Transcript EHR Incentive Payments for Eligible Professionals Working

EHR Incentive Payments for Eligible Professionals
Working in Rural Health Clinics
Bill Finerfrock
Executive Director
National Association of Rural Health Clinics
[email protected]
202-543-0348
EHR Incentive Payments for
Meaningful Use
What Does this mean for
Physicians, NPs, CNMs and
PAs working in RHCs?
On July 13th, the Obama Administration
published the final rules for Medicare and
Medicaid EHR incentive payments.
Although final rules were also released
adopting the EHR certification standards –
to date NO certifying organization(s) have
been identified nor has any EHR system
been certified for EHR incentive payment
purposes.
Medicare EHR Incentive Payments
Physicians – and only Physicians – are
eligible for Medicare EHR incentive
payments – even when working in an RHC
setting.
Physicians must choose whether to get a
Medicare EHR Incentive Payment or a
Medicaid EHR incentive payment.
Medicare EHR Incentive Payments
If a physician chooses to get a Medicare
EHR Incentive Payment, he/she is
ineligible for a Medicaid EHR Incentive
payment FOR THAT YEAR.
A physician can make a one-time switch
from either a Medicare-to-Medicaid or
Medicaid-to-Medicare for EHR incentive
payments.
Medicare EHR Incentive Payments
Medicare EHR incentive payments are
based upon a percentage of Medicare Part
B claims.
If a physician bills Medicare Part B more
than $24,000 per year, he/she is eligible for
the maximum Medicare EHR incentive
payment for that year ($18,000 first year).
In order to qualify for incentive payments,
the EHR system being adopted and used by
the provider MUST meet federal certification
standards.
Although certification standards have been
established, CMS has not yet identified
those entities that will qualify as an
approved certifying body.
Incentive Payments
EHR Incentive Payments go to the Eligible
Professional (EP) – NOT the organization. EPs
working in organizations, such as RHCs, should
assign their EHR Incentive payments to the
facility; however, the rules do not require the EP
to make such an assignment.
Incentive Payments are available for EPs
working in either independent OR Providerbased RHCs.
MAXIMUM TOTAL AMOUNT OF EHR INCENTIVE PAYMENTS
FOR A MEDICARE EP WHO DOES NOT
PREDOMINANTLY FURNISH SERVICES IN A HPSA
Calendar
year
First CY in which the EP receives an incentive payment
2011
2012
2013
2014
2015 and Subsequent
Years
2011
$18,000
2012
$12,000
$18,000
2013
$8,000
$12,000
$15,000
2014
$4,000
$8,000
$12,000
$12,000
2015
$2,000
$4,000
$8,000
$8,000
$0
$2,000
$4,000
$4,000
$0
$44,000
$39,000
$24,000
$0
2016
Total
$44,000
MAXIMUM ADDITIONAL AMOUNT OF INCENTIVE PAYMENTS
FOR A MEDICARE EP WHO PREDOMINANTLY
PERFORMS SERVICES IN A HPSA
Calendar
year
Year that an EP first receives the incentive
payment for Medicare covered professional
services furnished in a geographic HPSA
2011
2012
2013
2015 and Subsequent
Years
2014
2011
$19,800
2012
$13,200
$19,800
2013
$8,800
$13,200
$16,500
2014
$4,400
$8,800
$13,200
$13,200
2015
$2,200
$4,400
$8,800
$8,800
$0
$2,200
$4,400
$4,400
$0
$48,400
$42,900
$26,400
$0
2016
Total
$48,400
Requirements for MEDICAID Incentive Payments
Eligible Professionals (EP’s) must meet the
following qualifications:
Be a physician: (doctors of medicine and doctors
of osteopathy), dentists, nurse practitioners,
certified nurse midwives, and physician assistants
practicing in a Federally Qualified Health Center
(FQHC) or Rural Health Clinic as so led by a
physician assistant.
PA Led Clinic
An RHC or FQHC is considered “PA Led”
when any of the following circumstances
exists:
(1)
(2)
(3)
When a PA is the primary provider in a
clinic (for example, an RHC with a
part-time physician and full-time PA,
would be considered “PA led”
);
When a PA is a clinical or medical
director at a clinical site of practice; or
When a PA is an owner of an RHC
Needy individuals
EPs working in an RHC must demonstrate
that more than 50 percent of their clinical
encounters occurred at an RHC over a sixmonth period, and that they had a minimum
of 30 percent of their patient volume from
needy individuals.
Needy individuals are
*
*
*
*
Those patients enrolled in Medicaid
(including dual eligibles);
Those patients enrolled in your state’s
Children's Health Insurance Program;
Low-income individuals furnished care for no
cost by the provider;
Individuals furnished services at reduced
cost based on a sliding scale determined by
the individual’s ability to pay.
Calculating the 30% Threshold
The ratio where the numerator is the total
number of encounters with needy individuals
treated in any 90-day period in the previous
calendar year and the denominator is all
patient encounters over the same period.
Calculating the 30% Threshold
The 30% threshold is calculated per
provider.
The Clinic determines the 90 day time
period used.
The 90 day time period must be continuous.
Incentive Payments to RHCs
RHC incentive payments will run through the
Medicaid program but these payments will
Largely come from FEDERAL dollars
RHCs can receive payments for:
1. Adoption, Implementation or Upgrading of an
EHR
2. Meaningful Use of the EHR
PAYMENT SCENARIOS FOR MEDICAID EPs
WHO BEGIN ADOPTION IN THE FIRST YEAR
Calendar
year
Medicaid EPs who begin adoption in
2011
2012
2013
2014
2015
2016
2011
$21,250
2012
$8,500
$21,250
2013
$8,500
$8,500
$21,250
2014
$8,500
$8,500
$8,500
$21,250
2015
$8,500
$8,500
$8,500
$8,500
$21,250
2016
$8,500
$8,500
$8,500
$8,500
$8,500
$21,250
$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
$63,750
$63,750
$63,750
$63,750
In the Proposed Rule
CMS proposed 25 objectives/measures an
Eligible Professional would be required to
satisfy in order to meet the meaningful use
criteria.
In the Final Rule
CMS adjusted the criteria to 15 “Core” or
mandatory criteria and 10 “optional” criteria.
Under the “optional” criteria, an Eligible
Professional would have to meet 5 of the 10
in order to meet the Meaningful Use criteria.
CORE Requirements
The EP Must meet all of the
CORE criteria
Proposed
Final Rule
Objective:
Use CPOE
Objective:
Use CPOE
Measure:
CPOE is used for at least
80 percent of all orders.
Measure:
More than 30% of patients
with at least one
medication in their
medication list have at
least one medication
ordered through CPOE
Proposed
Objective:
Implement drug-drug,
drug-allergy, drugformulary checks
Final Rule
Objective:
Implementing drug-drug
and drug-allergy checks
Measure:
Measure:
The EP has enabled this Functionality is enabled
functionality
for these checks for the
entire reporting period.
Proposed
Final Rule
Objective:
Objective:
Generate and transmit permissible Generate and transmit permissible
prescriptions electronically (eRx). prescriptions electronically (eRx).
Measure:
At least 75 percent of all
permissible prescriptions written
by the EP are transmitted
electronically using certified EHR
technology.
Measure:
More than 40% of all permissible
prescriptions written by the EP are
transmitted electronically using
certified EHR technology
Proposed
Final Rule
Objective:
Record Demographics:
*Preferred Language *Insurance
Type
*Gender
*Race
*Ethnicity
*Date of Birth
Objective:
Record Demographics: *Preferred
language
*Gender
*Race
*Ethnicity
*Date of Birth
Measure: At least 80 percent of
all unique patients seen by the
EP have demographics recorded
as structured data.
Measure: More than 50% of all
unique patients seen by the EP
have demographics recorded as
structured data
Proposed
Final Rule
Objective:
Maintain an up-to-date
problem list of current and
active diagnoses.
Objective:
Maintain an up-to-date
problem list of current and
active diagnoses.
Measure:
At least 80 percent of all
unique patients seen by the
EP have at least one entry or
an indication of none
recorded as structured data.
Measure
More than 80% of all unique
patients seen by EP have at
least one entry or an
indication that no problems
are known for the patient
recorded as structured data
Proposed
Final Rule
Objective:
Objective:
Maintain active medication Maintain active medication
list
list
Measure:
At least 80 percent of all
unique patients seen by
the EP have at least one
entry (or an indication of
“none” if the patient is not
currently prescribed any
medication) recorded as
structured data.
Measure:
More than 80% of all
unique patients seen by the
EP have at least one entry
(or an indication that the
patient is not currently
prescribed any
medications) recorded as
structured data
Proposed
Final Rule
Objective:
Maintain active medication
allergy list.
Objective:
Maintain active medication
allergy list.
Measure:
At least 80 percent of all
unique patients seen by the
EP have at least one entry
(or an indication of “none” if
the patient is not currently
prescribed any medication)
recorded as structured data.
Measure:
More than 80% of patients
have at least one entry or an
indication that the patient
has no known medication
allergies, recorded as
structured data
Proposed
Final Rule
Objective:
Record and chart changes in vital
signs:
•Height
• Weight
• Blood Pressure
• Calculate and Display BMI
• Plot and display growth charts for
children 2-20 years, including BMI
Objective:
Record and chart changes in vital
signs:
•Height
• Weight
• Blood Pressure
• Calculate and Display BMI
• Plot and display growth charts for
children 2-20 years, including BMI
Measure:
For at least 80 percent of all unique
patients age 2 and over seen by the
EP, record blood pressure and BMI;
additionally, plot growth chart for
children age 2 to 20.
Measure:
More than 50% of all unique patients
age 2 and over seen by the EP, height,
weight and blood pressure are
recorded as structured data.
Proposed
Final Rule
Objective:
Record smoking status for
patients 13 years old or
older
Objective:
Record smoking status for
patients 13 years old or
older
Measure:
At least 80 percent of all
unique patients 13 years old
or older seen by the EP
“smoking status” recorded.
Measure:
More than 50% of all unique
patients 13 years or older
seen by the EP have
smoking status recorded as
structured data
Proposed
Objective:
Implement five clinical
decision support rules
relevant to specialty or high
clinical priority, including for
diagnostic test ordering,
along with the ability to track
compliance with those rules.
Measure:
Implement five clinical
decision support rules
relevant to the clinical quality
metrics the EP is responsible
for.
Final Rule
Objective:
Implement ONE clinical
decision support rule
relevant to specialty or high
clinical priority, including the
ability to track compliance
with those rule.
Measure:
Implement one clinical
decision support rule.
Proposed
Final Rule
Objective:
Report ambulatory quality
measures to CMS or the
States.
Objective:
Report ambulatory quality
measures to CMS or the
States.
Measure:
For 2011, provide the
aggregate numerator and
denominator through
attestation.
For 2012, electronically
submit the measures.
Measure:
For 2011, provide aggregate
numerator, denominator, and
exclusions through
attestation.
For 2012, electronically
submit the measures.
Proposed
Final Rule
Objective:
Provide patients with an
electronic copy of their
health information (including
diagnostic test results,
problem list, medication lists,
and allergies) upon request.
Objective:
Provide patients with an
electronic copy of their
health information (including
diagnostic test results,
problem list, medication lists,
and allergies) upon request.
Measure:
At least 80 percent of all
patients who request an
electronic copy of their
health
information are provided it
within 48 hours.
Measure:
More than 50% of all
patients of the EP who
request an electronic copy
of their health information
are provided it within 3
business days.
Proposed
Final Rule
Objective:
Provide clinical summaries to
patients for each office visit.
Objective:
Provide clinical summaries
to patients for each office
visit..
Measure:
Clinical summaries provided to
patients for at least 80 percent
of all office visits
Measure:
Clinical summaries provided
to patients for more than
50% of all office visits within
three business days
Proposed
Final Rule
Objective:
Capability to exchange key
clinical information (for example,
problem list, medication list,
allergies, and diagnostic test
results), among providers of care
and patient authorized entities
electronically.
Objective:
Capability to exchange key clinical
information (for example, problem
list, medication list, allergies, and
diagnostic test results), among
providers of care and patient
authorized entities electronically.
Measure:
Performed at least one test of
certified EHR technology's
capacity to electronically
exchange key clinical information.
Measure:
Performed at least one test of
certified EHR technology’s
capacity to electronically exchange
key clinical information
Proposed
Final Rule
Objective:
Protect electronic health
information maintained using
certified EHR technology through
the implementation of appropriate
technical capabilities.
Objective:
Protect electronic health
information maintained using
certified EHR technology through
the implementation of appropriate
technical capabilities.
Measure:
Conduct or review a security risk
analysis and implement security
updates as necessary
Measure:
Conduct or review a security risk
analysis in accordance with the
and implement security updates as
necessary and correct identified
security deficiencies as part of its
risk management process
MENU List
Must meet any select five out of this list
Proposed
Final Rule
**Objective:
Implement drug-drug,
drug-allergy, drugformulary checks
Objective:
Implement drug-formulary
checks
Measure:
The EP has enabled this
functionality
Measure:
Functionality is enabled for
these checks for the entire
reporting period.
Proposed
Final Rule
Objective:
Incorporate clinical lab-test results
into EHR as structured data.
Objective:
Incorporate clinical lab-test results
into EHR as structured data.
Measure:
At least 50 percent of all clinical
lab tests results ordered by the EP
or by an authorized provider of the
eligible hospital during the EHR
reporting period whose results are
in either in a positive/negative or
numerical format are incorporated
in certified EHR technology as
structured data.
Measure:
More than 40% of all clinical lab
tests results ordered by the EP
during the EHR reporting period
whose results are either in a
positive/negative or numerical
format are incorporated in certified
EHR technology as structured
data.
Proposed
Final Rule
Objective:
Generate lists of patients by
specific conditions to use for
quality improvement, reduction of
disparities, research, and
outreach.
Objective:
Generate lists of patients by
specific conditions to use for
quality improvement, reduction of
disparities, research, and
outreach.
Measure:
Generate at least one report listing
patients of the EP with a specific
condition
Measure:
Generate at least one report listing
patients of the EP with a specific
condition
Proposed
Final Rule
Objective:
Send reminders to patients per
patient preference for preventive/
follow-up care.
Objective:
Send reminders to patients per
patient preference for preventive/
follow-up care.
Measure:
Reminder sent to at least 50
percent of all unique patients seen
by the EP that are 50 and over
Measure:
More than 20% of all unique
patients 65 years or older or 5
years old or younger were sent an
appropriate reminder during the
EHR reporting period
Proposed
Final Rule
Objective:
Check insurance eligibility
electronically from public
and private payers.
DROPPED
Measure:
Insurance eligibility checked
for at least 80% of all unique
patients seen by the EP
DROPPED
Proposed
Final Rule
Objective:
Provide patients with timely
electronic access to their health
information (including lab results,
problem list, medication lists,
allergies).
Objective:
Provide patients with timely
electronic access to their health
information (including lab results,
problem list, medication lists,
allergies).
Measure:
At least 10 percent of all unique
patients seen by the EP are
provided timely electronic access
to their health information.
Measure:
At least 10% of all unique patients
seen by the EP are provided
timely (within four business days
of being updated in the certified
EHR technology) electronic
access to their health information
subject to the EP’s discretion to
withhold certain information.
Proposed
Final Rule
Objective:
None
Objective:
Using Certified EHR
technology to identify
patient-specific education
resources and provide those
resources to the patient if
appropriate.
Measure:
None
Measure:
More than 10% of all unique
patients seen by the EP are
provided patient-specific
education resources
Proposed
Final Rule
Objective:
Perform medication
reconciliation at relevant
encounters and each
transition of care.
Objective:
The EP who receives a
patient fro another setting of
care or provider of care or
believes an encounter is
relevant should perform
medication reconciliation
Measure:
Perform medication
reconciliation for at least
80% of relevant encounters
and transitions of care
Measure:
The EP performs medication
reconciliation for more than
50% of transitions of care in
which the patient is
transitioned into the care of
the EP
Proposed
Final Rule
Objective:
Provide summary care
record for each transition of
care and referral.
Objective:
Provide summary care
record for each transition of
care and referral.
Measure:
Provide summary of care
record for at least 80 percent
of transitions of care and
referrals.
Measure:
The EP who transitions or
refers their patient to another
setting of care or provider of
care provides a summary of
care record for more than
50% of transitions of care
and referrals.
Proposed
Final Rule
Objective:
Capability to submit electronic data
to immunization registries and
actual submission where required
and accepted..
Objective:
Capability to submit electronic
data to immunization registries or
Immunization Information Systems
and actual submission where
required and accepted
Measure:
Performed at least one test of
certified EHR technology's capacity
to submit electronic data to
immunization registries
Measures:
Performed at least one test of
certified EHR technology’s
capacity to submit electronic data
to immunization registries and
follow up submission if the test is
successful (unless none of the
immunization registries to which
the EP submits such information
have the capacity to receive the
information.
Proposed
Final Rule
Objective:
Capability to provide electronic
syndromic surveillance data to
public health agencies and actual
transmission according to
applicable law and practice.
Objective:
Capability to provide electronic
syndromic surveillance data to
public health agencies and actual
transmission according to
applicable law and practice.
Measure:
Performed at least one test of
certified EHR technology's
capacity to provide electronic
syndromic surveillance data to
public health agencies (unless
none of the public health agencies
to which an EP or eligible hospital
submits such information have the
capacity to receive the information
electronically).
Measure:
Performed at least one test of
certified EHR technology’s
capacity to provide electronic
syndromic surveillance data to
public health agencies and followup submission if the test is
successful (unless none of the
public health agencies to which an
EP submits such information have
the capacity to receive the
information electronically.
Next Steps
1. The National Coordinator for HIT will
announce the organizations deemed as
certifying bodies for certification of EHR
products.
2. Certifying bodies will announce what
products meet the “meaningful use”
certification standards.
Next Steps
3. Providers with an existing EHR will know
whether the system they have is certified
or certifiable.
4. RHC administrators should already be
reviewing and evaluating EHR products
and assessing both cost and ease of
integration.
Next Step
RHCs should send a representative to the
NARHC Fall Conference in Reno Nevada.
In addition to several presentations on
selecting an EHR, several EHR vendors
have already committed to attending and will
be available to answer questions about their
products.
NARHC Meeting in Reno, Nevada
October 20, 21 and 22nd. For information go
to: http://www.narhc.org/events/events.php
Bill Finerfrock
Executive Director
National Association of Rural Health Clinics
[email protected]
202-543-0348