes to the denominator of computerized provider order entry (CPOE) (Stage 1 Optional, Stage 2 Required) Changes to the age limitations for vital signs (Stage 1 Optional, Stage 2 Required) Elimination of the exchange of key clinical information core objective from Stage 1 in favor of a transitions of care core objective that requires electronic exchange of summary of care documents in Stage 2 (Effective Stage 2) Replacing provide patients with an electronic copy of their health information objective with a view online, download d and transmit core objective. (Effective Stage 2)

39 Meaningful Use Final Rule

40 Thank You! Jeff Grant, President HCMA, Inc