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
  • Hitech ehr incentive programs

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

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