2011 Medicaid EHR Incentive Program
January 21, 2011
1
Matthew Stanford
VP Policy & Regulatory Affairs
Associate Counsel
Wisconsin Hospital Association
[email protected]
Elise Braun
Medicaid HIT Planning Team – WI
Department of Health Services
Strategy & Operations
Deloitte Consulting LLP
Medicaid Incentive Program: Key Issues to Think About
•Entirely different payment scheme for the Medicaid Program.
The Medicare and Medicaid EHR Incentive Programs have key differences
•Maximum of 3 payment years.
•Before FFY 2016, a hospital does not lose a payment year if it has a gap
between participation years.
•A hospital can start as late as FFY 2016 and still receive the full Medicaid
incentive payments through FFY 2018.
•No penalties under the Medicaid Program for not meeting meaningful use.
•Must meet a 10% Title XIX Medicaid volume threshold or be a children’s
hospital to be eligible for the Medicaid EHR Incentive Program.
Medicaid Incentive Program: Key Issues to Think About
3
Key Difference with Medicare: MU not required in first payment year
•In the first fiscal year that a provider applies and is eligible for the Medicaid
incentive program, that provider can receive payment merely by showing
adoption, implementation, or upgrade of certified EHR.
•Adoption = Acquired and installed
•Implement = Commenced utilization
Medicaid Incentive Program: Key Issues to Think About
Maximizing your Medicare and Medicaid Incentive payments
•Considerations:
•Must demonstrate MU in FFY 2013 to receive the full Medicare EHR
Incentive. Hospitals that begin participation in FFY 2014 or later receive a
lower Medicare incentive.
•Stage 1 MU applies for the hospital’s first two years of participation in the
Medicare EHR Incentive Program.
•Current rules indicate that Stage 2 MU will apply on the hospital’s 3rd year
of demonstrating MU.
•Rules for Stage 2 MU are still in development; not likely finalized until
December 2011.
•Under current rules, hospitals that receive payment in FFY 2011 for
Medicaid Incentive Program: Key Issues to Think About
5
Maximizing your Medicare and Medicaid Incentive payments
•It may be most advantageous for hospitals to:
•Seek 1st Medicaid payment in FFY 2011 or 2012.
•Merely need to demonstrate adoption, implementation or upgrading
of certified EHR.
WHA Resources
WHA Toolkit
•http://www.wha.org/toolKit/default.aspx
•http://www.wha.org/education/default.aspx
WHA Education
Medicaid EHR Incentive Program Overview
◦
Eligibility Requirements
◦
Patient Volume Calculation
◦
Meaningful Use
◦
Incentive Payment Calculation
Participating in the Medicaid EHR Incentive
Program
◦
Registration and Receiving Payments
Timeline and Next Steps for Hospitals
Resources
Medicaid Eligible Hospitals, as defined in the Statute and the
Medicare and Medicaid Programs; Electronic Health Record Incentive
Program Final Rule, include:
◦
Acute Care Hospitals (including CAHs and Cancer Hospitals)*
Average length of patient stay is 25 days or fewer and with a CCN that has
the last four digits in the series 0001- 0879 or 1300 – 1399
◦
Children's Hospitals
with a CCN that has the last four digits in the series 3300 – 3399
Hospitals are eligible as determined by unique CMS
certification numbers (CCN)
Hospital Medicaid EHR Incentive Program Participation Years
are based on the Federal Fiscal Year (FFY)
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Protecting and promoting the health and safety of the people of Wisconsin
Section 4201 of the American Recovery and Reinvestment
Act (ARRA) of 2009 established a program for incentive
payments to certain classes of eligible Medicaid
professionals and hospitals who adopt and become
meaningful users of certified EHR technology
1st Participation Year
2nd – 3rd Participation Year
All Participation Years
• Adopt, Implement, or Upgrade certified EHR technology or demonstrate meaningful use of certified EHR technology
• Demonstrate meaningful use of certified EHR technology
• EHR Reporting Period *
• 90 consecutive days within the FFY for 1st year of demonstrating Meaningful Use (MU)
• 1 year for subsequent years of demonstrating MU
• Acute Care Hospitals:
• Have an Average Length of Stay (ALOS) of 25 days or fewer
• Have a minimum 10% Title XIX Medicaid Patient Volume
• Have a CCN that has the last 4 digits in the series 0001- 0879 or 1300 - 1399
• Children’s Hospitals:
• Separately certified as a children’s hospital, either freestanding or hospital-within –hospital
• Have a CCN that has the last 4 digits in the series 3300–3399
Medicaid Patient Volume Equation
Title XIX Medicaid Patient Encounter
◦ Services rendered to an individual per inpatient discharges where Medicaid or a
Medicaid demonstration project under section 1115 paid for part or all of the service;
◦ Services rendered to an individual per inpatient discharge where Medicaid or a
Medicaid demonstration project under section 1115 of the Act paid all or part of their premiums, co-payments, and/or cost-sharing;
◦ Services rendered to an individual in an emergency department on any one day where Medicaid or a Medicaid demonstration project under section 1115 of the Act either paid for part or all of the service; or
◦ Services rendered to an individual in an emergency department on any one day where Medicaid or a Medicaid demonstration project under section 1115 of the Act paid all or part of their premiums, co-payments, and/or cost-sharing.
11 Protecting and promoting the health and safety of the people of Wisconsin
Total Title XIX Medicaid Patient Encounters for a
90-day period in the preceding Federal Fiscal Year
Total Patient Encounters in that same 90-day period
WHA and DHS have been working collectively to determine Medicaid
Patient Volume for Hospitals
DHS is developing a report that will list Hospital Medicaid Patient
Volume eligibility by Federal Fiscal Year (FFY) Quarter. Information
for FFY 2010 will be available on the following dates:
2010 FFY Q1 (10/01/09 – 12/31/09): January 31, 2011
2010 FFY Q2 (1/01/10 – 3/31/10): March 7, 2011
2010 FFY Q3 (4/01/10 – 6/30/10): March 7, 2011
2010 FFY Q4 (7/01/10 – 9/30/10): May 31, 2011
It is anticipated that DHS will publish a list of all hospitals that meet
the volume threshold and are potentially eligible to receive a
Medicaid EHR Incentive Payment in FFY 2011 on the Medicaid EHR
Incentive Program website
(
http://www.dhs.wisconsin.gov/ehrincentive/
)
If Hospitals have questions about their Patient Volume calculation
MU measures are the same for the Medicare and Medicaid EHR
Incentive Programs
Hospitals must report on 19 of 24 MU objectives
◦
14 must be core objectives
◦
5 objectives may be chosen from the list of 10 menu set objectives
At least one objective must be a population or public health measure
Some MU objectives are not applicable to every Hospital, in
these cases the Hospital would be excluded from having to
meet that measure
◦
Exclusions do not count against the 5 deferred menu set objectives
EHR Reporting Period
◦
1st year of demonstrating MU is 90 days within the participation year (FFY),
all subsequent years of demonstrating MU it is the full participation year
(FFY)
Reporting MU Criteria
◦
Dually Eligible Hospitals
– Report to CMS
Hospitals deemed eligible by CMS will automatically be deemed eligible by Medicaid
◦
Medicaid Only Hospitals
– Report to Wisconsin Medicaid Agency
Aggregate EHR Hospital Incentive Amount will be calculated
by the State in Participation Year 1 per CCN
◦
Adjustments to the aggregate incentive payment may be needed
based upon updates to cost report data
States had the option to disburse the Aggregate EHR Hospital
Incentive Amount over 3 – 6 years
◦
The Wisconsin Medicaid Agency will distribute payments over 3
years according to the following percentages:
Participation Year 1: 50% of Aggregate EHR Hospital Incentive Amount
Participation Year 2: 40% of Aggregate EHR Hospital Incentive Amount
Participation Year 3: 10% of Aggregate EHR Hospital Incentive Amount
The # of years payments are distributed over does not impact
the Aggregate EHR Hospital Incentive Amount
For Dually Eligible Hospitals - Medicaid EHR Incentive Payments
are in addition to the Medicare EHR Incentive Payments
In order to receive an EHR incentive payment after 2016 the
Hospital must have received a payment in the previous year
◦
Hospitals receiving a Medicaid EHR incentive payment must
receive payments on a consecutive, annual basis after the year
2016
◦
Prior to 2016, Medicaid incentive payments to hospitals can be
made on a nonconsecutive, annual basis
Data elements used to calculate the Aggregate EHR Hospital
Incentive Amount will come from the most recently submitted
Hospital Cost Report period (the individual Hospital’s Fiscal
Year)
◦
With one exception – the average annual growth rate will be
calculated using the most recent three years of available discharge
data
15
Overall EHR Amount = Sum over 4 years of [(
Base Amount
+
Discharge Related Amount Applicable for Each Year
) *
Transition Factor Applicable for Each Year
]}
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Protecting and promoting the health and safety of the people of Wisconsin
Data Input Name Description Source of Data
Base Amount $2,000,000 Statute Defined
Discharge Related Amount $200*(the 1,150th through the
23,000th discharge for year 1, for subsequent years use
discharges adjusted for the
provider's average annual rate of growth for the most recent 3 years for which data are available per year.)
Hospital
(WHA will be able to provide assistance to Hospitals in determining this information)
Transition factor ◦ Year 1 = 1
◦ Year 2 = 0.75
◦ Year 3 = 0.50
◦ Year 4 = 0.25
Data Provided:
◦
Discharges
Hospital Fiscal Year 2010: 2,000 Base Year (BY)
Hospital Fiscal Year 2009: 1,900 BY (-1)
Hospital Fiscal Year 2008: 1,720 BY (-2)
Hospital Fiscal Year 2007: 1,500 BY (-3)
Formula
Calculation
Annual
Growth Rate
(BY (-2) – BY (-3))/ BY (-3) (1,720-1,500)/1,500 0.147
(BY (-1) – BY (-2))/ BY (-2) (1,900-1,720)/1,720 0.105
(BY – BY (-1))/ BY (-1)
(2,000-1,900)/1,900 0.053
Discharges Per Calculation
◦
Y1 = 2,000 (Base Year)
◦
Y2 = Y1 * 1.102 = 2,204
◦
Y3 = Y2 * 1.102 = 2,429
◦
Y4 = Y3 * 1.102 = 2,677
Discharge Related Amount
◦
Y1 = 200* (2,000 – 1,149) = 170,200
◦
Y2 = 200* (2,204 – 1,149) = 211,000
◦
Y3 = 200* (2,429 – 1,149) = 256,000
◦
Y4 = 200* (2,677 – 1,149) = 305,600
Overall EHR Amount
◦
Y1 = (2,000,000 + 170,200) * 1 = 2,170,200
◦
Y2 = (2,000,000 + 211,000) * 0.75 = 1,658,250
◦
Y3 = (2,000,000 + 256,000) * 0.50 = 1,128,000
◦
Y4 = (2,000,000 + 305,600) * 0.25 = 576,400
19 Protecting and promoting the health and safety of the people of Wisconsin
Overall EHR Amount = SUM OF ALL 4 Years = $5,532,850
Discharges increase each year
by the average annual growth
rate from the amount
calculated in the previous year
Discharges that count in this
formula are the 1,150 –
Medicaid Share = {(
Estimated Medicaid Inpatient Bed Days
+
Estimated Medicaid Managed Care Inpatient Bed Days
)
/
[(
Estimated Total Inpatient Bed Days
)*(
Estimated Total Charges
-
Charity Care Charges
)/(
Estimated Total Charges
)]}
Data Input Name Description Source of Data
Estimated Medicaid Inpatient
Bed Days * Medicaid Title XIX Fee for Service Inpatient Bed Days for the Hospital’s cost reporting period (provided by Wisconsin Medicaid)
State of Wisconsin – Medicaid Agency
Estimated Medicaid Managed
Care Inpatient Bed Days* Medicaid Title XIX Manage Care Inpatient Bed Days for the Hospital’s cost reporting period (provided by Wisconsin Medicaid)
State of Wisconsin – Medicaid Agency Estimated Total Inpatient Bed
Days Medicare Cost Report Worksheet S-3, Part 1, Column 6, line 12 Hospital
Estimated Total Charges Medicare Cost Report Worksheet C, Part 1,
Column 8, line 103 Hospital
Charity Care Charges Medicare Cost Report 2552–10, Worksheet
S-10, line 30 Hospital
Data Provided:
◦
Medicaid Inpatient Bed Days (FFS) = 5,000
◦
Medicaid MCO Inpatient Bed Days = 2,000
◦
Total Inpatient Bed Days = 21,000
Aggregate EHR Hospital Incentive Amount=
(Overall EHR Amount) * (Medicaid Share)
Aggregate EHR Hospital Incentive Amount =
$5,532,850 * 0.38 = $2,102,483
Participation
Year
Aggregate EHR
Amount
Percentage
Payment Amount
All Hospitals must register via the CMS’s National Level Repository (NLR)
https://ehrincentives.cms.gov
Information Hospitals will need:
◦
CMS Identity and Access Management (I&A) User ID and Password
◦
CMS Certification Number (CCN)
◦
National Provider Identifier (NPI)
◦
Hospital Tax Identification Number
For information on what will be required during registration go to:
http://www.cms.gov/EHRIncentivePrograms/20_RegistrationandAttestation.a
sp
Registration Types
◦
Medicaid Only
◦
Medicare Only
◦
Medicare and Medicaid (Dually Eligible Hospitals)
If at any time plan to participate in both programs then Hospital should
register for both a the time of initial registration
Targeted to be ready Summer 2011
To access the portal Hospitals must:
◦
Be a certified Wisconsin Medicaid Provider (no
sanctions, currently licensed)
◦
Have a ForwardHealth Provider Portal Account
In Participation Year 1 Hospitals can AIU certified EHR technology or
demonstrate MU for Medicaid
Medicaid Only Hospital
◦
Report all information (both AIU and MU) to the Wisconsin Medicaid
Agency through the ForwardHealth Portal
Dually Eligible Hospital
◦
Adopt, Implement, or Upgrade
Report all information to Wisconsin Medicaid Agency through the ForwardHealth
Portal
◦
Meaningful Use
Medicaid Attestations – Report to the Wisconsin Medicaid Agency through the
ForwardHealth Portal
Hospital Payment Calculation Data - Report to the Wisconsin Medicaid
Agency through the ForwardHealth
Meaningful Use Criteria - Report to CMS through the NLR
Dually Eligible Hospitals demonstrating MU will need to submit to Medicare
prior to requesting payment from the Wisconsin Medicaid Agency
Hospitals deemed eligible by CMS will automatically be deemed eligible by the
Information will be evaluated by Medicaid, if Hospital
meets the criteria the Hospital will be approved for a
Medicaid EHR incentive payment
Medicaid will inform the NLR of the payment made to
the Hospital to update the Hospital’s NLR record
Payments will be processed and distributed through
Electronic Fund Transfer (EFT)
◦
If Hospital does not currently have EFT established, one will need
to be established before requesting payment
APRIL 2011 Attestation for the Medicare EHR Incentive Program begins 29
Protecting and promoting the health and safety of the people of Wisconsin
Certified EHR technology available and listed on ONC website Registration and attestation for Wisconsin Medicaid EHR Incentive Program begins Wisconsin Medicaid EHR Incentive Payments begin NOVEMBER 30, 2011
Last day for eligible hospitals and CAHs to register and attest to receive an Incentive Payment for FFY 2011
Last year to receive a Medicare EHR
Incentive Payment Last year to initiate participation in Medicaid EHR Incentive Program Last year a Hospital can receive a Medicaid EHR Incentive Payment from Wisconsin WINTER 2010/2011 FALL 2010 2014 2015 SPRING 2011 SUMMER 2011 FALL 2011 WINTER 2011/2012 2016 2018 JANUARY 3, 2011 Registration for the Medicare EHR Incentive Program begins MAY 2011 Medicare EHR Incentive Payments begin
Last year to initiate participation in the Medicare EHR Incentive Program
Questions?
◦
Email:
[email protected]
Medicaid EHR Incentive Program
◦
https://www.cms.gov/EHRIncentivePrograms/
◦
http://www.dhs.wisconsin.gov/ehrincentive/
NLR Registration
◦ http://www.cms.gov/EHRIncentivePrograms/20_RegistrationandAttestation.asp
ONC list of Certified EHR Technology
◦
http://onc-chpl.force.com/ehrcert
ListServe
◦
Register your email to subscribe to email updates on the
Medicaid EHR Incentive Program:
http://lists.wi.gov/read/all_forums/subscribe?name=dhs-ehrincentiveprogram
Wisconsin Health Information Technology Extension Center
31 Protecting and promoting the health and safety of the people of Wisconsin
