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2016 Meaningful Use
Keys to Your Incentive Payments
San Diego Physicians’ EHR & MU Experts since 2011
• The information included in this presentation is for informational purposes only
• The CMS final rule reviewed in this deck may be
viewed at https://www.federalregister.gov/articles/2015/10/16/2015-
25595/medicare-and-medicaid-programs-electronic-health-record-incentive-program-stage-3-and-modifications
• A CMS fact sheet about Modification is also available: http://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2015-Fact-sheets-items/2015-04-10.html
• Many aspects of the legacy Stage 1 and Stage 2 published Final Rules are still applicable
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Disclaimer
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1. How much money is in it for us?
2. Rumor, Facts & News
3. Pitfall #1 - Registration
4. Pitfall #2 – EHR Objectives (Measures)
5. Pitfall #3 – Other MU Requirements
6. Payment Adjustments
7. Resources
Agenda
2016
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Medi-Cal 1st Year “AIU” = $ 21,250 … 2nd Year (90-days) = $8,500 … thereafter (365-days) = $8,500 >> incentives end in 2021, total possible = $63,750
Medicare incentives are almost over, it is “avoid penalties” territory for many practices.
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Easier to get your money!
The Stages have merged.
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A single set of objectives for all MU Stages & Years
Results
The Medi-Cal Special $21,250 for Year 1 Adoption of an EHR.
CMS Listened to Physicians Reduced complexity
Lessened reporting burden
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Timeline
AIU = $21,250 AIU = $21,250 AIU = $21,250 AIU = $21,250
MU = $8,500 MU = $8,500 MU = $8,500 MU = $8,500
Medi-Cal $
False MU ends True ~ Medicare 2015 attestations >> GO! ~ Medi-Cal attestations – on hold until Spring 2016 ~ Hardship application is streamlined ~ Attestations prompt for exclusions
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Rumor & Facts
• Requires upgrade to 2015 Certified EHR
• Optional in 2017 – 90 day reporting period
• Mandatory in 2018 – Full year reporting unless it is a Medicaid EP’s first year attesting to MU
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Stage 3 News
Update Yearly!!
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Update CMS Registration & National Identity Registration – 1st Wait 2 Business Days >> Then update Medi-Cal Registration Know your Qualification Status Know your Group versus Individual EP status Have you: ~ Changed practice affiliation? ~ Added a practice affiliation or expanded into a new location? ~ Changed your proxy?
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Pitfall #1 - Registration
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https://nppes.cms.hhs.gov/IAWeb/login.do
CMS Identity & Access System
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CMS I&A
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Pitfall #2 – EHR Objectives
Current EHR is a problem – Is change smart?
The billing system doesn’t give us the Qualification data
– Now what?
Some providers achieve all measures and others don’t – Solution?
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https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/2015EP_TableofContents.pdf
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MU Specification Sheets
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Pitfall #3 – Other Requirements
CMS can grab back the incentive money! The risk is great if you rely soley on the EHR to tell you how you are doing.
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We Keep It Clear
Simple as Possible Objective 01
Privacy-Security Report
10 Step Risk Assessment & Mitigation Plan Update Annually
Objective 02 A CDS Rule Function 5 CDS interventions related to 4 CQMs or High Priority Health Conditions
Objective 02 B CDS Rule Function drug-drug drug-allergy interactions - unless writes <100 med orders
Objective 10 Public Health and Cliniical Data Registry Active Engagement: Complete Registration or Testing & Validation or Submitting
SDIR Exclusions:
M1 Immunization Registry Does not vaccinate
M2 Syndromic Surveillance Does not treat-diagnose condition under SD County surveillance
M3 Case Reporting Does not treat-diagnose condition under SD County report collection
M4 Public Health Registry Does not treat-diagnose condition under SD County registry
M5 Clinical Data Registry Does not treat-diagnose condition under SD County registry
http://www.sdcounty.ca.gov/hhsa/programs/phs/community_epidemiology/meaningful_use.html
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• CMS allowing GENEROUS EXEMPTIONS • Due to late publishing of rule
• The application looks back to 2015 calendar year addressing payment adjustment for 2017
https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/PaymentAdj_Hardship.html http://go.cms.gov/23jrBwC
• 2015 – EP was not able to meet MU • 2016 – File hardship waiver application by MARCH 15 • 2017 – If the 2015 application was approved, 3% payment
adjustments in this CY will be waived • Check box 2.2.d on application
Hardship Waiver Application
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Resources
Information Overload is Eased when You have Help!
Information Overload is Eased When You Have Help!
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https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/index.html
CMS Links
https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/2015ProgramRequirements.html
https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/EducationalMaterials.html
https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/PaymentAdj_Hardship.html
California DHCS Link http://medi-cal.ehr.ca.gov/
Sarah.Koop@sdcms.org 858-300-2780 or 858-300-2779
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There is a State of California grant that pays for some our technical assistance. Contact us to find out if you qualify.
Questions
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