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Meaningful Use for Hospitals and Their Physician Practices. Elise Ames - Implementation Specialist/Consultant. Disclaimer. Not legal analysis or advice Preliminary Analysis based on reviewing CMS Final Rule, CMS guidance documents, and analysis by other health care policy organizations.

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Meaningful use for hospitals and their physician practices l.jpg

Meaningful Use for Hospitals and Their Physician Practices

Elise Ames - Implementation Specialist/Consultant


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Disclaimer

  • Not legal analysis or advice

  • Preliminary Analysis based on reviewing CMS Final Rule, CMS guidance documents, and analysis by other health care policy organizations


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Agenda

  • ARRA/HITECH Overview

  • Meaningful Use

  • Financial Incentives

  • Temporary Certification Program

  • Roadmap to Meaningful Use


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ARRA/HITECH

  • The ARRA/HITECH Act provides Medicare and Medicaid financial incentives for the Meaningful Use (MU) of certified EHR technology by hospitals and non-hospital based professionals

  • Intent is to achieve improved outcomes through automation with 3 stages of MU envisioned

  • Outcomes for Stage 1:

    • Improve quality, safety, efficiency and reduce healthcare disparities

    • Engage patient and their families in healthcare

    • Improve care coordination

    • Improve population and public health

    • Ensure adequate privacy and security of ePHI


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Financial Incentives

  • Eligible hospitals can receive incentive payments from Medicare and Medicaid programs, based on patient volume, revenue and actual EHR costs

  • Eligible professionals can receive incentive payments from either Medicare or Medicaid, based on patient volume, revenue and “net average allowable EHR cost”

  • Provider organizations that encompass eligible hospitals and eligible professionals can receive either or both hospital and EP incentives*

    * Subject to requirements related to Meaningful Use of certified EHR technology, or (for Medicaid ) adoption, implementation or upgrade of certified EHR Technology



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Medicare Incentive Time Line

  • Fall 2010 - Certification of EHR vendors will start

  • 2011-2012 – Hospitals and Eligible Professionals can begin using a certified EHR in a meaningful manner

  • Jan. 2011 – Registration with CMS can begin

  • April 2011 - Attestation of Meaningful Use begins

  • May 2011 - CMS payments will begin

    *Medicaid EHR incentives will be managed by states



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Meaningful Use

  • Use ofcertifiedElectronic Health Record (EHR) technology in accordance with the Meaningful Use criteria*

  • Electronic exchange of health information

  • Quality reporting

    *Medicaid allows hospitals and EPs who adopt, implement or upgrade to certified EHR technology to receive the first year incentive payment (through attestation) without demonstrating Meaningful Use


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Meaningful Use Requirements for Stage 1

  • Published in CMS final rule July 2010

  • In addition to core requirements there is also a “menu” of 10 additional requirements from which 5 must be chosen by hospitals and eligible professionals

  • The final rule specifies the method of MU reporting (measure or attestation) with a numerator and denominator defined for each measurable criterion

  • A hospital or EP who believes that a requirement does not apply to them based on the exclusion criteria defined in the final rule may attest to this and have the number of MU criteria reduced


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Meaningful Use Requirements Future Stages

  • Stage 2

    • Stage 1 menu set will be transitioned into core set

    • Administrative transactions will be added

    • CPOE measurement will go to 60%

    • CMS will evaluate additional criteria and probably increase thresholds for existing

  • Stage 3

    • Will be further defined in next rulemaking



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Medicare Hospital Incentive Payment Timelines

  • Can receive up to four years of incentive payments

  • First possible payment is in FY 2011

    • begins October 1, 2010

  • Last possible year to qualify for incentives is FY 2015

    • begins on October 1, 2014

  • Penalties begin in 2015 for failure to achieve Meaningful Use


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PPS Medicare Hospital Incentive Calculation

  • For each payment year the incentive amount is based on:

    • An initial amount of $2,000,000 + a discharge-related amount ($200 x number or discharges between 1,150 and 23,000)

    • The Medicare share (based on volume and charges)

    • A transition factor for each payment year that reduces the payments over time



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Estimated Medicare Incentive Payment(PPS Hospital Example)

Total Estimated Incentive Payment = $5,762,220 assuming MU by 2013

http://marketplace.himss.org/acct618b/Default.aspx?tabid=226


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CAH Medicare Hospital Incentive Calculation

  • For each payment year the incentive amount is based on:

    • Actual costs (including depreciation) of certified EHR technology

    • The Medicare share (same calculation as PPS Hospitals but add 20%)

    • A transition factor for each payment year that reduces the payments over time


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Hospital Medicaid Incentives

  • 10% Medicaid volume and ALOS < 25 days

  • Calculation is the same for all eligible hospitals

  • Four payment years between FY 2011 and FY 2016

  • Payments reduced each year by transition factor

  • Payments in years 2-4 adjusted by hospital growth rate for the prior 3 years


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Hospital Medicaid Incentive Calculation

  • For each payment year the incentive amount is based on:

    • An initial amount of $2,000,000 + a discharge-related amount

    • The Medicaid share based on volume and charges

    • A transition factor for each payment year that reduces the payments over time

  • First payment year uses prior fiscal year discharges

  • Subsequent years’ discharge-related amount will be based on the hospital’s average annual growth rate for the 3 most recent years of available data


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Medicaid Hospital Example

  • 2010 discharges = 2000

  • Medicaid inpatient bed days = 7000 (each year)

  • Total 2010 inpatient bed days = 21,000

  • Total charges – charity care = $8,700,000

  • Total charges = $10,000,000

  • Average annual growth rate = .0213


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Estimated Medicaid Incentive Payment

Total Estimated Incentive Payment = $ 2,069,936 assuming MU by 2013


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Incentives for Eligible Professionals


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EP Incentives

  • Non hospital-based EP’s must choose to receive incentives from either the Medicaid or Medicare program

  • EP’s may select Medicare or Medicaid incentive on a individual provider basis

  • An EP may switch incentive programs one time during the incentive period


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Definition of Hospital-Based Provider

  • Final rule clarified definition of “hospital-based” providers who are excluded from the incentive program

  • A provider employed by a hospital who has 90% of services classified under place of service code 22 (outpatient hospital) is considered an Eligible Professional

  • Specifically not eligible are Radiologists, Anesthesiologists, Hospitalists, and ED Physicians


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EP Medicare Incentive Timelines

  • Can receive up to 5 years of incentive payments

  • First possible payment is in Calendar Year 2011

    • begins January 1, 2011

  • No payments will be made after 2016

  • EP’s that are Meaningful Users by 2012 will maximize their incentive value

  • Penalties begin in 2015 for non-Meaningful Users


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Maximum Medicare EP incentives

* No Medicare early adoption option


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EP Qualifications for Medicaid Incentive

* Second year requires a full year of patient volume


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EP Medicaid Incentive Timeline

  • First possible payment year is 2011 calendar year

  • 6 years of payment, and the first payment year cannot occur after 2016

  • First year payment can be for Adopting, Implementing or Upgrading certified EHR technology rather than attaining Meaningful Use


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Maximum EP Medicaid Incentive

  • 1. Flat fee payment based on 85% of EHR “net allowable costs”

  • 2. Max. incentive for Pediatrician, with 20% patient threshold, is $42,500


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ONC Temporary Certification Program


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ONC Temporary CertificationProgram Timeline

  • June 18th 2010 – ONC established temporary certification program – including “final temporary” certification criteria

  • August 31, 2010 – First ONC-ACTB’s announced(No surprise, CCHIT is one)

  • Sunset date is December 31, 2010 unless ONC fails to establish a permanent certification program (rule expected Fall 2010)


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Certification

  • EHR certification is the software vendor’s responsibility

    • Unless you have “self developed software”

  • Systems may be certified as

    • “Complete EHR Systems”

    • “EHR modules”

  • EHR Modules may be certified if they meet just one certification criterion (plus security)

  • The final temporary certification rule requires that systems must be able to report the numerator and denominator for each measure


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The Road to Meaningful Use

  • Assessment and Gap Analysis

  • Planning

  • Implementation and Reporting


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Assessment and Gap Analysis

  • Is needed automation in place for each requirement?

  • For each system/module needed

    • When will it be certified?

    • Which version?

  • Conduct HIPAA Security Risk Assessment

  • Estimate potential incentives from Medicare and Medicaid for both hospital and providers

  • Assess interoperability


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Planning

  • Assign overall accountability

  • Identify and assign tasks

    • Workflow changes

    • IT implementations

    • Reporting

  • Develop schedule and budget

  • Select menu items for hospital and EPs based on level of effort, cost and timeline


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Implement and Report

  • Design process changes

  • Implement and/or upgrade systems

  • Test reporting mechanisms

  • Finalize plans for attestation and reporting


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How VITL Can Help

  • VITL can provide assistance with:

    • Gap analysis and readiness assessment

    • Planning

    • Implementation



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