Meaningful Use and Electronic Health Records: What You Need to Know

Meaningful Use and
Electronic Health Records:
What You Need to Know

Presented By:

Meaningful Use and EHRs

The EHR Incentive Program of Meaningful Use

• The Meaningful Use Incentive Programs are part of the
Health Information Technology for Economic and
Clinical Health (HITECH) Act, which is under the
American Recovery and Reinvestment Act (ARRA)
• The goals of using a certified EHR in a meaningful way
are to:
– Reduce medical errors
– Improve health care outcomes
– Ensure quality
– Reduce healthcare costs


Types of Meaningful Use Programs
• Medicare EHR Incentive Program
– Eligible Professionals
– Hospitals
• Medicaid EHR Incentive Program
– Eligible Professionals
– Hospitals
* If you are an EP who is eligible for both,
choose the Medicaid EHR Incentive program

Medicaid vs. Medicare EHR Incentive Programs: A side
by side comparison
Note: Before 2015,
and eligible
professional may
switch between the
Medicare and
Medicaid programs
(or vice versa) one
time after the first
incentive payment
is initiated.


Payments across the Medicaid EHR Incentive Program
Incentive 2012 2013 2014 2015 2016
year
2012 $21,250
2013 $8,500 $21,250
2014 $8,500 $8,500 $21,250
2015 $8,500 $8,500 $8,500 $21,250
2016 $8,500 $8,500 $8,500 $8,500 $21,250
2017 $8,500 $8,500 $8,500 $8,500 $8,500
2018 $8,500 $8,500 $8,500 $8,500
2019 $8,500 $8,500 $8,500
2020 $8,500 $8,500
2021 $8,500
Total: $67,350 $67,350 $67,350 $67,350 $67,350


Eligibility For Individual Providers – Eligible
Professionals (EPs)
• Medicaid: A Medicaid eligible professional (EP) is
defined as a non hospital-based
– Physician
– Nurse practitioner
– Certified nurse-midwife
– Dentist
– Physician assistant who furnish services in a
Federally Qualified Health Center or Rural
Health Clinic that is led by a physician
assistant.


Definition of a non-hospital based provider

• Hospital based: defined as 90% or more of the
provider's encounters taking place at an
inpatient (POS 21) or emergency room (POS
23) practice location.


Must be a Medicaid Provider in good standing

Each eligible professional must have an individual Medicaid Provider ID
– If rendering providers do not have one, they will need to get one
– Medicaid uses the Medicaid ID to validate patient volume and track payments
– Colorado Medicaid’s Provider Enrollment will need to know that the new providers
have been providing services under an already defined group Medicaid provider
ID
• If your agency has more than 1 group Medicaid ID, then for every Group
Medicaid number that an agency has, the agency must work with CO
Medicaid to ensure these individual Medicaid provider ID numbers get tied to
the group Medicaid Provider ID numbers.
• For those rendering providers who may already have an individual Medicaid
Provider ID that they were not using for services in the agency in which they
will participating in the EHR Incentive program with, the agency will need to
make sure those individual providers are associated with the group as well.
– Providers who do not have a Medicaid Provider number can get one by going to
http://www.colorado.gov/cs/Satellite/HCPF/HCPF/1214992377067 .
**If you have questions regarding your Medicaid ID or check enrollment statuses
contact ACS Provider Services at 1-800-237-0757.


Medicaid EHR Incentive Program and A/I/U

– Adopted > acquired, purchased or secured
access to
– Implemented > installed or commenced
utilization of
– Upgraded to certified EHR technology

*An EP does not have to demonstrate meaningful use
for stage 1 year 1 for the Medicaid EHR Incentive
Program.


Supporting documentation for A/I/U

To prove adoption of a system simply attach documentation of the EHR system during the
attestation process (for example - proof of a contract, software license, or purchase order).
The proof should be applicable to the type of attestation (Adoption, Implementation or
Upgrade).
• A screenshot of the ONC Certified HIT Product List (CHPL) site is also required.
• The ONC Certification number must match what is in Step 3 of the CO R&A

Colorado Medicaid also provides an A/I/U workbook which can be found downloaded at the
following link> http://co.arraincentive.com/docs/CO-EP-AIU-Attestation-Workbook.xls.


Must meet Medicaid patient volume
requirement
To qualify for an incentive payment under the Medicaid
EHR Incentive Program, an eligible professional must
meet one of the following criteria:

• Have a minimum 30% Medicaid patient volume
• Have a minimum 20% Medicaid patient volume, and is a
pediatrician
• Practice predominantly in a Federally Qualified Health
Center or Rural Health Center and have a minimum
30% patient volume attributable to needy individuals


Patient Volume
• Eligible Professionals must demonstrate 30% Medicaid patient volume for a
representative 90-day period in the previous calendar year. Pediatricians
may demonstrate a minimum of 20% Medicaid patient volumes to qualify
for a reduced incentive amount.
• Patient volumes are based on unique patient encounters per day for the 90
day period. In certain circumstances, you may also be able to count
Medically Needy patient volumes to help you meet the eligibility
requirements. You can also count patients seen in different states if you
practice in multiple states.
• Your patient volume information must come from an auditable data source,
so you must be able to provide documentation that supports your
volumes if requested.
• When determining patient volume, must use a representative 90
consecutive day period in the previous calendar year
• Multiple procedures in the same day for the same individual rendered by
the same provider would count as only one encounter.


Additional information for calculating patient volume

• Colorado has provided a Patient Volume Workbook. The workbook can be downloaded at the
following link> http://co.arraincentive.com/docs/CO-EP-Eligibility-Workbook.xls
Note: The state of Colorado requires that the EP retain a copy of this worksheet in their
records for Seven years in case of audit.
• Numerator includes fee for service and Medicaid HMO encounters that were paid in part or in
full by Medicaid.
– A Medicaid patient encounter is any patient encounter (as defined above) where a
Medicaid (not CHIP) fee-for-service claim or managed care organization paid for all or
part of the services provided, or the co-pays, cost sharing or premiums for the services
provided.
• Denominator includes all encounters regardless of payment status

• Eligible professionals may see their Medicaid patients at any health care POS location/setting
– Exception: eligible professionals practicing at a Federally Qualified Health Clinic (FQHC)
using the “needy individual” definition; that is applicable per the federal regulations only
at FQHCs.


Additional information for calculating patient volume

• There are no restrictions on hours worked or eligible professional employment type (e.g.,
contractual, permanent, temporary).

• An EP is allowed to aggregate or separate patients across practice sites and places of service;
however, one location that meets the applicable payment year's EHR technology incentive
payment eligibility criteria (Adopt, Implement, or Upgrade or Meaningful Use) MUST BE
INCLUDED in the provider's patient volume measurement.

• An EP is allowed to aggregate patients across States.

– The eligible professional must be able to document their out-of-state patient volume.

• EPs can count patients that are dual eligible for Medicare and Medicaid as long as Medicaid
was billed at least one cent ($ .01) for the provided service.

• All patient volume information entered into the Colorado EHR Incentive Program attestation
system may be subject to audit that could result in payment recoupment. Be sure to
assemble an audit file for everything used for attestation.


Group by proxy conditions
• Providers may use a clinic or group practice’s patient volume as a proxy for their own
under three conditions:
– The clinic or group practice’s patient volume is appropriate as a patient volume
methodology calculation for the EP (for example, if an EP only sees Medicare,
commercial, or self-pay patients, this is not an appropriate calculation).
– There is an auditable data source to support the clinic’s patient volume
determination.
– So long as the practice and EPs decide to use one methodology in each year (in
other words, clinics could not have some of the EPs using their individual
patient volume for patients seen at the clinic, while others use the clinic-level
data). The clinic or practice must use the entire practice’s patient volume and
not limit it in any way.

EPs may attest to patient volume under the individual calculation or the
group/clinic proxy in any participation year.
Furthermore, if the EP works in both the clinic and outside the clinic (or with and
outside a group practice), then the clinic/practice level determination includes
only those encounters associated with the clinic/practice.


Group Administrators
• As a group of physicians we can have an administrator do the attestation process
for us?

Yes, but each physician MUST sign the completed attestation form as knowledge
of attestation individually as well as submit their attestation. Signed
attestation forms can be uploaded (front and back) prior to submission. Lastly,
the administrator needs to send an electronic notice to each EP to notify them
to submit their attestation. The EP will need to create an individual login to
the CO R&A system and submit their attestation once they have been notified
by the group administrator.

• Which steps of the attestation system can be done by the administrator for a
group and which must be done by the individual professional?

The administrator for a group can complete all steps of the attestation process
except signing individual attestation forms and the actual submission of the
attestation. Each physician must sign the attestation completion form
individually to ensure compliance with all Federal and State regulations.
Each physician must also create their own CO R&A account login to submit
their completed attestation.


CMS New rules for 2013
• If our practice/clinic is attesting as a group for AIU and we have NOT received our
payment, can we add a recently hired, qualified EP that has seen Medicaid
patients but was not present in our 90-day period from the previous year for
eligibility in our group calculation?
– Yes. CMS has allowed for new EPs hired onto your practice/clinic to be
“grandfathered” into your practice/clinic’s volume as long as the volume is
representative of the entire practice/clinic if the EPs in your group have not
yet received payment. **For RHCs/FQHCs – the new EP must be able to prove
that in the previous calendar year they practiced predominately in an
RHC/FQHC to be able to use the Needy Individual Patient Volume.
• If our practice/clinic has attested as a group for AIU and we have RECEIVED OUR
PAYMENT, can we add a recently hired, qualified EP that has seen Medicaid
patients but was not present in our 90-day period from the previous year for
eligibility in our group calculation?
─ No. CMS does not allow EPs to be added to a group once a payment has been
received. Any new EPs must register and attest as individuals the following
year, following all current eligibility rules. **For RHCs/FQHCs – the new EP
must be able to prove that in the previous calendar year they practiced
predominately in an RHC/FQHC to be able to use the Needy Individual Patient
Volume.

Reassignment of incentive dollars for the CO Medicaid
EHR Incentive program

• Each EP would receive an incentive payment.

• EPs can reassign their incentive payments to one entity
such as his or her employer or an entity with which
they have a valid employment agreement or valid
contractual arrangement that allows the entity to bill
for the EP's services. Applicants will attest to this
relationship during the application process.

• Colorado Medicaid will allow providers to select a pay-
to provider based on the current financial relationships
established with CO Medicaid.

Stage 1 EHR Meaningful Use Specification
Sheets for Eligible Professionals
CORE MENU
1. *CPOE 1. *Implement drug formulary checks
2. Drug : drug and drug : allergy checks 2. *Incorporate Lab test results
3. Up to date problem list 3. Generate patient lists
4. *eRx 4. *Patient Reminders
5. Active Medication list 5. *Provide patients Electronic Access
6. Active Medication Allergy list 6. Patient Specific Education Resources
7. Demographics 7. *Medication Reconciliation
8. *Vital Signs 8. *Summary of Care record upon
9. *Smoking Status transition
10. Clinical Quality Measures 9. *Submit Electronic data to
11. Clinical Decision support rule immunization registry
12. *Electronic copy of Health Info upon request 10. *Submit syndromic surveillance data to
13. *Clinical Summaries after each visit public health agency
14. Exchange Key Clinical Information *MEASURES that have exclusions
15. Protect Health Information Note: each EP must meet all 15 CORE measures or be eligible for an
exclusion from the CORE Measures that have exclusions. They must also
meet 5 of the 10 Menu measures. In stage 1, An EP can defer the 5
remaining Menu measures.


What is the difference?
• Modular EHRs
– Each part of the system must be purchased
separately, i.e. billing A/R, scheduling, clinical
• Integrated EHRs:
─ One system, fully integrated solution. Designed to
handle every aspect of the organization.
• Client/Server site-based solutions
• Web-hosted/Cloud-based solutions


What is the difference?
• Partially Certified EHRs
– An “EHR Module” certification refers to any service, component, or
combination thereof that meets at least one certification criterion adopted by
the Secretary.
– An “EHR Module” certified EHR could include a single capability required by
one certification criterion, or it could provide all capabilities but one required
by the certification criteria for a Complete EHR.
• Complete Certified EHRs
– “Complete EHR is technology that has been developed to meet, at a
minimum, all applicable certification criteria adopted by the Secretary for an
Ambulatory setting (45 CFR 170.302 and 45 CFR 170.304).
– Because it is certified as a “Complete EHR,” it includes the functionality that
will enable an Eligible Professional to meet all of the measures for Stage 1.


Web-hosted SaaS Solutions
• Customer can access their software through
the internet from any location.
• Costs over infrastructural arrangements
significantly reduced.
• Provides for good data sharing between
clinical practitioners, thereby, ensuring that
the quality of health care will improve
appreciably and the true potential of
EMR/EHRs will not fall short.

Web-hosted SaaS Solutions
• Reduces the heavy staff requirements
associated with conventional licensed and
client/server solutions.
• State of the art data centers, expert
information security resources and round
the clock support professionals .
• Significantly reduces implementation costs


Staying current and compliant
• System updates are performed automatically
and rolled out simultaneously to all users
• Government, State, and Local regulation and
reporting changes are managed and
implemented in cooperation with the vendor
partner for all effected organizations
• HIPPA compliance is guaranteed by the vendor
– Data are safe, secure, and backed up by the
vendor


www.MUforBH.com
A resource for behavioral health professionals seeking advice, guidance, and
information on meeting Meaningful Use requirements.

• FAQs
o Get quick answers to the most common Meaningful Use questions
• Forum
o Chat and exchange ideas with others in your community
• Play the MU Game
o A step-by-step guide to claiming your Meaningful Use dollars
• Videos and Webinars
o Access past Meaningful Use presentations for additional help or join our
free live webinars
• MU State University
o Meaningful Use Education State by State


Disclaimer
It is important that each individual take responsibility for understanding of the final rules and regulations of the
Medicaid and Medicare EHR Incentive Programs. MUforBH.com offers these free webinars as a service and
makes every effort to provide accurate information. We make no claim that our information is complete or
contains no inaccuracies.

Under no circumstances shall anyone associated with MUforBH.com be liable for any incidental, indirect,
consequential or special damages or loss of any kind including those resulting from the expected incentives
themselves.

MUforBH.com in no way considers itself the ultimate authority or expert on the final rules and regulations of
the Medicare and Medicaid EHR Incentive Programs and expects that each individual will consult the state
specific Medicaid EHR Incentive Program website for their specific states rules and/or the CMS website for the
EHR Incentive Program rules.

It is important that each Eligible Professional note that CMS views the EP as ultimately responsible for the
numerator and denominator and their Medicaid Encounter volume as well as the data used for attestation on
the measures of Meaningful Use. CMS has announced there will be audits: “There are numerous pre-payment
edit checks built into the EHR Incentive Programs’ systems to detect inaccuracies in eligibility, reporting and
payment. Post-payment audits will also be completed during the course of the EHR Incentive Programs.”


Important Links
• Colorado Registration & Attestation System Provider
Outreach Page
• CMS EHR Incentive Programs Webinar Slides
• CMS FAQs
• Colorado State Specific FAQs
• Table of Contents for the Stage 1 Eligible Professional
Measure Specifications
• Colorado Registration and Attestation JUMP Start page
• Colorado EP eligibility workbook
• Colorado A/I/U attestation workbook
• www.MUforBH.com

Meaningful Use and Electronic Health Records: What You Need to Know

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