aaa for mu: roadside assistance for the ehr incentive program
DESCRIPTION
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 KAREO | @GoKareo; #KareoTip
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 KAREO | @GoKareo; #KareoTip
Your Hosts Today…
Barbara Drury,BA, FHIMSS, & President, Pricare, Inc.
Lea ChathamContent Marketing Manager, Kareo
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 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 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 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 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 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 KAREO | @GoKareo; #KareoTip
Ready or not, here’s a quick dip
in the MU alphabet soup!
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 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 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 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 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 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 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 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 KAREO | @GoKareo; #KareoTip
Would you rather munch a ‘carrot’ or
a ‘stick’?
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 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 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 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 KAREO | @GoKareo; #KareoTip
It wasn’t pretty and we made it, but we had some surprises
along the way!
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 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 KAREO | @GoKareo; #KareoTip
For some things, the EHR just didn’t fit us, so we figured out a
work-around.
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 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 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 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 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 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 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 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 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 KAREO | @GoKareo; #KareoTip
CMS Has Guides – worth reading
(75 pages)
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 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 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 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 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 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 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 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 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
PAGE 47 KAREO | @GoKareo; #KareoTip
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
PAGE 48 KAREO | @GoKareo; #KareoTip
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
PAGE 49 KAREO | @GoKareo; #KareoTip
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 KAREO | @GoKareo; #KareoTip
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)
PAGE 51 KAREO | @GoKareo; #KareoTip
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.
PAGE 52 KAREO | @GoKareo; #KareoTip
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 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 54 KAREO | @GoKareo; #KareoTip
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
PAGE 55 KAREO | @GoKareo; #KareoTip
Workflow CHANGES, all the time. Make the best use of your talent and your tools at the time.
PAGE 56 KAREO | @GoKareo; #KareoTip
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.
PAGE 57 KAREO | @GoKareo; #KareoTip
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)
PAGE 58 KAREO | @GoKareo; #KareoTip
Read a good non-fiction book lately?
PAGE 59 KAREO | @GoKareo; #KareoTip
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
PAGE 60 KAREO | @GoKareo; #KareoTip
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?
PAGE 61 KAREO | @GoKareo; #KareoTip
Ever surprised how much (or how little) water
comes out of a garden hose?
PAGE 62 KAREO | @GoKareo; #KareoTip
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 KAREO | @GoKareo; #KareoTip
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…
PAGE 64 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 65 KAREO | @GoKareo; #KareoTip
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
PAGE 66 KAREO | @GoKareo; #KareoTip
Discover Kareo’s Role
• Kareo EHR• 2014 Edition
certified
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Discover Kareo’s Role
• Kareo EHR• 2014 Edition
certified• MU Dashboard
PAGE 68 KAREO | @GoKareo; #KareoTip
Discover Kareo’s Role
• Kareo EHR• 2014 Edition
certified• MU Dashboard• Support &
Education• MU Expert Service
PAGE 69 KAREO | @GoKareo; #KareoTip
Kareo Marketplace
• Kareo Partners• Certified Specialty
EHR partners
PAGE 70 KAREO | @GoKareo; #KareoTip
Discover Kareo’s Role
PAGE 71 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 72 KAREO | @GoKareo; #KareoTip