meaningful use eligible professional - munson healthcare use presentation... · •eps may receive...
TRANSCRIPT
Meaningful Use – Eligible
Professional
Physician Office Breakfast
April 13, 2011
Briggs Pille, HIMformatics
Joe Cook, DO, Munson Family Practice
Randi Terry, IS Director and Meaningful Use Coordinator for MHC
Agenda
• Brief Meaningful Use Update and General Review - Briggs Pille
• ePrescribing and Meaningful Use – Joseph Cook, DO
• Medicaid Eligibility (how do you qualify, what insurance is listed under Medicaid, when will Michigan start paying) – Randi Terry
• Registration and Certification - Dr. Cook and Randi Terry
• Security Risk Analysis - Dr. Cook and Randi Terry
• Interconnectivity and Munson‟s role Briggs Pille and Randi Terry
• If you have an EMR, how do you look (a look at 4 Munson Hosted practices) – Briggs Pille
• Quality Measures – Briggs Pille
• Clinical Rules – Briggs Pille and Crystal Larson
• Portal requirement – Briggs Pille – there is a notion out there that Portals are REQUIRED (you need to address this and what the regulations actually say).
• MCEITA Update - Randi Terry, Lori Kissau, Kelly Bator
• Stage 2 and 3 – Briggs Pille
Brief Meaningful Use Update
and General Review
Briggs Pille
Intent of the HITECH program
1. Improve quality, safety, efficiency, and reduce health
disparities
2. Engage patients and families
3. Improve care coordination
4. Ensure adequate privacy and security protections for
personal health information
5. Improve population and public health
4 Oh yeah, reduce the cost of our healthcare system
The program emphasizes the meaningful use of an EHR to…
Medicare Incentives for EPs
• Maximum incentive amount is $44,000 over 5 years
• Must begin participation by 2012 to receive
maximum incentive
• Incentives based on 75% of Medicare-Allowed
Charges for that year
• Starting in 2015 – Penalties (reduction in Medicare
reimbursements) for EPs not demonstrating
Meaningful Use
5
Medicaid Incentives for EPs
• EPs may receive payments up to $63,750 over six
years
• Incentive based on up to 85% of state-calculated
global average costs for EHR
• Start no later than 2016
• Achievement of MU not required in first year
• No payments made after 2021
• No Medicaid penalty for failure to demonstrate
Meaningful Use
Maximum Incentives - EP
7
Incentive Program Progress
• Over 60,000 Providers have enrolled with ONC REC
(Regional Extension Centers - MCEITA in Michigan)
programs nationwide
• Over 45,000 Providers have requested Registration help
from RECs (It‟s not simple)
• Over 21,000 Providers have Registered for EHR incentive
programs
• MU Attestation capability will be available on April 28th (90
days since the program began on 1/1/11)
• CMS has paid more than $37.5M in EHR incentives in
Jan/Feb. This was Medicaid AIU
• Only $2.7M has been paid out to EP (Providers)
ePrescribing
and Meaningful Use
Joe Cook, DO
eRx Issues and Questions
1. Medicare eRx incentive/penalty process
vs
2. MU eRx requirement
MU eRX Requirement
• 40% of all Rxs
• Narcotic Rxs excluded
• eRx not e-fax
• Exclusion
• <100 Rx during reporting period
Medicare eRx
Incentive or Penalty
• 2011 Requirement
• G8553
• 25 reporting events
required
• Avoid 2012 Penalty Process
• If >10 claims with correct
G codes
• First 6 months of 2011
2010 2011 2012 2013
Incentive 2% 1% 1%
Penalty - 1% 1% 1.5%
Relationship of eRx Incentives
Medicare MU Medicaid MU
eRx No Yes
CMS clarification: Reporting eRx codes will not
impede receiving MU incentives.
eRx Recommendation
1. Report >25 eRx G codes (8553) in the
first 6 months of 2011
2. Maximize eRx utilization ASAP
Medicaid Eligibility
What qualifies as a Medicaid
encounter?
1. If you qualify for Medicaid, do it now (AIU – Adopting, Implementing and Upgrading)
2. State of Michigan administers this program over the course of 6 years, no money has been issues by the state to date
3. For example: 2011 (AIU), 2012 (Skip), 2013 (Attest for Meaningful Use for 90 days, this starts your year one of the program)
4. $$ differences that you are eligible to receive ($44,000 verses $63,750 maximum)
Randi Terry
Who Qualifies? Eligible Professionals
Medicare Medicaid
•Doctor of medicine or osteopathy
•Doctor of dental surgery or dental medicine
•Doctor of podiatric medicine •Doctor of optometry •Chiropractor
•Physicians •Dentists •Certified nurse midwives •Nurse practitioners •Physicians assistants (in rural
health clinic or FQHC led by a physician assistant)
Requires minimum 30% Medicaid patient mix (20% for Pediatrics)
Medicare EPs may not be hospital-based
What is included in the 30 %
(20% of Pediatrics) patient mix
• Asked MCEITA for further clarification, per MCEITA, the definition of Medicaid is: – For the purpose of this program, Medicaid is defined as any
program administered by the state authorized under Title 19 of the Social Security Act.
– This includes both fee-for-service and managed care. – It does not include any other program or programs authorized
under Title 21 for the Social Security Act, including the Children's Health Insurance Program (CHIP, known as MIChild in Michigan).
• Medicaid Managed Care includes the following plans: – PHP of Mid Michigan Family Care, OMNICARE, Great Lakes
Health Plan, Midwest Health Plan, CareSource MI, HealthPlus Partners, Upper Peninsula Health Plan, Molina Healthcare of MI, Health Plan of MI, Total Health Care, Priority Health Govt Programs, BlueCaid, McLaren Health Plan, Procare Health Plan
Here is a list of the Title 19
programs in Michigan that can
be included in Medicaid portion
of the eligible patient volume
ALMB Additional Low Income Medicare
Beneficiary BMP Beneficiary Monitoring Program CWP Children's Home and Community Based
Services Waiver SED Children's Serious Emotional Disturbance
Waiver Program SED-
DHS Children‟s Serious Emotional Disturbance
Waiver-DHS CMH Community Mental Health ESRD End Stage Renal Disease Plan
First Family Planning Waiver
MA Full Fee-for-Service Medicaid HSW Habilitation Supports Waiver Program MI
Choice Home and Community Based Waiver
Services Hospic
e Hospice
Hospic
e-18 Hospice Medicare Benefit Plan
INCAR-
ESO Incarceration - Emergency Services
INCAR-
MA Incarceration - MA
INCAR-
MA-E Incarceration - MA - Emergency Services
INCAR Incarceration - Other ICF/MR-
DD Intermediate Care Facility for Mental
Retarded - DD MA-MC Medicaid Managed Care MA-
ESO Medical Assistance Emergency Services
Spendo
wn Medical Spend-down
NH Nursing Home PIHP Prepaid Inpatient Health Plan PACE Program All-Inclusive Care for Elderly QDWI Qualified Disabled Working Individual QMB Qualified Medicare Beneficiary - All Inclusive SLMB Special Low Income Medicare Beneficiary SPF State Psychiatric Hospital SA Substance Abuse
Registration and Attestation
• Registration
• Medicaid AIU Submission
• Attestation
Randi Terry and Joe Cook, DO
Registration
• Do it NOW (even the CMS says to register now, there is no downside
other than you can only change from Medicaid to Medicare)
• What is needed to register:
– Active NPI number and NPPES Web User Account
– Tax Identifier Number (SS #)
– Medicare verse Medicaid
– Address, email (doesn‟t have to be yours
– Latest version of Internet Explorer
• Resources available
– https://ehrincentives.cms.gov
– Helpdesk number (MCEITA (888-MICHEHR) and CMS (888-734-
6433)
• April 18th Proxy Rights (you can attest, Meaningful Users Jan, Feb and
March)
Medicaid AIU Submission
• You do not have to be a meaningful use, YET
to submit for AIU
• Must first register at the CMS site
• Sent a letter to log into the state (Michigan
Department of Community Health) with your
NLR Registration Number.
• Must have an approved CHAMPS number
• www.michiganhealthit.org/EHR
• Must have encounter and discharge data
Attestation
• ONCE you have achieved Meaningful Use (with 90
consecutive days in the calendar year), you can
attest
• Must go to CHPL List and obtain an # (Certified HIT
Product List) – http://onc-chpl.force.com/ehrcert.
• Must go to Ambulatory Practice Type, select vendor
name (add to cart), select “Get CMS E.H.R
Certification ID”
• If you use one vendor for all requirements, the
number will be the same for everyone, but if you
certify using different modular certification, your
number will be unique
Security Risk Analysis
Joe Cook, DO
Randi Terry
MU Security
Risk Analysis Requirement
• “Conduct or review a security risk analysis
in accordance with 45 CFR 164.308 (a)
(1) and implement security updates as
necessary and correct identified security
deficiencies as part of it‟s risk
management process”
45 CFR 164.308 (A) (1)
“Implement policies and procedures to
prevent, detect, contain, and correct
security violations.”
45 CFR 164.308 (a) (1)
1. Risk Analysis
2. Risk Management
3. Sanction Policy
4. Information System Activity Review
45 CFR 164.308 (a) (1)
RISK ANALYSIS
“Conduct an accurate and thorough
assessment of the potential risks and
vulnerabilities to the confidentiality, integrity,
and availability of electronic protected health
information held by the covered entity”.
Risk Analysis
Recommendation and Tools
1. Individual practice due diligence
2. Proprietary tools
3. Examples
– Ambulatory EHR Security Risk Analysis A (sample
copy provided on Munson Website for physicians)
– Ambulatory EHR Security Risk Analysis B (sample
copy provided on Munson Website for physicians)
4. Timing
– During 2011
Interconnectivity and
Munson‟s Role
Briggs Pille
Randi Terry
Interconnectivity
• We are pursuing CEMR (Community
EMR) for hosted EMR‟s (Next Gen and
eCW).
• Non Hosted and other EMR‟s: – Talk to your vendor about requirements
– Munson Healthcare is willing to assist with Stage 1
testing of data exchange. (ie. Munson will be test
recipient.)
– There may be a cost from your vendor related to
the interface
If you have an EMR, how do
you look?
Inside 4 practices we
evaluated
Briggs Pille
Rating Scale
The following rating scale is used in the next two slides
Sample Hosted Practice – Core Requirements
Practic
e
1
Practic
e
2
Practic
e
3
Practice
4
The chart below shows the status of two sample practice for each ambulatory solution.
The first table is for the Core Stage 1 requirements that all EPs must meet to achieve MU.
Sample Hosted Practices – Menu Requirements
Practic
e
1
Practic
e
2
Practic
e
3
Practice
4
The following Menu requirements are considered good targets for most EPs:
• #1 Drug-Drug Formulary Checks
• #3 Structure Lab Results
• #4 Generate Patient Lists by Condition
• #8 Medication Reconciliation on Transfer
• #10 Submission to Immunization Registry
Each EP must select 5 Menu items to complete for Stage 1,
including at least one public health measure (10, 11, or 12).
Clinical Decision Support Rule
Briggs Pille
• Objective: Implement one clinical decision support rule relevant to specialty or high clinical priority along with the ability to track compliance with that rule
• Drug-Drug and Drug-Allergy interactions cannot be used to meet this objective
CDS Rule Example
• A rule should use EMR data to provide an
appropriate notification at an appropriate time
• For Example:
– Medication to be avoided during pregnancy.
– Diabetes A1C test reminder
– Mammogram -- Women 40 and over: yearly
• EP‟s must find a rule appropriate for their practice
• Other examples:
– See your vendor (MCEITA will have examples for NextGen
and eCw after meeting)
– www.informatics-review.com/wiki/index.php/cds
Clinical Decision Support Rule
• The Federal Drug Administration has published guidelines for labeling medications for potential teratogenic effects. These guidelines establish 5 risk categories.
– Category A: Adequate and well controlled studies in pregnant women have not shown an increase in risk of fetal abnormalities.
Examples: Levothyroxine,Potassium Chloride, Folic Acid
– Category B: Animal reproductive studies have failed to show risk and no adequate or well-controlled studies in pregnant women.
Examples: Ampicillin, Insulin, Budesimide, Vancomycin
– Category C: Animal reproductive studies have shown a risk the fetus and no adequate or well-controlled studies in pregnant women. The labeling does include that potential benefit of the drug may outweigh the potential risk.
Examples: Albuterol, Heparin, Miconizole, Digoxin
– Category D: Positive evidence of human fetal risk based on use or studies in humans. Includes a risk/benefit statement for use in serious or life threatening disease.
Examples: Lithium, Diazepam, Vincristine, Imipramine, Doxycycline
– Category X: Positive evidence of animal or human fetal abnormalities. Risk the use of the drug clearly outweighs benefit.
Examples: Ribaviron, Estradiol, Isotretinoin
Clinical Decision Support Rule
Patient overdue for hemoglobin A1c
• if the patient
– has diabetes on their problem list,
– is <100 years old,
– is not terminally ill,
– does not have a flag indicating that the HbA1c is
not clinically indicated,
– has not had a HbA1c in the last 12 months
• Then suggest a HbA1c
• Clinical reminders example:
– Mammogram -- Women 40 and over: yearly
Quality Measures
Have to report, You don‟t have to be “good”
PQRI Measures verses Quality Measures
Specialty Practices
Core/Menu Requirements verses Quality Measures
Briggs Pille
Stage 1 EP Quality Measures
2011-2012
• The HITECH Act required that in selecting clinical quality measures CMS give preference to those endorsed by the National Quality Forum.
• All of the measures selected have current electronic specifications and broad applicability to the range of Medicare-designated specialties and the services provided by Eps
• The 44 clinical quality measures are comprised of three types: – three core measures,
– three alternate core measures,
– and 38 additional measures.
• For the 2011 and 2012 reporting periods, EPs must submit calculated results for a total of six measures: three core measures and three of the 38 additional quality measures
• In instances where the denominator for one or more of the core measures is zero, the provider must report results for up to three of the alternate core measures
No Reporting Exclusions
• CMS does not delineate which measures may or may not apply for particular specialties
• EPs need only report the required clinical quality measures. Value may be zero for the numerator, denominator, or exclusions for any or all of those fields, if these are the results as displayed by the certified EHR technology
• For reporting in 2011 and 2012, CMS does not require the measures to meet any particular thresholds or, in all cases, to have patients that fall within the denominator of the measure.
• The final rule does not include exemptions. An EP will not be excluded from reporting any core, alternate, or additional clinical quality measures because the measure does not apply to the EP‟s scope of practice or patient population
• EPs are not excluded if zeros are reported in the denominator values. EPs are not penalized in the Stage 1 reporting years as long as they have adopted a certified EHR, it calculates the measures, and the EP submits the required information as defined in the final rule
Stage 1 Core and Alternative Measures
NQF Measure Number &
PQRI Implementation
Number
Clinical Quality Measure Title
NQF 0013 Title: Hypertension: Blood Pressure Measurement
NQF 0028 Title: Preventive Care and Screening Measure Pair:
a. Tobacco Use Assessment
b. Tobacco Cessation Intervention
NQF 0421 PQRI 128 Title: Adult Weight Screening and Follow-up
Alternative Core Measures
NQF 0024 Title: Weight Assessment and Counseling for Children and
Adolescents
NQF 0041 PQRI 100 Title: Preventive Care and Screening: Influenza Immunization
for Patient > 50 Years Old
NAF 0038 Title: Childhood Immunization Status
Detailed specification for each measure can be found at:
http://www.cms.gov/QualityMeasures/03_ElectronicSpecifications.asp#TopOfPage
Portal Requirements
Briggs Pille
Patient Information Related
Stage 1
• None of these requirements specifically require or mandate a patient
portal
• A portal could help an EP of Practice achieve these requirements
Vendor Specifics
• eCW requires eHx Hub for Stage 1
requirements. eHx Hub also includes a
portal
• Next Gen indicates that their “preferred”
solution is the Patient Portal
• Check with your ambulatory EMR
vendor for their requirements
Stage 2 and Stage 3
Briggs Pille
Stage 2 Meaningful Use
• Stage 2 Meaningful Use Requirements Hospitals and EPs
that qualify for meaningful use in 2011 under Stage 1 will
need to meet Stage 2 requirements in 2013 in order to
receive an incentive payment.
• Hospitals and EPs whose first payment year is 2012 will need
to meet Stage 2 criteria in 2014.
• All hospitals and EPs will need to possess an EHR in 2013
that is certified against the certification criteria adopted for
Stage 2 regardless of the year they first enter the Medicare or
Medicaid EHR incentive programs.
Goals by Stages
Key Dates for Stage 2
• Q4 2011
– CMS publishes NPRM on Stage 2 Criteria
– ONC publishes Interim Final Rule on
standards and certification for Stage 2
• Mid-to-late 2012
– Final rules for Stage 2 published
Stage 2 & 3: Major changes from Stage 1
50
Requirements Stage 2 Stage 3
CPOE Increase to 60%
Include med, lab & rad orders
80%
eRX 50% med orders (EP & hospital
discharge)
80%
Clinical Quality
Measures
TBD TBD
Clinical Decision
Support (CDS)
Use CDS Rules on high priority
conditions
Use CDS Rules to improve
performance
Patient lists Generate pt list for multiple
parameters
Use pt lists to manage
high-priority patients
HIE Connect to at least 3 external
providers in primary referral
network or 1 HIE
Connect to 30% of external
providers or 1 HIE
Med Rec 80% 90%
Other All Stage 1 menu items required Problem list, meds, allergy
lists are „up-to-date‟
Stage 2 & 3: Major New Criteria
51
Requirement Hospital EP
Clinical
Documentation
Physician, PA, NP Notes
Electronic MAR
Physician Notes
Patient Portal Electronic „relevant
information‟ about
hospital encounter
Download relevant information
about a clinical encounter
Download data from a longitudinal
record
20% of patient use a web-based
portal (30% in Stage 3)
Use online patient messaging
Continuity of
Care
List of care team
members
Longitudinal care plan for
pts with high-priority
conditions
List of care team members
Longitudinal care plan for pts with
high-priority conditions
Help and Questions
E.H.R. Helpline
MCEITA – Peggy Losey, 517-614-8636
MCEITA General Number – 888-MICHEHR
CMS Website (cms.gov/ehrincentiveprograms)