Meaningful Use - 8/2010

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Meaningful Use program definition as of August 2010 for physician practices

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  • Meaningful Use - 8/2010

    1. 1. 1 © 2010 The Hill Group, Inc. August 25, 2010 Preparing for Meaningful Use
    2. 2. 2 Agenda • Introduction • Timetable of Meaningful Use Announcements • Definition of Meaningful Use • Achieving Meaningful Use • Incentive Timetable • HIPAA/HITECH Control Environment • Q&A
    3. 3. 3 Introduction – Firm • The Hill Group, Inc. has provided strategy and management consulting services to clients across sectors since 1953. • Practice areas: – Strategy – Operations and Process Improvement – Survey and Diagnostic Measurement – Organizational Development • Healthcare Industry: – Preferred HIPAA Vendor for Vale-U-Health – Main strategy firm for many healthcare organizations including insurance plans, health systems, and physician offices – including developing strategies to ensure compliance
    4. 4. 4 Introduction - Presenter • Scott A. Rogerson, Consultant – Supervised multiple audits for clients across various industries in the areas of HIPAA, PCI, and SOX-404 – Assisted in development and execution of critical data analysis strategy for large regional health system – Strong background in strategy development and process improvement – Guest lectured at Duquesne University on system analysis and developing a robust control environment – Certified Information Systems Auditor (ISACA) – Certified Associate in Project Management (PMI) – Serving on Duquesne University ISM Undergraduate and Graduate Advisory Board
    5. 5. 5 Background • American Recovery and Reinvestment Act (ARRA) – February 2009 • Medicare and Medicaid Electronic Health Record (EHR) Incentive Program – Notice of Proposed Rulemaking (NPRM) – January 13, 2010 – NPRM Comment Period Closed – March 15, 2010 – Final Rule on Display – July 13, 2010 – Final Rule Published – July 28, 2010
    6. 6. 6 Purpose of Meaningful Use • Availability • Integrity • Confidentiality
    7. 7. 7 ARRA-defined Components of Meaningful Use 1. Use of certified EHR technology in a meaningful manner 2. Use of certified EHR technology for electronic exchange of health information to improve quality of health care 3. Use of verified EHR technology to submit clinical quality measures (CQM) and other such measures selected by the Secretary Data capture and sharing Advanced clinical processes Improved outcomes
    8. 8. 8 Stages • CMS plans to implement in three stages – Stage 1 requirements have been defined – Guidance has been given that Stage 2 and 3 will build upon Stage 1 • Health Outcome Priorities for Stage 1: – Improve quality, safety, efficiency, and reduce health disparities – Engage patients and families in their health care – Improve care coordination – Improve population and public health – Ensure adequate privacy and security protections for personal health information (HIPAA/HITECH)
    9. 9. 9 Incentive Programs and Eligibility • Medicare Fee-For-Service (FFS) – Eligible Professionals (EPs) – Eligible hospitals and critical access hospitals (CAHs) • Medicare Advantage (MA) – MA EPs – MS-affiliated eligible hospitals • Medicaid – EPs – Eligible Hospitals • NOTE: Eligible Professionals must select either the Medicare or Medicaid EHR incentive programs – no individual provider may participate in both – An EP may change his/her EHR incentive payment program election once before 2015
    10. 10. 10 Eligibility Fee-for-service (FFS) Medicare-advantage (MA) Eligible Professionals Doctor of Medicine of Osteopathy Doctor of Dental Survery or Dental Medicine Doctor of Podiatric Medicine Doctor of Optometry Chiropractor Must furnish, on average, at least 20 hours/week of patient-care services and be employed by a qualifying MA organization OR Must be employed by, or be a partner of, an entity that through contract with the qualifying MA organization furnished at least 80% of the entity's Medicare patient care services to enrollees of the qualifying MA organization Eligible Hospitals Acute Care Hospitals Critical Access Hospitals (CAHs) Will be paid under the Medicare Fee-for-service EHR incentive program Medicare Eligible Professionals Physicians Nurse Practicioners (NPs) Certified Nurse-Midwives (CNMs) Dentists Physician Assistants (Pas) working in a Federally Qualified Health Center (FQHC) or rural health clinic (RHC) that is so led by a PA Eligible Hospitals Acute Care Hospitals Inoe includeing CAHs) Children's Hospitals Medicaid NOTE: Hospital-based EPs (those performing 90% or more of their services in either the inpatient or emergency department of the hospital) DO NOT QUALIFY for Medicare or Medicaid EHR incentive payments
    11. 11. 11 Incentive Schedule – Medicare EPs NOTE: Additional incentive payments (up to $4,400) are available for Medicare EPs participating in Health Professional Shortage Areas (HPSAs)
    12. 12. 12 Incentive Schedule – Medicaid EPs
    13. 13. 13 Tale of the Tape – EHR Programs
    14. 14. 14 Evidencing Meaningful Use • Stage 1 (2011 and 2012) • To meet certain objectives/measures, 80% of patients must have records in certified EHR technology • EPs have to report on 20 of 25 MU objectives (15 core and 5/10 menu set-including at least 1 public health objective) • Clinical Quality Measures • 6 total measures (3 core and 3 alternate measures) • If core measures cannot be submitted, may be substituted for alternate measures • 2011 – submit via attestation • 2012 – electronic submission • Reporting period – 90 days for first year; one year subsequently
    15. 15. 15 Meaningful Use Denominators • Two types of percentage-based measures are included to address the burden of demonstrating MU 1. Denominator is all patients seen or admitted during the EHR reporting period • Regardless of whether records are kept using certified EHR technology 2. Denominator is actions or subsets of patients seen or admitted during EHR reporting period • Only includes patients, or actions taken on behalf of those patients, whose records are kept using certified EHR technology
    16. 16. 16 Considerations when Applying Objectives and Measures • Some MU objectives are not applicable to every provider’s clinical practice and therefore are excluded from having to meet the measure • Does not count against the 5 deferred measures • Example: • Dentists that do not perform immunizations • Chiropractors that do not e-prescribe • States can seek CMS approval to require 4 MU objectives to be core for their Medicaid providers • EPS must have 50% of total patient encounters at locations where certified EHR technology is available (all measures would be based only on these locations)
    17. 17. 17 Timetable for Meaningful Use http://www.cms.gov/EHRIncentivePrograms
    18. 18. 18 EHR Certification • HITECH Act – Required National Coordinator of Health IT to keep or recognize a program or programs for the voluntary certification of health IT • The purpose of certification is to provide assurance to the providers that the EHR technology they adopt will allow for achieving meaningful use
    19. 19. 19 State of EHR Certification • March 10, 2010 – NPRM for temporary and permanent programs to test and certify EHR • June 24, 2010 – HHS published final rule for temporary program • Currently reviewing proposals from certifying organizations • Fall 2010 expected final rule for permanent certification program • Expected to begin in 2012
    20. 20. 20 Next Steps • Fall 2010 – CMS Outreach and Education Campaign • CMS to issue State Medicaid Director Letter with policy guidance on implementation of Medicaid EHR Incentive Program • Early 2011- EPs and eligible hospitals can register for the Medicare and Medicaid EHR Incentive Programs • Enrolled in Medicare FFS, MA, or Medicaid • National Provider Identifier (NPI) • PECOS registered – attest in EHR Incentive potion (available in 2011) • States will announce additional registration requirements • Continued CMS guidance on alignment with other CQM reporting requirements (e.g. CHIPRA)
    21. 21. 21 HIPAA/HITECH Compliance •Goal: • Comply with applicable regulations • Minimize operational burden of integrating compliance activities • Mitigate liability to extent possible • Considerations: • Extent of PHI environment • Current controls in-place • Potential for PHI breach
    22. 22. 22 Resources • CMS EHR Incentive Program • http://www.cms.gov/EHRIncentivePrograms • Office of the National Coordinator for Health IT • http://healthit.hhs.gov
    23. 23. 23 © 2010 The Hill Group, Inc. The Hill Group, Inc 2 East Main St. Carnegie, PA 15106 412-722-1111 Scott A. Rogerson, Consultant srogerson@hillgroupinc.com

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