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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