aaa for mu: roadside assistance for the ehr incentive program

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PAGE 1 KAREO | @GoKareo; #KareoTip AAA for MU: Roadside Assistance for the EHR Incentive Program

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Much has changed in 2014 for Meaningful Use (MU)—and been changed back again, temporarily. Many practices have questions about how to participate effectively. Physicians and practice managers are concerned about putting undo burden on themselves and other staff, tracking and reporting accurately, and avoiding an audit. Find out how to get the incentive, avoid the penalty, and participate in MU through lessons learned from other EHR users.   Meaningful use expert Barbara Drury will shares her AAA advice: · A(dopt): Experiences learned from MU1 and MU2 EHR users · A(ttest): Issues to address during and after yearly attestations · A(udit): Housekeeping and preparation experiences to date · Quality opportunities beyond MU This is your chance to make sure you are doing MU right—from Adopting through Attestation and Audits! Barbara Drury, BA, FHIMSS, is President of Pricare Inc., an independent health information technology consulting firm founded in 1982. She frequently lectures and writes about the impact of office-based computer systems and electronic medical record systems for entities such as medical societies, healthcare organizations, and others. Ms. Drury served as an appointee to the ONC's Technical Expert Panel on Unintended Consequences of HIT Adoption. She has achieved Fellow Status with the Healthcare Information and Management Systems Society (HIMSS) and has served on the HIMSS Public Policy Committee and the Davies Ambulatory Award Committee. Ms. Drury is also a frequent speaker at the HIMSS Annual Conference and is the recipient of the December 2004 and the April 2009 Spirit of HIMSS award.

TRANSCRIPT

Page 1: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 1 KAREO | @GoKareo; #KareoTip

AAA for MU:Roadside Assistance for the EHR Incentive Program

Page 2: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 2 KAREO | @GoKareo; #KareoTip

Our Schedule for Today…

1 Introduction & Welcome Barbara

2 AAA for MU: Roadside Assistance for the EHR Incentive Program

3 Discover Kareo’s Role

4 Answer Questions

Page 3: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 3 KAREO | @GoKareo; #KareoTip

Your Hosts Today…

Barbara Drury,BA, FHIMSS, & President, Pricare, Inc.

Lea ChathamContent Marketing Manager, Kareo

Page 4: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 4 KAREO | @GoKareo; #KareoTip

Participate via Social

Facebook.com/GoKareo

Twitter.com/GoKareo

http://kareo.ly/kareogroup

We’ll be live tweeting during today’s webinar!

How to participate:

1. Follow @GoKareo on Twitter

2. Follow @LeaChatham on Twitter

3. Search for #KareoTip

4. Join the conversation using #KareoTip

5. Join Building Best Practices group on LinkedIn

Page 5: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 5 KAREO | @GoKareo; #KareoTip

Barbara Drury, BA, FHIMSS

Health information technology consultant

Speaks and writes on office-based computer systems for groups like HIMSS, ABA, MGMA, PAHCOM & AHIMA

Appointee to the ONC’s Technical Expert Panel on Unintended Consequences of HIT adoption

Fellow of the Healthcare Information and Management Systems Society

EHR Risk Manager for The Doctors Company and COPIC Insurance Co.

Barbara Drury, BA, FHIMSSPresident, Pricare, [email protected]

Page 6: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 6 KAREO | @GoKareo; #KareoTip

Our Schedule for Today…

1 Introduction & Welcome Barbara

2 AAA for MU: Roadside Assistance for the EHR Incentive Program

3 Discover Kareo’s Role

4 Answer Questions

Page 7: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 7 KAREO | @GoKareo; #KareoTip

AAA for MU!

Acute Anxiety Attack?Advanced Amphibious Assault?Amateur Astronomers Association?85 other definitions for “AAA”, but today:

–Adopt

–Attest

–Audit

Page 8: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 8 KAREO | @GoKareo; #KareoTip

Agenda:

Review of key definitions and concepts of the EHR Incentive Program

Adopt: Experiences learned from MU1 and MU2 EHR users

Attest: Issues to address during and after yearly attestations

Audit: Experiences to dateQuality opportunities beyond MU

Page 9: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 9 KAREO | @GoKareo; #KareoTip

Who May Earn the Incentive?

EP = eligible professional (maximum was MCR=$44k, MCD = $63,750) Individual physicians, not practices Doctors, (mid-levels only for MCD and

rural)

OFFICE encounters only, with Max of one per day per patient per EP May include or exclude “others on behalf

of EP”

Page 10: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 10 KAREO | @GoKareo; #KareoTip

Ready or not, here’s a quick dip

in the MU alphabet soup!

Page 11: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 11 KAREO | @GoKareo; #KareoTip

Incentive Program Lingo for EPs

CALENDAR Year: Jan 1 thru Dec 31.STAGE: MU1, MU2, MU3Stage YEAR: Yr1, Yr2

A Yr3-only applies to early adopters each stage

REPORTING Period: “any 90 days”, Calendar Quarter, 365 days.

PROGRAM Year: MCR 1 to 6. MCD 1 to 10.Change incentive program once—from MCR to

MCD or MCD to MCR, next ‘new’ year can’t be Yr1

Page 12: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 12 KAREO | @GoKareo; #KareoTip

Meaningful Use Lingo, part 1

MEASURE: a calculation, or Yes/No or Exclusion.CORE or MENU SET means Core = all measures are required Menu Set = you can pick (with some pre-set

requirements)OBJECTIVE: description of what you need to ‘do’THRESHOLD: minimum % (numerator/denominator) Note that some OBJECTIVES have multiple MEASURES

with different THRESHOLD %s.

Page 13: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 13 KAREO | @GoKareo; #KareoTip

Meaningful Use Lingo, part 2

EXCLUSION: doesn’t apply. Some MEASURES have NO Exclusions. Not the same as “exempt”.

Measure #s changed between 2011, 2013, 2014 so focus on the TITLE of the MEASURE, not #s.

MEANINGFUL USER: Meet all THRESHOLDs required for CORE and MENU OBJECTIVES.

EXEMPT from the EHR Incentive Program is limited to very few specialties.

Page 14: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 14 KAREO | @GoKareo; #KareoTip 14

MU1 at 2014 MU2 at 2014

CPOE CPOE

Drug Interactions Drug InteractionsProblem List Problem List

E-PrescribingE-Prescribing & formulary inquiry

Medication List Medication ListAllergy List Allergy ListDemographics Demographics

Vitals Vitals

Smoking Status Smoking Status

Clinical Decision Support (CDS)

Clinical Decision Support (CDS)

View/Download/ Transmit (VDT)

View/Download/ Transmit (VDT)

Offi ce Visit Summaries

Offi ce Visit Summaries

Security Risk Assessment

Security Risk Assessment

Formularies Formularies

Structured Lab Results

Structured Lab Results

Patient List Patient List

Reminders Reminders

Patient Education Patient Education

INBOUND Medication Reconciliation

INBOUND Medication Reconciliation

OUTBOUND Transitions of Care

OUTBOUND Transitions of Care

Immunization Registry (according to law)

Immunization Registry (except where prohibited by law)

Syndromic Surveillance Reporting (according to law)

Syndromic Surveillance Reporting (except where prohibited by law)

Secure Messaging Secure Messaging

Electronic Notes in EHR

Electronic Notes in EHR

Imaging Results Imaging Results

Family Health HistoryFamily Health History

Cancer RegistryCancer Registry (except where prohibited by law)

Specialty RegistrySpecialty Registry (except where prohibited by law)

MU1 at 2014 MU2 at 2014

CORE

MENU

Add, Delete

or Incorporate

2014 ‘names’, not

original 2011 and

not modified

2013.

Page 15: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 15 KAREO | @GoKareo; #KareoTip 15

MU1 at 2014 MU2 at 2014 Exclusions, for MU1 in 2014 Exclusions, for MU2 in 2014

Medication List Medication List No exclusion See "VDT", "OUTBOUND Transitions of Care"Allergy List Allergy List No exclusion See "VDT", "OUTBOUND Transitions of Care"Demographics Demographics No exclusion No exclusion

Clinical Decision Support (CDS)

Clinical Decision Support (CDS)

No exclusionNo exclusion for 5 rules on 4 CQMs. Excl #2 = less than 100 prescritions, then drug-drug interaction CDS not required.

View/Download/ Transmit (VDT)

View/Download/ Transmit (VDT)

Any EP who does not order or create any of the patient data other than name.

Excl #1 = Any EP who does not order or create any of the patient data other than name, Excl #2 = EP in county less than 50% of households without 3 mbps.

Offi ce Visit Summaries

Offi ce Visit Summaries

Any EP who has no offi ce visits during the reporting period.

Any EP who has no offi ce visits during the reporting period.

Security Risk Assessment

Security Risk Assessment

No exclusion No exclusion

Formularies FormulariesAny EP who writes fewer than 100 prescriptions. Must enter 0

See "e-Prescribing & formulary inquiry"

Structured Lab Results

Structured Lab Results

Any EP who orders no lab tests that have +/- or numeric during period.

Any EP who orders no lab tests that have +/- or numeric during period.

Patient List Patient List No exclusion No exclusion

Reminders Reminders EP has no patients over 65 or under 5 in the EHREP has no offi ce visits in the 24 months before EHR reporting period.

Patient Education Patient Education No exclusionEP has no offi ce visits in the 24 months before EHR reporting period.

INBOUND Medication Reconciliation

INBOUND Medication Reconciliation

EP with no inbound patients during the reporting period

EP with no inbound patients during the reporting period

OUTBOUND Transitions of Care

OUTBOUND Transitions of Care

EP with no transfers out or referrals outEP with transfers out or referrals out less than 100 times during the reporting period.

Immunization Registry (according to law)

Immunization Registry (except where prohibited by law)

EP who administers none or registry not capable.Excl #1 EP who administers none, Excl #2 = registry not capable, Excl #3 = registry is not timely, Excl #4 = enrollment not timely.

Syndromic Surveillance Reporting (according to law)

Syndromic Surveillance Reporting (except where prohibited by law)

EP does not collect reportable data, registry not capable, or prohibited

EP does not collect reportable data, registry not capable, or prohibited

Secure Messaging Secure Messaging New to MU2

Excl #1 = Any EP who does not order or create any of the patient data other than name, Excl #2 = EP in county less than 50% of households without 3 mbps.

Electronic Notes in EHR

Electronic Notes in EHR

New to MU2 Any EP who has no offi ce visits during the reporting period.

Exclusions also changed:

- Dependencies- More specificity- Incorporated as part of another

Partial List displayed

Page 16: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 16 KAREO | @GoKareo; #KareoTip

Your MU “world”

could look like this:

16

EP New MCR• CY 2014• MU1-2013• Yr1• Any 90 days• 1st year

EP Lisa• CY 2013• MU1• Yr3• 365 days• 3rd year

EP Betsy• CY 2013• MU1• Yr1• Any 90 days• 1st year

EP Lisa• CY 2012• MU1• Yr2• 365 days• 2nd year

EP Lisa• CY 2011• MU1• Yr1• Any 90 days• 1st year

EP Lisa• CY 2014• MU2• Yr1• Quarter• 4th year

EP Betsy• CY 2014• MU1-2013• Yr2• Quarter• 2nd year

EP Tom• CY 2013• No MU• 3rd year

EP Tom• CY 2012• No MU• 2nd year

EP Tom• CY 2011• MU1• Yr1• Any 90 days• 1st year

EP Tom• CY 2014• MU1-2013• Yr2• Quarter• 4th year

Page 17: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 17 KAREO | @GoKareo; #KareoTip

Your Vendor’s Certification “world”:Certification criteria = vendor productsMost align with MU measuresEHR Certification also defines data standardsA testing body uses your vendor’s ‘generic’

configuration but not necessarily your EPs setup.

CY 2011 use 2011 Edition to calculate MU1 and up to 44 CQMs

CY 2012 use 2011 Edition to calculate MU1 and up to 44 CQMs

CY 2013 use 2011 Edition with 2013 changes to calculate MU1 and up to 44 CQMs

CY 2014 use 2014 Edition with 2013 changes to calculate MU1, calculate MU2 and up to 64 CQMs

CY 2015 use 2014 Edition with 2013 changes to calculate MU1, calculate MU2 and up to 64 CQMs and optional 2015 certification criteria

Page 18: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 18 KAREO | @GoKareo; #KareoTip

And the “Editions”

are:

18

EP New MCR• CY 2014• MU1• Yr1• Any 90 days• 1st year

EP Lisa• CY 2013• MU1• Yr3• 365 days• 3rd year

EP Betsy• CY 2013• MU1• Yr1• Any 90 days• 1st year

EP Lisa• CY 2012• MU1• Yr2• 365 days• 2nd year

EP Lisa• CY 2011• MU1• Yr1• Any 90 days• 1st year

EP Lisa• CY 2014• MU2• Yr1• Quarter• 4th year

EP Betsy• CY 2014• MU1• Yr2• Quarter• 2nd year

EP Tom• CY 2013• No MU• 3rd year

EP Tom• CY 2012• No MU• 2nd year

EP Tom• CY 2011• MU1• Yr1• Any 90 days• 1st year

EP Tom• CY 2014• MU1• Yr2• Quarter• 4th year

2011 Edition

2011 Edition

2011 Edition

2011 Edition

w/2013

changes

2014 Edition for

MU22014 Editio

n for

2013 MU12014 Editio

n for

2013 MU12014 Editio

n for

2013 MU1

2011 Edition

w/2013

changes

Page 19: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 19 KAREO | @GoKareo; #KareoTip

Would you rather munch a ‘carrot’ or

a ‘stick’?

Page 20: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 20 KAREO | @GoKareo; #KareoTip

Stick (Medicare PFS Penalty)

Has a two-year look back period. 2015 PFS looks at 2013 MU, 2016, PFS looks at 2014 MU, 2017 PFS looks at 2015 MU, and so on

Begins Jan 1, 2015 and if not a MU, goes from 100% PFS in 2014 to 99% in 2015, 98% in 2016, 97% in 2017.

Applies to entire PFS, not just office encounters

Page 21: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 21 KAREO | @GoKareo; #KareoTip

Why Be a Meaningful User in 2014?

(carrot) Earn the incentive for 2014 (carrot) NOW is the last year to start MU to earn any

MCR incentive in 2015 and 2016. (stick) If not before Oct 1st, then 2015 MCR penalty (stick) If not in 2014, then a 2016 MCR penalty Discussions around the water cooler: It’s cheaper to take the penalty I hate leaving that much money on the table My patients want electronic access The hospital will buy us and we’ll be forced to use theirs It depends on …

Page 22: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 22 KAREO | @GoKareo; #KareoTip

From 12/18/13

ONC webinar

May 2014 NPRM changed December 2013’s schedule. Waiting for “Final Rule”, perhaps before Labor Day,

so it’s going to change AGAIN!

Page 23: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 23 KAREO | @GoKareo; #KareoTip

Agenda:

Review of key definitions and concepts of the EHR Incentive Program

Adopt: Experiences learned from MU1 and MU2 EHR users

Attest: Issues to address during and after yearly attestations

Audit: Experiences to dateQuality opportunities beyond MU

Page 24: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 24 KAREO | @GoKareo; #KareoTip

It wasn’t pretty and we made it, but we had some surprises

along the way!

Page 25: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 25 KAREO | @GoKareo; #KareoTip

EHR Setup Impacts Calculations

Rendering or billing—with mid-levels or ancillaryFree text can’t be counted by any EHRsEHR’s ‘right’ boxes aren’t necessarily obvious or

usually done by you Race, ethnicity and language = front desk Pharmacy = front desk or MA/RN staff Transition of care INBOUND = front desk, not MD Medication reconciliation = MA/RN/MD Diagnoses code for claim not same as problem list Prescription, transmitted, not same as medication list

Page 26: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 26 KAREO | @GoKareo; #KareoTip

Detective Work May Be Required

“In the beginning…” run EP’s MU report often Start running MU reports Make corrections to workflow or behaviors Show each EP team (MD+staff) how to run their personal report

“When” the MU report updates varies by product In real time, as soon as ‘saved’, or posted Overnight processing required, or month end process + 10 days MU calculations done outside of your data base, an export,

calculated elsewhere and returned to you as ‘finished’ documents

Not easy to find exactly where the numbers came from Keep after it until you believe the numbers and the ‘next’

person can understand as well

Page 27: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 27 KAREO | @GoKareo; #KareoTip

For some things, the EHR just didn’t fit us, so we figured out a

work-around.

Page 28: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 28 KAREO | @GoKareo; #KareoTip

An EHR for MU Might be a Mismatch

Your expectations, specialty, training, workflow… If you’re thinking about changing EHRs, plan for: Data conversion Records retention MU Reporting Periods, especially if yours is 365 days– Get a good reporting period out of old before changing.

– Timing so ‘next’ reporting period is all new EHR

Page 29: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 29 KAREO | @GoKareo; #KareoTip

Areas of Compromise

CPOE – e-orders out is less common.– Impact: drop-to-paper orders with manual matching of e-results

Interfaces – between medical devices and EHR = two parties– Impact: extra steps to ‘use’ interfaces (spot vitals, ultrasound, EKG,

etc.)

Quality Measures – different programs in different places– Impact: double work for staff (often the MD)

MU CQMs must come from an EHR that has been certified to calculate the CQMs you report on– Impact: Busy-work versus CQMs meaningful to your specialty, i.e.

Dermatology must choose “Functional Status for Hip Replacement” based on CQMs chosen by the dermatologist’s EHR vendor.

Page 30: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 30 KAREO | @GoKareo; #KareoTip

Patient Portal is a Big Deal

CMS changes to Stage 1 in FR for Stage 2 MU1 and MU2: Online access for patients within 4 business days after available to EP

“Access” for patient is key. Does not require any action by the patient, but requires that:–The patient has necessary Information which is defined as

“website address, username, password, instructions for logging in”.

Stage 2 is only stage that requires patient action: View, download, or transmit-to-3rd-party.

Page 31: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 31 KAREO | @GoKareo; #KareoTip

VDT Notes;

Retains the “harmful to the patient” caveatAll contributing EPs who saw this patient during

the reporting period may take credit for: “online access available” / MU1 & MU2 “VTD” / MU2 if patient VTDs ‘any’ contributed by any

EP.

CMS says “charging the patient a fee is not appropriate”

Page 32: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 32 KAREO | @GoKareo; #KareoTip

Roles for Rolling Out the Portal

Impact to staff and workflow Who is going to ‘enroll’ the patient Who is going to remind the patient to ‘enroll’ Who is going to monitor inbound communications Who will teach patients what is appropriate use Who will discharge patients for inappropriate use Who will teach patients responsibility for the privacy of

their data, sharing of passwords, printed copies, etc.

Page 33: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 33 KAREO | @GoKareo; #KareoTip

“It’s the patient’s record” to VDT:

No longer acceptable:– It’s too complicated; the patient won’t get what I said

– I don’t want another provider to read my note

– I’m the only one that knows what I meant

– I don’t want to become an editor of my own words

– I’m the doctor and my recommendation is best

New mantra = “It’s my words for the world to read, so I better read it before I save and sign!”

Page 34: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 34 KAREO | @GoKareo; #KareoTip

We’re on the Same Path, but….

EPs will be at different StagesEPs will be in different years of the MU StageEPs may require different Reporting PeriodsEPs may choose different exclusionsEPs can choose different Menu MeasuresEPs can choose different CQMsAnd, the certified EHR must be able to handle all!And pending the CMS NPRM on Hardship

Exemptions, EPs might be using different Editions

Page 35: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 35 KAREO | @GoKareo; #KareoTip

Agenda:

Review of key definitions and concepts of the EHR Incentive Program

Adopt: Experiences learned from MU1 and MU2 EHR users

Attest: Issues to address during and after yearly attestations

Audit: Experiences to dateQuality opportunities beyond MU

Page 36: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 36 KAREO | @GoKareo; #KareoTip

Attestation (starts with Registration)There is a registration process before you can

attest.Attestation:– End of reporting period

– Workbook (Stage 1 EP Attestation Worksheet , CMS site)

– Must ‘submit’ and CMS must ‘accept’

– On-behalf-of is permitted (review with providers before)

– You enter numerator/denominator and CMS calculates %

– You may change your mind but must re-enter, using a different period with different numbers

– CMS ‘accepts’ and ‘locks for payment’, attestation is done

Page 37: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 37 KAREO | @GoKareo; #KareoTip

CMS Has Guides – worth reading

(75 pages)

Page 38: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 38 KAREO | @GoKareo; #KareoTip

$16000 in Allowable Charges Required before Incentive Paid

Expected Incentive

Reporting Period

Attestation Accepted by CMS

CMS Has Paid Incentive?

Allowable Q1 Charges

Allowable Q2 Charges

Allowable Q3 Charges

Allowable Q4 Charges

Charges at

ATTESTATIONCMS Pay Date (appx)

MU1, Y1 (2011, or 2012, or 2013, OR 2014)

$12,000 = 75% of $16,000 allowable

2014, Jan 5 to Apr 5, any 90 days for 1st year of program

April 15, 2014Not at 7/24/2014

$ 5,000 $ 6,000 tbd tbd $ 11,000 60 days after $16k clears

MU1, Y2 occurring in 2014

$12,000 = 75% of $16,000 allowable

2014, Q3 October 20, 2014Yes on Nov 5,

2014 $ 7,000 $ 7,000 $ 7,000 $ 7,000 $ 21,000

As soon as processed

MU1, Y2 occurring in any year NOT 2014, i.e. 2013

$12,000 = 75% of $16,000 allowable

2013, 365 days

January 18, 2014Yes on Mar 3, 2014

$ 6,000 $ 7,000 $ 6,000 $ 7,000 $ 19,000

Within 60 days of attestation or year end

MU1, Y2 in 2013 $12,000 = 75% of $16,000 allowable

2013, 365 days

May 22, 2014None will be paid

$ 6,000 $ 7,000 $ 6,000 $ 7,000 $ 26,000

No payment will be

made for 2013 year

For Medicare: Show me the money!Incentive is a ‘max’, not a guarantee75% allowable charges, capped max for your year.

Page 39: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 39 KAREO | @GoKareo; #KareoTip

Attestation Basics

Yr1 Attestation starts the MCR “Program Year” clock Meet the measure at “80% or more”, systems round

DOWN, not up 79.6% = 79%, measure of 80% NOT met, no incentive 80.6% = 80%, measure of 80% met, earn incentive

Designate ‘who’ gets the money on EP’s behalf, must decide BEFORE CMS registration. Employed MDs?

Money is taxable, provider will receive a 1099.

Page 40: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 40 KAREO | @GoKareo; #KareoTip

About Medicaid Medicaid is different. First year for Medicaid may be AIU or MU AIU = meet visit%, no MU measure thresholds required MU = a “meaningful user “ for Year 1 only if visit % AND

Measures/thresholds are met

Percents for visit counts round DOWN, not up 29.7% Medicaid visits = 29%, not eligible, 30.7% Medicaid

visits = 30%, yes, eligible for incentive

AIU Incentive (adopt/implement/upgrade) may be documented and requested AFTER the visit count met.

Registration starts with CMS and if MCD, links to state Medicaid attestation tail = 60, 90, 120 days after last day

of reporting period and varies by state

Page 41: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 41 KAREO | @GoKareo; #KareoTip

State Medicaid Requirements Vary

CMS/ONC approved each state’s plan Some variations noted (really!) Provide an excel file with EP’s Medicaid #, patient’s MCD #,

DOS and source of payment or no charge Itemize which visits were billed incident-to MCD patients from multiple states will be validated by the state

you’re claiming, may delay payment Zero pay visits must be isolated for audit Name of patient’s pharmacy Name of person completing Security Risk Assessment

Will likely require custom work by EHR vendor

Page 42: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 42 KAREO | @GoKareo; #KareoTip

Did you know… For Medicare Incentive Program

Carrot is earning the incentive in 2014, either Q1, Q2, Q3, Q4 or if MU1, Yr1, any 90 days

Stick is if not an MU in 2013, and not an MU in 2014 before October 1st (Q1, Q2, Q3), then 1% Medicare PFS begins Jan 1, 2015

For Medicaid Incentive Program Carrot is AIU or MU between 2011 and 2021 No Stick for EP from Medicaid if sees no Medicare patients

For EP choosing Medicaid but sees MCD and MCR Medicaid AIU (not MU) carrot in 2014

• Not an MU in 2014 for MCD Program, stick is Medicare 1% penalty in 2015

Medicaid MU (not AIU) carrot in 2014• Considered an MU in 2014, therefore NO Medicare PFS penalty in 2015

Page 43: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 43 KAREO | @GoKareo; #KareoTip

Dotting the “I”s and crossing the “t”s

If certified EHR does the calculations and you use those numbers, CMS will not penalize you for bad data.

If you export to excel to manipulate what the EHR calculated, that is a risk. Keep all exported files and reports.

Check the math. Attestation does % after entry. Don’t be surprised by a miscalculation

EP’s MU Report should be printed, showing all data Product Name/Version Date period Date of report EH or EP name

If your product doesn’t, then add screen prints of the reporting setup screen as the ‘first’ page of the report.

Page 44: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 44 KAREO | @GoKareo; #KareoTip

What if you want to switch? One switch allowed, either way Dr. Lisa, 2014 is her 3rd year of the Incentive Program

2012 MCD, AIU $ 2013 MCD, MU1, Yr1, $ 2014 MCR, MU1, Yr2, $ 2015 MCR, MU2, Yr1, $ 2016 MCR, MU2, Yr2, $ Has until 2016 to earn MCR Incentives

Dr. Tom, 2014 is his 3rd year of the Incentive Program 2012 MCR, MU1, Yr1, $ 2013 MCR, MU1, Yr2, $ 2014 MCD, MU2, Yr1, $ (no AIU money, jumps in 3rd year MCD, $8500) May earn $8500 up to 3 more years between now and 2021.

Page 45: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 45 KAREO | @GoKareo; #KareoTip

Agenda:

Review of key definitions and concepts of the EHR Incentive Program

Adopt: Experiences learned from MU1 and MU2 EHR users

Attest: Issues to address during and after yearly attestations

Audit: Experiences to dateQuality opportunities beyond MU

Page 46: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 46 KAREO | @GoKareo; #KareoTip

Audits Mandated by Regulation

Figliozzi and Company: CMS designated auditor for MCR. States have separate auditors for MCD

Random and targeted (triggered by questionable data) Initial contact will be email letter to the email address in

CMS attestation system Initial review will be remote, of requested documentation

Potential to come on site Potential to see EHR in action, generate reports, alerts, etc.

Any single ‘oops’ of the Core and Menu and CMS will fail the audit, recoup the payment for the audited year.

See CMS “EHR Incentive Program Supporting Documentation for Audits” – 5 page pdf

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Audit “abnormal data” or “red flag”

Audits may be ‘targeted’ but randomPainful audit activity seen: Attesting for period when the EHR was not certified Generate reports with 0’s after attesting with numbers Original on-behalf-of staff now gone, no one knows

where documentation is, no records, fails audit Using billing system to generate data for calculations Achieving 100% of any/many measures

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Security Risk Assessment Big ‘red flag’ during audits, high failure rate No exclusion for MU1 or MU2, conduct or review Conduct is 1st year of Incentive Program for EP Review or update is each subsequent reporting period

Each EP should be provided a copy for review, initial to indicate review EP must review and update or indicate no update required this period. If EPs attest for different periods, the review must be during EP’s period

Produce copy of Security Risk Assessment Recommendations Your response to each recommendation (action plan)

You are responsible for Risk Assessment, not your vendor. Checklists not sufficient, assessment templates an option

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6 year period starts

6 year period starts

Audit Recap in Pictures

EP’s Reporting

Period

Attestation by EP or

on-behalf-of

MC

R P

aym

ent

Post-Payment

Audit Initiated

Pass/Fail, Appeal

MC

R R

eco

up

$$$

EP’s Reporting

Period

Attestation by EP or

on-behalf-of

MC

R P

aym

ent

Pre-Payment

Audit Initiated

MC

R D

enie

s $$

$OR

No

MC

R

Ad

just

men

t

OR

Pass/Fail, Appeal

Page 50: AAA for MU: Roadside Assistance for the EHR Incentive Program

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Internal Audit Process

Audit letter

emailed

Audit letter

received

Requested documents provided

Requested documents reviewed

Onsite review

date set

Figliozzi on site, Further

review

Determination Letter emailed. Fail = demand

Appeal process (option)

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Documentation Details for Audit

Backup copies of paper reports (in paper and pdf) Screen shots of any measure that is a yes/no. Redact PHI. Details on the security risk assessment including written

account of steps taken, not taken and why Indication that the EP getting the $ has read it!

If the CMS/ONC FAQs directed you how to handle a unique situation, keep a copy of the FAQ.

Audits for AIU for MCD (not MU) are different, see state If upgrading, evidence of staff training, vendor invoices, etc. If upgrading, may not have a new ‘contract’ or ‘SLSA’, but may have

an increase in costs that might be an invoice or a revised SLS

Audits began 2013 to audit 2011 EPs, through 2022.

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Tips

Don’t ignore correspondence – Check junk mail, absent staff person’s email.

Six years is a long time: two people should know how to access the Registration/Attestation website and where all the electronic and paper documentation is retained.

Instructions for finding documentation should be stored securely but not invisible.

If asked, could you access the EHR you were using two years ago (or 3, 4, or 5 years ago) and reproduce exactly your numbers for your Reporting Period?

Consider screen shots or audit logs as evidence of yes/no

Page 53: AAA for MU: Roadside Assistance for the EHR Incentive Program

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Agenda:

Review of key definitions and concepts of the EHR Incentive Program

Adopt: Experiences learned from MU1 and MU2 EHR users

Attest: Issues to address during and after yearly attestations

Audit: Experiences to dateQuality opportunities beyond MU

Page 54: AAA for MU: Roadside Assistance for the EHR Incentive Program

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Beyond Bean Counting: Workflow

Workflow you discussed pre-implementation Workflow you had in place at go-live Workflow you had in place before interfaces such as

Digital Fax machines HIEs with your hospitals and state registries Exchange (point-to-point or HIE) with your labs Transfer of care (HIEs or same-EHR-community)

Workflow you have with equipment changes Nothing in exam rooms Nothing in MAs hands to all MAs carrying mobile devices PCs in all rooms Portable devices wherever you left it last

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Workflow CHANGES, all the time. Make the best use of your talent and your tools at the time.

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Beyond Bean Counting: Physical Changes

Ergonomic Issues Mouse/stylus/fingers/keyboards Counter space/height Lab space/height for MAs/RNs, etc. Visual challenges for user, patient Physical challenges (carpal tunnel, Parkinsons, etc.)

Equipment locations – label printers, fax machines, prescription paper, prescription printers, digital equipment, counter space

Job descriptions: software will change who and where some tasks are completed.

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Beyond Bean Counting:Documentation Quality Opportunities

Needs a champion Many encounters stand alone, but the story over time can

highlight bad habits, poor readability, missing info. Patients, under Meaningful Use, are permitted to read

every note and will be able to VDT your note. What is displayed on your screen is often different than

the printed or download version. Printed documentation is easiest for this peer review task. Peer review is not discoverable, so be clear and frank.

(Check your state’s definitions)

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Read a good non-fiction book lately?

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Peer Review Examples

“Same Procedure” Stories: Patients with a 58100 biopsy belonging to each provider

“Same Disease” Stories: Patients, all with a diagnosis of hypertension seen by each provider

Abbreviations to ‘anonymize’ the records MD = any provider, MD, NP, CMW, etc. No provider name,

only MD1, MD2, MD3, MD4 MA = any clinical staff, MA, RN Visit = any documented ‘event’ – chart note, result,

message, etc. No PHI, only patient A, B, C or D

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The Process

Reviewers: providers, office, clinical and billing managers At your leisure, read each Patient/MD story When all have reviewed the Patient/MD stories, discuss:

Quality for billing Readability Best template Should templates be edited Workflow or policies need to be changed

Schedule another peer review discussion in 6 months Consider a different disease or procedure for review Did the discussions during the first peer review become habit? Workflow or policies need to be changed, again.

Most importantly, does the story reflect facts?

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Ever surprised how much (or how little) water

comes out of a garden hose?

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Another Review Using “Electronic” Views What does a ‘screen’ version in the EHR look like? What does this look like when viewed on the portal? You’ll need the cooperation of a portal-enabled patient

What does this look like when received by another EP

You’ll need the cooperation of outside physicians You may send this through an HIE or through DIRECT You might send this to hospital admissions or L&D

Changes needed? Accurate, complete, readable?

Page 63: AAA for MU: Roadside Assistance for the EHR Incentive Program

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Roadside Assistance for MU!Acute Anxiety Attack? Yes, to Anxiety!Advanced Amphibious Assault? Yes, some days

feel like an assault! Amateur Astronomers Association? Yes, there are

definitely “way-off” stars involved.You’ll be on your way to:

–Adopt

–Attest

–Audit

We’re all reading the MU

“user manual” as we go…

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Our Schedule for Today…

1 Introduction & Welcome Barbara

2 AAA for MU: Roadside Assistance for the EHR Incentive Program

3 Discover Kareo’s Role

4 Answer Questions

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Discover Kareo’s Role

Cloud-basedInsurance & Patient BillingScheduling & Practice ManagementElectronic Health RecordsMedical Billing ServicesEducation, Training, & SupportRanked #1 by Black Book 2 Years

25,000 Providers Nationwide

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Discover Kareo’s Role

• Kareo EHR• 2014 Edition

certified

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Discover Kareo’s Role

• Kareo EHR• 2014 Edition

certified• MU Dashboard

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Discover Kareo’s Role

• Kareo EHR• 2014 Edition

certified• MU Dashboard• Support &

Education• MU Expert Service

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Kareo Marketplace

• Kareo Partners• Certified Specialty

EHR partners

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Discover Kareo’s Role

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Our Schedule for Today…

1 Introduction & Welcome Barbara

2 AAA for MU: Roadside Assistance for the EHR Incentive Program

3 Discover Kareo’s Role

4 Answer Questions

Page 72: AAA for MU: Roadside Assistance for the EHR Incentive Program

PAGE 72 KAREO | @GoKareo; #KareoTip