Transcript Leadership Briefing Outline - Health and Human Services

Medicaid and CHIP
Health Information Exchange (HIE)
Advisory Committee
Meeting
August 2, 2010
Agenda
10:00 - 10:15
Welcome and Introductions
Approval of the Minutes
10:15 - 10:30
10:30 - 11:30
Background Briefing Items
• Update of Medicaid Health Information Technology Initiatives
• Follow-up from Previous Advisory Committee Meeting
• Recent Federal Regulatory Activity
Statewide Health Information Exchange Plan
11:30 - 12:15
Lunch
12:15 - 2:30
State Medicaid Health Information Technology Plan
• Overview
• As Is and To Be Landscape
• Administering the Electronic Health Record (EHR) Incentive
Program
• Roadmap to Meaningful Use
• Provider Outreach and Education
2:30 - 3:00
Public Comment and Meeting Wrap-Up
2
Update on Medicaid
Health IT Initiatives
• e-Prescribing and Health Information Exchange (HIE) Pilot
• Transfer to new pharmacy claims administrator still in
transition, delaying the implementation of e-prescribing and the
HIE pilot’s exchange of medication history.
• Controlled substances can now be electronically prescribed.
• Medicaid Eligibility and Health Information Services (MEHIS)
• Contract sent to the Centers for Medicare & Medicaid
Services (CMS) last week for approval.
• Anticipate contract to be executed by October.
3
Follow-up from June’s HIE
Advisory Committee
• Consent option decision still pending
• Briefing with the Executive Commission scheduled for August 9
• Standard for medication history in e-prescribing is one year
• Sensitive information and implications for Medicaid HIE
4
Medicaid HIE
Privacy and Security Workgroup
Presenter
LaDair Wright
Team Lead for Privacy and Security Workgroup
Medicaid and CHIP Division
Sensitive Information and
Implications for Medicaid HIE
Substance abuse treatment information is confidential, except that it
may be made available to a health information exchange
organization if:
• A qualified service organization agreement exists between the
HIE organization and a Part 2 program (federally-assisted
program providing alcohol or drug abuse diagnosis, treatment or
referral); and
• The patient signs a Part 2-compliant consent form.
6
Sensitive Information and
Implications for Medicaid HIE
HIV/AIDS test results are confidential, except that they may be
released to:
• State, local and federal health authorities.
• Physicians, nurses or other health care personnel ordering the
tests or who have a need to know in order to provide for their
protection and for the patient’s health and welfare.
• Patients tested or persons legally authorized to consent to the test
on the patients’ behalf.
• Spouses of persons who test positive for HIV or AIDS.
• Courts that have directed testing of persons indicted for sexual
assault, or have granted a request by the victim.
• First responders or correctional/juvenile probation staff exposed to
HIV infection.
• County or district courts to comply with rules relating to control and
treatment of communicable diseases and health conditions.
7
Sensitive Information and
Implications for Medicaid HIE
Psychotherapy notes are confidential except that they may be
made available with authorization that mentions only psychotherapy
notes. Authorization is not required for:
• Use by the creator of notes for treatment.
• Use by a covered entity for its own training programs or to defend
itself in a proceeding brought by the subject of the notes.
• Disclosure to the Secretary of Health and Human Services (HHS)
to determine Health Insurance Portability and Accountability
Act (HIPAA) compliance.
• As required by law for oversight of the creator of the notes.
• Disclosure to medical examiner for duties authorized by law.
• Disclosure that is necessary to prevent or lessen a serious threat
to a person or the public.
8
Sensitive Information and
Implications for Medicaid HIE
• Mental Health: Other than psychotherapy notes, communications
between a patient and a mental health professional and the patient’s
medical records are confidential.
• May be disclosed with written consent or to medical staff in the
course of treatment.
• Mental Retardation: The identity, diagnosis, evaluation or treatment
of a person in a program or activity related to mental retardation are
confidential, but may be disclosed with prior written consent, or for:
• Delivery of services to clients.
• Medical personnel during a medical emergency.
• Personnel for audits, program evaluations, or research approved
by the Department of Aging and Disability Services (DADS).
• Personnel authorized to conduct investigations of abuse and
denial of rights.
• Payment for services.
9
Sensitive Information and
Implications for Medicaid HIE
• Genetic information from a genetic test or scientific/medical
genetic characteristic determination is confidential.
• May be disclosed with written consent that includes a specific
description of the information to be disclosed.
• Sexually-transmitted disease information provided to a state
or local public health agency that relates to cases or suspected
cases of diseases or health conditions is confidential.
• Treatment of a minor: Minors have more authority to control
their health information when:*
• State law does not require parental consent for the minor to
obtain health care services, and
• The minor consents to the treatment.
* Should not affect the disclosure of Medicaid information to providers for treatment but
may affect providers’ ability to grant parental access to their child’s medical information
10
Federal Health IT
Regulatory Activity
• Electronic Prescribing of Controlled Substances Interim Final Rule
• Allows the option of e-prescribing controlled substances with the use of two of
the following authenticating factors: password, token, or biometric
– published March 31, 2010
• Medicare and Medicaid EHR Incentive Program Final Rule
• Establishes EHR Incentive Program requirements, including criteria for provider
eligibility, payment methodologies, meaningful use, and program oversight
– published July 13, 2010
• Standards and Certification for EHR Final Rule
• Establishes the capabilities, standards, and implementation specifications for
certified EHR technology to support meaningful use. The Office of the National
Coordinator (ONC) for Health Information Technology is accepting applications
for authorized testing and certification bodies under a temporary certification
program – published July 13, 2010
• Proposed Rule Change to HIPAA
• Expands rights and restricts certain types of disclosures; requires business
associates to be under same rules as the covered entities; sets limitations on
the use health information for marketing and fundraising; and prohibits the sale
of protected health information – posted for comment July 14, 2010
11
Statewide HIE Plan
Presenter:
Stephen Palmer, Director
Office of e-Health Coordination
Health and Human Services Commission
Statewide HIE Plan
Background
• Funding authority from the American Recovery and
Reinvestment Act (ARRA), Section 3013 for planning and
implementation grants to states or qualified state-designated
entities to facilitate and expand HIE.
• Grant opportunity with ONC.
• Coordinated effort between HHSC’s Office of e-Health
Coordination and Texas Health Services Authority.
13
Statewide HIE Plan
Timeline
• February 2009 – ARRA passed.
• August 2009 – Funding Opportunity Announcement released.
• October 2009 – Texas application submitted.
• March 2010 – Texas award of $28.8 million over four years
announcement released.
• August 2, 2010 – Draft Texas HIE plans published for public
comment.
• August 16, 2010 – Comments due.
• September 1, 2010 – Final target submission date for plans.
14
Statewide HIE Plan
Collaborative Planning Process
• Workgroups
• Governance and Finance
• Technical Infrastructure
• Privacy and Security
• EHR Adoption and Consumer Engagement
• Strategic and Operational Plans
• Environmental Scan
• Governance
• Finance
• Business and Technical Operations
• Policy and Legal
15
State Medicaid Health Information
Technology Plan
(SMHP)
Presenters
Kathleen Costello, Yvonne Sanchez, Noel Villarreal,
Anna Sicher, and Julia Alejandre
Medicaid and CHIP Division
EHR Incentive Program and
Meaningful Use
• Final federal rules on the EHR Incentive Program—including
meaningful use (MU) criteria—released July 13, 2010
• An eligible provider and hospital will be considered a meaningful
EHR user if they meet the following three requirements:
1. Demonstrates the use of certified EHR technology in a
meaningful manner.
2. Demonstrates that certified EHR technology is connected in a
manner that provides for the electronic exchange of health
information to improve the quality of health care.
3. Using its certified EHR, submits information on clinical quality
measures and other measures as specified.
• MU criteria to be defined in stages:
• Stage 1 criteria in current proposed rule.
• Stage 2 criteria to be defined in 2013.
• Stage 3 criteria in 2015.
17
MU Comparison
NPRM to Final Rule
NPRM
States could propose requirements
above/beyond MU floor, but not with
additional EHR functionality
Core clinical quality measures (CQM)
and specialty measure groups for EPs
90 CQM total for eligible
professionals (EPs)
Not all CQM had electronic
specifications at time of NPRM
35 CQM total for eligible hospitals with
8 alternate Medicaid CQM
5 CQM overlap with CHIPRA initial
core set
Final Rule
States’ flexibility in Stage 1 MU is
limited - with CMS approval, 4
public health-related objectives may
be moved from menu to the
required core measures
Modified Core CQM and removed
specialty measure groups for EPs
44 CQM total for EPs – must report
total of 6
All final CQM have electronic
specifications at time of final rule
publication
15 CQM total for eligible hospitals
4 CQM overlap with CHIPRA initial
core set
18
MU Comparison
NPRM to Final Rule
NPRM
Final Rule
Meet all MU reporting objectives
Must meet “core set”
Can defer 5 from optional “menu set”
25 measures for EPs
23 measures for eligible hospitals
Measure thresholds range from 10% to
80% of patients or orders (most at
higher range)
25 measures for EPs
24 for eligible hospitals
Measure thresholds range from 10% to
80% of patients or orders (most at
lower to middle range)
Denominators – To calculate the
threshold, some measures required
manual chart review
Denominators – No measures require
manual chart review to calculate
threshold
Administrative transactions (claims and
eligibility) included
Measures for patient-specific education
resources and advanced directives
discussed but not proposed
Administrative transactions removed
Measures for patient-specific education
resources and advanced directives (for
hospitals) included
19
State Medicaid Health
Information Technology Plan
• The SMHP provides a common understanding of the activities that
Medicaid will be engaged in over the next five years relative to
implementing Section 4201 of ARRA.
• CMS is interested in how Medicaid plans to:
• Make provider incentive payments.
• Monitor the payments.
• Coordinate with the Statewide HIE planning initiative and
Regional Extension Centers (RECs) supported by ONC.
• Integrate other Medicaid HIT projects and initiatives.
• CMS expects annual and as-needed updates to keep it informed as
the SMHP evolves.
20
Technology
Adoption Curve
92%
84%
100%
80%
50%
70%
60%
50%
16%
40%
30%
2.5%
20%
Innovators
Enthusiasts
10%
Late Majority
Conservatives
The
Chasm
90%
Laggards
Skeptics
0%
2008
Early
Majority
Pragmatists
Early
Adopters
Visionaries
2011
Consumer seeks technology
and performance
2014
2017
Consumer seeks solutions and convenience
The technology adoption lifecycle and curve is based on research by Joe M. Bohlen, George M. Beal and Everett M. Rogers
The chasm concept was popularized in the book Crossing the Chasm, Geoffrey A. Moore
21
Model for Quality
Improvement
Step 1: Plan
•
Plan the test or observation, including a plan for collecting data.
State the objective of the test.
•
Predict what will happen and why.
•
Plan to test the change. (Who? What? When? Where? What data
need to be collected?)
Step 2: Do
•
Try out the test on a small scale. Carry out the test.
•
Document problems and unexpected observations.
•
Begin analysis of the data.
Step 3: Study
•
Set aside time to analyze the data and study the results.
•
Complete the analysis of the data.
•
Compare the data to your predictions.
•
Summarize and reflect on what was learned.
Step 4: Act
•
Refine the change, based on what was learned from the test.
•
Determine what modifications should be made.
•
Prepare a plan for the next test.
22
SMHP Project Schedule
Medicaid HIT
P-APD
2010
O N D J F M A M J J A S O N D J
Appv original PAPD sched
P-APD-U
SMHP - v.1
SMHP - v.2
I-APD v.1 and COR
EHR Inc Pymt Pgm
2011
F M A M J J A S O N D J
2012
F M A M J J A S O N D
Visioning/EHR Inc Pgm
Related HIT/HIE Planning
Dev/appv
EHR Dev
Testing
Dev Appv
Implementation and Operations
Medicaid-Related HIT Prjcts
I-APD v.2
Other HIT Projects
Stage 1 E-Rx (PCRA)
HIE Pilot (med history)
MEHIS Phase 1/Stage 2 E-Rx
MEHIS Phase 2
MEHIS Phase 3
Imp
Operations
Imp
Operations
Implementation
Phase 1 Operations
Phase 2 Implemenation
Phase 3
23
SMHP Overview
Plan for health care reform enabled by meaningful use of certified EHRs
As Is HIT
Landscape
Current EHR & HIT
use
To Be HIT
Environment
Vision 2014+
Begin with end in
Mind
EHR Incentives
Audit Strategy
HIT Roadmap
Administration of
incentive payment
Program integrity
processes &
controls
Metrics to assess
progress towards
envisioned future
Medicaid Vision for Health Care Reform
1. By 2014, what goals and objectives does Medicaid need to achieve?
2. How will Medicaid address the needs of varying populations?
3. How will Medicaid assess and provide technical assistance for
providers?
4. What governance processes and structures need to be established?
5. What legislative or regulatory changes are needed?
24
As Is Landscape
Texas Medicaid
• Medicaid serves a population of approximately 3.6 million unique
clients per year and an average of 2.7 million in any given month.
• The percentage of Medicaid clients in managed care was 71
percent in 2008.
• Medicaid accounted for 25 percent of the appropriated Texas
budget for the 2006-2007 biennium.
• 29 percent of Medicaid budget spent on children in 2007.
• $21 billion (all funds) spent for Medicaid in federal fiscal year
2007.
• $1.9 billion in total Medicaid payments (all funds) to nursing
homes in federal fiscal year 2007.
• $2.1 billion in total Medicaid payments made to hospitals in
federal fiscal year 2007 (excluding disproportionate share hospital
[DSH] and upper payment limit payments).
25
As Is Landscape
• Conduct an environmental scan and assessment of current
practitioner and hospital EHR capabilities.
• Consider federally qualified health center (FQHC), rural health
clinic (RHC), Veterans Administration and Indian Health Service
clinical facilities with EHR capabilities; describe any Health IT
funding.
• Describe role of Medicaid Management Information Systems
(MMIS) in current Health IT environment and in coordination with
Medicaid Information Technology Architecture (MITA) transition
plans.
26
As Is Landscape
• Assess and describe broadband internet access, including grants.
• Explain Medicaid’s relationship with Statewide HIE planning
initiative and RECs supported by ONC and other programs.
• Describe the interoperability status of the state’s immunization
registry and public health surveillance reporting database(s).
• Describe any activities that will encourage adoption of EHRs;
consider health care service access that crosses state borders.
27
As Is Landscape
• Medicaid is conducting a survey, in coordination with the
statewide HIE and the four Health IT RECs, directed to hospitals
and all providers in the eligible professional category.
• Surveys will be used:
•
To meet program planning requirements.
•
As a benchmark for program evaluations.
• Surveys disseminated in early July 2010 with preliminary results
and analysis in August 2010.
• Medicaid is seeking the support of committee members and
professional associations to encourage completion of the
survey.
28
As Is Landscape
Medicaid Claims Systems
• MMIS is a distributed group of procedures and computer
processing operations and subsystems.
• HHSC contracts with a coalition of vendors headed by Affiliated
Computer Systems State Health Care, working under the name of
the Texas Medicaid & Healthcare Partnership (TMHP) to provide
MMIS services.
• TMHP provides the necessary services to process and adjudicate
Medicaid claims (with the exception of capitated arrangements
between health plans).
29
As Is Landscape
Medicaid Claims Systems
TMHP performs services to support the following claim and non-claim related
areas of MMIS operations:
• Compass 21: Supports processing of Medicaid claims.
• Case Management/Health Education: Supports case management and
health education functions for Primary Care Case Management (PCCM)
members.
• Provider Network Management – Supports provider network management,
credentialing and enrollment for PCCM providers.
• Member Management – Supports member processing for PCCM members
• Claims Submission (TexMedConnect): Provider application that supports
claims submission, eligibility verification and claims status inquiry.
• Claims Management System and Service Authorization System: Long-term
care service authorization and claims processing engine.
• Encounters Datamart: Stores managed care encounter data from
contracted managed care organizations.
30
To Be Landscape
New Capabilities
System
Description
Medicaid Eligibility and
Health Information
Services (MEHIS)
• will replace the current paper Medicaid
identification form with a permanent plastic card
• automate eligibility verification
• provide a claims-based EHR for Medicaid clients
• offer an e-prescribing tool
• establish a foundation for future HIE
• target implementation is March 2011
Medicaid electronic
prescribing (e-Rx)
• designed to get Medicaid formularies and
medication history into e-prescribing programs
• will satisfy the meaningful use objective of
information exchange
HIE Pilot
Medicaid will exchange medication history data
with regional health information exchange
organizations
31
To Be Landscape
HIE Connectivity
• THSA is evaluating
options for
statewide HIE
• MEHIS provides an
infrastructure for
Medicaid HIE
• MEHIS will enable
HHSC to exchange
data with the
statewide HIE
32
To Be Landscape
Medicaid Enterprise Vision
1. Texas HHSC will become a value purchaser of health care quality and
outcomes by supporting and “e-enabling” these capabilities
a) Develop value purchaser capabilities.
b) Utilize clinical decision support capabilities to analyze Medicaid health
care administrative and clinical data from across the state and enterprise
and to meaningful use patient summary information to improve health
care delivery and cost effectiveness.
c) Establish and maintain a comprehensive and robust provider network
capable of providing quality care based on population needs, unique
care conditions, and locus of service needs.
d) Implement effective and efficient primary and integrated care approaches.
e) Ensure the secure and private exchange of health care information
across the Medicaid enterprise consistent with national standards,
including specialty providers.
f) Increase health care coverage through insurance exchanges under
national health reform that effectively enrolls new clients in Medicaid or
other health care coverage and ensures timely access to quality care.
33
To Be Landscape
Provider Level Vision
2. Improve the health and well-being of citizens of Texas through the
widespread adoption and meaningful use of certified EHRs to:
a) Improve quality, safety, efficiency, and reduce health
disparities.
b) Engage patients and families in their health care.
c) Improve care coordination.
d) Ensure privacy and security protection for personal health
information.
e) Improve population and public health.
34
EHR Incentive Program
Overview
• Payment is an incentive for using certified EHRs in a meaningful
way
• Not a reimbursement and not intended to penalize early
adopters.
• First year payment can be received in 2011 through 2016
• Final payment can be received up to 2021
• Eligible professionals must meet certain criteria:
• Eligible provider type.
• Medicaid patient volume thresholds.
• MU of certified EHRs for at least 50 percent of patient
encounters during the reporting period.
35
EHR Incentive Program
Enrollment Process
Provider Registers with CMS at the
National Level Repository (NLR)
Forwarded to HHSC
Providers receive an automated mailing giving web link and
emphasizing importance of enrolling with Medicaid before applying
Provider fills out online application
attesting to all eligibility criteria
Provider fills out
Provider does not fill out
– but registers with NLR
HHSC confirms licensed and unsanctioned
Yes
No – Reject
36
EHR Incentive Program
Payment Process
HHSC reviews attested volume and compares reported
information to Medicaid data sources
Volume
Sufficient
Volume fails validity check
– request additional support
Volume
insufficient
– Reject
Adopt, Implement and Upgrade (AIU) – Year 1 only
Purchase/Upgrade
Verified
No documentation
provided – Request
Does not meet
AIU
– Reject
Meaningful Use (MU) and Clinical Quality Measures (CQM)
– Year 2 and beyond
Attest and submit to
MU/CQM measures
Attest MU but did not
provide CQM
– Request CQM
MU/CQM
not met
– Reject
37
EHR Incentive Program
Payment Process
Verify ongoing payment eligibility – Year 2 and beyond
Verified costs and
other criteria
Insufficient documentation
provided – Request
Does not meet
– Reject
Payment calculated
Provider paid
38
Eligibility: Patient Volume
Provider
Physicians
- Pediatricians
Minimum Medicaid
Patient Volume
Threshold
if the Medicaid EP practices
30%
predominantly in a Federal
20%
OR
Qualified Health Clinic (FQHC)
or Rural Health Clinic (RHC)
Dentists
30%
Nurse Practitioners
30%
— 30% needy individual
Certified Nurse
Midwives
30%
patient volume threshold
Physician Assistants
(PAs) when practicing
at an FQHC/RHC that
is led by a PA
30%
Acute Care Hospitals
10%
Children's Hospitals
No requirement
Not an option for hospitals
39
Eligible Provider
Estimates
Eligible Provider Types
Enrolled Medicaid
Providers
Potentially
Eligible*
1480
310
77
TBD
8
8
32,453
TBD
5,122
3,150
5,431
3,400
186
150
Nurse Practitioners
3,545
TBD
Physician Assistants that leads an FQHC or RHC
TBD
TBD
FQHC/RHC (64 grantees operating multiple sites)
304 sites
n/a
Eligible Hospitals
Acute Care
Critical Access
Children’s
Eligible Professionals
Physicians
Pediatricians
Dentists
Certified Nurse Midwives
* Estimate of eligible providers are based on a preliminary counts of enrolled
Medicaid providers, claims history and eligibility criteria from the NPRM.
40
Proposed Process for
Provider Eligibility
• Goal is to complete application reviews within 90 days.
• As applications come in, the clock starts based on when
documentation is complete.
• Requests for additional information issued within 60 days.
• For eligible professionals, a single application must show sufficient
Medicaid practice volume, EHR costs, and EHR use.
• For hospitals, a single application must show sufficient Medicaid
practice volume, incentive formula, and EHR use.
41
Proposed Process for
Provider Eligibility
• All providers will attest to their number of patient encounters by
payor source with separate tabs in the application for:
• Medicaid fee-for-service.
• Medicaid managed care listed by managed care plan.
• PCCM payments.
• In order to facilitate pre-eligibility verification and post-payment
audits as necessary, will require the “90-day” period for
demonstrating EP Medicaid share to equate to three full calendar
months.
• Encounters will be defined around count of procedures per
performing provider rather than count of submitted claims.
42
Patient Volume
Calculation
• Defined “encounter” for three scenarios:
• Fee-for-service.
• Managed care and medical homes.
• Hospitals.
• Two main options for calculating patient volume:
• Encounters.
• Patient panel.
• State picks from these or proposes new method for approval.
May use approved approach of another state.
43
Entities Promoting the
Adoption of EHRs
• States may designate entities “promoting the adoption.”
• EPs may voluntarily assign their incentive payments to these
entities.
• Promotion would include:
• Enabling and oversight of the business operational and legal
issues involved in the adoption and implementation of EHR
and/or the secure exchange and use of electronic health
information.
• Maintaining the physical and organizational relationship
integral to the adoption of certified EHR technology by EPs.
• Required transparency guidelines for selection.
44
EHR Incentive Program
Payment Processes
• Ensure that there is no duplication of Medicare and Medicaid
incentive payments to EPs.
• Ensure that incentive payments are made for no more than six
years and that no EP or hospital begins receiving payments after
2016.
• Ensure that incentive payments are not paid at amounts higher
than 85 percent of the net average allowable cost of certified EHRs
and do not exceed yearly maximum allowable payment thresholds.
• Ensure timely and accurate payments to EPs and hospitals.
• Ensure that any monies paid inappropriately will be recouped and
federal financial participation (FFP) is repaid.
45
Incentive Payments for
Eligible Professionals
First Calendar Year in which the EP receives an Incentive Payment
Year
CY 2011
CY 2012
CY 2013
CY 2014
CY 2015
CY 2016
2011
2012
$21,250
$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
$8,500
$8,500
$8,500
$8,500
$8,500
$8,500
$8,500
$8,500
$8,500
$8,500
$8,500
$8,500
$8,500
$8,500
2017
2018
2019
2020
2021
TOTAL
$8,500
$63,750
$63,750
Source: Centers for Medicare and Medicaid Services
$63,750
$63,750
$63,750
$63,750
46
Proposed Payment
Process for EPs
• Provide option for EPs practicing in a group to impute the group’s
Medicaid share for their individual application, referencing the
group’s Texas Identification Number (TIN), but under the individual
provider’s National Provider Identifier (NPI).
• Will require EPs to attest that this is the only group TIN that they
are applying under.
• Still requires an individual online application/attestation for each
provider claiming incentives, but can be batched together by
TIN.
• One time per year with annual payment dates staggered monthly.
• For part-time providers, if the attested total billing is less than the
amount of the incentive they are trying to claim, will require
submission of Form 1099 and documentation of the nature of the
provider’s engagement with the group or clinic.
47
Incentive Payments for
Eligible Hospitals
• Medicaid hospital incentive payments based on a formula similar
to Medicare hospital methodology.
• A product of the overall EHR amount multiplied by the Medicaid
share.
• Payment is calculated, then disbursed over three to six years.
• Payments in any one year cannot exceed 50 percent of the total
payment cap and payment in any two years cannot exceed 90
percent of this limit.
• Data to be derived from the hospital cost reports and other
auditable data sources.
• Will propose that hospitals attest regarding their own most recent
fiscal year (which will overlap with the most recent federal fiscal
year).
48
Incentive Payments for
Eligible Hospitals
The basic calculation—performed for each of four projected years:
$2,000,000 + $200/discharge
(for number of discharges between 1,150 to 23,000)
x
transition factor based on the hospital’s current payment year
x
provider’s average annual rate of growth
for the most recent 3 year period
x
Medicaid share
(12 month Medicaid bed days ÷ total bed days x (total charges charity care) ÷ total charges)
49
Proposed Payment
Process for Hospitals
• One time per year with annual payment dates staggered
monthly.
• Payment will be made in the first monthly date after incentive is
approved.
• Medicaid has the flexibility to spread out hospital incentive
payments over as few as three or as many as six years
• Texas proposes to use a five year payout for the incentives
according to the following schedule:
Five Year Payout Schedule for Hospitals
Year 1
Year 2
Year 3
Year 4
Year 5
40%
20%
20%
10%
10%
50
Provider Appeals
Medicaid needs to ensure that appeal processes are established
for and consistent with all criteria, including verification of:
•
Provider eligibility determinations.
•
Incentive payments and amounts.
•
Demonstration of efforts to adopt, implement or upgrade and
meaningful use eligibility.
51
Proposed Process
for Oversight and Auditing
Four stages of review and appeals for eligibility:
1. Attestation.
2. Compare attestation to Medicaid data sources for that provider.
• Additional information (e.g., billing data) needed for
significant discrepancies.
3. If information provided is inconsistent with Medicaid data or
other third party data source, application is rejected and
providers will have the opportunity to file an initial appeal to
TMHP.
• TMHP will have two EHR application adjudication entities,
one to conduct initial eligibility determinations and another to
conduct appeals.
4. If TMHP rejects appeal, the final appeal will be to HHSC’s
Medicaid/CHIP Health IT division.
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Discussion Questions
1. The final rule provides options for counting “encounters” for
patient volume reporting.
What method provides the most flexibility for providers?
2. Eligible professionals without an NPI, but seeing Medicaid
clients under another billing provider’s NPI, will be required to
obtain one and enroll in Medicaid for purposes of receiving an
incentive payment.
Would this be considered a barrier to providers?
3. Entities that “promote adoption” will need to enroll and obtain
state approval.
What factors should Medicaid consider when approving their
enrollment to receive incentive payments on behalf of providers
who opt to assign their payment to these entities?
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Roadmap to MU
• MU of a certified EHR requires:
•
Use of certified EHRs in a meaningful manner such as
e-prescribing.
•
That the certified EHR is connected in a manner that
provides for the electronic exchange of health
information to improve the quality of care.
• In using this technology, the provider submits information on
clinical quality measures (CQM) and such other measures
selected by the Secretary of HHS.
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Applicability of MU
Objectives and Measures
• 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.
Examples:
• Dentists who do not perform immunizations.
• Certified nurse midwives who do not prescribe medications.
• In these cases, the eligible professional or hospital would be
excluded from having to meet that measure.
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Measures for
Meaningful Use
• 20 measures for EPs
• Must meet 15 from the “core set”.
• Must select 5 of 10 from “menu set”.
• 19 measures for eligible hospitals
• Must meet 14 from the “core set”.
• Must select 5 of 10 from “menu set”.
• Professionals must report total of 6 CQMs
• Blood pressure reading.
• Tobacco status.
• Adult weight screen and follow up or alternate if not applicable.
• 3 from list of clinical measures of the provider’s choice.
• Hospitals must report 15 CQMs
• 4 CQM overlap with CHIPRA initial core set.
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States’ Flexibility to
Revise Meaningful Use
• Medicaid can seek CMS approval to require four MU objectives as
core measures for providers:
• Generating lists of patients by specific conditions for quality
improvement, reduction of disparities, research or outreach.
• Submit electronic data on immunizations to registries.
• Submit electronic data on reportable lab results to public
health agencies.
• Submit electronic syndromic surveillance data to public health
agencies.
• Can specify for providers how to test the data submission and to
which specific destination.
• Medicaid is still determining options as whether or not to require
these MU measures.
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Proposed Plan to
Meaningful Use
• Establish a Medicaid Quality Outcomes workgroup to streamline
and align current outcome measures and prioritize quality
improvement initiatives and strategies. The workgroup will:
• Obtain stakeholder input.
• Address current and future data analytical staff capabilities.
• Identify the need for decision support system capabilities to
produce data driven decisions and improve health outcomes,
care quality, and cost efficiency.
• HHSC plans to:
• Collect and verify meaningful use quality data through a single
point of entry for client and provider data.
• Simplify provider reporting to the extent possible.
• Begin data collection in 2012.
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Adoption Rate and
Provider Participation
A baseline for provider adoption of EHR technology and participation
in the incentive program will be established in 2011.
• Subsequent years will have projected target adoption rates.
2011
Baseline
(Estimate)
2012
2013
2014
EH - Acute Care
10%
20%
40%
70%
EH – Children’s Hospital
20%
40%
60%
85%
5%
10%
25%
45%
EP – PAs when practicing at an
FQHC/RHC
3%
10%
20%
35%
EP – Dentists
3%
6%
8%
15%
Provider Type
EP – Physician
EP – Pediatrician
EP – CNMs
EP – Nurse Practitioners
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Discussion Questions
1. The Medicaid Program has the flexibility to move four public
health “menu” measures into required “core” measures.
Should Medicaid make these menu options required?
2. Are targeted adoption rates achievable?
3. Are there any additional recommendations in terms of goals or
targets for the HIT Roadmap?
4. Any suggestions how the Medicaid Program can best utilize the
reported MU Measures?
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Provider Outreach
and Education
• Use a variety of communication methods to reach providers and
other stakeholders around the state.
• Provide information regarding the incentive payment process and
details via web site, call centers, and presentations.
• Leverage existing communication channels and build additional
ones as appropriate.
• Develop webinars and other web-based educational materials for
convenient access.
• Develop the communication strategy and structure for ongoing
outreach and education.
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Provider Outreach and
Education Methods
• Medicaid Bulletin
• e-newsletter now includes an “Health IT corner”
• HHSC websites (i.e., TMHP, Office of e-Health Coordination) and
related links (e.g., CMS)
• Health IT page
• Contact Us form
• Communication through professional associations
• Health IT Regional Extension Centers (RECs)
• Provider presentations that are convenient, accessible and flexible
to schedules
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Key Considerations
in Communication Plan
• Consistency of information across communication channels and
with CMS.
• Coordination of information across Health IT and HIE
organizations in Texas, especially the four RECs.
• Accuracy and timeliness of information in a dynamic environment.
• Responsiveness to provider questions and concerns.
• Other considerations.
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Collaboration with RECs
• Weekly conference calls with RECs and the Office of e-Health
Coordination.
• Continuing discussion regarding collaborative relationship to
provide support for Medicaid providers.
• Leveraging opportunities for provider outreach and education
statewide.
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Provider Outreach
Important Links
Medicaid EHR Incentive Program Information
www.tmhp.com
Texas Regional Extension Centers
www.txrecs.org
Texas Health Services Authority
www.thsa.org
Medicaid Provider Survey
Practitioner: www.surveymonkey.com/s/593369B
Hospital: www.surveymonkey.com/s/WKB2JFR
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SMHP Stakeholder Feedback
August 3, 2010
• Open for comment until
August 6.
• Feedback on practical
implications to the plan.
• All input will be reviewed
and considered for inclusion
in the plan.
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HIE Advisory Committee
Meeting Wrap-Up
• Public Comments
• Review of Action Items for Next Meeting
• Next Meeting:
October 6, 2010
10:00 a.m. - 3:00 p.m.
Public Hearing Room, Winters Bldg.
This presentation is available at:
http://www.hhsc.state.tx.us/about_hhsc/AdvisoryCommittees/HIE.shtml
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