PYA Offers Regulatory Updates and Operational Implications of Meaningful Use
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PYA Offers Regulatory Updates and Operational Implications of Meaningful Use

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PYA executives Linda ClenDening and Erin Phillips recently addressed the Nashville MGMA, providing regulatory updates on the CMS meaningful use attestation process. They also shared perspectives......

PYA executives Linda ClenDening and Erin Phillips recently addressed the Nashville MGMA, providing regulatory updates on the CMS meaningful use attestation process. They also shared perspectives on the operational implications of “meaningful use” for physician practices.

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  • 1. Page 0August 13, 2013 Prepared for Nashville MGMA Meaningful Use: Regulatory and Operational Implications Nashville MGMA August 13, 2013
  • 2. Page 1August 13, 2013 Prepared for Nashville MGMA Agenda • Data and quality clinical outcomes • Regulatory information highlights and audits • Meaningful Use (MU) implications for – Staffing/Roles – Alliances/Referrals – Meaningful data
  • 3. Page 2August 13, 2013 Prepared for Nashville MGMA Quality Outcomes
  • 4. Page 3August 13, 2013 Prepared for Nashville MGMA Quality Data in the Exam Room xx% of my patients over 18 who have their tonsils removed experience post-surgical hemorrhaging. These outcomes are less than the national average of yy% of patients over 18.
  • 5. Page 4August 13, 2013 Prepared for Nashville MGMA Quality Data What’s the source of the data?
  • 6. Page 5August 13, 2013 Prepared for Nashville MGMA Communicating About Quality If he’s using clinical outcomes statistics in the exam room, where else is he using them?
  • 7. Page 6August 13, 2013 Prepared for Nashville MGMA Doctor’s Lounge Communicating with referring physicians?
  • 8. Page 7August 13, 2013 Prepared for Nashville MGMA Board Table Quality contractual requirements between hospitals and physicians – Employment arrangements – Clinical co-management – ACOs – Other partnerships
  • 9. Page 8August 13, 2013 Prepared for Nashville MGMA Negotiating Table Once quality metrics are operationalized for one payor, the provider can build on that strength to discuss quality with other contracting payors.
  • 10. Page 9August 13, 2013 Prepared for Nashville MGMA Website How is he attracting patients to his practice based on quality outcomes?
  • 11. Page 10August 13, 2013 Prepared for Nashville MGMA Take Away #1 • What story are you telling about the physicians in your practice using the quality data collected in the MU process? • Focus on a core measure metric or clinical quality metrics and develop the story.
  • 12. Page 11August 13, 2013 Prepared for Nashville MGMA MU Statistics as of June 2013 $- $500,000,000 $1,000,000,000 $1,500,000,000 $2,000,000,000 $2,500,000,000 $3,000,000,000 2011 2012 2013 YTD Medicare EP.s Medicaid EP.s http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/June_PaymentRegistration_Summary.pdf Almost 6 billion dollars to EP.s to- date
  • 13. Page 12August 13, 2013 Prepared for Nashville MGMA Real World Impact of MU • More than 458 million test results were entered into the EHR by 111,954 Eligible Providers (EP.s). • Medication reconciliation was performed on over 40 million patient transitions of care by 83,035 EP.s. • More than 4.3 million patient transitions of care summaries were generated by 24,827 EP.s.
  • 14. Page 13August 13, 2013 Prepared for Nashville MGMA Meaningful Use Headlines • July 25, 2013 – AMA and AHA ask for flexibility in Meaningful Use program requirements. • July 30, 2013 – AHA and AMA, as well as CHIME (College of Healthcare Information Management Executives), request more time for Stage 2. • July 30, 2013 –AHA report calls for a delay of Eligible Hospital Stage 2 deadline of October 1, 2013. As reported in HealthLeaders Media.
  • 15. Page 14August 13, 2013 Prepared for Nashville MGMA Meaningful Use Current Details • Stage 2 Meaningful Use (MU) Attestation begins in calendar year 2014 for Eligible Providers (EP.s). – If a provider began MU in 2011, he/she will meet three consecutive years of MU before beginning Stage 2 in 2014. – All other providers meet two years of MU before advancing to Stage 2 in their third reporting year. • For 2014 only, all providers – regardless of MU stage – are only required to demonstrate MU for a 3 month reporting period. • Beginning in 2015, Medicare eligible professionals who do not successfully demonstrate meaningful use will be subject to a payment adjustment.
  • 16. Page 15August 13, 2013 Prepared for Nashville MGMA Public Health Reporting Objectives: Providers must perform at least one test of their certified EHR technology’s capability to send data to public health agencies. Timing/Compliance: Required in 2013 and beyond for all Stage 1 public health objectives. Affected Providers: EPs, eligible hospitals, and CAHs What It Means: The intent of this modification is to encourage all EPs, eligible hospitals, and CAHs to submit public health data, even when not required by State/local law, if authorized. Public health reporting objectives include submitting data to: an immunization registry, a syndromic surveillance database, OR lab results to a public health agency. What’s New in MU Stage 1 in 2013
  • 17. Page 16August 13, 2013 Prepared for Nashville MGMA What’s New in MU Stage 1 in 2013 Electronic Exchange of Key Clinical Information: Removal of electronic exchange of key clinical information objective for Stage 1 for EPs, eligible hospitals, and CAHs Timing/Compliance: Removed in 2013 and beyond Affected Providers: EPs, eligible hospitals, and CAHs What It Means: Providers will no longer have to meet or attest to this objective for the EHR incentive programs. MU Stage 2 will include a more robust requirement for electronic health information exchange associated with a transition of care or referral.
  • 18. Page 17August 13, 2013 Prepared for Nashville MGMA What’s New in MU Stage 1 in 2013 Computerized Physician Order Entry (CPOE): Addition of an alternative measure based on the total number of medication orders creating during the EHR reporting period. Timing/Compliance: Option to choose the alternative measure in 2013 and beyond. Affected Providers: EPs, eligible hospitals, and CAHs What It Means: Providers will have the option of using the original measure or the alternative measure to meet the CPOE objective.
  • 19. Page 18August 13, 2013 Prepared for Nashville MGMA What’s New in MU Stage 1 in 2013 Record and Chart Changes in Vital Signs: Increase in age limit for recording blood pressure in patients to age 3; removal of age limit requirement for height and weight. Timing/Compliance: Optional to implement the changes in 2013; required in 2014 and beyond. Affected Providers: EPs, eligible hospitals, and CAHs What It Means: In 2013, providers have a choice of reporting under either the original or new age limits. However, in 2014, all providers must report under the new age limits.
  • 20. Page 19August 13, 2013 Prepared for Nashville MGMA What’s New in MU Stage 1 in 2013 Electronic Prescribing: Additional exclusion to the objective for electronic prescribing for providers who are not within a 10 mile radius of a pharmacy that accepts electronic prescriptions. Timing/Compliance: Optional to select the additional exclusion starting in 2013 and beyond. Affected Providers: EPs What It Means: EPs may select the additional exclusion if they qualify.
  • 21. Page 20August 13, 2013 Prepared for Nashville MGMA What’s New in MU Stage 1 in 2013 Record and Chart Changes in Vital Signs: New exclusion for EPs: If they see no patients 3 years or older; if all three vital signs are not relevant to their scope of practice; if height and weight are not relevant to their scope of practice; or if blood pressure is not relevant to their scope of practice. Timing/Compliance: Optional to select new exclusion criteria in 2013; replaces current exclusion criteria starting in 2014. Affected Providers: EPs What It Means: Previously, EPs could only exclude the objective if all three vital signs were not relevant to their scope of practice or if they saw no patients 3 years or older. Beginning in 2013, EPs can also now be excluded from reporting blood pressure if blood pressure is not relevant to their scope of practice, or recording height and weight if both height and weight are not relevant to their scope of practice.
  • 22. Page 21August 13, 2013 Prepared for Nashville MGMA MU Stage 1 to Stage 2 • Increase in required percentage of qualifying unique patients in percentage-based objectives. • All clinical quality measures (CQMs) will be submitted electronically to CMS. • New requirements for summary of care documents at transition of care/referrals and patient electronic access via secure messaging.
  • 23. Page 22August 13, 2013 Prepared for Nashville MGMA Penalty Scenarios First Year of MU Requirement to Avoid Penalty 2015 2016 2017 2011 Achieve MU in 2013 (365 days) Achieve MU in 2014 (One 3-month quarter) Achieve MU in 2015 (365 days) 2012 Achieve MU in 2013 (365 days) Achieve MU in 2014 (One 3-month quarter) Achieve MU in 2015 (365 days) 2013 Achieve MU in 2013 (Any 90-consecutive-day period) Achieve MU in 2014 (One 3-month quarter) Achieve MU in 2015 (365 days) 2014 Achieve MU in 2014 (Any 90-consecutive-day period ending no later than 3 months before the end of the reporting period) Achieve MU in 2014 (One 3-month quarter) Achieve MU in 2015 (365 days)
  • 24. Page 23August 13, 2013 Prepared for Nashville MGMA EHR Incentive Programs (MU) Supporting Documentation • Retain ALL relevant supporting documentation for SIX YEARS post-attestation. • Audit letters will be sent electronically from CMS email address. • Pre-payment audits: – Both random and targeted (based on suspicious or anomalous data). – Supporting documentation will be requested prior to payment of incentive monies. http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/EHR_SupportingDocumentation_Audits.pdf
  • 25. Page 24August 13, 2013 Prepared for Nashville MGMA EHR Incentive Programs (MU) Supporting Documentation (cont.) • Post-payment audits: – Initially conducted as “desk” (off-site) audits using requested copies of documentation. – Follow-up data requests and even on-site reviews in the provider office could be done. – Be sure to retain a report from the certified EHR to validate all clinical quality measure (CQM) data. – For non-percentage-based documentation, screenshots from the EHR during the reporting period may be required.
  • 26. Page 25August 13, 2013 Prepared for Nashville MGMA Favorite Government Audits Techniques • . Audit Method IRS MU Example Discriminant Function System (DIF) Scoring Analyze population groupings, standards and trends for potential abnormal circumstances based on past experience. E.g., zip code = Bel Air; DMV tags = Lamborghini; pay interest on a $1 million mortgage; BUT declare less than $100,000 of income. Hospital with certain higher level of IP days or discharges but low volume on percentage based measures Hot-Spot Market Segments Every year the IRS selects a particular industry for compliance examinations. E.g., foreign trusts, s-corps, restaurant servers Certain EP specialties, hospitals of a certain size or location Information Matching Employers, banks, brokerage firms, independent contractors all file documents with the IRS and send the same documents to tax payers e.g., Forms 1099, W2. Unusual variations in volume of percentage based measures among EPs within the same TIN; or between MU and PQRS
  • 27. Page 26August 13, 2013 Prepared for Nashville MGMA MU Role in New Care Model Development • Consolidation/M&A • ACOs • Clinically Integrated Networks • Private Payor Network Development/Contracting • Others
  • 28. Page 27August 13, 2013 Prepared for Nashville MGMA MU & Consolidation • Weathering the storm with a bigger ship: – From 2000 to 2010, hospital physician employment rose 32%. – Hospitals directly employ about a quarter of all U.S. physicians. – By 2013, 2/3rds of physicians will work for hospitals or large groups. • Strategic Consideration: – Affiliate or Merge with an organization without an MU plan or at risk of a penalty?
  • 29. Page 28August 13, 2013 Prepared for Nashville MGMA MU & Consolidation • Transaction Due Diligence Consideration: – Meaningful Use due diligence now occurs in most health care transactions. – Organizational readiness for Meaningful Use Attestation requires detailed supporting documentation.
  • 30. Page 29August 13, 2013 Prepared for Nashville MGMA MU & ACOs • Public Payor • Medicare • Medicaid • Private Payor • Private Payors (Blue Cross, United, Cigna, Aetna) • ACOs with private insurers in effect or development at four times the rate of Medicare ACOs • Large Employers • Self-Insured Hospitals and Health Systems
  • 31. Page 30August 13, 2013 Prepared for Nashville MGMA MU & ACOs • ACO 33 Quality Measures include: – Percent of PCPs who Successfully Qualify for MU Payment – CQMs overlap with ACO measures
  • 32. Page 31August 13, 2013 Prepared for Nashville MGMA Clinical Quality Measure (CQM) Overlap with ACO and Other Programs Stage 2 2014 CQM Measure Other CMS Program Controlling High Blood Pressure Percentage of patients 18-85 years of age who had a diagnosis of hypertension and whose blood pressure was adequately controlled (<140/90mmHg) during the measurement period. ACO; EHR PQRS; Group Reporting PQRS Use of High-Risk Medications in the Elderly PQRS Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention ACO; EHR PQRS Group Reporting PQRS Use of Imaging Studies for Low Back Pain Preventive Care and Screening: Screening for Clinical Depression and Follow-Up Plan EHR PQRS; ACO; Group Reporting PQRS Documentation of Current Medications in the Medical Record PQRS; EHR PQRS Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up EHR PQRS; ACO; Group Reporting PQRS
  • 33. Page 32August 13, 2013 Prepared for Nashville MGMA 2013 PQRS • If you have EPs that meet MU, don’t leave money on the table: – 2013: 0.5% incentive – 2015: 1.5% penalty • Assess crosswalk opportunities for quality reporting across programs.
  • 34. Page 33August 13, 2013 Prepared for Nashville MGMA MU & Private Payor Contracting • A growing number of private payers have added the MU requirements to their P4P programs: – Aetna, United and WellPoint – Highmark modified "Quality Blue" program to include MU: • Require copy of attestation • Incorporate CQM for physician practice best practice indicator program • Payors not setting up proprietary mini-MU programs – Rather use developed MU system – Similar to using DRGs as a reference price for rates
  • 35. Page 34August 13, 2013 Prepared for Nashville MGMA Take Away #2 • Incorporate MU into Compliance Program. – Compliance Officer involvement in attestation and annual review. • Ensure Attestation documentation is consistent with CMS’s recommendations. • Prepare for more oversight – not just from CMS. • Maximize MU attestation benefits with other payors and alliances.
  • 36. Page 35August 13, 2013 Prepared for Nashville MGMA Operationalizing to imperfect users. Adapting a perfect program
  • 37. Page 36August 13, 2013 Prepared for Nashville MGMA Much more about the people, than the systems. Operationalizing
  • 38. Page 37August 13, 2013 Prepared for Nashville MGMA Meaningful Use Progression The systems need to carry the burden to prompt users to do the right thing. As Meaningful Use requirements progress there will be a higher volume of data requirements and more complexity.
  • 39. Page 38August 13, 2013 Prepared for Nashville MGMA We can only do so much
  • 40. Page 39August 13, 2013 Prepared for Nashville MGMA Meaningful Use Attestation Stage 1 only Stage 1 and planning For Stage 2 in 2014 Not yet attested
  • 41. Page 40August 13, 2013 Prepared for Nashville MGMA Meaningful Use Attestation Comments: • Working on it [Meaningful Use attestation]. • Small office and older physician who is not going to [attest]. • We plan on attesting for Stage 1 by the end of this year.
  • 42. Page 41August 13, 2013 Prepared for Nashville MGMA MU Staffing Changes? Increased clerical staff (i.e., Front Office, Billing or Support) Increased clinical staff Increased IT staff No staffing changes made Other (please specify) Previous survey: 20 % increased IT
  • 43. Page 42August 13, 2013 Prepared for Nashville MGMA MU Staffing Changes? Comments: • Increased data input demands on current staff. • Hired dedicated quality manager. • Shift in resources in IT department to focus on MU readiness. • We used outside consultants for MU attestation.
  • 44. Page 43August 13, 2013 Prepared for Nashville MGMA MU Staffing Changes Increased duties and responsibilities of current staff, including Administrator/Director. Use of consultants for MU implementation and attestation process. New IT team members: Quality staff, EMR analysts, and EMR trainers Comments from previous survey:
  • 45. Page 44August 13, 2013 Prepared for Nashville MGMA New IT Staff Positions for MU? Yes No
  • 46. Page 45August 13, 2013 Prepared for Nashville MGMA New IT Staff Positions for MU? Comments: • Not yet, but we are discussing these. • Hired a portal manager.
  • 47. Page 46August 13, 2013 Prepared for Nashville MGMA IT Positions Added for MU Help desk staff Clinical data analyst Report /data specia list Training /front line Impleme ntation support staff Information exchange/ Network specialist Other - Additional Roles not yet Determined
  • 48. Page 47August 13, 2013 Prepared for Nashville MGMA Staff Positions Added in IT Report/Data SpecialistClinical data analyst Help desk staff Information exchange/network specialist Training/front line Implementation support staff. Other Previous survey
  • 49. Page 48August 13, 2013 Prepared for Nashville MGMA Staffing Changes Source: 7 Hottest IT Healthcare Skills http://www.cio.com/slideshow/detail/70112#slide1 www.CIO.com October 18, 2012 EMR Build Specialists Healthcare Analytics Project Management Program Management Application Development Data Architecture Quality Assurance
  • 50. Page 49August 13, 2013 Prepared for Nashville MGMA IT Functional Roles Changing • Anticipate increased need of support for – New hardware – Networking – Remote access – Interoperability issues 2012 HIMSS Leadership Survey
  • 51. Page 50August 13, 2013 Prepared for Nashville MGMA Staff Role Changes Driven by MU Increase in support/help desk functionality within the organization. Increase in liaison/networking support with healthcare partners/alliances. Increase in leadership/ management to support strategic initiatives. Other
  • 52. Page 51August 13, 2013 Prepared for Nashville MGMA Referral/Alliance Decisions Driven by MU Our organization asks potential referrers/ partners about MU Our organization only has referrals/ partners with MU attested providers Not considered Other (please specify) Previous survey: 84% Not considered
  • 53. Page 52August 13, 2013 Prepared for Nashville MGMA Partnership Strategy with ‘Quality’ Providers Yes – 44.4% No – 16.7% Unknown – 38.9% Previous survey: 40% YES
  • 54. Page 53August 13, 2013 Prepared for Nashville MGMA Biggest Barrier to MU Success Practice budget/financing Internal resources for training Practice culture/resistance to change. Complexity of regulations and program instructions.
  • 55. Page 54August 13, 2013 Prepared for Nashville MGMA Survey Statistics • Organization description: – 90% Independent Physician Practices – 10% Hospital-Owned Physician Practices • Average practice size: 27 physicians • Practice size range: 1 to 1,000 physicians
  • 56. Page 55August 13, 2013 Prepared for Nashville MGMA Take Away #3 • Re-assess staff skills and training for EHR usage. • Determine possible staff duty changes. • Document process and workflow redesign for EHR/MU implementation. • Update all affected policies and procedures. • Redesign monthly reports and dashboards to include key MU metrics.
  • 57. Page 56August 13, 2013 Prepared for Nashville MGMA The Meaningful Use Goal Language is the road map of a culture. It tells you where its people come from and where they are going. ‒Rita Mae Brown Healthcare executives are engaged in developing a new language.
  • 58. Page 57August 13, 2013 Prepared for Nashville MGMA Thank you! Linda ClenDening, MS, CMPE Manager PYA lclendening@pyapc.com 615-305-5218 865-684-2735