Rural Health Information Technology Conference

May 2010

Theresa RogersSenior Vice President

HITECH Components

• Incentives/penalties related to Meaningful EHR Use

• Certification and Standards• Regional Extension Centers • State Medicaid support including HIT• Comparative Effectiveness Research• Broadband Expansion and Innovation• Privacy and Security beyond HIPAA• State designated entity HIE support

CMS Proposed Rule on “Meaningful Use”

“Meaningful Use” Rule• Proposed rule published January 13, 2010• Final comments received March 15, 2010• Expect final rule sometime in June 2010

Outlines provisions governing EHR incentive programs

Defines “meaningful use”• Requires use of “certified” EHR• Requires functional measures• Requires clinical quality measures to be reported from EHR

“Meaningful Use” Vision for 2015

Prevention, and management, of chronic diseases• A million heart attacks and strokes prevented• Heart disease no longer the leading cause of death in the US

Medical errors• 50% fewer preventable medication errors

Health disparities• The racial/ethnic gap in diabetes control halved

Care Coordination• Preventable hospitalizations and re-admissions cut by 50%

Patients and families• All patients have access to their own health information• Patient preferences for end of life care are followed more often

Public health• All health departments have real-time situational awareness of outbreaks

MHA Comments to CMS “Meaningful Use”

• Timeline is too aggressive and unrealistic

• Need a glide path to achievable “meaningful use”

• Delay automated quality reporting until EHR quality measures have been tested and validated for EHR reporting

• As proposed wrongfully excludes too many physicians as “hospital-based”

Meaningful Use for 2011

• For EPs• 25 Objectives and Measures• 8 yes/no; 17 numerator/denominator• Clinical reporting

• Hospitals• 23 Objectives and Measures• 10 yes/no; 13 numerator/denominator• Clinical reporting

MHA Comments to CMS “Meaningful Use”

• Unfairly excludes critical access hospitals as “eligible” for Medicaid incentives

• Too restrictive in what qualifies as “reasonable costs” for CAHs

• As a plus, deems those who are “meaningful users” under Medicare to have met “meaningful use” requirements for Medicaid

• Agree with CMS that “meaningful use” is not the appropriate tool to ensure HIPAA privacy and security compliance

Consumer Reaction to “Meaningful Use”

• Proposed rules don’t include sufficient patient privacy protections

• Rules should ensure that consumers have control over their personal health information

Potential Incentive Dollars* – Missouri Hospitals

Medicare

$369 million

Medicaid

$17 million

*Estimated by BKD; data from Medicare cost report and HIDI 2008 data; must meet "meaningful use" criteria using a certified EHR to qualify for incentives; hospitals must have 10% Medicaid utilization to qualify for Medicaid incentive

Funding and IncentivesMedicare Hospital Incentives Timeline

Year of Adoption 2011 2012 2013 2014 2015 2016 2017 Payment for adopting in FY 2011 or before

100% 75% 50% 25%

If first adopting in FY 2012: 100% 75% 50% 25% If first adopting in FY 2013: 100% 75% 50% 25% If first adopting in FY 2014: 75% 50% 25% If first adopting in FY 2015: 50% 25% Penalties begin if not adopting by FY 2015: Three-quarters of the applicable market basket update is reduced by:

33.33% 66.66% 100%

Incentive Eligibility: Medicare

• Subsection (d) hospitals

• Critical Access Hospitals (CAH)

• Non Hospital-based Physicians• Doctor of Medicine, Osteopathy, Doctors of dental

surgery or dental medicine, podiatry, optometry or a chiropractor

PPS Hospital Incentives: Medicare

• Formula as stated in legislation• “Medicare Share” of “Initial Amount” multiplied by “Transition Factor”

adjusted for “Charity Care”

• Based on CMC Certification Number (CCN) not TIN

• Discharges:• Taken from hospital FY ending prior to FY serving as payment year

for preliminary payment; final payment determined using cost report for FY ending during the payment year using discharges from that reporting period

CAH Incentives: Medicare

• Excluded from Medicaid payments

• Up to four years of Medicare incentives• “Reasonable acquisition costs, excluding depreciation and

interest expenses” for computers and associated hardware and software

• “Medicare Share” of “Reasonable Costs” and may depreciate in first year

• Medicare Share bumped 20 percentage points from calculation• Subject to adjustments if not “meaningful user” by 2015

(exemptions up to 5 years)

Incentive Eligibility: Medicaid

• Acute care hospitals• Average stay < 25 days and Medicare CCN within range of 0001-0879• 10 percent Medicaid

• Children’s hospitals• Physicians, nurse midwives, nurse

practitioners, physician assistants, dentists

Medicaid Incentives

• Needn’t demonstrate MU in first year• CAHs don’t qualify under proposed rule• EPs cannot take both incentives *• EP payments higher• Formulas very similar• States paid 100% providers, 90% admin cost

* EPs and Hospitals are allowed a one time “switch” between Medicare and Medicaid programs

Medicare / Medicaid Differences

Medicare MedicaidImplemented at federal level Voluntary State implementation

MBU reductions in 2015 No fee reductions

Must achieve MU in Year 1May adopt, implement or upgrade

Year 1

Up to $44,000 for EPs Up to $63,750 for EPs

Common MU definition States may add requirements

Last year EP may start is 2014; Last payment 2016; Penalties start 2015

Last year EP may start is 2016; Last payments in 2021

Physicians, CAHs, subsection (d) hospitals

Additional EP types and three hospital types

MHA Outreach/Advocacy

• Issue brief(s) on rules• Regular MHA board agenda items• Newsletter updates on HIT and HIE• MHA HIT Advisory Committee• Multi-stakeholder/provider task forces• Educational programming/Webinars• Full participation in MO-HITECH work groups• Seat on Mo-HITECH Advisory Board• Seat on KCBHIE Board• Ongoing discussions with bordering states

Missouri HIT Assistance Center

• University of Missouri Columbia awarded REC grant for Missouri

• Core Support - outreach and educational activities, grants and program mgmt., local workforce support, best practices

• Direct Assistance Support - providing direct onsite technical assistance to providers

REC Priority Providers

• Individual and small group (10 or fewer prescribers) primarily focused on primary care

• Small rural and Critical Access Hospitals • Community Health Centers and Rural Health

Clinics; and • Other settings that predominantly serve

uninsured, underinsured and medically underserved populations.

REC Supplemental Expansion Grant

• Two-year expansion supplement to original REC grant awards

• Intended to ensure the provision of services to CAHs and rural hospitals

• HIDI will be the REC partner to provide and coordinate REC services to hospitals

Potential REC Services for Small Rural and CAHs

Outreach and Education • HIT Web site• Newsletter updates• Meaningful Use Summit

HIT Web Resources Toolkit

Fee-based Services through Group Purchasing Organization (GPO)

Meaningful Use SymposiumAugust 11 – 12, 2010

2-day summit with concurrent sessions • Understanding “meaningful use” basics• EHR functional requirements• Clinical reporting requirements• Incentive calculations• Understanding the vendor certification process• Working sessions with vendors and customer peers• Developing a project plan to meet “meaningful use”• Rural Assistance Center introduction• Missouri statewide HIE update

HIT Web Resources Toolkit

• EHR readiness assessment – tool to learn where you are in the EHR implementation cycle

• EHR Connector – tool to connect you to other customers using your EHR platform

• EHR Selection basics – step-by-step guide to selection of an EHR

• EHR evaluation tool – electronic template organizer to match EHR requirements against vendor capabilities

HIT Web Resources Toolkit

Implementation tutorials including• Project management – timeline, milestones,

risk assessment• Stakeholder engagement• Communication plan• How to manage your vendor• Workflow redesign basics• Parallel testing• “Go live” day management

HIT Web Resources Toolkit

• Physician engagement – how to engage and secure physician buy-in

• Security basics• Technical support requirements outline

Optional Discounted Fee-based Services through GPO

Technical Assistance for• Vendor Selection• Project Management• Shoulder to Shoulder Implementation Management• Practice Workflow Redesign• Assistance with Interoperability and HIE• Implementation of Privacy & Security Best Practices• Technical Infrastructure Support• Data Center Hosting

Ready, Set, Go!

• Implement technology for the right reasons

• Steer the organization toward that vision

• Stay educated and be mindful of “meaningful use” requirements – develop a “meaningful use” roadmap

• Plan for change

Thank you!

trogers@mail.mhanet.com