Government Announces Changes to Timeline for Meaningful Use
Published on
January 3rd, 2012
In November 2011, Health and Human Services (HHS) Secretary Kathleen Sebelius announced policy changes designed to make it easier for health care providers and hospitals to qualify for meaningful use incentive payments. Under the 2009 federal economic stimulus package, health care providers who demonstrate meaningful use of certified electronic health records can qualify for Medicaid and Medicare incentive payments.
Under current regulations, eligible health care providers that attest to Stage 1 of the Medicare EHR incentive program in 2011would need to meet Stage 2 requirements in 2013. However, health care providers who attest to Stage 1 in 2012 would not need to meet Stage 2 requirements until 2014, but they still would be eligible for the same total incentive payment amount.
This new online tool from CMS allows providers to test whether or not they would successfully demonstrate meaningful use for the EHR Incentive Programs. SMARTMD has provided this tool to assist you in your process to attest successful to meaningful use.
This new CMS eligible provider attestation worksheet allows EPs to log their meaningful use measures on this page to use as a reference when attesting for the Medicare EHR Incentive Program in the CMS system.
Meaningful Use penalties are scheduled to begin in 2015 for
providers who are not meaningful users of certified EHR technology by 2014. Here's what you need to know about the penalties:
Penalties apply to Medicare only- these penalties or “Adjustments” will be applied as a percent of Medicare Part B Professional Fee. They are scheduled to begin in 2015, and continue as follows:
- 2015: 1%
- 2016: 2%
- 2017: 3%
- 2018 and 2019: may increase 1%/year, at the discretion of the Secretary of HHS.
There has been speculation by some industry pundits that the penalties will be delayed or not implemented at all, but to rely upon that as a given would be a mistake.
There are no penalties associated with the Medicaid program—adjustments do not apply to Medicaid revenue. Pursuing the EHR incentives as a Medicaid provider, however, does not totally insulate a physician from the penalties. If a Medicaid provider does not become a meaningful user by 2014, the revenue he/she generates under Medicare would be subject to the adjustments above.
CMS Medicare & Medicaid EHR Incentive Program Deadlines
Incentive payments for the Medicare EHR Incentive Program will be made approximately four to eight weeks after an eligible professional, eligible hospital or critical access hospital meets the program requirements and successfully attests they have demonstrated meaningful use of certified EHR technology. CMS expects that Medicare incentive payments will begin in May 2011. Payments will be held for eligible professionals until the eligible professional meets the $24,000 threshold in allowed charges.
Eligible hospitals and critical access hospitals attesting in April 2011 could receive their initial payments as early as May 2011. Final payment will be determined at the time of settling the hospital Medicare cost report.
Medicaid incentives will be paid by the states and are expected also to begin in 2011. States are required to issue incentive payments within 45 days of providers successfully attesting to having adopted, implemented or upgraded certified EHR technology during their first year of participation in the Medicaid EHR Incentive Program. Launch date for the Medicaid EHR Incentive Program varies by state, so the earliest date attestation can begin also varies by state. Several states have disbursed incentive payments as early as April 2011.
GET READY! Standards for Electronic Transactions- New Versions, New Standard and New Code Set - 5010 and ICD-10 Final Rules
Published on 11/26/2011
On January 16, 2009, HHS published two final rules to adopt updated HIPAA standards; these rules are available at the Federal Register.
In one rule, HHS is adopting X12 Version 5010 and NCPDP Version D.0 for HIPAA transactions. In this rule, HHS also adopts a new standard for Medicaid subrogation for pharmacy claims, known as NCPDP Version 3.0. For Version 5010 and Version D.0, the compliance date for all covered entities is January 1, 2012. This gives the industry enough time to test the standards internally, to ensure that systems have been appropriately updated, and then to test between trading partners before the compliance date. The compliance date for the Medicaid subrogation standard is also January 1, 2012, except for small health plans, which will have until January 1, 2013 to come into compliance.
In a separate final rule, HHS modifies the standard medical data code sets for coding diagnoses and inpatient hospital procedures by concurrently adopting the International Classification of Diseases, 10th Revision, Clinical Modification (ICD-10-CM) for diagnosis coding and the International Classification of Diseases, 10th Revision, Procedural Coding System (ICD-10-PCS) for inpatient hospital procedure coding. These new codes replace the current International Classification , 9th Revision, Clinical Modification, Volumes 1 and 2 and the International Classification , 9th Revision, Clinical Modification, Volume 3 for diagnosis and procedure codes respectively. The implementation date for ICD-10-CM and ICD-10-PCS is October 1, 2013 for all covered entities.
Version 5010 accommodates the ICD-10 code sets, and has an earlier compliance date than ICD-10 in order to ensure adequate testing time for the industry. These two rules apply to all HIPAA covered entities, including health plans, health care clearinghouses, and certain health care providers.
Government mandated changes require upgrades to your billing software by January 1st 2012. Limited Time! Free Billing Module with the SMARTMD EHR system.
Don't wait, call: (855) SMARTMD.
Flow Chart to Help Eligible Professionals (EP) Determine Eligibility for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs
CMS has now issued a final rule making changes to Medicare's Electronic Prescribing Incentive program. The rule will be published in the Federal Register on Sept. 6, 2011.
CMS has finalized a proposal to better align the eRx Incentive program with the electronic health record meaningful use incentive program. Under the final rule, EHRs that have received meaningful use certification are deemed to qualify for the eRx Incentive program. The new rule also finalizes ways for providers to get a "hardship exemption" from the eRx program to avoid reimbursement penalties for non-participation. For instance, an eligible professional who has registered to participate in the Medicare or Medicaid EHR incentive programs and has adopted certified EHR technology can request a hardship exemption from the eRx program. Even if an eligible professional practices in a state where the Medicaid EHR incentive program is not yet fully implemented, the EP can still register for the program and then seek an exemption from the eRx program. The deadline for submitting hardship exemption requests, detailed in the final rule, is Nov. 1, 2011 .
CMS has added basically four additional significant hardship exemptions that will make professionals exempt from the 2012 payment adjustment:
Eligible professionals who register to participate in the Medicare or Medicaid EHR Incentive Program and adopt certified EHR technology
Eligible professionals who are unable to electronically prescribe due to local, state, or federal law or regulation
Eligible professionals who have limited prescribing activity
Eligible professionals who have insufficient opportunities to report the e-prescribing measure due to limitations of the measure's denominator.
The two hardship exemptions already available to professionals are:
Eligible professional or group practice practices in rural areas with limited high-speed internet access
Eligible professional or group practice practices in an area with limited available pharmacies for electronic prescribing.
Final Note: CMS has extended the deadline for requesting significant hardship
exemptions to November 1, 2011. EPs are allowed to report hardship exemptions online and group practices are allowed to report via mailed letter.
Eligible Professional (EP) Attestation Worksheet for the Medicare
Electronic Health Record (EHR) Incentive Program
What is the Federal Governments Incentive Program?
American Recovery & Reinvestment Act of 2009 - This Federal Program was established by U.S. Federal law
Incentive programs for Eligible Providers whom participate and see patients from Federal Medicare or State Medicaid programs.
The Medicaid incentive program is run by States and is voluntary and the Medicare program is Federal and managed by Center for Medicare Services (CMS)
Incentive programs are for hospitals and eligible professionals
Providers and hospitals must use certified EHR technology AND demonstrate adoption, implementation, upgrading or meaningful use
Programs differ between Medicare and Medicaid
What's changed between January and now?
The main difference between the old policy & temporary rule and now the “Final Rule” on Meaningful Use recently published was that we no longer have an “all or nothing” approach, in which hospitals and eligible incentive professionals who failed to meet any one of the requirements were ineligible for funding. Now the final rule has not just reduced the total number of requirements, but introduced choice.
In the notice of proposed rulemaking (NPRM) there were 25 requirements for Eligible Professionals and 23 for hospitals. In the Final Rule there are 15 core requirements for Eligible Professionals and 14 for hospitals. For both hospitals and professionals, there are 10 discretionary requirements from which five must be chosen.
Thresholds have been reduced in many cases. For example, under the NPRM, 80 percent of orders for eligible professionals and 10 percent of orders for hospitals had to utilize computerized physician order entry (CPOE). The language in the final rule focuses on order entry of medications and requires that 30 percent of patients with medication orders have at least one medication order entered electronically. This requirement applies to both eligible professionals and hospitals.
Administrative simplification, which addresses formats for the exchange of information among different systems, has been postponed to Stage 2.
Only one clinical decision support rule must be included under the final rule, down from five in the proposed rule.
Required clinical quality measures have been reduced to 6 for professionals and 15 for hospitals. For professionals, there are 3 core measures required, 3 alternative core measures, and a choice of 3 from a pool of discretionary measures. Reporting by attestation is required in 2011, electronic reporting is required in 2012. Clinical quality measurements for specialists have been eliminated for stage 1. There has been great effort to align meaningful use with the measures tracked through CMS' Physician Quality Reporting Initiative.
The NPRM did not include the recording of advanced directives or a provision for providing patients with educational materials. The final rule includes these as discretionary meaningful use requirements.
Overall, the final rule maintains a balance between the policy objectives sought and the technology changes that are achievable now. There will still be three stages of meaningful use and later stages will be more demanding. All the Stage 1 requirements included in the NPRM will still be part of meaningful use by Stage 2.
In January of 2011, the clinicians may begin the 90 day process of using a certified record per meaningful use requirements. Attestation of this use begins in April 2011. CMS payments will begin May 2011.
Who is Eligible to Participate?
“EP”- Eligible Professional
An EP is determined by Federal law. Hospital-based EPs are NOT eligible for incentives if
90% or more of their covered professional services in either an in-patient or emergency room
of a hospital. Incentive programs for Eligible Providers whom participate and see patients from
Federal Medicare or State Medicaid programs.
Medicare- EP defined
Doctors of Medicine or Osteopathy
Doctors of Dental Surgery or Dental Medicine
Doctors of Podiatric Medicine
Doctors of Optometry
Chiropractic Physicians
Medicaid- EP defined
Physicians…meaning MD's and DO's
Nurse practitioners
Certified nurse-midwives
Dentists
Physician's assistant's working in a Federally Qualified Health Center (FQHC) or rural health clinic (RHC) that is so led by a physicians assistant
Medicare Advantage
EP's participating in Medicare Advantage programs must furnish on average at least 20 hours per week of their patient-care services and be employed by the qualifying MA organization
(or)
Furnish, on average, at least 20 hours per week of patient care services and be employed by, or be a partner of an entity that through contract with the qualifying MA organization furnishes at least 80% of the entity's Medicare patient care services to enrollees of the qualifying MA organization
Medicaid
Medicaid EP's must meet one of the three patient volume thresholds:
Have a minimum of 30% Medicaid patient volume
Pediatricians ONLY: Have a minimum of 20% Medicaid patient volume
Working in FQHC or RHC ONLY: Have a minimum of 30% patient volume attributed to needy individuals
How Much Are the Medicare Incentives?
Medicare Incentive Payments Overview:
Maximum incentives are $44,000 over 5 years
Incentives decrease if starting after 2012
Must begin by 2014 to receive incentive payments. Last payment year is 2016.
Extra bonus amount available for practicing predominantly in a Health Professional Shortage Area
Only 1 incentive payment per year
For your first EHR, your incentive check is 75% of your total Medicare or Medicaid charges up to a maximum of $15,000
Those physicians implementing EHR no later than 2012 are eligible for a maximum of $18,000 the first year they prove meaningful use. Your EHR implementation must start in 2011 or 2012
There will be no payments for those physicians implementing EHR after year 2014…in other words beyond 2015.
How are the Medicare incentives calculated?
Incentives are based on the lesser of either 75% of the provider's Medicare Part B billings or the maximum allowable incentive.
All non-hospital physicians who see Medicare patients and are meaningful users of an approved EHR by year 2011 are eligible to receive a stimulus payment of up to $44,000 per physician over five years according to the following schedule.
Medicare incentives are reduced over time and will be phased out after 2014.
Rural health physicians are eligible for a 25% increase over and above the base incentive. (up to $55,000)
Medicare Incentive Schedule and Payments
What Year and how much incentive dollars to be received?
Year EHR use is first demonstrated
2011
2012
2013
2014
2015
2016
Total
2011
$
18,000
12,000
8,000
4,000
2,000
0
44,000
2012
$
0
18,000
12,000
8,000
4,000
2,000
44,000
2013
$
0
0
15,000
12,000
8,000
4,000
39,000
2014
$
0
0
0
12,000
8,000
4,000
24,000
2015 or Later
$
0
0
0
0
0
0
0
How Much Are the Medicaid Incentives?
Medicaid Incentive Payments Overview Maximum incentives are $63,750 over 6 years
Incentives are same regardless of start year
The first year payment is $21,250
Must begin by 2016 to receive incentive payments
No extra bonus for health professional shortage areas available
Incentives available through 2021
Only 1 incentive payment per year
How are Medicaid incentives calculated?
All non-hospital based physicians whose practice is greater than 30% Medicaid (or 20% for pediatricians), as well as their Certified Nurse Midwives & Nurse Practitioners, and Physician Assistants who are practicing in federally qualified health centers (FQHCs) or rural health clinic (RHCs) led by a physician assistant are qualified to receive up to $63,750 EACH, once they become meaningful users of a Certified EHR:
The exact incentive is calculated at 85% of the Net Average Allowable Cost of the HER system, including cost of software, hardware, implementation, training, maintenance, etc.; and it is capped at a maximum per year according to the following schedule:
Year 1: $21,250 or 85% of your Net Average Allowable Cost, whichever is less
Year 2 through 6: $8,500 or 85% of your Net Average Allowable Cost, whichever is less
Total incentive not to exceed $63,750
How Much Are the Medicaid Incentives?
Medicaid Incentive Payments Detail Columns = first calendar year EP receives a payment
Rows = Amount of payment each year if continue to meet requirements :
CY 2011
CY 2012
CY 2013
CY 2014
CY 2015
CY 2016
CY 2011
$21,250
CY 2012
$8,500
$21,250
CY 2013
$8,500
$8,500
$21,250
CY 2014
$8,500
$8,500
$8,500
$21,250
CY 2015
$8,500
$8,500
$8,500
$8,500
$21,250
CY 2016
$8,500
$8,500
$8,500
$8,500
$8,500
$21,250
CY 2017
$8,500
$8,500
$8,500
$8,500
$8,500
CY 2018
$8,500
$8,500
$8,500
$8,500
CY 2019
$8,500
$8,500
$8,500
CY 2020
$8,500
$8,500
CY 2021
$8,500
Total
$63,750
$63,750
$63,750
$63,750
$63,750
$63,750
What are the Requirements/ Meaningful Use?
Meaningful Use is using certified EHR technology to Improve quality, safety, efficiency, and reduce health disparities
Engage patients and families in their health care
Improve care coordination
Improve population and public health
All the while maintaining privacy and security
The Recovery Act specifies the following 3 components of Meaningful Use:
Use of certified EHR in a meaningful manner (e.g., 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 measures (CQM) and other such measures selected by the Secretary
Basic Overview of Stage 1 Meaningful Use:
The FIRST stage of meaningful use emphasizes 4 area's:
Collecting electronic health data
Implementing clinical decision support tools
Reporting clinical quality measures & public health data
Using EHR data to track conditions and coordinate care
Reporting period is 90 days for first year (2011)
Reporting through attestation
Objectives and Clinical Quality Measures
Reporting may be yes/no or numerator/denominator attestation
To meet certain objectives/measures, 80% of patients must have records in the certified EHR technology
For the first payment year only of 2011, the EHR reporting period can be a continuous
90-day period within a payment year in which an EP or eligible hospital successfully demonstrates meaningful use of certified EHR technology. The EHR reporting period therefore could be any continuous period beginning and ending within the relevant payment year.
Example:
For payment year 2011, an EHR reporting period of March 13, 2011 to June 11, 2011 would be just as valid as an EHR reporting period of January 1, 2011 to April 1, 2011. An example of an unallowable EHR reporting period would be for an EP to begin on November 1, 2011 and finish on January 31, 2012. Starting with the second payment year and any subsequent payment years for a given EP or eligible hospital, we propose to define the term EHR reporting period to mean the entire payment year.
Stage 1 Objectives and Measures Reporting
Eligible Professionals must complete: 15 core objectives
5 objectives out of 10 from menu set
6 total Clinical Quality Measures (3 core or alternate core, and 3 out of 38 from menu set)
Some MU objectives not applicable to every provider's clinical practice, thus they would not have any eligible patients or actions for the measure denominator. Exclusions do not count against the 5 deferred measures
In these cases, the eligible professional would be excluded from having to meet that measure Eg: Dentists who do not perform immunizations; Chiropractors do not e- prescribe
While the original proposed rule required hospitals and EPs to demonstrate 23 and 25 objectives respectively, the final rule divided the meaningful use requirements into two categories:
A set of "core" objectives that must be met, 14 for hospitals and 15 for EPs
A set of 10 "menu" objectives each from which hospitals and EPs must meet any five
Of the five menu objectives, one must be from the population health category. While this two- track approach ensures that all providers qualifying for incentives meet a baseline for meaningful use, it does offer them latitude in other requirements to reflect their technical maturity and organizational priorities.
In addition to adopting certified EHRs and demonstrating compliance with the meaningful use measures, hospitals and EPs aiming to collect incentives must report on a set of clinical quality measures. The final rule significantly reduced the number of clinical quality measures from the proposed rule. Hospitals now must report on 15 clinical quality measures, while EPs must report on just six -- three of which must come from the "core or alternate core" set and the remaining three can be selected from a set of 38 clinical quality measures- www.ihealthbeat.org
15 Core Objective to be met by EP's
E-Prescribing (eRx)
Computerized physician order entry (CPOE)
Report ambulatory clinical quality measures to CMS/States
Implement one clinical decision support rule
Provide patients with an electronic copy of their health information, upon request
Provide clinical summaries for patients for each office visit
Drug-drug and drug-allergy interaction checks
Record demographics
Maintain an up-to-date problem list of current and active diagnoses
Maintain active medication list
Maintain active medication allergy list
Record and chart changes in vital signs
Record smoking status for patients 13 years or older
Capability to exchange key clinical information among providers of care and patient- authorized entities electronically
Protect electronic health information
10 Menu objectives – must complete 5 of 10
Drug-formulary checks
Incorporate clinical lab test results as structured data
Generate lists of patients by specific conditions
Send reminders to patients per patient preference for preventive/follow up care
Provide patients with timely electronic access to their health information
Use certified EHR technology to identify patient-specific education resources and provide to patient, if appropriate
Medication reconciliation
Summary of care record for each transition of care/referrals
Capability to submit electronic data to immunization registries/systems*
Capability to provide electronic syndrome surveillance data to public health agencies*
Clinical Quality Measures – Core Set
NQF Measure Number & PQRI Implementation Number/ Clinical Quality Measure Title
NQF 0013 Hypertension: Blood Pressure Measurement
NQF 0028 Preventive Care & Screening Measure Pair:
Tobacco Use
Assessment,
Tobacco Cessation Intervention
NQF 0421 & PQRI 128 Adult Weight Screening and Follow-up
Clinical Quality Measures – Alternate Core Set
NQF Measure Number & PQRI Implementation Number/ Clinical Quality Measure Title
NQF 0024 Weight Assessment and Counseling for Children and Adolescents
NQF0041 & PQRI 110 Preventive Care and Screening: Influenza Immunization for
Patients50 Years Old or Older
NQF 0038 Childhood Immunization Status
Additional set CQM–must complete 3 of 38
Diabetes: Low Density Lipoprotein (LDL) Management and Control
Diabetes: Blood Pressure Management
Diabetes: Hemoglobin A1c Poor Control
Heart Failure (HF): Angiotensin- Converting Enzyme (ACE) Inhibitor or Angiotensin Receptor Blocker (ARB) Therapy for Left Ventricular Systolic Dysfunction (LVSD)
Coronary Artery Disease (CAD): Beta-Blocker Therapy for CAD Patients with Prior Myocardial Infarction (MI)
Pneumonia Vaccination Status for Older Adults
Breast Cancer Screening
Coronary Artery Disease (CAD): Oral Anti-platelet Therapy Prescribed for Patients with CAD
Heart Failure (HF): Beta-Blocker Therapy for Left Ventricular Systolic Dysfunction (LVSD)
Colorectal Cancer Screening
Anti-depressant medication management:
(a) Effective Acute Phase Treatment,
(b) Effective Continuation Phase Treatment
Primary Open Angle Glaucoma (POAG): Optic Nerve Evaluation
Diabetic Retinopathy: Documentation of Presence or Absence of Macular Edema and Level of Severity of Retinopathy
Diabetic Retinopathy: Communication with the Physician Managing Ongoing Diabetes Care
Asthma Pharmacologic Therapy
Asthma Assessment
Appropriate Testing for Children with Pharyngitis
Oncology Breast Cancer: Hormonal Therapy for Stage IC-IIIC Estrogen Receptor/Progesterone Receptor (ER/PR) Positive Breast Cancer
Oncology Colon Cancer: Chemotherapy for Stage III Colon Cancer Patients
Prostate Cancer: Avoidance of Overuse of Bone Scan for Staging Low Risk Prostate Cancer Patients
Smoking and Tobacco Use Cessation, Medical Assistance: a) Advising Smokers and Tobacco Users to Quit, b) Discussing Smoking and Tobacco Use Cessation Medications, c) Discussing Smoking and Tobacco Use Cessation Strategies
Diabetes: Eye Exam
Diabetes: Urine Screening
Diabetes: Foot Exam
Coronary Artery Disease (CAD): Drug Therapy for Lowering LDL-Cholesterol
Heart Failure (HF): Warfarin Therapy Patients with Atrial Fibrillation
Ischemic Vascular Disease (IVD): Use of Aspirin or Another Anti-thrombotic
Initiation and Engagement of Alcohol and Other Drug Dependence Treatment: a) Initiation, b) Engagement
Prenatal Care: Screening for Human Immunodeficiency Virus (HIV)
Prenatal Care: Anti-D Immune Globulin
Controlling High Blood Pressure
Cervical Cancer Screening
Chlamydia Screening for Women
Use of Appropriate Medications for Asthma
Low Back Pain: Use of Imaging Studies
Ischemic Vascular Disease (IVD): Complete Lipid Panel and LDL Control
Diabetes: Hemoglobin A1c Control (<8.0%)
Eligible Professional- Multiple Locations
An Eligible Professional who works at multiple locations, but does not have certified EHR technology available at all of them would:
Have to have 50% of their total patient encounters at locations where certified EHR technology is available
Would base all meaningful use measures only on encounters that occurred at locations where certified EHR technology is available
Final Rule News from CMS- Medicare and Medicaid
A Medicare Eligible Professional who does NOT demonstrate meaningful use by 2015 will be subject to payment adjustments in their Medicare reimbursement schedule
Medicaid-only EPs are not subject to payment adjustments
Payment adjustments may apply for any EP who accepts Medicare and does not demonstrate meaningful use in 2015
Final Rule News from CMS- Medicaid
Adopt, implement, or upgrade clause allows eligible providers to collect Medicaid incentives in Year 1 without demonstrating meaningful use. The proposed rule required EPs and hospitals to demonstrate efforts to adopt, implement or upgrade EHRs for 90 continuous days before being eligible for Medicaid incentives in Year 1. The final rule modified this requirement stripping away the reporting time associated with collecting Medicaid incentives in Year 1 for adoption, implementation or upgrade of EHRs. Instead, the 90 days of continuous reporting now applies to the second year of the Medicaid incentive program, which will be the first year that a Medicaid eligible hospital or EP demonstrates meaningful use. By eliminating the reporting time requirement for Year 1, CMS has paved the way for all Medicaid eligible hospitals and EPs to collect incentives in 2011 provided they can demonstrate tangible signs of adoption, implementation, or upgrading EHRs. Furthermore, by modifying the reporting period requirement for the second year under the Medicaid program, CMS has further expanded the window of time available to hospitals and EPs to demonstrate meaningful use and collect incentives.
Final Rule News from CMS- Medicare
Under Medicare, hospitals and physicians must demonstrate meaningful use in successive years to maximize incentive. The final rule clarifies that Medicare-eligible hospitals and physicians have exactly four and five successive years of incentive payouts respectively. This means a hospital that achieves meaningful use in 2011 will receive payouts for three more years, ending in 2014, provided the hospital can demonstrate meaningful use in each of the subsequent three years. Failure to meet the requirements in any year, based on hospital's stage of meaningful use, will result in lost incentives that cannot be recovered in later years. Given the restrictions in the Medicare incentive program -- the potential to lose incentive payments for failure to meet meaningful use requirements in any year following the first payment year, and the shorter timeframe of the Medicare incentive program (hospitals must demonstrate meaningful use by 2015 and EPs must do the same by 2014) -- hospitals essentially have no margin for error if they want to maximize their incentives.
Summary of both Medicare and Medicaid Programs
Medicare
$44,000
Physician shortage area location 10% bonus
No minimum # of patients
Calculation: 75% of submitted of allowable charges by doc, up to cap for the year
First year of program is 2011
Penalties for non-compliance
Medicaid
$64,000
• 30% threshold; 20% for pediatricians
No calculation based on fees – flat payment intended to offset purchase of the EHR
and maintenance costs
Can collect in 2010 if State is ready
No penalties (yet!)
Stark $$ or Fed grants may lower the incentive payment
You may not be a solely hospital based Medicare or Medicaid provider
If you choose to collect incentive checks thru Medicaid, than a minimum of 30% of your patient volume must be Medicaid patients. Only Medicaid, not Medicare, is eligible for incentive checks based on a % of your patient volume
You may still see Medicare and Medicaid patients, but you may not “double-collect” incentive checks
Incentive payments are fixed partial payments via a set schedule. It is earned by qualifying the same year
For your first EHR, your incentive check is 75% of your total Medicare or Medicaid charges up to a maximum of $15,000
Those physicians implementing EHR no later than 2012 are eligible for a maximum of $18,000 the first year they prove meaningful use. Your EHR implementation must start in 2011 or 2012.
There will be no payments for those physicians implementing EHR after year 2014…in other words beyond 2015.
Medicaid Summary
30% of all your patient encounters must be attributable to Medicaid over any continuous 90- day period within the most recent calendar year
Required to annually re-attest to patient volume thresholds
Medicaid replacement plans count towards the threshold
Medicaid patients assigned through capitation count, too
Pediatricians can qualify with 20%
What are the requirements/ Clinical Outcome Measures
Details of Clinical Quality Measures 2011 –Eligible Professionals seeking to demonstrate Meaningful Use are required to submit aggregate CQM numerator, denominator, and exclusion data to CMS or the States by ATTESTATION
2012 –Eligible Professionals seeking to demonstrate Meaningful Use are required to electronically submit aggregate CQM numerator, denominator, and exclusion data to CMS or the States
What You Need to Participate
All providers must: Register via the EHR Incentive Program website
Be enrolled in Medicare FFS, MA, or Medicaid (FFS or managed care)
Have a National Provider Identifier (NPI)
Use certified EHR technology Medicaid providers may adopt, implement, or upgrade in their first year
While more detail on the EHR incentive program is forthcoming in the an impending final rule,
CMS is announcing that Provider Enrollment, Chain and Ownership System (PECOS) records
will be used to verify Medicare enrollment prior to making Medicare EHR incentive payments.
Your enrollment information must be in PECOS, so act now if you do not have an enrollment
record in this system.
If you are a physician who enrolled in Medicare before November 2003 AND have not updated
your Medicare enrollment information since then, you do NOT have an enrollment record in
PECOS. Act now to establish your enrollment record in PECOS. For instructions, go to
www.cms.hhs.gov/MedicareProviderSupEnroll and click on “Tips to Facilitate the Medicare
Enrollment Process” under “Downloads.” If you enrolled in Medicare after November 2003, or
if you enrolled before November 2003 and have updated your Medicare enrollment information
since November 2003, no further action is required.
What will the process be for registration?
Starting January 1, 2011, a web-based registration function will be launched
You will have to give the following information when registering:
Name, NPI, business address and business phone
Taxpayer Identification Number (TIN) to which you want the incentive payment made
Whether you elect to participate in the Medicare EHR incentive programs or the Medicaid EHR incentive program
How will I submit proof and required reports?
First opportunity to actually file for the incentives will be April 2011
New web-based portal is being developed through which all required reports will be submitted
Note: Must keep records of all qualification & reports for six years following each Reporting Year (similar to HIPAA)
What You Need to Participate
Registration requirements include:
Name of the eligible professional
National Provider Identifier (NPI)
Business address and business phone
Taxpayer Identification Number (TIN) to which the provider would like their incentive payment made
Medicare or Medicaid program selection (may only switch once after receiving an incentive payment before 2015) for EPs
State selection for Medicaid providers
States will interface with the EHR Incentive Program registration website.
States will ask providers to provide and/or attest to additional information in order to make accurate and timely payments, such as:
Licensure
Patient Volume
A/I/U or Meaningful Use
Certified EHR Technology
Certified EHR Technology: Required in order to achieve meaningful use
RHQDAPU – Reporting Hospital Quality Data for Annual Payment Update
TIN – Taxpayer Identification Number
About those penalties?
What about the penalties?
Must demonstrate Meaningful Use by 2014 or penalties will begin in 2015
1% reduction in the Medicare Physician Fee Schedule
If course isn't corrected, additional 1% in 2016 and again in 2017
Secretary of HHS can reduce additional 2% if nationwide
So what does “Certification” mean?
Certification provides assurance to purchasers and other users that an EHR system, or other relevant technology, offers the necessary technological capability, functionality, and security to enable them meet the meaningful use criteria established for a given phase
ONC Authorized Testing and Certification Bodies (ONC- ATCBs ) will test and certify conformance with the standards, implementation specifications, and certification criteria adopted by the HHS Secretary, to meet the definition of “certified EHR technology”.
Standards and certification criteria against which ONC-ATCBs will test were published in a final rule in July 2010
Use of “certified EHR technology” is required, but not sufficient, to achieve or meet meaningful use requirements to qualify for incentive programs. Eligible professionals and hospitals must also meet the requirements specified by the Medicare and Medicaid incentive programs
Who Will Provide Certification Services?
The Office of the National Coordinator is authorizing testing and certification bodies or “ONC- ATCBs,” which will test and certify both complete EHRs and EHR Modules for conformance with adopted standards, implementation specifications, and certification criteria, as well as other requirements adopted by regulation
ONC has been receiving and evaluating applications by organizations who wish to become ATCBs
HHS names CCHIT and The Drummond Group first EHR certification bodies. These are the very first two organizations that have passed and qualified to test and certify electronic health-record systems as capable of meeting meaningful use (MU) criteria. These criteria were created and established under the federal IT subsidy program of the American Recovery and Reinvestment Act of 2009. In a press release on Monday August 30th, 2010, David Blumenthal, head of the Office of the National Coordinator for Health Information Technology at HHS, shared that these organizations will be aligned with one another on key standards and doctors and hospitals can invest with confidence in the systems they certify. Under the stimulus law, providers must use certified EHRs in a meaningful manner to be eligible to receive federal health IT subsidy payments.
How Will You Know If Your EHR or EHR Module Is Certified?
Once ONC-ATCBs are authorized, and immediately after training and orientation, they are expected to begin testing and certifying complete EHRs and EHR modules against the standards and certification criteria adopted by the HHS Secretary
In addition to publication by the ATCBs, ONC will maintain a “Certified HIT Product List” (CHPL) as a single, aggregated source of all certified complete EHRs and EHR Modules reported by ONC-ATCBs to the National Coordinator.
Certified EHR Version Numbers will be provided
Validation of whether EHR modules in combination will satisfy the applicable certification criteria will also be provided
Certified complete EHRs and EHR modules are expected to be available (and listed within the CHPL) in the late Summer or early Fall.
What's my next step?
Give our sales team either a call or e-mail at your earliest convenience and hear more about SMARTMD's EHR. Allow our company a few minutes of your time to demonstrate and share more regarding our software solution
For Sales, e-mail us: sales@smartmd.com or via phone: (414) 418-6695
• Or toll free at 855-SMARTMD (855-762-7863) and ask to speak to one of our sales specialists
SMARTMD offering best solutions for physician dictation service, medical transcription, Electronic Health Records, EHR software systems, practice management, PMS and Medical billing revenue management. We are best EHR software vendor.
