Hitech ehr incentive programs

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  • Image – CMS Logo
  • Eligible Providers in MedicareEligible Professionals (EPs) Doctorof Medicine or OsteopathyDoctor of Dental Surgery or Dental MedicineDoctor of Podiatric MedicineDoctor of OptometryChiropractor Eligible Hospitals*Acute Care HospitalsCritical Access Hospitals (CAHs)*Subsection (d) hospitals that are paid under the PPS and are located in the 50 States or DC (including Maryland hospitals)
  • Eligible Providers in Medicare Advantage (MA)MA Eligible Professionals (EPs) Must furnish, on average, at least 20 hours/week of patient-care services and be employed by the qualifying MA organization-or-Must be employed by, or be a partner of, an entity that through contract with the qualifying MA organization furnishes at least 80 percent of the entity’s Medicare patient care services to enrollees of the qualifying MA organizationQualifying MA-AffiliatedEligible HospitalsWill be paid under the Medicare Fee-for-service EHR incentive program
  • Eligible Providers in MedicaidEligible Professionals (EPs)Physicians (Pediatricians have special eligibility & payment rules)Nurse Practitioners (NPs)Certified Nurse-Midwives (CNMs)DentistsPhysician Assistants (PAs) who lead a Federally Qualified Health Center (FQHC) or rural health clinic (RHC) that is directed by a PAEligible HospitalsAcute Care HospitalsChildren’s Hospitals
  • *Adapted from National Priorities Partnership. National Priorities and Goals: Aligning Our Efforts to Transform America’s Healthcare. Washington, DC: National Quality Forum; 2008.
  • First Payment Year 2011CY 2011 – Stage 1CY 2012 – Stage 1CY 2013 – Stage 2CY 2014 – Stage 2CY 2015 and Later** - Stage 3First Payment Year 2012 CY 2012 – Stage 1CY 2013 – Stage 1CY 2014 – Stage 2CY 2015 and Later** - Stage 3First Payment Year 2013CY 2013 – Stage 1CY 2014 – Stage 2CY 2015 and Later** - Stage 3 First Payment Year 2014CY 2014 – Stage 1CY 2015 and Later** - Stage 3First Payment Year 2015 and Later*CY 2015 and Later** - Stage 3*Avoids payment adjustments only for EPs in Medicare EHR Incentive Program**Stage 3 criteria of meaningful use or a subsequent update to criteria if one is established
  • DeletionsRecord advance directivesDocument a progress note for each encounterProvide access to patient-specific education resourcesAdditionsProvide summary care record for each transition of care and referralChangesAdding date of birth to record demographics and cause and date of death for hospitalsAdding growth charts to record vital signsLimiting smoking status to age 13+Increasing clinical decision support (CDS) rules from 1 to 5Removed “where possible” from insurance eligibility checksChanged the provision of clinical summaries from “each encounter” to “each office visit”Changed compliance with HIPAA to protect electronic health information maintained by certified EHR technology
  • EPs will need to select one of the following specialtiesCardiologyObstetrics and GynecologyPulmonologyNeurologyEndocrinologyPsychiatryOncologyOphthalmologyProceduralist/SurgeryPodiatryPrimary CareRadiologyPediatricsGastroenterologyNephrology
  • 2011 - First Calendar Year in which the EP receives an Incentive PaymentCY 2011 - $18,000CY 2012 - $12,000CY 2013 - $8,000CY 2014 - $4,000CY 2015 - $2,000Total - $44,0002012 - First Calendar Year in which the EP receives an Incentive PaymentCY 2012 - $18,000CY 2013 - $12,000CY 2014 - $8,000CY 2015 - $4,000CY 2016 - $2,000Total - $44,0002013 - First Calendar Year in which the EP receives an Incentive PaymentCY 2013 - $15,000CY 2014 - $12,000CY 2015 - $8,000CY 2016 - $4,000Total - $39,0002014 - First Calendar Year in which the EP receives an Incentive PaymentCY 2014 - $12,000CY 2015 – $8,000CY 2016 - $4,000 Total - $24,0002015 or later - First Calendar Year in which the EP receives an Incentive PaymentCY 2015 - $0CY 2016 - $0 Total - $0
  • 2011 - First Calendar Year in which the EP receives an Incentive PaymentCY 2011 - $1,800CY 2012 - $1,200CY 2013 - $800CY 2014 - $400CY 2015 - $200Total - $4,4002012 - First Calendar Year in which the EP receives an Incentive PaymentCY 2012 - $1,800CY 2013 - $1,200CY 2014 - $800CY 2015 - $400CY 2016 - $200Total - $4,4002013 - First Calendar Year in which the EP receives an Incentive PaymentCY 2013 - $1,500CY 2014 - $1,200CY 2015 - $800CY 2016 - $400Total - $3,9002014 - First Calendar Year in which the EP receives an Incentive PaymentCY 2014 - $1,200CY 2015 – $800CY 2016 - $400 Total - $2,4002015 or later - First Calendar Year in which the EP receives an Incentive PaymentCY 2015 - $0CY 2016 - $0 Total - $0
  • 2011 – First Calendar Year in which the EP receives an Incentive PaymentCY 2011 - $21,250CY 2012 - $8,500CY 2013 - $8,500CY 2014 - $8,500CY 2015 - $8,500CY 2016 - $8,500Total - $63,7502012 - First Calendar Year in which the EP receives an Incentive Payment CY 2012 - $21,250CY 2013 - $8,500CY 2014 - $8,500CY 2015 - $8,500 CY 2016 - $8,500CY 2017 - $8,500Total - $63,7502013 - First Calendar Year in which the EP receives an Incentive PaymentCY 2013 - $21,250CY 2014 - $8,500CY 2015 - $8,500CY 2016 - $8,500CY 2017 - $8,500CY 2018 - $8,500Total - $63,7502014 - First Calendar Year in which the EP receives an Incentive PaymentCY 2014 - $21,250CY 2015 - $8,500CY 2016 - $8,500CY 2017 - $8,500CY 2018 - $8,500CY 2019 - $8,500Total - $63,7502015 - First Calendar Year in which the EP receives an Incentive PaymentCY 2015 - $21,250CY 2016 - $8,500CY 2017 - $8,500CY 2018 - $8,500CY 2019 - $8,500CY 2020 - $8,500Total - $63,7502016 - First Calendar Year in which the EP receives an Incentive PaymentCY 2016 - $21,250CY 2017 - $8,500CY 2018 - $8,500CY 2019 - $8,500CY 2020 - $8,500CY 2021 - $8,500Total - $63,750
  • Other Medicare Incentive Program -- Eligible for HITECH?Medicare Physician Quality Reporting Initiative (PQRI) -- Yes, if the PQRI incentive is extended in its current format beyond 2010, EPs can participate in both if they are eligibleMedicare Electronic Health Records Demonstration (EHR Demo) -- Yes, if the EP is eligibleMedicare Care Management Performance Demonstration (MCMP) -- Yes, if the practice is eligible. The MCMP demo will end before EHR incentive payments are availableElectronic Prescribing Incentive Program (eRx) -- If the EP chooses to participate in the Medicare EHR Incentive Program, they cannot participate in the Medicare eRx Incentive Program simultaneously. If the EP chooses to participate in the Medicaid EHR Incentive Program, they can participate in the Medicare eRx Incentive Program simultaneously
  • Medicare vs. MedicaidFeds will implement (will be an option nationally) vs. Voluntary for States to implement (may not be an option in every State)Fee schedule reductions begin in 2015 for providers that are not Meaningful Users vs. No Medicaid fee schedule reductionsMust be a meaningful user in Year 1 vs. A/I/U option for 1st participation yearMaximum incentive is $44,000 for EPs vs. Maximum incentive is $63,750 for EPsMU definition will be common for Medicare vs. States can adopt a more rigorous definition (based on common definition)Medicare Advantage EPs have special eligibility accommodations vs. Medicaid managed care providers must meet regular eligibility requirementsLast year an EP may initiate program is 2014; Last payment in program is 2016; Payment adjustments begin in 2015 vs. Last year an EP may initiate program is 2016; Last payment in program is 2021 Only physicians, subsection (d) hospitals and CAHs vs. 5 types of EPs, 3 types of hospitals

Transcript

  • 1. Medicare & Medicaid EHR Incentive NPRM
    Implementing the American
    Reinvestment & Recovery Act of 2009
    Office of E-Health Standards and Services
    Centers for Medicare & Medicaid Services
  • 2.
    • American Reinvestment & Recovery Act (Recovery Act) – February 2009
    • 3. Electronic Health Record (EHR) Incentive Notice of Proposed Rulemaking (NPRM) on Display – December 30, 2009; published January 13, 2010
    • 4. NPRM Comment Period Closes – March 15, 2010
    2
    Overview
  • 5.
    • Definition of Meaningful Use (MU)
    • 6. Definition of Eligible Professional (EP) and Eligible Hospital/Critical Access Hospital (CAH)
    • 7. Definition of Hospital-Based Eligible Professional
    • 8. Medicare Fee-for-service (FFS) EHR Incentive Program
    • 9. Medicare Advantage (MA) EHR Incentive Program
    • 10. Medicaid EHR Incentive Program
    • 11. Collection of Information Analysis (Paperwork Reduction Act)
    • 12. Regulatory Impact Analysis
    3
    What is in the CMS EHR Incentive program NPRM?
  • 13.
    • Information about applying for grants
    • 14. Changes to HIPAA
    • 15. Office of the National Coordinator (ONC) Interim Final Rule (IFR) – Health Information Technology (HIT): Initial Set of Standards, Implementation Specifications, and Certification Criteria for EHR Technology
    • 16. EHR certification requirements
    • 17. ONC NPRM - Establishment of Certification Programs for Health Information Technology
    • 18. Procedures to become a certifying body
    4
    What is not in the CMS NPRM?
  • 19.
    • Harmonizes MU criteria across CMS programs as much as possible
    • 20. Closely links with the ONC certification and standards IFR
    • 21. Builds on the recommendations of the HIT Policy Committee
    • 22. Coordinates with the existing CMS quality initiatives
    • 23. Provides a platform that allows for a staged implementation over time
    5
    What the NPRM Does
  • 24.
    • Medicare FFS
    Eligible professionals (EPs)
    Eligible hospitals and critical access hospitals (CAHs)
    • Medicare Advantage (MA)
    MA EPs
    MA-affiliated eligible hospital
    • Medicaid
    EPs
    Eligible hospitals
    6
    Eligibility Overview
  • 25. 7
    Who is a Medicare Eligible Provider?
    *Subsection (d) hospitals that are paid under the PPS and are located in the 50 States or DC (including Maryland hospitals)
  • 26. 8
    Who is a Medicare Advantage Eligible Provider?
  • 27. 9
    Who is a Medicaid Eligible Provider?
  • 28.
    • Hospital-based EPs do not qualify for Medicare EHR incentive payments
    • 29. Most hospital-based EPs will not qualify for Medicaid EHR incentive payments
    • 30. Defined as an EP who furnishes 90% or more of their services in a hospital setting (inpatient, outpatient, or emergency room)
    10
    Hospital-based EPs
  • 31.
    • The Recovery Act specifies the following 3 components of Meaningful Use:
    Use of certified EHR in a meaningful manner (ex: e-prescribing)
    Use of certified EHR technology for electronic exchange of health information to improve quality of health care
    Use of certified EHR technology to submit clinical quality and other measures
    11
    What is Meaningful Use?
  • 32.
    • Definition
    • 33. To be determined by Secretary
    • 34. Must include quality reporting, electronic prescribing, information exchange
    • 35. Process of defining
    • 36. NCVHS hearings
    • 37. HIT Policy Committee (HITPC) recommendations
    • 38. Listening Sessions with providers/organizations
    • 39. Public comments on HITPC recommendations
    • 40. Comments received from the Department and the Office of Management and Budget (OMB)
    12
    Defining Meaningful Use
  • 41. 13
    Conceptual Approach toMeaningful Use
  • 42.
    • Meaningful Use will be defined in 3 stages through rulemaking
    Stage 1 – 2011
    Stage 2 – 2013*
    Stage 3 – 2015*
    *Stages 2 and 3 will be defined in future CMS rulemaking.
    14
    Meaningful Use Stages
  • 43.
    • Improving quality, safety, efficiency, and reducing health disparities
    • 44. Engage patients and families in their health care
    • 45. Improve care coordination
    • 46. Improve population and public health
    • 47. Ensure adequate privacy and security protections for personal health information
    15
    Stage 1 – Health Outcome Priorities*
    *Adapted from National Priorities Partnership. National Priorities and Goals: Aligning Our Efforts to Transform America’s Healthcare. Washington, DC: National Quality Forum; 2008.
  • 48. 16
    Proposed Stages of Meaningful Use Timeline
    *Avoids payment adjustments only for EPs in Medicare EHR Incentive Program
    **Stage 3 criteria of meaningful use or a subsequent update to criteria if one is established
  • 49.
    • EPs
    25 Objectives and Measures
    8 Measures require ‘Yes’ or ‘No’ as structured data
    17 Measures require numerator and denominator
    • Eligible Hospitals and CAHs
    23 Objectives and Measures
    10 Measures require ‘Yes’ or ‘No’ as structured data
    13 Measures require numerator and denominator
    • Reporting Period – 90 days for first year; one year subsequently
    17
    Meaningful Use Summary
  • 50. Use CPOE
    Implement drug-drug, drug-allergy, drug-formulary checks
    Maintain an up-to-date problem list of current and active diagnoses based on ICD-9-CM or SNOMED CT®
    Maintain active medication list
    Maintain active medication allergy list
    Record demographics
    Record and chart changes in vital signs
    18
    Meaningful Use Objectives for EPs & Eligible Hospitals/CAHs
  • 51. Record smoking status for patients 13 years and older
    Incorporate clinical lab-test results into EHR as structured data
    Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, and outreach
    Report ambulatory quality measures to CMS or the States
    Implement 5 clinical decision support rules relevant to specialty or high clinical priority, including diagnostic test ordering, along with the ability to track compliance with those rules
    Check insurance eligibility electronically from public and private payers
    Submit claims electronically to public and private payers
    19
    Meaningful Use Objectives for EPs & Eligible Hospitals/CAHs
  • 52. Provide patients with an electronic copy of their health information upon request
    Capability to electronically exchange key clinical information among providers of care and patient-authorized entities
    Perform medication reconciliation at relevant encounters and each transition of care
    Provide summary care record for each transition of care and referral
    Capability to submit electronic data to immunization registries and actual submission where required and accepted
    Capability to provide electronic syndromic surveillance data to public health agencies and actual transmission according to applicable law and practice
    Protect electronic health information created or maintained by the certified EHR technology through the implementation of appropriate technical capabilities
    20
    Meaningful Use Objectives for EPs & Eligible Hospitals/CAHs
  • 53. Generate and transmit permissible prescriptions electronically
    Send reminders to patients per patient preference for preventive/follow-up care
    Provide patients with timely electronic access to their health information within 96 hours of information being available to the EP
    Provide clinical summaries for patients for each office visit
    21
    Additional Meaningful Use Objectives for EPs Only
  • 54. Provide patients with an electronic copy of their discharge instructions and procedures at time of discharge, upon request
    Capability to provide electronic submission of reportable lab results, as required by state or local law, to public health agencies and actual submission where it can be received.
    22
    Additional Meaningful Use Objectives for Eligible Hospitals/CAHs Only
  • 55. NPRM changes from HITPC Recommendations
    23
  • 56. NPRM changes from the HITPC Recommendations
    Measures
    • Ensured every objective is matched to a measure
    • 57. Added a % threshold to measures recommended as “% of …”
    • 58. Calculated some % based on “unique patients seen” as not every action would be taken for every office visit
    • 59. Narrowed lab results to those “whose results are in a positive/negative or numeric format”
    • 60. For exchange of information changed “implemented ability” to “Performed at least one test”
    • 61. Clinical quality measures were greatly expanded to accommodate the diversity of specialists meeting the definition of an eligible professional
    24
  • 62.
    • 2011 – Providers required to submit summary quality measure data to CMS or States by attestation
    • 63. 2012 – Providers required to electronically submit summary quality measure data to CMS or States
    • 64. EPs are required to submit clinical data on the 2 measure groups: core measures and a subset of clinical measures most appropriate to the EP’s specialty
    • 65. Eligible hospitals are required to report summary quality measures for applicable cases
    25
    Clinical Quality Measures Overview
  • 66.
    • Preventive care and screening: Inquiry regarding tobacco use
    • 67. Blood pressure management
    • 68. Drugs to be avoided by the elderly:
    • 69. Patients who receive at least one drug to be avoided
    • 70. Patients who receive at least two different drugs to be avoided
    26
    Core Quality Measures for EPs
  • 71. 27
    Specialty Quality Measures for EPs
  • 72.
    • Hospitals are required to report summary data to CMS on 35 clinical measures
    • 73. For Medicaid, hospitals have the option to select 8 alternative Medicaid clinical quality measures if the 35 measures do not apply to their patient population
    • 74. Hospitals only eligible for Medicaid will report directly to the States
    • 75. For hospitals in which the measures don’t apply, they will have the option of selecting an alternative set of Medicaid clinical quality measures
    28
    Clinical Quality Measures for Eligible Hospitals
  • 76.
    • EPs
    Medicare FFS
    Medicare Advantage
    Medicaid
    • Eligible Hospitals and CAHs
    Medicare FFS
    Medicare Advantage (paid under Medicare FFS)
    Medicaid
    29
    EHR Incentive Payments Overview
  • 77.
    • Eligible professionals (EPs)
    • 78. Calendar Year
    • 79. 2011-2016 (Medicare) – Up to $44,000 over 5 years if “meaningful EHR user”
    • 80. 2011-2021 (Medicaid) – Up to $63,750 over 6 years – Adopt/Implement/Upgrade or meaningful use in Year 1, MU Years 2-6
    • 81. 2015 and later – If not “meaningful EHR user” up to 3% payment adjustment in Medicare reimbursement
    • 82. We propose that after the initial designation, EPs be allowed to change their program selection only once during payment years 2012 through 2014
    30
    Incentive Payments for EPs
  • 83. 31
    Incentive Payments for Medicare EPs
  • 84. 32
    Additional Incentives for Medicare EPs Practicing in HPSAs
  • 85. 33
    Incentive Payments for Medicaid EPs
  • 86.
    • Eligible hospitals
    Federal Fiscal Year
    $2M base + per discharge amount (based on Medicare/Medicaid share)
    Hospitals meeting Medicare MU requirements may be deemed eligible for Medicaid payments
    Payment adjustments for Medicare after 2015
    Medicare hospitals cannot receive payments after 2016. For Medicaid, hospitals cannot initiate payments after 2016 but can receive payments if they initiated the program before 2016
    No penalties for Medicaid
    NPRM has narrative and sample calculation
    34
    Incentive Payments for Eligible Hospitals
  • 87.
    • Medicare can pay incentives to EPs no sooner than January 2011
    • 88. Medicare can pay eligible hospitals and CAHs no sooner than October 2010
    • 89. Medicaid EPs can potentially receive payments as early as 2010 for adopting, implementing or upgrading
    35
    Incentive Payment Timeline
  • 90.
    • More information on registration will be released following the publication of the final rule in Spring 2010
    • 91. Providers must be enrolled in Medicare FFS, MA or Medicaid to qualify for incentive payments
    • 92. Medicare incentive is based on 75% of Medicare allowable charges subject to maximum payments
    • 93. All providers must have a National Provider Identifier
    • 94. For Medicare – Must be using an EHR that is certified for the EHR Incentive Program
    36
    Registration Requirements
  • 95. Name of the EP, eligible hospital or qualifying CAH
    National Provider Identifier (NPI)
    Business address and business phone
    Taxpayer Identification Number (TIN) to which the provider would like their incentive payment made
    Eligible Hospitals – CMS Certification Number (CCN)
    Eligible Professionals – Medicare or Medicaid program selection (may only switch once over the course of the program)
    37
    To register, the following are required:
  • 96. 38
    Participation in HITECH and other Medicare Incentive Programs for EPs
  • 97. 39
    Notable Differences Between the Medicare & Medicaid EHR Programs
  • 98.
    • HIT Policy and Standards Committees Input - March 1, 2010
    • 99. Public comment period ends March 15, 2010
    • 100. CMS review of comments
    • 101. Draft final regulation
    • 102. CMS/HHS/OMB clearance
    • 103. Final rule publication - Spring 2010
    40
    Next Steps
  • 104.
    • Visit http://www.regulations.gov
    • 105. Document type: Proposed Rule
    • 106. Keyword or ID: CMS-2009-0117-0002
    • 107. Comments are due March 15, 2010 at 5 p.m.
    41
    How to Comment on the NPRM
  • 108.
    • A/I/U – Adopt, implement or upgrade
    • 109. CAH – Critical Access Hospital
    • 110. CCN – CMS Certification Number
    • 111. CDS – Clinical Decision Support
    • 112. CMS – Centers for Medicare & Medicaid Services
    • 113. CY – Calendar Year
    • 114. EHR – Electronic Health Record
    • 115. EP – Eligible Professional
    • 116. eRx – E-Prescribing
    • 117. FFS – Fee-for-service
    • 118. FY – Federal Fiscal Year
    • 119. HHS – U.S. Department of Health and Human Services
    • 120. HIT – Health Information Technology
    • 121. HITECH Act – Health Information Technology for Electronic and Clinical Health Act
    • 122. HITPC – Health Information Technology Policy Committee
    • 123. HIPAA – Health Insurance Portability and Accountability Act of 1996
    • 124. HPSA – Health Professional Shortage Area
    • 125. IFR – Interim Final Rule
    • 126. MA – Medicare Advantage
    • 127. MCMP – Medicare Care Management Performance Demonstration
    • 128. MU – Meaningful Use
    • 129. NPI – National Provider Identifier
    • 130. NPRM – Notice of Proposed Rulemaking
    • 131. OMB – Office of Management and Budget
    • 132. ONC – Office of the National Coordinator of Health Information Technology
    • 133. PQRI – Medicare Physician Quality Reporting Initiative
    • 134. Recovery Act – American Reinvestment & Recovery Act of 2009
    • 135. TIN – Taxpayer Identification Number
    42
    Acronyms