Stage 1 CMS EHR Incentive Program

Conflict of Interest Disclosure

Elizabeth Holland

Travis Broome, MPH, MBA

Jason McNamara

Learning Objectives

1.Updates on the Medicare & Medicaid EHR

Incentive Programs

2.Understand the stage timeline and how the

stages impact implementation decisions

Medicare & Medicaid EHR

Incentives Program

Created by the American Recovery and Reinvestment Act of 2009 Where are we now?

• Medicaid launched in January 2011, started making payments for adopting/implementing/upgrading (AIU) soon after

• Today 49 states and 2 territories have Medicaid EHR incentive programs in place (Puerto Rico and Mariana Islands)

• Medicare opened registration in Jan 2011, opened attestation in April 2011 and started paying in May 2011

As of Jan 31, 2013

15.05%

84.95%

Registered Eligible Hospitals

As of Jan 31, 2013

30.13%

48.08%

21.79%

Registered Eligible Professionals

527,200 Total EPs

Registered Medicare EPs (253,477)

Payment Summary

Paid hospitals

26.82%

73.18%

Paid Eligible Professionals

60.74%

23.26%

13.89%

2.11%

Paid Eligible Professionals

527,200 Total EPs

Medicare-only Eligible Professionals

Could be eligible for both Medicare & Medicaid

incentives

Medicaid-only Eligible Professionals

Hospitals only eligible for Medicare incentive

Could be eligible for both Medicare & Medicaid

(most hospitals)

Everyone starts in Stage 1

When do

I

start Stage 2?

1

st

_Year

of MU

2 years

Stage 2

24

Avoiding 2015 Payment Adjustments

•

Demonstrate meaningful use to CMS or Texas by:

Hospitals subtract 3 months

Hospitals Subtract 3 Months

Apply to CMS for a hardship exemption by:

July 1, 2014

Meaningful EHR User in 2011

or 2012

Never been a Meaningful

EHR User

End EHR reporting period by

Impact of Certification

Q: What Certified EHR Technology do I need in 2014?

A: EHR Technology certified to the 2014 Criteria

covering the “base” EHR plus all objectives I intend to

attest for in 2014.

Q: Does it matter if I am in Stage 1 or 2?

A: No

Q: Can I use 2014 Certified EHR Technology to satisfy

Stage 1 in 2013?

MU and Implementation

•

Put each objective in the context of the goal

•

Is it measurable?

•

How can usability and workflow be better?

Why does CPOE

improve quality, safety

Always looking to the future

•

Stage 2 moves 9 of the 10 menu measures from Stage 1 to core

•

Of the 23 objectives in Stage 2 only 5 are completely new for Stage

2

28

Eligible Professionals

15 core objectives

5 of 10 menu objectives

20 total objectives

Eligible Professionals

17 core objectives

3 of 6 menu objectives

20 total objectives

Eligible Hospitals &

CAHs

14 core objectives

5 of 10 menu objectives

19 total objectives

• Lab Results

• Patient Lists

• Patient Education

• Summary of Care Records

• Medication Reconciliation

• Immunizations

• Patient Reminders

• Online Patient Information

EP

• Lab Results

• Patient Lists

• Patient Education

• Summary of Care Records

• Medication Reconciliation

• Immunizations

• Public health lab results

• Syndromic surveillance

• Secure Messaging

• Family Health History

• Imaging Results

• Registry Reporting

• Progress Notes

EP

• Online Patient Information

• Family Health History

• Imaging Results

• Registry Reporting

• Progress Notes

• E-Prescribing

• eMAR

• Electronic lab results

Current Stage 1 Measure

Age Limits= Age 2 for Blood Pressure & Height/ Weight

New Stage 1 Measure

Age Limits=

Age 3 for Blood Pressure, No age limit for Height/

Weight 30 Exclusion= All three elements not relevant to scope of practice Exclusion= Blood pressure to be separated from height /weight

Current Stage 1 Measure

One test of electronic

transmission of key clinical information

Stage 1 Measure Removed

Requirement removed effective

2013

32

33

Current Stage 1 Objective

Objective= Provide patients with e-copy of health information upon request Provide electronic access to health information

New

1

Objective

33 Objective= Provide patients the ability to view online, download and transmit their health information

• The measure of the new objective is 50% of patients are provided access to their information; there is no requirement that 5% of patients do access their information for Stage 1.

Clinical Quality Measures

CQM Requirements Stage of Meaningful Use

CQM Requirements Year

36

Changes to CQMs Reporting

Beginning in 2014

Selected CQMs must cover at least 3 of the 6 NQS domains Recommended core CQMs: 9 for adult populations

9 for pediatric populations

37

Category Data Level Payer Level Submission Type Reporting Schema

EPs in 1st _{Year of} Demonstrating MU*

Aggregate

All payer Attestation Submit 9 CQMs from EP measures table (includes adult and pediatric recommended core CQMs), covering at least 3 domains

EPs Beyond the 1st _{Year of Demonstrating Meaningful Use}

Option 1 Aggregate All payer Electronic Submit 9 CQMs from EP measures table (includes adult and pediatric recommended core CQMs), covering at least 3 domains

Option 2 Patient Medicare Electronic Satisfy requirements of PQRS EHR Reporting Option using CEHRT

Group Reporting (only EPs Beyond the 1st _{Year of Demonstrating Meaningful Use)**}

EPs in an ACO (Medicare Shared Savings Program or Pioneer ACOs)

Patient Medicare Electronic Satisfy requirements of Medicare Shared Savings Program of Pioneer ACOs using CEHRT

EPs satisfactorily reporting via PQRS group reporting options

Patient Medicare Electronic Satisfy requirements of PQRS group reporting options using CEHRT

*Attestation is required for EPs in their 1st _{year of demonstrating MU because it is the only reporting method that}

would allow them to meet the submission deadline of October 1 to avoid a payment adjustment.

**Groups with EPs in their 1st _{year of demonstrating MU can report as a group, however the individual EP(s) who}

are in their 1st _{year must attest to their CQM results by October 1 to avoid a payment adjustment.}

38

Category Data Level Payer Level Submission Type Reporting Schema

Eligible Hospitals in 1st _{Year of} Demonstrating MU* Aggregate

All payer Attestation Submit 16 CQMs from Eligible Hospital/CAH measures table, covering at least 3 domains

Eligible Hospitals/CAHs Beyond the 1st _{Year of Demonstrating Meaningful Use}

Option 1 Aggregate All payer Electronic Submit 16 CQMs from Eligible Hospital/CAH measures table, covering at least 3 domains

Option 2 Patient All payer (sample)

Electronic Submit 16 CQMs from Eligible Hospital/CAH measures table, covering at least 3 domains

 Manner similar to the 2012 Medicare EHR Incentive Program Electronic Reporting Pilot

Eligible Hospitals reporting for the Medicare EHR Incentive Program

*Attestation is required for Eligible Hospitals in their 1st _{year of demonstrating MU because it is the only reporting}

Resources

• CMS Program Website www.cms.gov/EHRincentiveprograms • ONC Program Website www.healthit.gov

• Details on the Stage 1 Meaningful Use Objectives/Measures

• EPs:

http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/EP-MU-TOC.pdf

• Hospitals:

http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/Hosp_CAH_MU-TOC.pdf

• How much are the incentives?

• http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Basics.html

• Is my EHR certified?

• http://oncchpl.force.com/ehrcert?q=CHPL

• I advise others on meaningful use for a living/I develop certified EHRs

How are EPs doing on Stage 1 improving care?

Objective Performance Threshold 50% Interval Exclusion Deferral

CPOE 84% 30% 99.1%–74.3% 19% N/A

Electronic

Prescribing 79% 40% 92.6%–68.8% 23% N/A

Maintain Problem

List 96% 80% 100%–94.6% N/A N/A

Maintain

Medication List 97% 80% 100%–96.2% N/A N/A

Maintain

Medication Allergy List

96% 80% 99.8%–94.8% N/A N/A

Record

Demographics 91% 50% 99.6%–85.7% N/A N/A

Record Vital Signs 91% 50% 98.6%–86.1% 8% N/A

Record Smoking

Status 90% 50% 98.7%–84.7% 0.5% N/A

Drug Formulary

Checks N/A N/A N/A 14% 16%

Incorporate Lab

Results 91% 40% 100%–89.1% 4% 38%

Patient Lists N/A N/A N/A N/A 25%

Send Reminders to

How are EPs doing on Stage 1 Patient Engagement?

Objective Performance Threshold Interval 50% Exclusion Deferral

How are EPs doing on Stage 1 Care Coordination?

Objective Performance Threshold 50% Interval Exclusion Deferral

Medication

Reconciliation 89% 50% 99.9%–83.5% 3% 56%

Summary of Care at

Medicaid Eligibility Expansion

Patient Encounters

• The definition of what constitutes a Medicaid patient encounter has changed. The rule includes encounters for anyone enrolled in a Medicaid program,

including Medicaid expansion encounters (except stand-alone Title 21), and those with zero-pay claims

44

•

Patient Volume - Medicaid Encounters:

•Previously under Stage 1 rule:

• Service rendered on any one day where Medicaid paid for all or part of the service or Medicaid paid the co-pays, cost-sharing, or premiums

•Changed in Stage 2 rule (applicable to all stages):

• Service rendered on any one day to a Medicaid-enrolled individual, regardless of payment liability

45

•

Zero-pay claims include:

• Claim denied because the Medicaid beneficiary has maxed out the service limit • Claim denied because the service wasn’t covered under the State’s Medicaid

program

• Claim paid at $0 because another payer’s payment exceeded the Medicaid payment

• Claim denied because claim wasn’t submitted timely

46

•

CHIP encounters in patient volume calculation

•Previously under Stage 1 rule:

• Only CHIP encounters for patients in Title 19 Medicaid expansion programs •Under Stage 2 rule (applicable to all stages):

• CHIP encounters for patients in Title 19 and Title 21 Medicaid expansion programs

47

•

90-day Reporting Period for Patient Volume

•Under Stage 1 rule, Medicaid patient volume for providers calculated across 90-day

period in last calendar year (for EPs) or Federal fiscal year (for hospitals)

•Under Stage 2 rule (applicable to all stages), States also have option to allow

providers to calculate Medicaid patient volume across 90-day period in last 12 months preceding provider’s attestation

•Also applies to needy individual patient volume •Applies to patient panel methodology

•

Children’s Hospitals

•Medicaid made approximately 12 additional children’s hospitals eligible that have

not been able to participate to date, despite meeting all other eligibility criteria, because they do not have a CMS Certification Number since they do not bill Medicare.

49

•

Hospital Incentive Calculation - discharge-related amount:

•

Hospitals that began participating before FFY 2013 use

discharge data from hospital fiscal year that ends during FFY

prior to hospital fiscal year that services as the first payment

year

•

Hospitals that begin participating in FFY 2013 or later use

50

•

Adopt, Implement, or Upgrade (AIU) - starting in 2014:

•

To align our polices with ONC EHR Certification Standards we

modified our definition of Adopt, Implement or Upgrade.

•

Providers can no longer attest to AIU with any Certified EHR

Technology.

•

Providers who attest to AIU in 2014 are required to secure Certified

EHR Technology that can bring them to Meaningful Use in the

TITLE SESSION # DATE TIME ROOM SPEAKERS Stage 1: CMS EHR Incentive

Programs 23 Monday, March 4 11:00 AM - 12:00 PM New Orleans Theater C

•Elizabeth Holland, CMS •Travis Broome, CMS •Jason McNamara, CMS

Stage 2: CMS EHR Incentive

Programs 62 Tuesday, March 5 9:45 AM - 10:45 AM New Orleans Theater C

•Elizabeth Holland, CMS •Robert Anthony, CMS •Jason McNamara, CMS •Steven Posnack, ONC

CMS Town Hall:

CMS and eHealth: Building the Future

81 Tuesday, March 5 1:00 PM - 2:00 PM New Orleans Theater C

•Robert Tagalicod, CMS •Kate Goodrich, CMS •Elizabeth Holland, CMS

• Christine Stahlecker, CMS

•Maribel Franey, CMS

ICD-10 and Administrative

Simplification 131 Wednesday, March 6 8:30 AM - 9:30 AM Room 294

• Christine Stahlecker, CMS

•Matthew Albright, CMS •Kari Gaare, CMS •Denesecia Green, CMS

Views from the CMS

Administrator 138 Wednesday, March 6 9:45 AM - 10:45 AM New Orleans Theater C •Marilyn Tavenner, CMS CMS Quality Measurement 178 Thursday, March 7 11:15 AM - 12:15 PM New Orleans Theater C

•Maria Michaels, CMS •Deborah Kraus, CMS •Maria Harr, CMS

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