ARRA and Meaningful Use Incentives - Texas Council of ... · ARRA February 2009 • $787 Billion,...
Transcript of ARRA and Meaningful Use Incentives - Texas Council of ... · ARRA February 2009 • $787 Billion,...
ARRA and Meaningful Use Incentives
What?When?How?
Presentation for the Executive Director’s Consortium
April 14th, 2011
ARRA February 2009• $787 Billion, $50 Billion for Health Information
Technology (HIT)
• Includes about $27 Million for Meaningful UseIncentives
• Title XIII of ARRA
• Health Information Technology for Economic andClinical Health Act (HITECH Act)
• Corrective Legislation would add more fundingopportunities for BH – Still pending
HITECH Act – 3 Parts
• Create Standards, Implementation Specifications andCertification Criteria
• Implement the HIT Infrastructure and HER’s throughgrants, loans and incentives for the Meaningful Use ofCertified EHR’s.
• Encourage the use of HIT Infrastructure by improvinginformation privacy and security.
HITECH ACT – Key Goals
• Improve quality, safety & efficiency
• Engage patients and their families
• Improve care coordination
• Improve population and public health; reduce disparities
• Ensure privacy and security protections
HITECH Act – Incentives
• Medicare Incentives – Eligible Professionals up to $44Kover a 5 year period (Fewer years & $$ if starting CY2013 or later)
• Medicaid Incentives – Eligible Professionals up to $63Kover a 6 year period
HITECH Act – Eligible Professionals
• Physicians
• Nurse Practitioners
• Corrective Legislation (if/when passed) would addLCSW’s
HITECH Act – Patient VolumeRequirements - MEDICAID
• 30% Patient Volume (20% Pediatricians)
• Option 1 – Based on patient encounters over a 3 fullconsecutive months. Each EP measuredindepedently
• Option 2 – Based on Patient Panels (intended formanaged care PCP’s only)
• Option 3 – Based on patient encounters for a full 3consecutive months at the group or practice level.
Clinic Volume Proxy for EP Eligibility - NEW
• Applies under three conditoins
• The clinic volume is an appropriate proxy for the clinician (e.g. ifthe EP only sees commercial clients, it would not be appropriatefor Medicaid Volume)
• There is an auditable data source to support the clinic volumecalculation
• The clinic and the clinician can only use one methodology peryear
• Not sure if this is in addition, replacement, or clarification to Option 3noted above.
Clinic Volume Proxy - Example
• Using EP Volume Calculation, 2 EP’’s would qualify
• Using Clinic Volume Proxy Calculation, 5 EP’s qualify
Patient Volume Requirements - Medicaid
• Basic Formula for Patient Volume
• Denominator = Total Documented Unduplicated PatientEncounters
• Numerator = Total Documented Unduplicated MedicaidPatient Encounters
• (Numerator / Denominator) x 100 = Medicaid Volume %
Patient Volume Requirements – MedicaidSubsequent Years
• Same options and formula – But for 12 consecutivemonths of the calendar year
Medicaid Incentives – The Details
• Example from Option 1
$63,750 x Two (2) EP’s - $127,500
• Example from Option 2
$63,750 x Two (5) EP’s - $318,750
• Waiting to Long to Start Can Cost Your Center
Meaningful Use Stages - Medicaid
• Stage 1
• Capture and Share Data (Typically RequiresStructured Data)
• Stage 2
• Advanced Care Processes
• Decision Support
• Stage 3
• Improved Outcomes
When are Stages Required?
• First Payment Received in 2011
• Stage 2 Required in 2013
• Stage 3 Required in 2015
• First Payment Received in 2012
• Stage 2 Required in 2014
• Sage 3 Required in 2015
• First Payment Received in 2014
• Stage 3 Required in 2015
IMPORTANT – Payments are ONLY madeto Eligible Professionals (EP’s)
• EP’s May Assign Incentive to an organization (Employer)
• EP’s may ONLY Assign Incentive to One (1) Organization perCalendar Year.
• EP’s working for 2 organizations at the same time
• EP’s working for an organization and self employed
• EP’s Can Only Participate in One (1) State’s Incentive Program
• EP’s working in 2 States.
• EP’s typically will not have the expertise or resources to achieve thetechnical aspects of MU
• EP’s will need their Center and Centers will need their EP’s in orderto obtain incentives.
• There must be cooperation between EP’s and Center to ObtainIncentives. Will likely require some formal agreement between EPand Center
Medicare Incentives – The Details
• These are maximum limits
• Incentive is based on $75% of Reimbursed MedicareClaims for that EM up to the amounts noted.
• Examples:
Medicare Incentives – What Phases?
• EP’s (and their organization) Must be at the Equivalentof Stage 3 Before the First Incentive is Claimed
Incentives – Medicare vs. MedicaidSummary
• EP’s may switch between the Medicare and Medicaid IncentiveProgram, but only once.
• Incentive Amounts
• Medicaid Incentive Amount is based on full amounts in eachyear.
• Medicare Incentive Amount is based on 75% of ReimbursedMedicare Claims up to the limits prescribed in the program
• Meaningful Use Implementation
• Medicaid has a phased in or staged approach to MeaningfulUse.
• Medicare requires that EP’s be at the equivalent of Stage 3before making application for the first year’s incentive dollars.
Where Do We Start?
• Do we have Qualified Eligible Professionals
• EP Credentials
• Medicare
• Equivalent of Stage 3 Meaningful Use
• Medicaid
• 30% Patient Volume (20% Pediatricians)
• Stage 1 Meaningful Use
Eligible Providers – More Details
• ARRA HITECH Meaningful Use Issues/Question List (Handout)
• Number of Eligible Providers on Staff or Contract
• Do these EP’s work for other provider entities. Will they re-assign their incentivepayments to you?
• Have you implemented an EMR system for EP’s. Is it ONC-ATC “certified”?
• If not certified, will it be? When?
• Do your EP’s meet the Medicaid volume requirements?
• If your EP’s don’t qualify for the Medicaid incentives, do they qualify for theMedicare Incentives?
• Are your EP’s located in a HPSA (Health Professional Shortage Area)? If yes,they may qualify for up to 10% more. http://hpsafind.hrsa.gov/HPSASearch.aspx
• What are the steps to claim the incentive dollars? Handout: TMHP document“Prerequisites to Participate in the Electronic Health Record (EHR) IncentiveProgram.http://www.tmhp.com/TMHP_File_Library/HealthIT/Prerequisite%20checklist%20for%20EHR%20enrollment.pdf
Define ARRA/HITECH Project Team
• Clinical Operations
• Medical Staff Leader
• Financial Leader
• Human Resources Leader
• IS Leader
• Medical Records Leader
• QM Leader
Project Plan – Core and Menu SetRequirements
• Functional Objectives/Requirements Sets (Core/Menu)
• Determine if your organization meets each of the CORErequirements
• If not yet met, determine if/when it will
• Choose at least 5 from the Menu Set of Requirementsand determine if your organization meets those corerequirements
• If not yet met, determine if/when it will
Get Eligible Providers Registered
• NPI Registry https://nppes.cms.hhs.gov/NPPES/Welcome.do
• CMS – EHR Incentive Registryhttps://ehrincentives.cms.gov/hitech/login.action
• Texas Provider Identifier (Most probably have this)http://www.tmhp.com/Provider_Forms/Provider%20Enrollment/Texas%20Medicaid%20Provider%20Enrollment%20Application.pdf
• EP’s must have an individual account with TMHPhttp://www.tmhp.com/TMHP_File_Library/Provider_Manuals/TMHP_Portal_Security/TMHP_PortalSecurityManual.pdf
Keep Eligible Provider Engaged
• EP’s will need to assign their incentive dollars to the Center
• This will likely require some negotiation between HR and EP’s andLegal
• HR Consortium
• TX Council Attorney
• Develop a plan to handle
• EP’s working for multiple entities
• EP’s working in multiple states (if applicable)
• EP’s that are also self employed
• EP’s that have already assigned Incentive Benefit to anotherprovider entity
• EP’s that want to keep some of the incentive money
Budgeting – Incentives (And Costs)
• Review Qualifying EP’s and project Incentive Revenue
• Medicaid Projections
• First Payment Year and Beyond
• Stage I and Beyond
• New EP’s in subsequent years
• Medicare Projections
• Only after organization has achieved theequivalent of Stage III MU
• First Payment Year and Beyond
• New EP’s in Subsequent Years.
Easy Part Checklist
• Eligible Providers
• Qualified Eligible Providers
• Eligible Providers Registered in all the Right Places
• Software is Certified
What’s Left?
• Meaningful Use
• Implementing New or Existing Features of a CertifiedSoftware Product typically requires changes to howan organization operates.
• These changes are rarely just an IT task. It will requireplanning, leadership, expertise and effort of theARRA/HITECH project team.
• Planning Stage II and Stage III Implementation
Remember
• Incentives are for Meaningful Use
• Meaningful Use of Certified Software by appropriatelyRegistered, Qualified, Eligible Providers
• Incentives are NOT:
• Grant Funds to Purchase Hardware and Software
• Centers cannot get incentive dollars without the EP’sand the EP’s cannot get incentive dollars without theCenters (in most cases)
Thank You
• Ralph Whaite – Helen Farabee Centers
• Larry Jonczak – Lakes Regional MHMR Center