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SUCCOR CONSULTING GROUP
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__________________________________________

      Medicare & Medicaid Meaningful Use
         Incentives Program Specifics

                         May 2011




              Copyright 2011 © Succor Consulting Group, Inc
TABLE OF CONTENTS
EHR INCENTIVE PROGRAM - OVERVIEW                                           1
MEDICARE/MEDICAID ELIGIBLE PROFESSIONALS (EPs)                             3
ELIGIBILITY REQUIREMENTS FOR PHYSICIANS                                    4
MEDICAID INCENTIVES OVERVIEW                                               6
ELIGIBLE PROFESSIONAL SHORTAGE BONUSES                                     7
PROFESSIONALS ELIGIBLE FOR BOTH PROGRAMS                                   8
MEDICARE VS MEDICAID                                                       9
PENDING EXPANDED MEDICARE & MEDICAID ELIGIBLE PROFESSIONALS & FACILITIES   10
MEDICARE EHR INCENTIVES BASICS OVERVIEW FOR ELIGIBLE PROFESSIONALS         11
MEDICAID EHR INCENTIVES BASICS OVERVIEW FOR ELIGIBLE PROFESSIONALS         12
MEDICARE ADVANTAGE ELIGIBLE PROFESSIONALS                                  13
MEDICARE ELIGIBLE HOSPITALS                                                14
MEDICAID ELIGIBLE HOSPITALS                                                19
MEDICARE & MEDICAID DUALLY ELIGIBLE HOSPITALS                              22
E-PRESCRIBING INCENTIVES PROGRAM OVERVIEW                                  23
E-PRESCRIPTION – ELIGIBLE PROFESSIONALS                                    26
E-PRESCRIBING INCENTIVES PAYMENT DETAILS                                   28
WHAT IS MEANINGFUL USE (MU)?                                               29
BASIC OVERVIEW OF STAGE 1 MU OBJECTIVES AND MEASURES REPORTING             32
ELIGIBLE PROFESSIONALS 15 CORE/10 MENU OBJECTIVES                          33
ELIGIBLE PROFESSIONALS & MEANINGFUL USE                                    34
WHAT ARE CLINICAL QUALITY MEASURES?                                        35
WHAT ARE QUALITY MEASURES?                                                 35
EP REQUIREMENTS FOR CLINICAL QUALITY MEASURES                              36
EP REQUIREMENTS FOR CLINICAL QUALITY MEASURES REPORTING                    36
EP REPORTING PERIOD                                                        37
CLINICAL QUALITY MEASURES CORE SET                                         38
ALTERNATE CORE SET                                                         38
ADDITIONAL SET CQM                                                         39
REGISTRATION REQUIREMENTS                                                  41
PROGRAM TIMELINE                                                           42
ACRONYMS                                                                   43
EHR INCENTIVES PROGRAM OVERVIEW


EHR Incentive Programs were established by law through the American
Recovery & Reinvestment Act (ARRA) of 2009.

The Medicare and Medicaid EHR Incentive Programs will provide incentive
payments to eligible professionals (EPs), eligible hospitals and critical access
hospitals (CAHs), Integrated Delivery Networks (IDNs) and other Medical
Establishments as they adopt, implement, upgrade or demonstrate Meaningful
Use (MU) of CCHIT certified EHR technology.

We have been preparing to cross this threshold for many decades. The
potential for information technology to support and improve health care was
recognized early. Government and private support for development and
assessment of health informatics began in the 1960s. Yet, even as computers
transformed almost every other sector of the economy, health care remained
mostly paper-based.

In 2009, Congress and President Obama took a definitive new step when they
enacted the Health Information Technology Economic and Clinical Heath Act
(HITECH), part of ARRA. HITECH authorized up to $27 billion in incentive
payments for providers and $2 billion to build a national infrastructure for the
adoption of EHRs. Most importantly, HITECH established the goal of the
meaningful use of electronic health records. However cryptic this term may
have seemed at first, it holds the key to unlocking the power of information to
transform health care for the better.

Put plainly, “meaningful use” is a shorthand for three things:
An incentive program, rewarding not only deployment of EHRs, but also their
effective use for patient benefit;
A new national infrastructure to support deployment and beneficial use of
EHRs; and
A vision for the evolving, dynamic and optimal uses of information to support
health and health care improvement – the tip of the spear for an information-
powered leap in the quality, safety and effectiveness (including cost
effectiveness) of our health care system.




                                                                                   1
As an incentive program, meaningful use went live January 1, 2011. That was
when registration opened for eligible providers and hospitals to take part in the
Medicare and Medicaid incentive payments programs. Surveys in the latter part
of 2010 by the American Hospital Association (AHA) and CDC’s National Center
for Health Statistics indicated that 81 percent of hospitals and 41 percent of
office-based physicians were already planning to achieve meaningful use and
qualify for incentive payments. In January alone, 21,300 providers initiated the
registration process.




                                                                                    2
MEDICARE ELIGIBLE PROFESSIONALS


Eligible professionals under the Medicare EHR Incentive Program include:

•   Doctor of medicine or osteopathy
•   Doctor of dental surgery or dental medicine
•   Doctor of podiatry
•   Doctor of optometry
•   Chiropractor

EPs may not be hospital-based.


MEDICAID ELIGIBLE PROFESSIONALS


Eligible professionals under the Medicaid EHR Incentive Program include:

•   Physicians (primarily doctors of medicine and doctors of osteopathy)
•   Nurse practitioner
•   Certified nurse-midwife
•   Dentist
•   Physician assistant who furnishes services in a
    Federally Qualified Health Center or Rural Health
    Clinic that is led by a physician assistant.

EPs may not be hospital-based.

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

1. Have a minimum of 30% Medicaid patient volume*
2. Have a minimum of 20% Medicaid patient volume and is a pediatrician*
3. Practice predominantly in a Federally Qualified Health Center or Rural Health
Center and have a minimum of 30% patient volume attributable to needy
individuals

*Note - Children's Health Insurance Program (CHIP) patients do not count toward the
Medicaid patient volume criteria.




                                                                                      3
ELIGIBILITY REQUIREMENTS FOR PROFESSIONALS


• Incentive payments for eligible professionals are based on individual
  practitioners.

• If you are part of a practice, each eligible professional may qualify for an
  incentive payment if each eligible professional successfully demonstrates
  meaningful use of certified EHR technology.

• Each eligible professional is only eligible for one incentive payment per year,
  regardless of how many practices or locations at which he or she provides
  services.

Hospital-based eligible professionals are not eligible for incentive
payments. An eligible professional is considered hospital-based if 90% or more
of his or her services are performed in a hospital inpatient (Place Of Service
code 21) or emergency room (Place Of Service code 23) setting.




                                                                                    4
Medicare EP Incentive Payments amounts are based on:

• Fee-for-Service (FFS) allowable charges
• 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
• Receive one (1) incentive payment per year




    Payment          First Year you    First Year you    First Year you    First Year you
    Amount for       Qualify to        Qualify to        Qualify to        Qualify to
    Year:            Receive Payment   Receive Payment   Receive Payment   Receive Payment
                     2011              2012              2013              2014
    2011                    $18,000               -                 -                 -
    2012                    $12,000           $18,000               -                 -
    2013                     $8,000           $12,000           $15,000               -
    2014                     $4,000            $8,000           $12,000           $12,000
    2015                     $2,000            $4,000            $8,000            $8,000
    2016                        -              $2,000            $4,000            $4,000

    TOTAL Possible
                          $44,000           $44,000           $39,000           $24,000
    Incentive
    Payments




                                                                                             5
Medicaid Incentives Payments Overview

•   Maximum incentives are $63,750 over six years
•   Incentives are the same regardless of start year
•   The first year payment is $21,250
•   Must begin by 2016 to receive incentive payments
•   Incentives are available through 2021
•   Pays one (1) incentive payment per year

*NOTE: No extra bonus for health professional shortage area




     Payment          First Year you    First Year you    First Year you    First Year you    First Year you    First Year you
     Amount for       Qualify to        Qualify to        Qualify to        Qualify to        Qualify to        Qualify to
     Year:            Receive Payment   Receive Payment   Receive Payment   Receive Payment   Receive Payment   Receive Payment
                      2011              2012              2013              2014              2015              2016
     2011                    $21,250               -                 -                 -                 -                 -
     2012                     $8,500           $21,250               -                 -                 -                 -
     2013                     $8,500            $8,500           $21,250               -                 -                 -
     2014                     $8,500            $8,500            $8,500           $21,250               -                 -
     2015                     $8,500            $8,500            $8,500            $8,500           $21,250               -
     2016                     $8,500            $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 Possible
                           $63,750           $63,750           $63,750           $63,750           $63,750           $63,750
     Incentive
     Payments




                                                                                                                                  6
ELIGIBLE PROFESSIONAL SHORTAGE BONUSES


You may qualify for more!

Practices with 30% or more of their patient population paying with Medicaid
(20% for pediatricians) are eligible for stimulus incentive payments of up to
$65,000.

Practices operating in a "health provider shortage area" (HPSA) can qualify
for bonus incentives, e-prescribing, Medicare's physician quality reporting
initiative (PQRI) and Medicare Care Manage Performance (MCMP) can also
increase your bonuses.




                      Private Practice     Non-FQHC Safety NetClinics      FQHC Clinics

Medicare HITECH
Incentive           $44,000 per provider      $44,000 per provider      $44,000 per provider
Medicare Plus
HSPA                $48,400 per provider      $48,400 per provider      $48,400 per provider
Medicaid HITECH
Incentive                    -                $65,000 per provider      $65,000 per provider
Bonus
E-Prescribe              2% bonus                  2% bonus                  2% bonus
Medicare PQRI            2% bonus                  2% bonus                      -
Medicare MCMP       $12,500 per provider      $12,500 per provider               -




                                                                                               7
PROFESSIONALS ELIGIBLE FOR BOTH PROGRAMS


EPs eligible for both the Medicare and Medicaid EHR Incentive Programs
must choose which incentive program they wish to participate in when they
register.

Before 2015, an EP may switch programs only once after the first incentive
payment is initiated. Medicare EPs who also qualify as a Medicaid EP must
choose between the Medicare and Medicaid incentive programs when they
register.

Medicaid EPs and providers who are not eligible to participate in the Medicare
and Medicaid EHR Incentive Programs will not be subject to payment
adjustments. However, Medicaid EPs who also treat Medicare patients will
have a payment adjustment to Medicare reimbursements, starting in 2015 if
they do not successfully demonstrate meaningful use.


                                   Eligible for both



                                   Doctors or Medicine
                                  Doctors of Osteopathy
                               Doctors of Dental Medicine or
                                          Surgery



                                                          Nurse Practitioners
        Doctors of Optometry                              Certified Nurse-Midwives
        Doctors of Podiatric                              Physician Assistants
        Medicine
                                                          (when working at an
        Chiropractor                                      FQHC or RHA that is led
                                                          by a PA)




                Medicare only                               Medicaid only



*Most eligible professionals will maximize their incentive payments by
participating in the Medicaid EHR Incentive Program.




                                                                                     8
MEDICARE VS MEDICAID




Medicare                                  Medicaid
Federal Government will implement         Voluntary for States to implement -
starting January 2011                     Most expected to start late summer 2011
Payment reductions begin in 2015 for      No Medicaid payment reductions
providers that do not demonstrate MU
Must demonstrate MU in Year 1             A/I/U option for 1st participation year
Maximum incentive is $44,000 for EPs      Maximum incentive is $63,750 for EPs
(bonus for Eps in HPSAs)
MU definition is common for Medicare      States can adopt certain additional
                                          requirements for MU
Last year a provider may initiate program Last year a provider may register for &
is 2014; Last year to register is 2016;   initiate program is 2016; Last payment
Payment adjustments begin in 2015         year is 2021
Only physicians, subsection (d)           5 types of EPs, acute care hospitals
hospitals and CAHs                        (including CAHs) & children's hospitals




                                                                                    9
PENDING EXPANDED MEDICARE & MEDICAID ELIGIBLE
PROFESSIONALS & FACILITIES


Legislation introduced in the U.S. Senate would extend eligibility for electronic
health records meaningful use incentive payments to:

• Behavioral health professionals and facilities
• Mental health professionals and facilities
• Substance abuse professionals and facilities

Sen. Sheldon Whitehouse (D-RI) introduced S. 539, which has been referred to
the Finance Committee. Facilities eligible under the bill include:

•   Community mental health centers
•   Psychiatric hospitals
•   Residential mental health treatment facilities
•   Outpatient mental health treatment facilities
•   Substance abuse treatment facilities
•   Including facilities operated by counties

The legislation also would make these professionals and facilities eligible for
services from health information technology extension centers. Text of S. 529 is
available at congress.gov. Please check back for updates.




                                                                                    10
MEDICARE EHR INCENTIVES BASICS OVERVIEW FOR
ELIGIBLE PROFESSIONALS

The Medicare EHR Incentive Program for EPs starts in 2011 and will continue
through 2016. Depending on the first year they participate, EPs can participate
for up to 5 years throughout the duration of the program. The last year to begin
participation in the Medicare EHR Incentive Program is 2014.

• To qualify for Medicare EHR incentive payments, Medicare EPs must
successfully demonstrate meaningful use for each year of participation in
 the program.

• Incentive payments are made based on the calendar year. The reporting
period for the first year is any 90 continuous days during the calendar year. The
reporting period for all subsequent years is the entire calendar year.

• For calendar years 2011–2016, EPs who demonstrate meaningful use of
certified EHR technology can receive up to $44,000 over 5 years under the
Medicare EHR Incentive Program.

To receive the maximum EHR incentive payment, Medicare EPs must begin
 participation by 2012.

 Important! For 2015 and later, Medicare EPs who do not successfully
demonstrate meaningful use will have a payment adjustment to their Medicare
reimbursement. The payment reduction starts at 1% and increases each year
that a Medicare EP does not demonstrate meaningful use, to a maximum of 5%.




                                                                                    11
MEDICAID EHR INCENTIVES BASICS OVERVIEW FOR
ELIGIBLE PROFESSIONALS

The Medicaid EHR Incentive Program is offered and administered voluntarily by
states and territories. States can start offering their program to EPs as early as
2011. The program continues through 2021. EPs can participate for 6 years
throughout the duration of the program. The last year to begin participation
in the Medicaid EHR Incentive Program is 2016.

• To qualify for Medicaid incentive payments, Medicaid EPs must adopt,
implement, upgrade or demonstrate meaningful use of certified EHR technology
in the first year of participation and successfully demonstrate meaningful use in
subsequent participation years.

• For calendar years 2011–2021, participants can receive up to $63,750 over 6
years under the Medicaid EHR incentive program. EHR incentive payments are
made by the state based on the calendar year.

• Medicaid EPs who also qualify as Medicare EPs must choose between the
Medicare and Medicaid EHR Incentive Programs when they register.

• Medicaid EPs and providers who are not eligible to participate in the Medicare
and Medicaid EHR Incentive Programs will not be subject to payment
adjustments. However, Medicaid EPs who also treat Medicare patients will have
a payment adjustment to Medicare reimbursements starting in 2015 if they do
not successfully demonstrate meaningful use.




                                                                                     12
MEDICARE ADVANTAGE ELIGIBLE PROFESSIONALS?


Medicare Advantage (MA) EPs are physicians that are either:

• Employed by the Medicare Advantage organization
  OR
• Employed by, or partner of, an entity through a contract with the Medicare
  Advantage organization, that furnishes at least 80% of that entity's Medicare
  patient care services to enrollees of the MA organization.

Also, Medicare Advantage EPs must furnish at least 80% of their Medicare-
related professional services to enrollees of the MA organization and must
furnish, on average, at least 20 hours per week of patient care services.

Medicare Advantage (MA) organizations may also qualify to receive EHR
incentive payments. Under the Medicare Advantage EHR Incentive Program,
payments are made only to Medicare Advantage organizations that are licensed
as HMOs, or in the same manner as HMOs, by a State. These Medicare
Advantage organizations may receive incentive payments by way of Medicare
Advantage affiliated hospitals (MA-affiliated hospitals) and Medicare Advantage
EPs.

What is a Medicare Advantage affiliated hospital?

Medicare Advantage affiliated hospitals are hospitals that:

• Are under a common corporate governance with the Medicare Advantage
  organization
  AND
• Serve individuals enrolled under Medicare Advantage plans offered by the
  Medicare Advantage organization, where less than one-third are Medicare
  individuals covered under Medicare Part A.




*For additional information regarding the Medicare Advantage EHR incentive payment,
please review section 4101(c) of subtitle D of the HITECH ACT.




                                                                                      13
MEDICARE ELIGIBLE HOSPITALS


Eligible hospitals and Critical Access Hospitals (CAHs) will qualify for incentive
payments under the Medicare EHR Incentive Program if they successfully
demonstrate meaningful use of certified EHR technology.

What is an Eligible Hospital under the Medicare EHR Incentive Program?

• "Subsection (d) hospitals" in the 50 states or DC that are paid under the
Inpatient Prospective Payment System (IPPS)

• Critical Access Hospitals (CAHs)

• Medicare Advantage (MA-Affiliated) Hospitals

• Eligible hospitals and CAHs that adopt and successfully demonstrate
meaningful use of certified EHR technology can begin receiving incentive
payments for any year from federal fiscal year (FY) 2011 to FY 2015.

• Incentive payments to eligible hospitals and CAHs may begin as early as
2011 and are based on a number of factors, beginning with a $2 million base
payment.

• The law defines a payment year for eligible hospitals and CAHs in terms of
federal fiscal year (FY) beginning with FY 2011. However, a hospital does not
have to begin receiving incentive payments in FY 2011.

• Hospitals can begin receiving EHR incentive payments in any year from FY
2011 to FY 2015, but payments will decrease for hospitals that start receiving
payments in 2014 and later.

• Hospitals that do not successfully demonstrate meaningful use of certified
EHR technology beginning in FY 2015 will be subject to payment adjustments.




                                                                                     14
Eligible acute care inpatient hospitals are defined as “subsection (d) hospitals”
in section 1886(d)(1)(B) of the Act—which are hospitals that are paid under the
hospital inpatient prospective payment system (IPPS) and are located in one of
the 50 states or the District of Columbia. Section 1853(m)(2) of the Act also
specifies that qualifying Medicare Advantage (MA) organizations will be eligible
for incentive payments by way of their MA-affiliated eligible hospitals. An MA-
affiliated eligible hospital is a “subsection (d)” hospital that operates under
common corporate governance with a qualifying MA organization and serves
primarily individuals enrolled under MA plans offered by such organizations.

Medicare hospitals and MA-affiliated eligible hospitals that adopt a certified
EHR system and are meaningful users can begin receiving incentive payments
in any year from FY 2011 to FY 2015.

Medicare Incentive Payment Calculation

Regardless of the payment year, the Medicare incentive payment is the product
of three factors:
1. An Initial Amount
2. The Medicare Share
3. A Transition Factor applicable to the payment year This payment
methodology will be utilized to calculate Medicare hospital-based EHR incentive
payments for eligible hospitals participating under both the Medicare fee for
service and MA incentive programs.

Initial Amount = a base amount of $2,000,000 + discharge-related amount

The Initial Amount is the sum of a base amount and a discharge-related
amount. The base amount is $2,000,000, and the discharge-related amount
provides an additional $200 for each acute care hospital discharge during a
payment year, beginning with a hospital’s 1,150th discharge of the year and
ending with a hospital’s 23,000th discharge of the year. No additional payment
is made for discharges prior to the 1,150th discharge or for those discharges
after the 23,000th discharge.

Data on acute care hospital discharges from the hospital’s most recently filed
12-month cost report at the time of the calculation will be used as the basis for
making preliminary incentive payments. Final payments will be determined at
the time of settling the first 12-month cost report for the hospital FY that begins
after the beginning of the payment year and settled on the basis of the hospital
discharge data from that cost reporting period.




                                                                                      15
For example, for an eligible hospital with a cost reporting period running from
 July 1, 2010 through June 30, 2011, CMS would employ the relevant data from
 the hospital’s most recently filed 12-month cost report at the time of the
 calculation (most likely the June 30, 2010 cost report) to determine the
 preliminary incentive payment for the hospital during FY 2011. However, the
 final incentive payment would probably be based on hospital discharge data
 from the cost report beginning July 1, 2011 (fiscal year ending June 30, 2012)
 and determined at the time of settlement for that cost reporting period. If that
 cost report is not filed for a 12-month period, the next full 12-month cost report
 would be employed.

 For purposes of determining the Initial Amount, three (3) classes of hospitals
 are distinguished on the basis of the number of discharges as shown in Table 1.


                         Table 1: Initial Amount Calculation
  Type of Hospital    with 1,149 or fewer    with at least 1,150 but no   with 23,001 or more
                     discharges during the       more than 23,000          discharges during
                         payment year        discharges during payment        payment year
                                                         year
  Base Amount              $2,000,000                $2,000,000               $2,000,000

    Discharge                 $0                $200 x (n-1,149)          $200 x (23,001-
  Related Amount                             (n=number of discharges          1,149)
                                             during the payment year)
   Total Initial          $2,000,000         Between $2M & $6,370,400     Limited by law to
    Amount                                    depending on number of         $6,370,400
                                                   Discharges



Medicare Share Calculation is as follows:

# of IP Part A Bed Days + # of IP Part C Days________________________
Total IP Bed Days x Total Charges - Charges Attributable to Charity Care
   IP=inpatient                      Total Charges


The second step in determining the hospital payment for a meaningful user of
certified EHR technology is to calculate the Medicare Share.




                                                                                                16
As in calculating the Initial Amount, the time period used to determine the
Medicare Share fraction is based on data from the latest filed 12-month cost
report at the time the calculation is made and that is later update when the first
12-month cost report for the hospital fiscal year that begins after the beginning of
the payment year is settled.

The numerator of the Medicare Share is the sum of:
• The estimated number of acute care inpatient-bed-days attributable to
individuals for whom payment may be made under Part A; and
• The estimated number of acute care inpatient-bed-days attributable to
individuals who are enrolled with a Medicare Advantage organization under Part
C.

The denominator of the Medicare Share is the product of:
• The estimated total number of acute care inpatient-bed-days for the eligible
hospital during such a period; and
• The estimated total amount of the eligible hospital’s charges during such
period, not including any charges that are attributable to charity care, divided by
the estimated total amount of the hospitals charges during such period.

Note: The removal of charges attributable to charity care in the formula, in effect,
increases the Medicare Share resulting in higher incentive payments for
hospitals that provide a greater proportion of charity care. The amount comes
from the Medicare Cost Report, Worksheet S-10.


Transition Factor
The third (3rd) factor in the formula to determine the incentive payment to an
eligible hospital for a payment year is the Transition Factor. As seen in Table 2 on
the following page, this element phases down the incentive payments over time.

Hospitals that demonstrate that they are meaningful users of certified EHR
technology in FYs 2011, 2012 or 2013, could receive up to four (4) years of
financial incentive payments. Hospitals that begin receiving incentive payments
later than FY 2013 will receive no more than three (3) years of incentive
payments. Specifically, if a hospital were to begin to demonstrate meaningful use
of certified EHR technology in FY 2014, it would receive incentive payments for
FY 2014, FY 2015, and FY 2016.




                                                                                       17
Similarly, if a hospital were to begin meaningful use of certified EHR
technology in FY 2015, it would receive incentive payments for FYs 2015 and
2016. Table 2 shows the possible years an eligible hospital could receive an
incentive payment and the Transition Factor applicable to each year.



Table 2: Fiscal Year That Eligible Hospital First Receives the Incentive
Payment

          Fiscal
          Year
                      2011      2012     2013      2014      2015

           2011       1.00

           2012       0.75      1.00

           2013       0.50      0.75     1.00

           2014       0.25      0.50     0.75      0.75

           2015                 0.25     0.50      0.50      0.50

           2016                          0.25      0.25      0.25




                                                                               18
MEDICAID ELIGIBLE HOSPITALS


Eligible hospitals will qualify for incentive payments if they adopt, implement,
upgrade or demonstrate meaningful use of certified EHR technology during
the first participation year or successfully demonstrate meaningful use of
certified EHR technology in subsequent participation years.

What is an Eligible Hospital under the Medicaid EHR Incentive
Program?

• Acute care hospitals (including CAHs and cancer hospitals) with at least
10% Medicaid patient volume Children's hospitals (no Medicaid patient
volume requirements)
• Medicaid hospitals that qualify for EHR incentive payments may begin
receiving incentive payments in any year from fiscal year (FY) 2011 to FY
2016.
• While the law defines a payment year in terms of a FY beginning with FY
2011, a hospital does not have to begin receiving incentive payments
 in FY 2011.

 An eligible acute care inpatient hospital is defined as a health care facility
with an average length of patient stay of 25 days or fewer and with a Claim
Control Number that has the last four digits in the series 0001-0879 or 1300-
1399. This includes the 11 cancer hospitals and all Critical Access Hospitals
(CAHs) in the United States. In addition, to be eligible to receive a Medicaid
EHR incentive payment, acute care hospitals must also meet a 10 percent
(10%) Medicaid patient volume threshold. There is no Medicaid patient
volume requirement for children’s hospitals.

The method for estimating Medicaid patient volume will be designated by the
State Medicaid Agency and approved by CMS, but CMS provided States with
acceptable alternatives for making such estimates in the final rule.

Provided the state where the hospital is located is ready and participating in
the Medicaid EHR Incentive Program, acute care and children’s hospitals that
adopt a certified EHR system and are meaningful users can begin receiving
incentive payments in any year from fiscal year (FY) 2011 to FY 2016.




                                                                                   19
While the law defines a payment year in terms of a federal fiscal year, a hospital
does not have to begin receiving incentive payments in FY 2011. Hospitals can
begin receiving payments in any year from FY 2011 to FY 2016; however, the last
year a hospital can first receive a Medicaid incentive program payment is 2016.
Acute care hospitals may receive EHR Incentive Program payments from both
Medicare and Medicaid if eligible for both programs.

Medicaid Incentive Payment Calculation States may pay children’s hospitals and
acute care hospitals up to 100 percent (100%) of an aggregate EHR hospital
incentive amount provided over a minimum of a three-year period and a
maximum of a six-year period. The aggregate EHR incentive amount is the total
amount the hospital could receive in Medicaid payments over a theoretical four
(4) years of the program. It is the product of two factors:

1. The overall EHR amount.
2. The Medicaid Share.

The overall EHR amount is based upon the sum over a theoretical four years of
payment where the amount for each year is the product of three (3) factors:
1. An Initial Amount
2. The Medicare Share
3. A Transition Factor applicable to each of a theoretical four (4) years.

Initial Amount
Initial Amount = a base amount of $2,000,000 + a discharge-related amount
The Initial Amount is the sum of a base amount and a discharge-related amount.
The base amount is $2,000,000, and the discharge-related amount provides an
additional $200 for estimated discharges between 1,150 and 23,000 discharges.
No payment is made for discharges prior to the 1,150th discharge or for
discharges after the 23,000th discharge.

For the first payment year, data on hospital discharges from the hospital fiscal
year that ends during the federal fiscal year prior to the hospital fiscal year that
serves as the first payment year will be used as the basis for determining the
discharge-related amount. To determine the discharge-related amount for the
three subsequent payment years that are included in determining the overall
EHR amount, the number of discharges will be based on the average annual
growth rate for the hospital over the most recent three years of available data.

Note: If a hospital’s average annual rate of growth is negative over the three-year
period, the rate should be applied as such.




                                                                                       20
This factor in the formula determines the Medicaid incentive payment to an
 eligible hospital. For each of the four (4) years of theoretical payment, a different
 transition factor applies, as demonstrated in Table 1. Note that for the Medicaid
 Program, an aggregate EHR amount is calculated only once, and this amount is
 then spread over all years of a hospital’s payments. Therefore, the transition
 factors in Table 1 are used to calculate the aggregate EHR amount but do not
 indicate that the hospital’s payment will be calculated anew on a yearly basis.

 The second step in determining the aggregate EHR amount for a meaningful
 user of certified EHR technology is to calculate the Medicaid Share. The
 Medicaid Share is essentially the percentage of a hospital’s inpatient, non-charity
 care days that are attributable to Medicaid inpatients.

                           Table 1: Transition Factor by Year

                                               TRANSITION FACTOR

                     Year 1                             1.00

                     Year 2                             0.75

                     Year 3                             0.50

                     Year 4                             0.25


The Medicaid Share

The numerator of the Medicaid Share is the sum of:
1. The estimated number of Medicaid inpatient-bed-days
2. The estimated number of Medicaid managed care inpatient-bed-days

The denominator of the Medicaid Share is the product of:
1. The estimated total number of inpatient-bed-days for the eligible hospital
during that period
2. The estimated total amount of the eligible hospital’s charges during that period,
not including any charges that are attributable to charity care divided by the
estimated total amount of the hospital’s charges during that period. The hospital’s
final payments would be based on the State Health Information Technology plan
for incentive payments.

Note: The removal of charges attributable to charity care in the formula, in effect, increases the
Medicaid Share resulting in higher incentive payments for hospitals that provide a greater proportion
of charity care.




                                                                                                        21
MEDICARE & MEDICAID DUALLY ELIGIBLE HOSPITALS



Some hospitals may receive incentive payments from both Medicare and
Medicaid if they meet all eligibility criteria.

Hospitals that are eligible for EHR incentive payments under both Medicare and
Medicaid should select "Both Medicare and Medicaid" during the
registration process, even if they plan to apply ONLY for a Medicaid EHR
incentive payment by adopting, implementing or upgrading certified EHR
technology.

Dually-eligible hospitals can then attest through CMS for their Medicare EHR
incentive payment at a later date, if they so desire. It is important for a dually-
eligible hospital to select "Both Medicare and Medicaid" from the start of
registration in order to maintain this option.

Hospitals that register only for the Medicaid program (or only the Medicare
program) will not be able to manually change their registration (i.e., change to
"Both Medicare and Medicaid" or from one program to the other) after a
payment is initiated and this may cause significant delays in receiving a
Medicare EHR incentive payment.




                                                                                      22
E-PRESCRIBING INCENTIVES PROGRAM OVERVIEW


Eligible Professionals who participate in the eRx Incentive Program by
reporting on their adoption and use of a qualified eRx system that has the
functionalities required by CMS may qualify for an incentive payment.

E-prescribing is the transmission of prescription or prescription-related
information through electronic media. The Medicare Improvements for Patients
and Providers Act of 2008 (known as MIPPA) authorized the Medicare
Electronic Prescribing Incentive Program to promote adoption and use of
electronic-prescribing systems.

With eRx, health care professionals can electronically transmit both new
prescriptions and responses to renewal requests to a pharmacy without having
to write or fax the prescription.

The eRx incentive payment is similar to the Physician Quality Reporting
Initiative, or PQRI incentive in that it is based on the Medicare Part B
Physician Fee Schedule (PFS) covered professional services furnished by the
EPs during a reporting period. To be eligible for the incentive, you must meet
the criteria for being a successful electronic prescriber. The criteria used to
determine whether an EP is a successful electronic prescriber are established
for each program year through rulemaking.

Beginning 2012, CMS will apply payment adjustments to EPs who are not
successful electronic prescribers under the eRx Incentive Program. To become
successful e-prescribers for purposes of avoiding the 2012 eRx payment
adjustment, EPs must report the electronic prescribing measure for a required
minimum number of unique electronic prescribing events via claims between
January 1, 2011 and June 30, 2011

EPs may begin reporting the eRx measure at any time throughout the 2011
program year of January 1-December 31, 2011 to be incentive eligible, but
must do so prior to June 30, 2011 to be exempt from the 2012 eRx payment
adjustment.




                                                                                  23
EPs must have adopted a "qualified" e-prescribing system in order to be able to
report the e-prescribing measure. There are two (2) types of systems.

1) a system for eRx only (stand-alone).
2) an EHR system with eRx functionality.

Regardless of the type of system used, to be considered "qualified" it must be
based on ALL of the following capabilities:

• Generating a complete active medication list incorporating electronic data
received from applicable pharmacies and pharmacy benefit managers (PBMs) if
available.

• Selecting medications, printing prescriptions, electronically transmitting
prescriptions and conducting all alerts.
• Providing information related to lower cost, therapeutically appropriate
alternatives (if any). (The availability of an eRx system to receive tiered formulary
information, if available, would meet this requirement for 2011)
• Providing information on formulary or tiered formulary medications, patient
eligibility and authorization requirements received electronically from the patient's
drug plan, if available.

EPs can begin by reporting e-prescribing data for January 1-December 31, 2011.
Beginning in 2012, EPs who are not successful e-prescribers may be subject to
a payment adjustment. Section 132 of the Medicare Improvements for Patients
and Providers Act of 2008 (MIPPA) authorizes CMS to apply this payment
adjustment whether or not the EP is planning to participate in the eRx Incentive
Program.

The payment adjustment in 2012, with regard to all of the EP’s Part B-covered
professional services, will result in the EP’s or group practice receiving 99% of
the Physician Fee Schedule (PFS) amount that would otherwise apply to such
services. In 2013, the EPs will receive 98.5% of their covered Part B-eligible
charges if they aren’t a successful e-prescriber. In 2014, the penalty for not being
a successful e-prescriber is 2% resulting in EPs receiving 98% of their covered
Part B charges.




                                                                                        24
For purposes of determining which EPs or group practices are subject to the
payment adjustment in 2012, CMS will analyze claims data from January 1,
2011- June 30, 2011 to determine if the EP has submitted at least ten (10)
electronic prescriptions during the first six months of calendar year 2011. Group
practices reporting as a GPRO I or GPRO II in 2011must report all of their
required e-prescribing events in the first six months of 2011 to avoid the
payment adjustment in 2012.

If an EP or selected group practice wishes to request an exemption to the eRx
Incentive Program and the payment adjustment, there are two “hardship codes”
that can be reported via claims should one of the following situations apply:

• G8642 - The EP practices in a rural area without sufficient high speed internet
access and requests a hardship exemption from the application of the payment
adjustment under section 1848(a)(5)(A) of the Social Security Act.

• G8643 - The eligible professional practices in an area without sufficient
available pharmacies for electronic prescribing and requests a hardship
exemption from the application of the payment adjustment under section
1848(a)(5)(A) of the Social Security Act

Additionally, there will be a G code which can be used by EPs to indicate that
they do not have prescribing privileges. Reporting this G code will prevent the
EP from being subjected to a payment adjustment in 2012 .




                                                                                    25
EPRESCRIPTION – ELIGIBLE PROFESSIONALS

Eligible professionals do not need to participate in the Physician Quality
Reporting System to participate in the Electronic Prescribing (eRx) Incentive
Program.
Under the eRx Incentive Program, covered professional services are those paid
under the Medicare Physician Fee Schedule (PFS). To the extent that eligible
professionals are providing services which are paid under the PFS, those
services are eligible for eRx Incentive Program.


Eligible and Able to Participate
The following professionals are eligible to participate in eRx Incentive Program:
Eligible professionals must have prescribing authority in order to participate in
this program.

1. Medicare physicians
   • Doctor of Medicine
   • Doctor of Osteopathy
   • Doctor of Podiatric Medicine
   • Doctor of Optometry
   • Doctor of Oral Surgery
   • Doctor of Dental Medicine
   • Doctor of Chiropractic
2. Practitioners
   • Physician Assistant
   • Nurse Practitioner
   • Clinical Nurse Specialist
   • Certified Registered Nurse Anesthetist (and Anesthesiologist Assistant)
   • Certified Nurse Midwife
   • Clinical Social Worker
   • Clinical Psychologist
   • Registered Dietician
   • Nutrition Professional
   • Audiologists
3. Therapists
   • Physical Therapist
   • Occupational Therapist
   • Qualified Speech-Language Therapist




                                                                                    26
Eligible But Not Able to Participate


The following professionals are eligible to participate but are not able to
participate for one or more reasons:

1. Professionals paid under or based upon the PFS billing Medicare Carriers/
Medicare Administrative Contractors (MACs) who do not bill directly.
2. Professionals paid under the PFS billing Medicare fiscal intermediaries
(FIs) or MACs. The FI/MAC claims processing systems currently cannot
accommodate billing at the individual physician or practitioner level:

• Critical access hospital (CAH), method II payment, where the physician or
practitioner has reassigned his or her benefits to the CAH. In this situation,
the CAH bills the regular FI for the professional services provided by the
physician or practitioner.

• All institutional providers that bill for outpatient therapy provided by physical
and occupational therapists and speech language pathologists (for example,
hospital, skilled nursing facility Part B, home health agency, comprehensive
outpatient rehabilitation facility, or outpatient rehabilitation facility). This does
not apply to skilled nursing facilities under Part A.

Services payable under fee schedules or methodologies other than the PFS
are not included in Physician Quality Reporting (for example, services
provided in federally qualified health centers, independent diagnostic testing
facilities, independent laboratories, hospitals [including method I critical
access hospitals], rural health clinics, ambulance providers, and ambulatory
surgery center facilities).




                                                                                        27
EPRESCRIBING INCENTIVES PAYMENT DETAILS


Beginning 2012, Section 132 of the Medicare Improvements for Patients and
Providers Act of 2008 (P.L.110-275) (MIPPA) requires CMS to subject eligible
professionals who are not successful electronic prescribers under the eRx
Incentive Program to a payment adjustment.

This payment adjustment applies to all of the eligible professional's Part B-
covered professional services under the Medicare Physician Fee Schedule
(MPFS). From 2012 through 2014, the payment adjustment will increase with
each new reporting period. Accordingly, for 2012, eligible professionals
receiving a payment adjustment will be paid 1.0% less than the MPFS
amount for that service. In 2013 and 2014, the payment adjustment increases
to 1.5% and 2.0% respectively.

Significant Hardship Exception: Eligible professionals may be exempt from
the application of the payment adjustment if CMS determines that compliance
with the requirement for being a successful electronic prescriber would result
in a significant hardship. This hardship exception is subject to annual
renewal.




                                                                                 28
WHAT IS MEANINGFUL USE (MU)?


The Medicare and Medicaid EHR Incentive Programs provide a financial
incentive for the "meaningful use" (MU) of certified EHR technology to
achieve health and efficiency goals. By putting into action and meaningfully
using an EHR system, providers will reap benefits beyond financial
incentives–such as reduction in errors, availability of records and data,
reminders and alerts, clinical decision support, and e-prescribing/refill
automation.

The American Recovery and Reinvestment Act (ARRA) specifies three (3)
main components of Meaningful Use:
1. The use of a certified EHR in a meaningful manner, such as e-Prescribing.

2. The use of certified EHR technology for electronic exchange of health
information to improve quality of health care.

3. The use of certified EHR technology to submit clinical quality and other
measures.

Simply put, "meaningful use" means providers need to show they are using
certified EHR technology in ways that can be measured significantly in quality
and in quantity.

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
•   Maintaining privacy and security

The criteria for meaningful use will be staged in three (3) steps over the
course of the next five (5) years.




                                                                                 29
Stage 1 (2011 and 2012) sets the baseline for electronic data capture and
information sharing.

Stage 2 (expected to be implemented in 2013)

Stage 3 (expected to be implemented in 2015) and will continue to expand
on this baseline and be developed through future rule making.


To qualify for incentive payments, meaningful use requirements must be met in
the following ways:

Medicare EHR Incentive Program—Eligible professionals, eligible hospitals,
and critical access hospitals (CAHs) must successfully demonstrate meaningful
use of certified electronic health record technology every year they participate in
the program.
Medicaid EHR Incentive Program—Eligible professionals and eligible
hospitals may qualify for incentive payments if they adopt, implement, upgrade
or demonstrate meaningful use in their first year of participation. They must
successfully demonstrate meaningful use for subsequent participation years.

Adopted: Acquired and installed certified EHR technology. (For example, can
show evidence of installation.)

Implemented: Began using certified EHR technology. (For example, provide
staff training or data entry of patient demographic information into EHR.)

Upgraded: Expanded existing technology to meet certification requirements.
(For example, upgrade to certified EHR technology or add new functionality to
meet the definition of certified EHR technology.)

What are the requirements for Stage 1 of Meaningful Use (2011 and 2012)?

Meaningful use includes both a core set and a menu set of objectives that are
specific to eligible professionals or eligible hospitals and CAHs.

• For eligible professionals, there are a total of 25 meaningful use objectives.
To qualify for an incentive payment, 20 of these 25 objectives must be met.
       -There are 15 required core objectives.
       -The remaining 5 objectives may be chosen from the list of 10 menu set
       objectives.




                                                                                      30
• For eligible hospitals and CAHs, there are a total of 24 meaningful use
objectives. To qualify for an incentive payment, 19 of these 24 objectives must
  be met.
       -There are 14 required core objectives.
       -The remaining 5 objectives may be chosen from the list of 10 menu set
       objectives.


How do I meet the Requirements?

To qualify for incentive payments, meaningful use requirements must be met in the
following ways:

Medicare EHR Incentive Program—Eligible professionals, eligible hospitals and
critical access hospitals (CAHs) must successfully demonstrate meaningful use of
certified electronic health record technology every year they participate in the
program.
Medicaid EHR Incentive Program—Eligible professionals and eligible hospitals
may qualify for incentive payments if they adopt, implement, upgrade or
demonstrate meaningful use in their first year of participation. They must
successfully demonstrate meaningful use for subsequent participation years.

Adopted: Acquired and installed certified EHR technology. (For example, can
show evidence of installation.)
Implemented: Began using certified EHR technology. (For example, provide staff
training or data entry of patient demographic information into EHR.)
Upgraded: Expanded existing technology to meet certification requirements. (For
example, upgrade to certified EHR technology or add new functionality to meet the
definition of certified EHR technology.)




                                                                                    31
BASIC OVERVIEW OF STAGE 1 MEANINGFUL USE


• Reporting period is 90 days for first year and one (1) year subsequently
• 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


 *SCG assists with the registration and Attestation Processes – see related white
 paper




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)


NOTE: Some MU objectives are 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 five (5) deferred
measures. In these cases, the eligible professional would be excluded from
having to meet that measure.
IE: Dentists who do not perform immunizations; Chiropractors do not e-Prescribe

There are two types of percentage-based measures for denominator:

1. All patients seen during EHR reporting period
2. Patients or actions taken for patients who’s records are kept in the
certified EHR technology




                                                                                    32
ELIGIBLE PROFESSIONALS 15 CORE OBJECTIVES


1. Computerized physician order entry (CPOE)
2. E-Prescribing (eRx)
3. Report ambulatory clinical quality measures to CMS/States
4. Implement one clinical decision support rule
5. Provide patients with an electronic copy of their health information, upon
   request
6. Provide clinical summaries for patients for each office visit
7. Drug-drug and drug-allergy interaction checks
8. Record demographics
9. Maintain an up-to-date problem list of current and active diagnoses
10. Maintain active medication list
11. Maintain active medication allergy list
12. Record and chart changes in vital signs
13. Record smoking status for patients 13 years or older
14. Capability to exchange key clinical information among providers of care and
    patient-authorized entities electronically
15. Protect electronic health information


 ELIGIBLE PROFESSIONALS 10 MENU OBJECTIVES

 EPs must complete 5 of 10, listed below

 1. Drug-formulary checks
 2. Incorporate clinical lab test results as structured data
 3. Generate lists of patients by specific conditions
 4. Send reminders to patients per patient preference for preventive/follow up
    care
 5. Provide patients with timely electronic access to their health information
 6. Use certified EHR technology to identify patient- specific education
     resources and provide to patient, if appropriate
 7. Medication reconciliation
 8. Summary of care record for each transition of care/referrals
 9. Capability to submit electronic data to immunization registries/systems*
 10.Capability to provide electronic syndromic surveillance data to public
    health agencies*




                                                                                  33
ELIGIBLE PROFESSIONALS & MEANINGFUL USE



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

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




                                                                              34
WHAT ARE CLINICAL QUALITY MEASURES?



Quality health care is a high priority for the President, the Department of Health
and Human Services (HHS) and the Centers for Medicare & Medicaid Services
(CMS). CMS implements quality initiatives to assure quality health care for
Medicare Beneficiaries through accountability and public disclosure. CMS uses
quality measures in its various quality initiatives that include quality
improvement, pay for reporting, and public reporting.




WHAT ARE QUALITY MEASURES?

Quality measures are tools that help us measure or quantify healthcare
processes, outcomes, patient perceptions, and organizational structure and/or
systems that are associated with the ability to provide high-quality health care
and/or that relate to one or more quality goals for health care. These goals
include: effective, safe, efficient, patient-centered, equitable and timely care.

To demonstrate meaningful use successfully, eligible professionals, eligible
hospitals and CAHs are required also to report clinical quality measures
specific to eligible professionals or eligible hospitals and CAHs.

Eligible professionals must report on six (6) total clinical quality measures:
Three (3) required core measures (substituting alternate core measures
where necessary) and three (3) additional measures (selected from a set of 38
clinical quality measures).

Eligible hospitals and CAHs must report on all 15 of their clinical quality
measures.




                                                                                     35
ELIGIBLE PROFESSIONALS REQUIREMENTS FOR
CLINICAL QUALITY 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.




ELIGIBLE PROFESSIONALS REQUIREMENTS FOR
CLINICAL QUALITY MEASURES REPORTING

 EHR Incentive Program Electronic Specifications Introduction:

 In order to report quality measures from an EHR, electronic specifications
 must be developed that include the data elements, logic and definitions for
 that measure in a format that can be captured or stored in the EHR so that
 the data can be sent or shared electronically with other entities in a
 structured, standardized format and unaltered.

 These electronic specifications are derived from certified EHRs. As part of the
 criteria for satisfying meaningful use, clinical quality measures results
 (numerators, denominators, and exclusions) must be reported to CMS.




                                                                                   36
ELIGIBLE PROFESSIONALS REPORTING PERIOD


The reporting period for the EHR Incentive program using a certified EHR is
any continuous 90 day period during the first payment year. Please note
that although the measure specifications assume a full calendar year, you
should only calculate the denominator and numerator from the first day of the
90 day reporting period to the last day of the 90 day reporting period.

Eligible professionals must report from the table of 44 clinical quality measures
which includes, 3 Core, 3 Alternate Core, and 38 additional CQMs.

• Core CQMs - EPs must report on 3 required core CQMs, and if the
denominator of 1 or more of the required core measures is 0, then EPs are
required to report results for up to 3 alternate core measures.

• EPs must also select 3 additional CQMs from a set of 38 CQMs (excluding
the core/alternate core measures). It is acceptable to have a '0' denominator,
provided the EP does not have an applicable population.

In sum, EPs must report on six (6) total measures: 3 required core measures
(substituting alternate core measures where necessary) and 3 additional
measures. A maximum of 9 measures would be reported if the EP needed to
attest to the 3 required core, the three alternate core and the 3 additional
measures.




                                                                                    37
CLINICAL QUALITY MEASURES CORE SET


NQF Measure Number & PQRI Clinical Quality Measure Title
Implementation Number
NQF 0013                  Hypertension: Blood Pressure
                          Measurement
NQF 0028                  Preventive Care & Screening Measure
                          Pair: a) Tobacco Use Assessment,
                          b) Tobacco Cessation Intervention
NQF 0421                  Adult Weight Screening & Follow-up
PQRI 128


ALTERNATE CORE SET


NQF Measure Number & PQRI Clinical Quality Measure Title
Implementation Number
NQF 0024                  Weight Assessment & Counseling for
                          Children & Adolescents
NQF 0041                  Preventive Care & Screening:
PQRI 110                  Influenza Immunization for Patients
                          50 Years Old or Older
NQF 0038                  Childhood Immunization Status




                                                                38
ADDITIONAL SET CQM


Must Complete 3 of 38

1. Diabetes: Hemoglobin A1c Poor Control
2. Diabetes: Low Density Lipoprotein (LDL) Management and Control
3. Diabetes: Blood Pressure Management
4. Heart Failure (HF): Angiotensin-Converting Enzyme (ACE) Inhibitor or
   Angiotensin Receptor Blocker (ARB) Therapy for Left Ventricular Systolic
   Dysfunction (LVSD)
5. Coronary Artery Disease (CAD): Beta-Blocker Therapy for CAD Patients
   with Prior Myocardial Infarction (MI)
6. Pneumonia Vaccination Status for Older Adults
7. Breast Cancer Screening
8. Colorectal Cancer Screening
9. Coronary Artery Disease (CAD): Oral Antiplatelet Therapy Prescribed for
   Patients with CAD
10. Heart Failure (HF): Beta-Blocker Therapy for Left Ventricular Systolic
11. Dysfunction (LVSD) Anti-depressant medication management: (a)
    Effective Acute Phase Treatment, (b)Effective Continuation Phase
    Treatment
12. Primary Open Angle Glaucoma (POAG): Optic Nerve Evaluation
13. Diabetic Retinopathy: Documentation of Presence or Absence of Macular
    Edema and Level of Severity of Retinopathy
14. Diabetic Retinopathy: Communication with the
15. Physician Managing Ongoing Diabetes Care
16. Asthma Pharmacologic Therapy
17. Asthma Assessment
18. Appropriate Testing for Children with Pharyngitis Oncology Breast Cancer:
    Hormonal Therapy for Stage IC-IIIC Estrogen Receptor/Progesterone
    Receptor (ER/PR) Positive Breast Cancer
19. Oncology Colon Cancer: Chemotherapy for Stage III Colon Cancer Patients
20. Prostate Cancer: Avoidance of Overuse of Bone Scan for Staging Low Risk
    Prostate Cancer Patients
 21.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




                                                                                39
22. Diabetes: Eye Exam
23. Diabetes: Urine Screening
24. Diabetes: Foot Exam
25. Coronary Artery Disease (CAD): Drug Therapy for Lowering LDL-
    Cholesterol
26. Heart Failure (HF): Warfarin Therapy Patients with Atrial Fibrillation
27. Ischemic Vascular Disease (IVD): Blood Pressure Management
28. Ischemic Vascular Disease (IVD): Use of Aspirin or Another Antithrombotic
29. Initiation and Engagement of Alcohol and Other Drug Dependence
    Treatment: a) Initiation, b) Engagement
30. Prenatal Care: Screening for Human Immunodeficiency Virus (HIV)
31. Prenatal Care: Anti-D Immune Globulin
32. Controlling High Blood Pressure
33. Cervical Cancer Screening
34. Chlamydia Screening for Women
35. Use of Appropriate Medications for Asthma
36. Low Back Pain: Use of Imaging Studies
37. Ischemic Vascular Disease (IVD): Complete Lipid Panel and LDL Control
38. Diabetes: Hemoglobin A1c Control (<8.0%)


• Clinical Quality Measures align with Physicians Clinical Quality reporting
(PQRI)

• Alignment between 4 HITECH CQM and the CHIPRA initial core set that
providers report to States




                                                                                40
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




                                                                                41
PROGRAM TIMELINE


 January 2011 –Registration for the EHR Incentive
 Programs begins

 January 2011 –For Medicaid providers. States may
  launch their programs if they choose

 April 2011 –Attestation for the Medicare EHR Incentive
 Program begins

 May 2011 –Medicare EHR incentive payments begin

 February 29, 2012 –Last day for EPs to register and
 attest to receive an incentive payment for CY 2011

 2015–Medicare payment adjustments begin for EPs and eligible hospitals that
 are not meaningful users of EHR technology

 2016–Last year to receive a Medicare EHR incentive payment; Last year to
 initiate participation in Medicaid EHR Incentive Program

 2021–Last year to receive Medicaid EHR incentive payment




**for details on how SCG assists with the registration & MU process, see our
“procedure for assistance” white paper.




                                                                               42
ACRONYMS


ACA –Patient Protection and Affordable Care Act
A/I/U –Adopt, implement, or upgrade
CAH –Critical Access Hospital
CCN –CMS Certification Number
CHIPRA –Children's Health Insurance Program Reauthorization Act of 2009
CMS –Centers for Medicare & Medicaid Services
CNM –Certified Nurse Midwife
CPOE –Computerized Physician Order Entry
CQM –Clinical Quality Measures
CY –Calendar Year
EHR –Electronic Health Record
EP –Eligible Professional
eRx–E-Prescribing
FFS –Fee-for-service
FQHC –Federally Qualified Health Center
FFY –Federal Fiscal Year
HHS –U.S. Department of Health and Human Services
HIT –Health Information Technology
HITECH –Health Information Technology for Economic and Clinical Health Act
HITPC –Health Information Technology Policy Committee
HPSA –Health Professional Shortage Area
MA –Medicare Advantage
MCMP –Medicare Care Management Performance Demonstration
MU –Meaningful Use
NCVHS –National Committee on Vital and Health Statistics
NP –Nurse Practitioner
NPI –National Provider Identifier
NPRM –Notice of Proposed Rulemaking
OMB –Office of Management and Budget
ONC –Office of the National Coordinator of Health Information Technology
ATCB –Authorized Testing and Certification Body
CCHIT –Certification Commission for Health Information Technology
EMR –Electronic Medical Records




                                                                             43
HIPAA –Health Insurance Portability and Accountability Act of 1996
PA –Physician Assistant
PECOS –Provider Enrollment, Chain, and Ownership System
PPS –Prospective Payment System (Part A)
PQRI –Medicare Physician Quality Reporting Initiative
ARRA –American Reinvestment & Recovery Act of 2009
RHC –Rural Health Clinic
RHQDAPU –Reporting Hospital Quality Data for Annual Payment Update
TIN –Taxpayer Identification Number




                                                                     44
Questions or Comments?


      1-888-803-9431
      1-704-405-3085
Email: help@mysuccor.com
   www.mysuccor.com

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SCG's Meaningful Use White Paper

  • 1. SUCCOR CONSULTING GROUP Help has arrived. __________________________________________ Medicare & Medicaid Meaningful Use Incentives Program Specifics May 2011 Copyright 2011 © Succor Consulting Group, Inc
  • 2. TABLE OF CONTENTS EHR INCENTIVE PROGRAM - OVERVIEW 1 MEDICARE/MEDICAID ELIGIBLE PROFESSIONALS (EPs) 3 ELIGIBILITY REQUIREMENTS FOR PHYSICIANS 4 MEDICAID INCENTIVES OVERVIEW 6 ELIGIBLE PROFESSIONAL SHORTAGE BONUSES 7 PROFESSIONALS ELIGIBLE FOR BOTH PROGRAMS 8 MEDICARE VS MEDICAID 9 PENDING EXPANDED MEDICARE & MEDICAID ELIGIBLE PROFESSIONALS & FACILITIES 10 MEDICARE EHR INCENTIVES BASICS OVERVIEW FOR ELIGIBLE PROFESSIONALS 11 MEDICAID EHR INCENTIVES BASICS OVERVIEW FOR ELIGIBLE PROFESSIONALS 12 MEDICARE ADVANTAGE ELIGIBLE PROFESSIONALS 13 MEDICARE ELIGIBLE HOSPITALS 14 MEDICAID ELIGIBLE HOSPITALS 19 MEDICARE & MEDICAID DUALLY ELIGIBLE HOSPITALS 22 E-PRESCRIBING INCENTIVES PROGRAM OVERVIEW 23 E-PRESCRIPTION – ELIGIBLE PROFESSIONALS 26 E-PRESCRIBING INCENTIVES PAYMENT DETAILS 28 WHAT IS MEANINGFUL USE (MU)? 29 BASIC OVERVIEW OF STAGE 1 MU OBJECTIVES AND MEASURES REPORTING 32 ELIGIBLE PROFESSIONALS 15 CORE/10 MENU OBJECTIVES 33 ELIGIBLE PROFESSIONALS & MEANINGFUL USE 34 WHAT ARE CLINICAL QUALITY MEASURES? 35 WHAT ARE QUALITY MEASURES? 35 EP REQUIREMENTS FOR CLINICAL QUALITY MEASURES 36 EP REQUIREMENTS FOR CLINICAL QUALITY MEASURES REPORTING 36 EP REPORTING PERIOD 37 CLINICAL QUALITY MEASURES CORE SET 38 ALTERNATE CORE SET 38 ADDITIONAL SET CQM 39 REGISTRATION REQUIREMENTS 41 PROGRAM TIMELINE 42 ACRONYMS 43
  • 3. EHR INCENTIVES PROGRAM OVERVIEW EHR Incentive Programs were established by law through the American Recovery & Reinvestment Act (ARRA) of 2009. The Medicare and Medicaid EHR Incentive Programs will provide incentive payments to eligible professionals (EPs), eligible hospitals and critical access hospitals (CAHs), Integrated Delivery Networks (IDNs) and other Medical Establishments as they adopt, implement, upgrade or demonstrate Meaningful Use (MU) of CCHIT certified EHR technology. We have been preparing to cross this threshold for many decades. The potential for information technology to support and improve health care was recognized early. Government and private support for development and assessment of health informatics began in the 1960s. Yet, even as computers transformed almost every other sector of the economy, health care remained mostly paper-based. In 2009, Congress and President Obama took a definitive new step when they enacted the Health Information Technology Economic and Clinical Heath Act (HITECH), part of ARRA. HITECH authorized up to $27 billion in incentive payments for providers and $2 billion to build a national infrastructure for the adoption of EHRs. Most importantly, HITECH established the goal of the meaningful use of electronic health records. However cryptic this term may have seemed at first, it holds the key to unlocking the power of information to transform health care for the better. Put plainly, “meaningful use” is a shorthand for three things: An incentive program, rewarding not only deployment of EHRs, but also their effective use for patient benefit; A new national infrastructure to support deployment and beneficial use of EHRs; and A vision for the evolving, dynamic and optimal uses of information to support health and health care improvement – the tip of the spear for an information- powered leap in the quality, safety and effectiveness (including cost effectiveness) of our health care system. 1
  • 4. As an incentive program, meaningful use went live January 1, 2011. That was when registration opened for eligible providers and hospitals to take part in the Medicare and Medicaid incentive payments programs. Surveys in the latter part of 2010 by the American Hospital Association (AHA) and CDC’s National Center for Health Statistics indicated that 81 percent of hospitals and 41 percent of office-based physicians were already planning to achieve meaningful use and qualify for incentive payments. In January alone, 21,300 providers initiated the registration process. 2
  • 5. MEDICARE ELIGIBLE PROFESSIONALS Eligible professionals under the Medicare EHR Incentive Program include: • Doctor of medicine or osteopathy • Doctor of dental surgery or dental medicine • Doctor of podiatry • Doctor of optometry • Chiropractor EPs may not be hospital-based. MEDICAID ELIGIBLE PROFESSIONALS Eligible professionals under the Medicaid EHR Incentive Program include: • Physicians (primarily doctors of medicine and doctors of osteopathy) • Nurse practitioner • Certified nurse-midwife • Dentist • Physician assistant who furnishes services in a Federally Qualified Health Center or Rural Health Clinic that is led by a physician assistant. EPs may not be hospital-based. To qualify for an incentive payment under the Medicaid EHR Incentive Program, an eligible professional must meet one of the following criteria: 1. Have a minimum of 30% Medicaid patient volume* 2. Have a minimum of 20% Medicaid patient volume and is a pediatrician* 3. Practice predominantly in a Federally Qualified Health Center or Rural Health Center and have a minimum of 30% patient volume attributable to needy individuals *Note - Children's Health Insurance Program (CHIP) patients do not count toward the Medicaid patient volume criteria. 3
  • 6. ELIGIBILITY REQUIREMENTS FOR PROFESSIONALS • Incentive payments for eligible professionals are based on individual practitioners. • If you are part of a practice, each eligible professional may qualify for an incentive payment if each eligible professional successfully demonstrates meaningful use of certified EHR technology. • Each eligible professional is only eligible for one incentive payment per year, regardless of how many practices or locations at which he or she provides services. Hospital-based eligible professionals are not eligible for incentive payments. An eligible professional is considered hospital-based if 90% or more of his or her services are performed in a hospital inpatient (Place Of Service code 21) or emergency room (Place Of Service code 23) setting. 4
  • 7. Medicare EP Incentive Payments amounts are based on: • Fee-for-Service (FFS) allowable charges • 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 • Receive one (1) incentive payment per year Payment First Year you First Year you First Year you First Year you Amount for Qualify to Qualify to Qualify to Qualify to Year: Receive Payment Receive Payment Receive Payment Receive Payment 2011 2012 2013 2014 2011 $18,000 - - - 2012 $12,000 $18,000 - - 2013 $8,000 $12,000 $15,000 - 2014 $4,000 $8,000 $12,000 $12,000 2015 $2,000 $4,000 $8,000 $8,000 2016 - $2,000 $4,000 $4,000 TOTAL Possible $44,000 $44,000 $39,000 $24,000 Incentive Payments 5
  • 8. Medicaid Incentives Payments Overview • Maximum incentives are $63,750 over six years • Incentives are the same regardless of start year • The first year payment is $21,250 • Must begin by 2016 to receive incentive payments • Incentives are available through 2021 • Pays one (1) incentive payment per year *NOTE: No extra bonus for health professional shortage area Payment First Year you First Year you First Year you First Year you First Year you First Year you Amount for Qualify to Qualify to Qualify to Qualify to Qualify to Qualify to Year: Receive Payment Receive Payment Receive Payment Receive Payment Receive Payment Receive Payment 2011 2012 2013 2014 2015 2016 2011 $21,250 - - - - - 2012 $8,500 $21,250 - - - - 2013 $8,500 $8,500 $21,250 - - - 2014 $8,500 $8,500 $8,500 $21,250 - - 2015 $8,500 $8,500 $8,500 $8,500 $21,250 - 2016 $8,500 $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 Possible $63,750 $63,750 $63,750 $63,750 $63,750 $63,750 Incentive Payments 6
  • 9. ELIGIBLE PROFESSIONAL SHORTAGE BONUSES You may qualify for more! Practices with 30% or more of their patient population paying with Medicaid (20% for pediatricians) are eligible for stimulus incentive payments of up to $65,000. Practices operating in a "health provider shortage area" (HPSA) can qualify for bonus incentives, e-prescribing, Medicare's physician quality reporting initiative (PQRI) and Medicare Care Manage Performance (MCMP) can also increase your bonuses. Private Practice Non-FQHC Safety NetClinics FQHC Clinics Medicare HITECH Incentive $44,000 per provider $44,000 per provider $44,000 per provider Medicare Plus HSPA $48,400 per provider $48,400 per provider $48,400 per provider Medicaid HITECH Incentive - $65,000 per provider $65,000 per provider Bonus E-Prescribe 2% bonus 2% bonus 2% bonus Medicare PQRI 2% bonus 2% bonus - Medicare MCMP $12,500 per provider $12,500 per provider - 7
  • 10. PROFESSIONALS ELIGIBLE FOR BOTH PROGRAMS EPs eligible for both the Medicare and Medicaid EHR Incentive Programs must choose which incentive program they wish to participate in when they register. Before 2015, an EP may switch programs only once after the first incentive payment is initiated. Medicare EPs who also qualify as a Medicaid EP must choose between the Medicare and Medicaid incentive programs when they register. Medicaid EPs and providers who are not eligible to participate in the Medicare and Medicaid EHR Incentive Programs will not be subject to payment adjustments. However, Medicaid EPs who also treat Medicare patients will have a payment adjustment to Medicare reimbursements, starting in 2015 if they do not successfully demonstrate meaningful use. Eligible for both Doctors or Medicine Doctors of Osteopathy Doctors of Dental Medicine or Surgery Nurse Practitioners Doctors of Optometry Certified Nurse-Midwives Doctors of Podiatric Physician Assistants Medicine (when working at an Chiropractor FQHC or RHA that is led by a PA) Medicare only Medicaid only *Most eligible professionals will maximize their incentive payments by participating in the Medicaid EHR Incentive Program. 8
  • 11. MEDICARE VS MEDICAID Medicare Medicaid Federal Government will implement Voluntary for States to implement - starting January 2011 Most expected to start late summer 2011 Payment reductions begin in 2015 for No Medicaid payment reductions providers that do not demonstrate MU Must demonstrate MU in Year 1 A/I/U option for 1st participation year Maximum incentive is $44,000 for EPs Maximum incentive is $63,750 for EPs (bonus for Eps in HPSAs) MU definition is common for Medicare States can adopt certain additional requirements for MU Last year a provider may initiate program Last year a provider may register for & is 2014; Last year to register is 2016; initiate program is 2016; Last payment Payment adjustments begin in 2015 year is 2021 Only physicians, subsection (d) 5 types of EPs, acute care hospitals hospitals and CAHs (including CAHs) & children's hospitals 9
  • 12. PENDING EXPANDED MEDICARE & MEDICAID ELIGIBLE PROFESSIONALS & FACILITIES Legislation introduced in the U.S. Senate would extend eligibility for electronic health records meaningful use incentive payments to: • Behavioral health professionals and facilities • Mental health professionals and facilities • Substance abuse professionals and facilities Sen. Sheldon Whitehouse (D-RI) introduced S. 539, which has been referred to the Finance Committee. Facilities eligible under the bill include: • Community mental health centers • Psychiatric hospitals • Residential mental health treatment facilities • Outpatient mental health treatment facilities • Substance abuse treatment facilities • Including facilities operated by counties The legislation also would make these professionals and facilities eligible for services from health information technology extension centers. Text of S. 529 is available at congress.gov. Please check back for updates. 10
  • 13. MEDICARE EHR INCENTIVES BASICS OVERVIEW FOR ELIGIBLE PROFESSIONALS The Medicare EHR Incentive Program for EPs starts in 2011 and will continue through 2016. Depending on the first year they participate, EPs can participate for up to 5 years throughout the duration of the program. The last year to begin participation in the Medicare EHR Incentive Program is 2014. • To qualify for Medicare EHR incentive payments, Medicare EPs must successfully demonstrate meaningful use for each year of participation in the program. • Incentive payments are made based on the calendar year. The reporting period for the first year is any 90 continuous days during the calendar year. The reporting period for all subsequent years is the entire calendar year. • For calendar years 2011–2016, EPs who demonstrate meaningful use of certified EHR technology can receive up to $44,000 over 5 years under the Medicare EHR Incentive Program. To receive the maximum EHR incentive payment, Medicare EPs must begin participation by 2012. Important! For 2015 and later, Medicare EPs who do not successfully demonstrate meaningful use will have a payment adjustment to their Medicare reimbursement. The payment reduction starts at 1% and increases each year that a Medicare EP does not demonstrate meaningful use, to a maximum of 5%. 11
  • 14. MEDICAID EHR INCENTIVES BASICS OVERVIEW FOR ELIGIBLE PROFESSIONALS The Medicaid EHR Incentive Program is offered and administered voluntarily by states and territories. States can start offering their program to EPs as early as 2011. The program continues through 2021. EPs can participate for 6 years throughout the duration of the program. The last year to begin participation in the Medicaid EHR Incentive Program is 2016. • To qualify for Medicaid incentive payments, Medicaid EPs must adopt, implement, upgrade or demonstrate meaningful use of certified EHR technology in the first year of participation and successfully demonstrate meaningful use in subsequent participation years. • For calendar years 2011–2021, participants can receive up to $63,750 over 6 years under the Medicaid EHR incentive program. EHR incentive payments are made by the state based on the calendar year. • Medicaid EPs who also qualify as Medicare EPs must choose between the Medicare and Medicaid EHR Incentive Programs when they register. • Medicaid EPs and providers who are not eligible to participate in the Medicare and Medicaid EHR Incentive Programs will not be subject to payment adjustments. However, Medicaid EPs who also treat Medicare patients will have a payment adjustment to Medicare reimbursements starting in 2015 if they do not successfully demonstrate meaningful use. 12
  • 15. MEDICARE ADVANTAGE ELIGIBLE PROFESSIONALS? Medicare Advantage (MA) EPs are physicians that are either: • Employed by the Medicare Advantage organization OR • Employed by, or partner of, an entity through a contract with the Medicare Advantage organization, that furnishes at least 80% of that entity's Medicare patient care services to enrollees of the MA organization. Also, Medicare Advantage EPs must furnish at least 80% of their Medicare- related professional services to enrollees of the MA organization and must furnish, on average, at least 20 hours per week of patient care services. Medicare Advantage (MA) organizations may also qualify to receive EHR incentive payments. Under the Medicare Advantage EHR Incentive Program, payments are made only to Medicare Advantage organizations that are licensed as HMOs, or in the same manner as HMOs, by a State. These Medicare Advantage organizations may receive incentive payments by way of Medicare Advantage affiliated hospitals (MA-affiliated hospitals) and Medicare Advantage EPs. What is a Medicare Advantage affiliated hospital? Medicare Advantage affiliated hospitals are hospitals that: • Are under a common corporate governance with the Medicare Advantage organization AND • Serve individuals enrolled under Medicare Advantage plans offered by the Medicare Advantage organization, where less than one-third are Medicare individuals covered under Medicare Part A. *For additional information regarding the Medicare Advantage EHR incentive payment, please review section 4101(c) of subtitle D of the HITECH ACT. 13
  • 16. MEDICARE ELIGIBLE HOSPITALS Eligible hospitals and Critical Access Hospitals (CAHs) will qualify for incentive payments under the Medicare EHR Incentive Program if they successfully demonstrate meaningful use of certified EHR technology. What is an Eligible Hospital under the Medicare EHR Incentive Program? • "Subsection (d) hospitals" in the 50 states or DC that are paid under the Inpatient Prospective Payment System (IPPS) • Critical Access Hospitals (CAHs) • Medicare Advantage (MA-Affiliated) Hospitals • Eligible hospitals and CAHs that adopt and successfully demonstrate meaningful use of certified EHR technology can begin receiving incentive payments for any year from federal fiscal year (FY) 2011 to FY 2015. • Incentive payments to eligible hospitals and CAHs may begin as early as 2011 and are based on a number of factors, beginning with a $2 million base payment. • The law defines a payment year for eligible hospitals and CAHs in terms of federal fiscal year (FY) beginning with FY 2011. However, a hospital does not have to begin receiving incentive payments in FY 2011. • Hospitals can begin receiving EHR incentive payments in any year from FY 2011 to FY 2015, but payments will decrease for hospitals that start receiving payments in 2014 and later. • Hospitals that do not successfully demonstrate meaningful use of certified EHR technology beginning in FY 2015 will be subject to payment adjustments. 14
  • 17. Eligible acute care inpatient hospitals are defined as “subsection (d) hospitals” in section 1886(d)(1)(B) of the Act—which are hospitals that are paid under the hospital inpatient prospective payment system (IPPS) and are located in one of the 50 states or the District of Columbia. Section 1853(m)(2) of the Act also specifies that qualifying Medicare Advantage (MA) organizations will be eligible for incentive payments by way of their MA-affiliated eligible hospitals. An MA- affiliated eligible hospital is a “subsection (d)” hospital that operates under common corporate governance with a qualifying MA organization and serves primarily individuals enrolled under MA plans offered by such organizations. Medicare hospitals and MA-affiliated eligible hospitals that adopt a certified EHR system and are meaningful users can begin receiving incentive payments in any year from FY 2011 to FY 2015. Medicare Incentive Payment Calculation Regardless of the payment year, the Medicare incentive payment is the product of three factors: 1. An Initial Amount 2. The Medicare Share 3. A Transition Factor applicable to the payment year This payment methodology will be utilized to calculate Medicare hospital-based EHR incentive payments for eligible hospitals participating under both the Medicare fee for service and MA incentive programs. Initial Amount = a base amount of $2,000,000 + discharge-related amount The Initial Amount is the sum of a base amount and a discharge-related amount. The base amount is $2,000,000, and the discharge-related amount provides an additional $200 for each acute care hospital discharge during a payment year, beginning with a hospital’s 1,150th discharge of the year and ending with a hospital’s 23,000th discharge of the year. No additional payment is made for discharges prior to the 1,150th discharge or for those discharges after the 23,000th discharge. Data on acute care hospital discharges from the hospital’s most recently filed 12-month cost report at the time of the calculation will be used as the basis for making preliminary incentive payments. Final payments will be determined at the time of settling the first 12-month cost report for the hospital FY that begins after the beginning of the payment year and settled on the basis of the hospital discharge data from that cost reporting period. 15
  • 18. For example, for an eligible hospital with a cost reporting period running from July 1, 2010 through June 30, 2011, CMS would employ the relevant data from the hospital’s most recently filed 12-month cost report at the time of the calculation (most likely the June 30, 2010 cost report) to determine the preliminary incentive payment for the hospital during FY 2011. However, the final incentive payment would probably be based on hospital discharge data from the cost report beginning July 1, 2011 (fiscal year ending June 30, 2012) and determined at the time of settlement for that cost reporting period. If that cost report is not filed for a 12-month period, the next full 12-month cost report would be employed. For purposes of determining the Initial Amount, three (3) classes of hospitals are distinguished on the basis of the number of discharges as shown in Table 1. Table 1: Initial Amount Calculation Type of Hospital with 1,149 or fewer with at least 1,150 but no with 23,001 or more discharges during the more than 23,000 discharges during payment year discharges during payment payment year year Base Amount $2,000,000 $2,000,000 $2,000,000 Discharge $0 $200 x (n-1,149) $200 x (23,001- Related Amount (n=number of discharges 1,149) during the payment year) Total Initial $2,000,000 Between $2M & $6,370,400 Limited by law to Amount depending on number of $6,370,400 Discharges Medicare Share Calculation is as follows: # of IP Part A Bed Days + # of IP Part C Days________________________ Total IP Bed Days x Total Charges - Charges Attributable to Charity Care IP=inpatient Total Charges The second step in determining the hospital payment for a meaningful user of certified EHR technology is to calculate the Medicare Share. 16
  • 19. As in calculating the Initial Amount, the time period used to determine the Medicare Share fraction is based on data from the latest filed 12-month cost report at the time the calculation is made and that is later update when the first 12-month cost report for the hospital fiscal year that begins after the beginning of the payment year is settled. The numerator of the Medicare Share is the sum of: • The estimated number of acute care inpatient-bed-days attributable to individuals for whom payment may be made under Part A; and • The estimated number of acute care inpatient-bed-days attributable to individuals who are enrolled with a Medicare Advantage organization under Part C. The denominator of the Medicare Share is the product of: • The estimated total number of acute care inpatient-bed-days for the eligible hospital during such a period; and • The estimated total amount of the eligible hospital’s charges during such period, not including any charges that are attributable to charity care, divided by the estimated total amount of the hospitals charges during such period. Note: The removal of charges attributable to charity care in the formula, in effect, increases the Medicare Share resulting in higher incentive payments for hospitals that provide a greater proportion of charity care. The amount comes from the Medicare Cost Report, Worksheet S-10. Transition Factor The third (3rd) factor in the formula to determine the incentive payment to an eligible hospital for a payment year is the Transition Factor. As seen in Table 2 on the following page, this element phases down the incentive payments over time. Hospitals that demonstrate that they are meaningful users of certified EHR technology in FYs 2011, 2012 or 2013, could receive up to four (4) years of financial incentive payments. Hospitals that begin receiving incentive payments later than FY 2013 will receive no more than three (3) years of incentive payments. Specifically, if a hospital were to begin to demonstrate meaningful use of certified EHR technology in FY 2014, it would receive incentive payments for FY 2014, FY 2015, and FY 2016. 17
  • 20. Similarly, if a hospital were to begin meaningful use of certified EHR technology in FY 2015, it would receive incentive payments for FYs 2015 and 2016. Table 2 shows the possible years an eligible hospital could receive an incentive payment and the Transition Factor applicable to each year. Table 2: Fiscal Year That Eligible Hospital First Receives the Incentive Payment Fiscal Year 2011 2012 2013 2014 2015 2011 1.00 2012 0.75 1.00 2013 0.50 0.75 1.00 2014 0.25 0.50 0.75 0.75 2015 0.25 0.50 0.50 0.50 2016 0.25 0.25 0.25 18
  • 21. MEDICAID ELIGIBLE HOSPITALS Eligible hospitals will qualify for incentive payments if they adopt, implement, upgrade or demonstrate meaningful use of certified EHR technology during the first participation year or successfully demonstrate meaningful use of certified EHR technology in subsequent participation years. What is an Eligible Hospital under the Medicaid EHR Incentive Program? • Acute care hospitals (including CAHs and cancer hospitals) with at least 10% Medicaid patient volume Children's hospitals (no Medicaid patient volume requirements) • Medicaid hospitals that qualify for EHR incentive payments may begin receiving incentive payments in any year from fiscal year (FY) 2011 to FY 2016. • While the law defines a payment year in terms of a FY beginning with FY 2011, a hospital does not have to begin receiving incentive payments in FY 2011. An eligible acute care inpatient hospital is defined as a health care facility with an average length of patient stay of 25 days or fewer and with a Claim Control Number that has the last four digits in the series 0001-0879 or 1300- 1399. This includes the 11 cancer hospitals and all Critical Access Hospitals (CAHs) in the United States. In addition, to be eligible to receive a Medicaid EHR incentive payment, acute care hospitals must also meet a 10 percent (10%) Medicaid patient volume threshold. There is no Medicaid patient volume requirement for children’s hospitals. The method for estimating Medicaid patient volume will be designated by the State Medicaid Agency and approved by CMS, but CMS provided States with acceptable alternatives for making such estimates in the final rule. Provided the state where the hospital is located is ready and participating in the Medicaid EHR Incentive Program, acute care and children’s hospitals that adopt a certified EHR system and are meaningful users can begin receiving incentive payments in any year from fiscal year (FY) 2011 to FY 2016. 19
  • 22. While the law defines a payment year in terms of a federal fiscal year, a hospital does not have to begin receiving incentive payments in FY 2011. Hospitals can begin receiving payments in any year from FY 2011 to FY 2016; however, the last year a hospital can first receive a Medicaid incentive program payment is 2016. Acute care hospitals may receive EHR Incentive Program payments from both Medicare and Medicaid if eligible for both programs. Medicaid Incentive Payment Calculation States may pay children’s hospitals and acute care hospitals up to 100 percent (100%) of an aggregate EHR hospital incentive amount provided over a minimum of a three-year period and a maximum of a six-year period. The aggregate EHR incentive amount is the total amount the hospital could receive in Medicaid payments over a theoretical four (4) years of the program. It is the product of two factors: 1. The overall EHR amount. 2. The Medicaid Share. The overall EHR amount is based upon the sum over a theoretical four years of payment where the amount for each year is the product of three (3) factors: 1. An Initial Amount 2. The Medicare Share 3. A Transition Factor applicable to each of a theoretical four (4) years. Initial Amount Initial Amount = a base amount of $2,000,000 + a discharge-related amount The Initial Amount is the sum of a base amount and a discharge-related amount. The base amount is $2,000,000, and the discharge-related amount provides an additional $200 for estimated discharges between 1,150 and 23,000 discharges. No payment is made for discharges prior to the 1,150th discharge or for discharges after the 23,000th discharge. For the first payment year, data on hospital discharges from the hospital fiscal year that ends during the federal fiscal year prior to the hospital fiscal year that serves as the first payment year will be used as the basis for determining the discharge-related amount. To determine the discharge-related amount for the three subsequent payment years that are included in determining the overall EHR amount, the number of discharges will be based on the average annual growth rate for the hospital over the most recent three years of available data. Note: If a hospital’s average annual rate of growth is negative over the three-year period, the rate should be applied as such. 20
  • 23. This factor in the formula determines the Medicaid incentive payment to an eligible hospital. For each of the four (4) years of theoretical payment, a different transition factor applies, as demonstrated in Table 1. Note that for the Medicaid Program, an aggregate EHR amount is calculated only once, and this amount is then spread over all years of a hospital’s payments. Therefore, the transition factors in Table 1 are used to calculate the aggregate EHR amount but do not indicate that the hospital’s payment will be calculated anew on a yearly basis. The second step in determining the aggregate EHR amount for a meaningful user of certified EHR technology is to calculate the Medicaid Share. The Medicaid Share is essentially the percentage of a hospital’s inpatient, non-charity care days that are attributable to Medicaid inpatients. Table 1: Transition Factor by Year TRANSITION FACTOR Year 1 1.00 Year 2 0.75 Year 3 0.50 Year 4 0.25 The Medicaid Share The numerator of the Medicaid Share is the sum of: 1. The estimated number of Medicaid inpatient-bed-days 2. The estimated number of Medicaid managed care inpatient-bed-days The denominator of the Medicaid Share is the product of: 1. The estimated total number of inpatient-bed-days for the eligible hospital during that period 2. The estimated total amount of the eligible hospital’s charges during that period, not including any charges that are attributable to charity care divided by the estimated total amount of the hospital’s charges during that period. The hospital’s final payments would be based on the State Health Information Technology plan for incentive payments. Note: The removal of charges attributable to charity care in the formula, in effect, increases the Medicaid Share resulting in higher incentive payments for hospitals that provide a greater proportion of charity care. 21
  • 24. MEDICARE & MEDICAID DUALLY ELIGIBLE HOSPITALS Some hospitals may receive incentive payments from both Medicare and Medicaid if they meet all eligibility criteria. Hospitals that are eligible for EHR incentive payments under both Medicare and Medicaid should select "Both Medicare and Medicaid" during the registration process, even if they plan to apply ONLY for a Medicaid EHR incentive payment by adopting, implementing or upgrading certified EHR technology. Dually-eligible hospitals can then attest through CMS for their Medicare EHR incentive payment at a later date, if they so desire. It is important for a dually- eligible hospital to select "Both Medicare and Medicaid" from the start of registration in order to maintain this option. Hospitals that register only for the Medicaid program (or only the Medicare program) will not be able to manually change their registration (i.e., change to "Both Medicare and Medicaid" or from one program to the other) after a payment is initiated and this may cause significant delays in receiving a Medicare EHR incentive payment. 22
  • 25. E-PRESCRIBING INCENTIVES PROGRAM OVERVIEW Eligible Professionals who participate in the eRx Incentive Program by reporting on their adoption and use of a qualified eRx system that has the functionalities required by CMS may qualify for an incentive payment. E-prescribing is the transmission of prescription or prescription-related information through electronic media. The Medicare Improvements for Patients and Providers Act of 2008 (known as MIPPA) authorized the Medicare Electronic Prescribing Incentive Program to promote adoption and use of electronic-prescribing systems. With eRx, health care professionals can electronically transmit both new prescriptions and responses to renewal requests to a pharmacy without having to write or fax the prescription. The eRx incentive payment is similar to the Physician Quality Reporting Initiative, or PQRI incentive in that it is based on the Medicare Part B Physician Fee Schedule (PFS) covered professional services furnished by the EPs during a reporting period. To be eligible for the incentive, you must meet the criteria for being a successful electronic prescriber. The criteria used to determine whether an EP is a successful electronic prescriber are established for each program year through rulemaking. Beginning 2012, CMS will apply payment adjustments to EPs who are not successful electronic prescribers under the eRx Incentive Program. To become successful e-prescribers for purposes of avoiding the 2012 eRx payment adjustment, EPs must report the electronic prescribing measure for a required minimum number of unique electronic prescribing events via claims between January 1, 2011 and June 30, 2011 EPs may begin reporting the eRx measure at any time throughout the 2011 program year of January 1-December 31, 2011 to be incentive eligible, but must do so prior to June 30, 2011 to be exempt from the 2012 eRx payment adjustment. 23
  • 26. EPs must have adopted a "qualified" e-prescribing system in order to be able to report the e-prescribing measure. There are two (2) types of systems. 1) a system for eRx only (stand-alone). 2) an EHR system with eRx functionality. Regardless of the type of system used, to be considered "qualified" it must be based on ALL of the following capabilities: • Generating a complete active medication list incorporating electronic data received from applicable pharmacies and pharmacy benefit managers (PBMs) if available. • Selecting medications, printing prescriptions, electronically transmitting prescriptions and conducting all alerts. • Providing information related to lower cost, therapeutically appropriate alternatives (if any). (The availability of an eRx system to receive tiered formulary information, if available, would meet this requirement for 2011) • Providing information on formulary or tiered formulary medications, patient eligibility and authorization requirements received electronically from the patient's drug plan, if available. EPs can begin by reporting e-prescribing data for January 1-December 31, 2011. Beginning in 2012, EPs who are not successful e-prescribers may be subject to a payment adjustment. Section 132 of the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) authorizes CMS to apply this payment adjustment whether or not the EP is planning to participate in the eRx Incentive Program. The payment adjustment in 2012, with regard to all of the EP’s Part B-covered professional services, will result in the EP’s or group practice receiving 99% of the Physician Fee Schedule (PFS) amount that would otherwise apply to such services. In 2013, the EPs will receive 98.5% of their covered Part B-eligible charges if they aren’t a successful e-prescriber. In 2014, the penalty for not being a successful e-prescriber is 2% resulting in EPs receiving 98% of their covered Part B charges. 24
  • 27. For purposes of determining which EPs or group practices are subject to the payment adjustment in 2012, CMS will analyze claims data from January 1, 2011- June 30, 2011 to determine if the EP has submitted at least ten (10) electronic prescriptions during the first six months of calendar year 2011. Group practices reporting as a GPRO I or GPRO II in 2011must report all of their required e-prescribing events in the first six months of 2011 to avoid the payment adjustment in 2012. If an EP or selected group practice wishes to request an exemption to the eRx Incentive Program and the payment adjustment, there are two “hardship codes” that can be reported via claims should one of the following situations apply: • G8642 - The EP practices in a rural area without sufficient high speed internet access and requests a hardship exemption from the application of the payment adjustment under section 1848(a)(5)(A) of the Social Security Act. • G8643 - The eligible professional practices in an area without sufficient available pharmacies for electronic prescribing and requests a hardship exemption from the application of the payment adjustment under section 1848(a)(5)(A) of the Social Security Act Additionally, there will be a G code which can be used by EPs to indicate that they do not have prescribing privileges. Reporting this G code will prevent the EP from being subjected to a payment adjustment in 2012 . 25
  • 28. EPRESCRIPTION – ELIGIBLE PROFESSIONALS Eligible professionals do not need to participate in the Physician Quality Reporting System to participate in the Electronic Prescribing (eRx) Incentive Program. Under the eRx Incentive Program, covered professional services are those paid under the Medicare Physician Fee Schedule (PFS). To the extent that eligible professionals are providing services which are paid under the PFS, those services are eligible for eRx Incentive Program. Eligible and Able to Participate The following professionals are eligible to participate in eRx Incentive Program: Eligible professionals must have prescribing authority in order to participate in this program. 1. Medicare physicians • Doctor of Medicine • Doctor of Osteopathy • Doctor of Podiatric Medicine • Doctor of Optometry • Doctor of Oral Surgery • Doctor of Dental Medicine • Doctor of Chiropractic 2. Practitioners • Physician Assistant • Nurse Practitioner • Clinical Nurse Specialist • Certified Registered Nurse Anesthetist (and Anesthesiologist Assistant) • Certified Nurse Midwife • Clinical Social Worker • Clinical Psychologist • Registered Dietician • Nutrition Professional • Audiologists 3. Therapists • Physical Therapist • Occupational Therapist • Qualified Speech-Language Therapist 26
  • 29. Eligible But Not Able to Participate The following professionals are eligible to participate but are not able to participate for one or more reasons: 1. Professionals paid under or based upon the PFS billing Medicare Carriers/ Medicare Administrative Contractors (MACs) who do not bill directly. 2. Professionals paid under the PFS billing Medicare fiscal intermediaries (FIs) or MACs. The FI/MAC claims processing systems currently cannot accommodate billing at the individual physician or practitioner level: • Critical access hospital (CAH), method II payment, where the physician or practitioner has reassigned his or her benefits to the CAH. In this situation, the CAH bills the regular FI for the professional services provided by the physician or practitioner. • All institutional providers that bill for outpatient therapy provided by physical and occupational therapists and speech language pathologists (for example, hospital, skilled nursing facility Part B, home health agency, comprehensive outpatient rehabilitation facility, or outpatient rehabilitation facility). This does not apply to skilled nursing facilities under Part A. Services payable under fee schedules or methodologies other than the PFS are not included in Physician Quality Reporting (for example, services provided in federally qualified health centers, independent diagnostic testing facilities, independent laboratories, hospitals [including method I critical access hospitals], rural health clinics, ambulance providers, and ambulatory surgery center facilities). 27
  • 30. EPRESCRIBING INCENTIVES PAYMENT DETAILS Beginning 2012, Section 132 of the Medicare Improvements for Patients and Providers Act of 2008 (P.L.110-275) (MIPPA) requires CMS to subject eligible professionals who are not successful electronic prescribers under the eRx Incentive Program to a payment adjustment. This payment adjustment applies to all of the eligible professional's Part B- covered professional services under the Medicare Physician Fee Schedule (MPFS). From 2012 through 2014, the payment adjustment will increase with each new reporting period. Accordingly, for 2012, eligible professionals receiving a payment adjustment will be paid 1.0% less than the MPFS amount for that service. In 2013 and 2014, the payment adjustment increases to 1.5% and 2.0% respectively. Significant Hardship Exception: Eligible professionals may be exempt from the application of the payment adjustment if CMS determines that compliance with the requirement for being a successful electronic prescriber would result in a significant hardship. This hardship exception is subject to annual renewal. 28
  • 31. WHAT IS MEANINGFUL USE (MU)? The Medicare and Medicaid EHR Incentive Programs provide a financial incentive for the "meaningful use" (MU) of certified EHR technology to achieve health and efficiency goals. By putting into action and meaningfully using an EHR system, providers will reap benefits beyond financial incentives–such as reduction in errors, availability of records and data, reminders and alerts, clinical decision support, and e-prescribing/refill automation. The American Recovery and Reinvestment Act (ARRA) specifies three (3) main components of Meaningful Use: 1. The use of a certified EHR in a meaningful manner, such as e-Prescribing. 2. The use of certified EHR technology for electronic exchange of health information to improve quality of health care. 3. The use of certified EHR technology to submit clinical quality and other measures. Simply put, "meaningful use" means providers need to show they are using certified EHR technology in ways that can be measured significantly in quality and in quantity. 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 • Maintaining privacy and security The criteria for meaningful use will be staged in three (3) steps over the course of the next five (5) years. 29
  • 32. Stage 1 (2011 and 2012) sets the baseline for electronic data capture and information sharing. Stage 2 (expected to be implemented in 2013) Stage 3 (expected to be implemented in 2015) and will continue to expand on this baseline and be developed through future rule making. To qualify for incentive payments, meaningful use requirements must be met in the following ways: Medicare EHR Incentive Program—Eligible professionals, eligible hospitals, and critical access hospitals (CAHs) must successfully demonstrate meaningful use of certified electronic health record technology every year they participate in the program. Medicaid EHR Incentive Program—Eligible professionals and eligible hospitals may qualify for incentive payments if they adopt, implement, upgrade or demonstrate meaningful use in their first year of participation. They must successfully demonstrate meaningful use for subsequent participation years. Adopted: Acquired and installed certified EHR technology. (For example, can show evidence of installation.) Implemented: Began using certified EHR technology. (For example, provide staff training or data entry of patient demographic information into EHR.) Upgraded: Expanded existing technology to meet certification requirements. (For example, upgrade to certified EHR technology or add new functionality to meet the definition of certified EHR technology.) What are the requirements for Stage 1 of Meaningful Use (2011 and 2012)? Meaningful use includes both a core set and a menu set of objectives that are specific to eligible professionals or eligible hospitals and CAHs. • For eligible professionals, there are a total of 25 meaningful use objectives. To qualify for an incentive payment, 20 of these 25 objectives must be met. -There are 15 required core objectives. -The remaining 5 objectives may be chosen from the list of 10 menu set objectives. 30
  • 33. • For eligible hospitals and CAHs, there are a total of 24 meaningful use objectives. To qualify for an incentive payment, 19 of these 24 objectives must be met. -There are 14 required core objectives. -The remaining 5 objectives may be chosen from the list of 10 menu set objectives. How do I meet the Requirements? To qualify for incentive payments, meaningful use requirements must be met in the following ways: Medicare EHR Incentive Program—Eligible professionals, eligible hospitals and critical access hospitals (CAHs) must successfully demonstrate meaningful use of certified electronic health record technology every year they participate in the program. Medicaid EHR Incentive Program—Eligible professionals and eligible hospitals may qualify for incentive payments if they adopt, implement, upgrade or demonstrate meaningful use in their first year of participation. They must successfully demonstrate meaningful use for subsequent participation years. Adopted: Acquired and installed certified EHR technology. (For example, can show evidence of installation.) Implemented: Began using certified EHR technology. (For example, provide staff training or data entry of patient demographic information into EHR.) Upgraded: Expanded existing technology to meet certification requirements. (For example, upgrade to certified EHR technology or add new functionality to meet the definition of certified EHR technology.) 31
  • 34. BASIC OVERVIEW OF STAGE 1 MEANINGFUL USE • Reporting period is 90 days for first year and one (1) year subsequently • 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 *SCG assists with the registration and Attestation Processes – see related white paper 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) NOTE: Some MU objectives are 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 five (5) deferred measures. In these cases, the eligible professional would be excluded from having to meet that measure. IE: Dentists who do not perform immunizations; Chiropractors do not e-Prescribe There are two types of percentage-based measures for denominator: 1. All patients seen during EHR reporting period 2. Patients or actions taken for patients who’s records are kept in the certified EHR technology 32
  • 35. ELIGIBLE PROFESSIONALS 15 CORE OBJECTIVES 1. Computerized physician order entry (CPOE) 2. E-Prescribing (eRx) 3. Report ambulatory clinical quality measures to CMS/States 4. Implement one clinical decision support rule 5. Provide patients with an electronic copy of their health information, upon request 6. Provide clinical summaries for patients for each office visit 7. Drug-drug and drug-allergy interaction checks 8. Record demographics 9. Maintain an up-to-date problem list of current and active diagnoses 10. Maintain active medication list 11. Maintain active medication allergy list 12. Record and chart changes in vital signs 13. Record smoking status for patients 13 years or older 14. Capability to exchange key clinical information among providers of care and patient-authorized entities electronically 15. Protect electronic health information ELIGIBLE PROFESSIONALS 10 MENU OBJECTIVES EPs must complete 5 of 10, listed below 1. Drug-formulary checks 2. Incorporate clinical lab test results as structured data 3. Generate lists of patients by specific conditions 4. Send reminders to patients per patient preference for preventive/follow up care 5. Provide patients with timely electronic access to their health information 6. Use certified EHR technology to identify patient- specific education resources and provide to patient, if appropriate 7. Medication reconciliation 8. Summary of care record for each transition of care/referrals 9. Capability to submit electronic data to immunization registries/systems* 10.Capability to provide electronic syndromic surveillance data to public health agencies* 33
  • 36. ELIGIBLE PROFESSIONALS & MEANINGFUL USE 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 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 34
  • 37. WHAT ARE CLINICAL QUALITY MEASURES? Quality health care is a high priority for the President, the Department of Health and Human Services (HHS) and the Centers for Medicare & Medicaid Services (CMS). CMS implements quality initiatives to assure quality health care for Medicare Beneficiaries through accountability and public disclosure. CMS uses quality measures in its various quality initiatives that include quality improvement, pay for reporting, and public reporting. WHAT ARE QUALITY MEASURES? Quality measures are tools that help us measure or quantify healthcare processes, outcomes, patient perceptions, and organizational structure and/or systems that are associated with the ability to provide high-quality health care and/or that relate to one or more quality goals for health care. These goals include: effective, safe, efficient, patient-centered, equitable and timely care. To demonstrate meaningful use successfully, eligible professionals, eligible hospitals and CAHs are required also to report clinical quality measures specific to eligible professionals or eligible hospitals and CAHs. Eligible professionals must report on six (6) total clinical quality measures: Three (3) required core measures (substituting alternate core measures where necessary) and three (3) additional measures (selected from a set of 38 clinical quality measures). Eligible hospitals and CAHs must report on all 15 of their clinical quality measures. 35
  • 38. ELIGIBLE PROFESSIONALS REQUIREMENTS FOR CLINICAL QUALITY 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. ELIGIBLE PROFESSIONALS REQUIREMENTS FOR CLINICAL QUALITY MEASURES REPORTING EHR Incentive Program Electronic Specifications Introduction: In order to report quality measures from an EHR, electronic specifications must be developed that include the data elements, logic and definitions for that measure in a format that can be captured or stored in the EHR so that the data can be sent or shared electronically with other entities in a structured, standardized format and unaltered. These electronic specifications are derived from certified EHRs. As part of the criteria for satisfying meaningful use, clinical quality measures results (numerators, denominators, and exclusions) must be reported to CMS. 36
  • 39. ELIGIBLE PROFESSIONALS REPORTING PERIOD The reporting period for the EHR Incentive program using a certified EHR is any continuous 90 day period during the first payment year. Please note that although the measure specifications assume a full calendar year, you should only calculate the denominator and numerator from the first day of the 90 day reporting period to the last day of the 90 day reporting period. Eligible professionals must report from the table of 44 clinical quality measures which includes, 3 Core, 3 Alternate Core, and 38 additional CQMs. • Core CQMs - EPs must report on 3 required core CQMs, and if the denominator of 1 or more of the required core measures is 0, then EPs are required to report results for up to 3 alternate core measures. • EPs must also select 3 additional CQMs from a set of 38 CQMs (excluding the core/alternate core measures). It is acceptable to have a '0' denominator, provided the EP does not have an applicable population. In sum, EPs must report on six (6) total measures: 3 required core measures (substituting alternate core measures where necessary) and 3 additional measures. A maximum of 9 measures would be reported if the EP needed to attest to the 3 required core, the three alternate core and the 3 additional measures. 37
  • 40. CLINICAL QUALITY MEASURES CORE SET NQF Measure Number & PQRI Clinical Quality Measure Title Implementation Number NQF 0013 Hypertension: Blood Pressure Measurement NQF 0028 Preventive Care & Screening Measure Pair: a) Tobacco Use Assessment, b) Tobacco Cessation Intervention NQF 0421 Adult Weight Screening & Follow-up PQRI 128 ALTERNATE CORE SET NQF Measure Number & PQRI Clinical Quality Measure Title Implementation Number NQF 0024 Weight Assessment & Counseling for Children & Adolescents NQF 0041 Preventive Care & Screening: PQRI 110 Influenza Immunization for Patients 50 Years Old or Older NQF 0038 Childhood Immunization Status 38
  • 41. ADDITIONAL SET CQM Must Complete 3 of 38 1. Diabetes: Hemoglobin A1c Poor Control 2. Diabetes: Low Density Lipoprotein (LDL) Management and Control 3. Diabetes: Blood Pressure Management 4. Heart Failure (HF): Angiotensin-Converting Enzyme (ACE) Inhibitor or Angiotensin Receptor Blocker (ARB) Therapy for Left Ventricular Systolic Dysfunction (LVSD) 5. Coronary Artery Disease (CAD): Beta-Blocker Therapy for CAD Patients with Prior Myocardial Infarction (MI) 6. Pneumonia Vaccination Status for Older Adults 7. Breast Cancer Screening 8. Colorectal Cancer Screening 9. Coronary Artery Disease (CAD): Oral Antiplatelet Therapy Prescribed for Patients with CAD 10. Heart Failure (HF): Beta-Blocker Therapy for Left Ventricular Systolic 11. Dysfunction (LVSD) Anti-depressant medication management: (a) Effective Acute Phase Treatment, (b)Effective Continuation Phase Treatment 12. Primary Open Angle Glaucoma (POAG): Optic Nerve Evaluation 13. Diabetic Retinopathy: Documentation of Presence or Absence of Macular Edema and Level of Severity of Retinopathy 14. Diabetic Retinopathy: Communication with the 15. Physician Managing Ongoing Diabetes Care 16. Asthma Pharmacologic Therapy 17. Asthma Assessment 18. Appropriate Testing for Children with Pharyngitis Oncology Breast Cancer: Hormonal Therapy for Stage IC-IIIC Estrogen Receptor/Progesterone Receptor (ER/PR) Positive Breast Cancer 19. Oncology Colon Cancer: Chemotherapy for Stage III Colon Cancer Patients 20. Prostate Cancer: Avoidance of Overuse of Bone Scan for Staging Low Risk Prostate Cancer Patients 21.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 39
  • 42. 22. Diabetes: Eye Exam 23. Diabetes: Urine Screening 24. Diabetes: Foot Exam 25. Coronary Artery Disease (CAD): Drug Therapy for Lowering LDL- Cholesterol 26. Heart Failure (HF): Warfarin Therapy Patients with Atrial Fibrillation 27. Ischemic Vascular Disease (IVD): Blood Pressure Management 28. Ischemic Vascular Disease (IVD): Use of Aspirin or Another Antithrombotic 29. Initiation and Engagement of Alcohol and Other Drug Dependence Treatment: a) Initiation, b) Engagement 30. Prenatal Care: Screening for Human Immunodeficiency Virus (HIV) 31. Prenatal Care: Anti-D Immune Globulin 32. Controlling High Blood Pressure 33. Cervical Cancer Screening 34. Chlamydia Screening for Women 35. Use of Appropriate Medications for Asthma 36. Low Back Pain: Use of Imaging Studies 37. Ischemic Vascular Disease (IVD): Complete Lipid Panel and LDL Control 38. Diabetes: Hemoglobin A1c Control (<8.0%) • Clinical Quality Measures align with Physicians Clinical Quality reporting (PQRI) • Alignment between 4 HITECH CQM and the CHIPRA initial core set that providers report to States 40
  • 43. 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 41
  • 44. PROGRAM TIMELINE January 2011 –Registration for the EHR Incentive Programs begins January 2011 –For Medicaid providers. States may launch their programs if they choose April 2011 –Attestation for the Medicare EHR Incentive Program begins May 2011 –Medicare EHR incentive payments begin February 29, 2012 –Last day for EPs to register and attest to receive an incentive payment for CY 2011 2015–Medicare payment adjustments begin for EPs and eligible hospitals that are not meaningful users of EHR technology 2016–Last year to receive a Medicare EHR incentive payment; Last year to initiate participation in Medicaid EHR Incentive Program 2021–Last year to receive Medicaid EHR incentive payment **for details on how SCG assists with the registration & MU process, see our “procedure for assistance” white paper. 42
  • 45. ACRONYMS ACA –Patient Protection and Affordable Care Act A/I/U –Adopt, implement, or upgrade CAH –Critical Access Hospital CCN –CMS Certification Number CHIPRA –Children's Health Insurance Program Reauthorization Act of 2009 CMS –Centers for Medicare & Medicaid Services CNM –Certified Nurse Midwife CPOE –Computerized Physician Order Entry CQM –Clinical Quality Measures CY –Calendar Year EHR –Electronic Health Record EP –Eligible Professional eRx–E-Prescribing FFS –Fee-for-service FQHC –Federally Qualified Health Center FFY –Federal Fiscal Year HHS –U.S. Department of Health and Human Services HIT –Health Information Technology HITECH –Health Information Technology for Economic and Clinical Health Act HITPC –Health Information Technology Policy Committee HPSA –Health Professional Shortage Area MA –Medicare Advantage MCMP –Medicare Care Management Performance Demonstration MU –Meaningful Use NCVHS –National Committee on Vital and Health Statistics NP –Nurse Practitioner NPI –National Provider Identifier NPRM –Notice of Proposed Rulemaking OMB –Office of Management and Budget ONC –Office of the National Coordinator of Health Information Technology ATCB –Authorized Testing and Certification Body CCHIT –Certification Commission for Health Information Technology EMR –Electronic Medical Records 43
  • 46. HIPAA –Health Insurance Portability and Accountability Act of 1996 PA –Physician Assistant PECOS –Provider Enrollment, Chain, and Ownership System PPS –Prospective Payment System (Part A) PQRI –Medicare Physician Quality Reporting Initiative ARRA –American Reinvestment & Recovery Act of 2009 RHC –Rural Health Clinic RHQDAPU –Reporting Hospital Quality Data for Annual Payment Update TIN –Taxpayer Identification Number 44
  • 47. Questions or Comments? 1-888-803-9431 1-704-405-3085 Email: help@mysuccor.com www.mysuccor.com