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Presenter: Mary Givens, Program Manager for Meaningful Use, Qualifacts Systems, Inc. July 25, 2012 The Minnesota Medicaid Electronic Health Record Incentive.

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Presentation on theme: "Presenter: Mary Givens, Program Manager for Meaningful Use, Qualifacts Systems, Inc. July 25, 2012 The Minnesota Medicaid Electronic Health Record Incentive."— Presentation transcript:

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2 Presenter: Mary Givens, Program Manager for Meaningful Use, Qualifacts Systems, Inc. July 25, 2012 The Minnesota Medicaid Electronic Health Record Incentive Program of Meaningful Use (MEIP)

3 Agenda  Overview of Meaningful Use Program  Timelines for the MN Medicaid EHR Incentive Program for Eligible Professionals  What can an eligible professional do to get ready for MEIP?  Important Links MN EHR INCENTIVE PROGRAM

4 Overview of the Meaningful Use Programs The Meaningful Use Incentive Programs are part of the Health Information Technology for Economic and Clinical Health (HITECH) Act, which is under the American Recovery and Reinvestment Act (ARRA) The goals of using a certified EHR in a meaningful way are to – Reduce medical errors; – Improve health care outcomes; – Ensure quality; and – Reduce health care costs MN EHR INCENTIVE PROGRAM

5 Types of Meaningful Use Programs Medicare EHR Incentive Program – Eligible Professionals – Hospitals Medicaid EHR Incentive Program – Eligible Professionals – Hospitals * If you are an EP who is eligible for both, choose the Medicaid EHR Incentive program MN EHR INCENTIVE PROGRAM

6 Medicaid vs. Medicare EHR Incentive Programs: A side by side comparison. MN EHR INCENTIVE PROGRAM

7 The Recovery Act specifies three main components of meaningful use that correspond with the 3 stages Capture & Share Data Exchange of clinical data Advancement of processes Improved outcomes MN EHR INCENTIVE PROGRAM Stage 1: The use of a certified EHR in a meaningful manner, such as e-prescribing ( ). Stage 2: The use of certified EHR technology for electronic exchange of health information to improve quality of health care (2014). Stage 3: The use of certified EHR technology to submit clinical quality and other measures (2015).

8 Payments across the Program Incentive Paid In Meaningful Use of a Certified EHR $21, $8,500$21, $8,500 $21, $8,500 $21, $8,500 $21, $8,500 $21, $8, $8, $8, $8, $8,500 Total$63,750

9 Important Dates for MN Medicaid EHR Incentive Program MN EHR INCENTIVE PROGRAM NOVEMBER 2011 CMS approved the MN State Medicaid HIT Plan (SMHP OCTOBER 2012 Target date for Providers to be able to submit applications to MEIP

10 MN Medicaid Electronic Health Record Incentive Program WebsiteMN Medicaid Electronic Health Record Incentive Program Website LINK What can we do to get ready for the MEIP right now? To get ready for MEIP, follow the steps below: 1. Learn more about the Medicaid and Medicare EHR Incentives for Eligible Providers from the CMS EHR website by clicking on the CMS EHR Incentive icon at the top of this page. 2. Adopt, implement or upgrade to a certified EHR system (site allows you to check if your EHR is certified; if it is not, ask your EHR vendor when they expect their product to be certified).certified EHR system 3. Determine if you may be eligible.Determine if you may be eligible 4.Review CMS Registration User Guides for eligible professionals (PDF) and eligible hospitals (PDF), and gather necessary documentation.eligible professionals (PDF) eligible hospitals (PDF) 5. Register for the Medicaid or Medicare incentive program on the CMS Registration and Attestation System. 6. Keep up-to-date with latest news and information about the Medicaid EHR Incentive Program. Save this page and the CMS EHR website as a favorite in your browser and come back frequently for updates. 7. Sign up for the MEIP list MN EHR INCENTIVE PROGRAM

11 MN Medicaid EHR Incentive Program Year 1 can attest to ADOPT/IMPLEMENT/or UPGRADE – Adopted > acquired, purchased or secured access to – Implemented > installed or commenced utilization of – Upgraded to certified EHR technology Eligibility – Cannot be a hospital based provider – Must be a Medicaid Provider in good standing – Must be one of these Medicaid Provider types Physicians (primarily doctors of medicine and doctors of osteopathy) Nurse practitioner Certified nurse-midwife Dentist Physician assistant who furnishes services in a Federally Qualified Health Center or Rural Health Clinic that is led by a physician assistant. – Must meet Medicaid patient volume requirement MN EHR INCENTIVE PROGRAM

12 Cannot be a hospital based provider “hospital based”, defined as 90% or more of the provider's encounters taking place at an inpatient (POS 21) or emergency room (POS 23) practice location. MN EHR INCENTIVE PROGRAM

13 Must be a Medicaid Provider in good standing Each eligible professional must have their own, individual Medicaid Provider ID – If rendering providers do not have one, they will need to get one – Medicaid uses the Medicaid ID to validate patient volume and track payments – Provider Enrollment, MEIP, will need to know that the new providers have been providing services under an already defined group Medicaid provider ID. MN EHR INCENTIVE PROGRAM

14 Must meet Medicaid patient volume requirement To qualify for an incentive payment under the Medicaid EHR Incentive Program, an eligible professional must meet one of the following criteria: Have a minimum 30% Medicaid patient volume Have a minimum 20% Medicaid patient volume, and is a pediatrician Practice predominantly in a Federally Qualified Health Center or Rural Health Center and have a minimum 30% patient volume attributable to needy individuals MN EHR INCENTIVE PROGRAM

15 Patient Volume A patient encounter is defined as a distinct patient, date- of-service, and place-of-service combination. A Medicaid patient encounter is any patient encounter (as defined above) where a Medicaid (not CHIP) fee-for- service claim or managed care organization paid for all or part of the services provided, or the co-pays, cost sharing or premiums for the services provided. When determining patient, must use a representative 90 consecutive day period in the previous calendar year MN EHR INCENTIVE PROGRAM

16 Calculating Patient Volume MN EHR INCENTIVE PROGRAM

17 Additional information for calculating patient volume There are no restrictions on hours worked or eligible professional employment type (e.g., contractual, permanent, temporary). An EP is allowed to aggregate or separate patients across practice sites and places of service; however, one location that meets the applicable payment year's EHR technology incentive payment eligibility criteria (Adopt, Implement, or Upgrade or Meaningful Use) MUST BE INCLUDED in the provider's patient volume measurement. An EP is allowed to aggregate patients across States. – The eligible professional must be able document their out-of-state patient volume. All patient volume information entered into the MEIP System may be subject to audit that could result in payment recoupment. MN EHR INCENTIVE PROGRAM

18 Group by proxy conditions Providers may use a clinic or group practice’s patient volume as a proxy for their own under three conditions: – The clinic or group practice’s patient volume is appropriate as a patient volume methodology calculation for the EP (for example, if an EP only sees Medicare, commercial, or self-pay patients, this is not an appropriate calculation). – There is an auditable data source to support the clinic’s patient volume determination. – So long as the practice and EPs decide to use one methodology in each year (in other words, clinics could not have some of the EPs using their individual patient volume for patients seen at the clinic, while others use the clinic-level data). The clinic or practice must use the entire practice’s patient volume and not limit it in any way. EPs may attest to patient volume under the individual calculation or the group/clinic proxy in any participation year. Furthermore, if the EP works in both the clinic and outside the clinic (or with and outside a group practice), then the clinic/practice level determination includes only those encounters associated with the clinic/practice. MN EHR INCENTIVE PROGRAM

19 Auditable for 6 years following payment : pre-payment audit and monitoring Pre Payment The provider is enrolled in Minnesota Medicaid. The provider is licensed and was licensed for the applicable time frame with no suspensions or revocations (including pharmaceutical prescribing licensure). The provider is not deceased. The provider has not been sanctioned The provider’s Tax Identification Number (TIN) has been verified by matching with an IRS TIN From a check of claims volume and the supporting information submitted, the minimum patient volume threshold is achieved. No previous year payment was made, for providers claiming incentives based on adoption, implementation, or upgrading of EHR technology. The provider has adopted certified EHR technology. MN EHR INCENTIVE PROGRAM

20 Auditable for 6 years following payment : post payment audit and monitoring Includes onsite audits Types of documents that will be required include: – documents that support the patient and claims volumes Paper encounter forms – invoices or contracts that support the adoption, implementation or upgrading of certified EHR technology – Reports used for calculating patient volume If an audit determines that an error in payment has been made, a written notification will be created and sent, informing the provider of the intent to recover funds. The recovery process will follow current New Jersey Division of Medical Assistance and Health Services recovery practices and guidelines. MN EHR INCENTIVE PROGRAM

21 Additional things to consider in prep for audits Assemble an “audit package” – Include documentation to support all eligibility requirements Non hospital based Patient volume Reassignment agreement Certified EHR documents Other possible documents to include: – EP did not participate in Medicare program or Medicaid in anther state for same year – EP was in good standing with Medicaid Note: Medicaid may review MU as part of regular audits and investigations MN EHR INCENTIVE PROGRAM

22 Details on audit strategy from the MN State Medicaid HIT Plan MN HITPLAN PAGE 6: D. Audit Strategy The SMA will build on its existing audit program and automated MMIS system checks to assure that MEIP is effectively administered and that payments are made only to providers enrolled in the program and who are using it as intended. Pre-payment controls include 100 percent verification of applicants’ licensure and EHR certification numbers and cross-checking all providers against the federal and state debarment and suspension lists and OIG and Master Death lists. Additionally, hospitals’ Medicare costs reports, providers’ uploaded proofs-of-purchase and MMIS claims information will be used. Post-payment controls include verifying any EP patient volume if reported volume is within two percentage points of the threshold value and a random sample methodology for all others. All EH patient volumes will be verified using Medicare cost reports. Additionally, the SMA will confirm that through the NLR that an EP does not receive a Medicare and Medicaid incentive payment for the same payment year. Our audit strategy will also combine a risk-based approach with random sampling audits of attested denominator volumes. MN HITPLAN PAGE 6 MN HIT PLAN PAGE 54: M. Post-payment controls: The SMA will verify any EP patient volume within two percentage points of the threshold value and randomly sample all others. All EH patient volumes will be verified using Medicare cost reports. Additionally, the SMA will confirm that a provider did not receive a Medicare payment and combine a risk-based approach with random sampling audits of attested denominator volumes. MN HIT PLAN PAGE 54 MN EHR INCENTIVE PROGRAM

23 Professionals who work in flat rate per day programs It comes down to an objective, auditable data source. Is there a service document that can show date of service, begin and end time of service, person who delivered to service, what type of service was provided, service notes, signature of provider? MN EHR INCENTIVE PROGRAM

24 Reassignment of incentive dollars EPs may reassign their incentive payment to the taxpayer identification number (TIN) of their employer (including group practices or clinics), if they so choose. – Each agency should have a discussion about reassignment with each EP and put a formal written agreement in place. – Sample “reassignment of benefit” agreement: one of our other Qualifacts customers, Gail Lawson of Sound Community Services of CT, graciously offered to allow us to share their agencies reassignment of incentive dollars agreement to be used as a sample. ***Please note that Gail shares this as a sample only and your agency will want your legal advisor to review your final agreement as there may be specific state laws, employment laws, etc. that need to be considered for your agency. This sample is available on Qualifacts Connect. MN EHR INCENTIVE PROGRAM

25 How does year 1 differ from years 2 – 6? Non Hospital Based Meet eligibility Attest to A/I/U Non Hospital Based Meet eligibility 50 % or more EPs patient encounters during the reporting period at a practice/location or practices/locations equipped with certified EHR technology Demonstrate meaningful use of an EHR for 90 consecutive days Non Hospital Based Meet eligibility 50 % or more EPs patient encounters during the reporting period at a practice/location or practices/locations equipped with certified EHR technology Demonstrate meaningful use of an EHR for full calendar year MN EHR INCENTIVE PROGRAM

26 Stage 1 EHR Meaningful Use Specification Sheets for Eligible Professionals CORE 1.*CPOE 2.Drug : drug and drug : allergy checks 3.Up to date problem list 4.*eRx 5.Active Medication list 6.Active Medication Allergy list 7.Demographics 8.*Vital Signs 9.*Smoking Status 10.Clinical Quality Measures 11.Clinical Decision support rule 12.*Electronic copy of Health Info upon request 13.*Clinical Summaries after each visit 14.Exchange Key Clinical Information 15.Protect Health Information MENU 1.*Implement drug formulary checks 2.*Incorporate Lab test results 3.Generate patient lists 4.*Patient Reminders 5.*Provide patients Electronic Access 6.Patient Specific Education Resources 7.*Medication Reconciliation 8.*Summary of Care record upon transition 9.*Submit Electronic data to immunization registry 10.*Submit syndromic surveillance data to public health agency MEASURES that have exclusions IMPORTANT LINK: Specification sheets for measures of meaningful use for eligible professionals. MN EHR INCENTIVE PROGRAM

27 Questions? MN EHR INCENTIVE PROGRAM

28 Important Links MN State Medicaid HIT plan MINNESOTA MEDICAID EHR INCENTIVE PROGRAM (MEIP) MINNESOTA MEDICAID EHR INCENTIVE PROGRAM (MEIP) Sign up for updates from MEIP >Electronic Health Records Sign Up For Mailing ListElectronic Health Records Sign Up For Mailing List CMS Final Rules: Medicare and Medicaid Electronic Health Record Incentive Program (pdf) CMS Final Rules: Medicare and Medicaid Electronic Health Record Incentive Program (pdf) MN eHealth “ A Practical Guide to Effective Use of EHR Systems”“ A Practical Guide to Effective Use of EHR Systems” CMS SPECIFCATION SHEETS TO MEASURES OF MU FOR ELIGIBLE PROFESSIONALS CMS SPECIFCATION SHEETS TO MEASURES OF MU FOR ELIGIBLE PROFESSIONALS MN EHR INCENTIVE PROGRAM

29 Qualifacts can help Please contact us for help. Our Meaningful Use Program Manager, Mary Givens is available to ensure every customer receives their incentive payments. Mary was our lead project manager for the Meaningful Use certification process. Because of her expertise and experience we decided to make her a dedicated Meaningful Use and incentive payment resource to customers. Mary and her team can help you: Calculate your maximum number of EPs Register and attest for the Medicaid and Medicare programs Analyze workflows and make modifications for meeting MU criteria Answer all questions Mary Givens | | MN EHR INCENTIVE PROGRAM

30 Disclaimer It is important that each individual eligible professional and their surrogates take responsibility for understanding of the final rules and regulations of the Medicaid and Medicare EHR Incentive Programs. Qualifacts Systems Inc offers these free webinars as a service and makes every effort to provide accurate information. We make no claim that our information is complete or contains no inaccuracies. Under no circumstances shall anyone associated with Qualifacts Systems Inc. Be liable for any incidental, indirect, consequential or special damages or loss of any kind including those resulting from the expected incentives themselves. Qualifacts Systems, Inc in no way considers itself the ultimate authority or expert on the final rules and regulations of the Medicare and Medicaid EHR Incentive Programs and expects that each individual will consult the state specific Medicaid EHR Incentive Program website for their specific states rules and/or the CMS website for the EHR Incentive Program Rules. It is important that each Eligible Professional note that CMS views the EP as ultimately responsible for the numerator and denominator and their Medicaid Encounter volume as well as the data used for attestation on the measures of Meaningful Use. CMS has announced there will be audits. “There are numerous pre-payment edit checks built into the EHR Incentive Programs’ systems to detect inaccuracies in eligibility, reporting and payment. Post-payment audits will also be completed during the course of the EHR Incentive Programs.” MN EHR INCENTIVE PROGRAM


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