Eligible Professionals:NH Medicaid Electronic Health Records

Incentive Program

Eve FralickProject Director, NH DHHS Medicaid EHR Incentive Program

Agenda

• Background on HITECH• NH DHHS planning efforts to date• Next steps in NH DHHS planning • Provider Survey #1 Results • Overview of EHR incentive program criteria• Basics of ‘meaningful use’ • Contact and website information • Questions

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The HITECH Act• HITECH = Health Information Technology for Economic

and Clinical Health

• Passed in February 2009 as part of the American Recovery and Reinvestment Act

• Goal: ‘…the utilization of an electronic health record (EHR) for each person in the United States by 2014…’

• Offers reimbursement incentives through Medicare and Medicaid for providers who demonstrate they are ‘meaningful users’ of certified EHRs

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EHR Incentive Program Funding

• Medicare incentive program is federally run by CMS

• Medicaid incentive program is a voluntary program that is regulated by CMS and run by the States– Medicaid payments to providers are administered by

the States but reimbursed at 100% by CMS– Payments to States for expenses incurred in planning,

administering, overseeing, and carrying out the Medicaid incentive payment provisions are reimbursed at 90% by CMS and 10% by State funds

EHR Incentive Program Regulations

• HITECH Act Regulations; 42 CFR – Subchapter D, Part 170: Health Information

Technology– Subchapter G, Part 495 – Standards for the Electronic

Health Record Technology Incentive Program• Final Rule

– Federal Register: Document Number: 2010-17207 – http://federalregister.gov/a/2010-17207

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NH DHHS Program Status • Official CMS program start: July 1, 2010• NH DHHS is currently in the ‘planning stages’ for the Medicaid EHR

incentive program• Tasks completed:

– Planning Advance Planning Document (PAPD) submitted to CMS: March 2010

– CMS approved PAPD: July 2010– Provider survey #1 completed: August 2010– Project Director hired: September 2010 – Massachusetts eHealth Collaborative named as NH Regional Extension

Center (to support NH providers in becoming meaningful users of electronic health records): September 2010

– NH DHHS launched informational website: October 2010 (www.NHMedicaidHIT.org )

NH DHHS Upcoming ProjectsTask

• Write/Submit State Medicaid Health Information Technology Plan (SMHP) to CMS

• Write/Submit Implementation Advance Planning Document (IAPD) to CMS

• Develop process to coordinate with National Level Repository (tool to verify provider eligibility and meaningful use and track payments)

• Complete implementation tasks required prior to first payment

‘Anticipated’ Timeline

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• March 2011

• June 2011

• 3rd / 4th quarters 2011

• TBD

Pending successful approvals from CMS and timely implementation of required tasks, first Medicaid payments to

eligible professionals projected during CY 2012

NH DHHS Next Steps…

• Continue to reach out to key stakeholders and stakeholder organizations to communicate program information and solicit feedback on challenges and barriers

• Coordinate closely with Massachusetts eHealthCollaborative (the Regional Extension Center of New Hampshire) to mutually share program information and barrier concerns

• Solicit information from eligible professionals on individual preferences towards selection of Medicaid or Medicare incentive

• Practice-level provider survey - 1st quarter 2011

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Provider Survey #1Results

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Provider Survey Background

• NH DHHS (Health Information Exchange Planning and Implementation Project) commissioned a survey to assess technology usage in NH practices with prescribing privileges (physicians and nurse practitioners) – Goal: use information collected to inform multiple projects associated

with federal and state health information technology and health information exchange priorities

– One survey component addressed the use of EHRs• Survey implemented by NH Institute for Health Policy and Practice in

June through August 2010• Sent to hospital-level information managers, practice-level information

managers, and individual providers (some overlap)

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Provider Survey Respondents

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Facility Type Count Practice

Private Solo/Group Practice 62 57%

Hospital Owned/Affiliated Practice 18 17%

Community Health Center 11 10%

Community Mental Health Center 7 6%

Nursing Home 7 6%

Home Health Care 3 3%

TOTAL 108 100%

108 organizations (representing 2,741 providers) responded*:

*9 surveys had incomplete information

Provider Survey Respondents

• High sampling of prescribers represented, but not all…– Some providers may not have received survey due to lack of

a comprehensive method in New Hampshire for identifying prescribers at the individual or practice level

– Some surveys weren’t returned

• Hospital, and stand-alone, larger practices within New Hampshire well represented

• Smaller, and independent, practices under-represented

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Least Common Uses

Connections to Patient Drug Formularies

46%

Best Practices 53%

E-Prescribing 60%

Radiology Results 64%

Referrals & Consults 67%

Provider Survey Key Findings

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57% Of Respondents Used EHR In Some Form

Connections Outside The Practice

Primary Uses

Patient Demographics 97%

Medication Histories 88%

Patient Care Histories 86%

Billing Integration 76%

Point Of Care Functions

Provider Survey EHR Barriers

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Perceived Major Barriers To EHR Adoption

Lack of Capital Resources 25%

Loss of Productivity During Transition 19%

Insufficient Return on Investment 16%

Insufficient Time to Select, Contract, Install, and Implement EHR

11%

Security and Privacy 9%

Willingness to Use EHR 8%

Available Software Does Not Meet Needs 6%

Inability to Integrate To Billing/Claims 6%

Cost Was The Primary Reason For Not Adopting EHRs

MixedResponses

Provider Survey Barriers

• Mixed responses on several major barriers to adoption– Security and privacy– Whether providers would use systems– Whether software/integration met practice needs

• Potential reasons– Respondents might have been unclear on effects of

technology adoption in these areas– In large practices, these issues were being addressed by

other staff members

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Provider Survey Results

Providers Indicated A General Need For Assistance In All Areas

Overview of EHR Incentive Program Criteria

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Medicaid Eligible Professionals (EPs)

• Must meet volume thresholds– Non-Hospital Based Physicians*– Dentists– Certified Nurse-Midwives– Nurse Practitioners– Physician Assistants Practicing in a Federally Qualified

Health Center (FQHC) or Rural Health Center (RHC) led by a Physician Assistant

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*A Medicaid EP is considered hospital-based if 90% or more of the EP's services are performed in a hospital inpatient or emergency room setting

Medicare Eligible Professionals*

• Must bill the Medicare Physician Fee Schedule– Non-Hospital Based Doctors of Medicine or

Osteopathy– Doctors of Oral Surgery or Dental Medicine– Doctors of Podiatric Medicine– Doctors of Optometry– Chiropractors

19*Medicare Advantage providers have other eligibility criteria

EHR Incentive Program Participation

• EPs can participate in either the Medicare or Medicaid EHR incentive program (note: hospitals can participate in both)

• A one-time switch is allowed (before 2015) between Medicare or Medicaid

• Medicaid providers can collect an incentive payment from one state only per year

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EHR Incentive Program Participation

• Each EP is eligible for one incentive payment per year, regardless of how many practices or locations at which they provide services

• Incentives are based on individual EPs who meet program requirements…not their group practice*

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*Clinics or group practices will be permitted to calculate Medicaid patient volume at the group practice/clinic level in accordance with statute limitations

Medicare versus Medicaid

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are Starting in May

2011with CMSStarting in May 2011with CMS

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aid To be

determined pending NH DHHS planning efforts(but projected later than 2011)

To be determined pending NH DHHS planning efforts(but projected later than 2011)

Availability of Incentive Funds

Medicare versus Medicaid

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are Providers must bill

the Medicare Physician Fee Schedule for patient services

Providers must bill the Medicare Physician Fee Schedule for patient services

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aid Non-pediatricians:

minimum 30% Medicaid patient volume* Pediatricians: minimum 20% Medicaid patient volume*

Non-pediatricians: minimum 30% Medicaid patient volume* Pediatricians: minimum 20% Medicaid patient volume*

Eligibility

*Children's Health Insurance Program (CHIP) patients do not count towards Medicaid patient volume criteria

Medicare versus Medicaid

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are Providers must bill

the Medicare Physician Fee Schedule for patient services

Providers must bill the Medicare Physician Fee Schedule for patient services

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aid Physician assistants

who practice predominantly* in a FQHC or RHC and have minimum 30% patient volume attributable to needy individuals**

Physician assistants who practice predominantly* in a FQHC or RHC and have minimum 30% patient volume attributable to needy individuals**

Eligibility (cont’d)

*Predominantly = 50% or more patient encounters over 6-months

**Needy individuals = • Medicaid or Children's Health Insurance Program enrollees• Patients furnished uncompensated care by the provider• Patients furnished services at either no cost or on a sliding scale

Medicare versus Medicaid

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are Cannot

participate in the EHR incentive program and the e-Prescribing program in the same year

Cannot participate in the EHR incentive program and the e-Prescribing program in the same year

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aid May participate

in the EHR incentive and e-Prescribing programs at the same time if eligibility requirements met

May participate in the EHR incentive and e-Prescribing programs at the same time if eligibility requirements met M

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& M

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aid

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d May participate in Physicians Quality Reporting Initiative and EHR incentive programs at the same time if eligibility requirements met

May participate in Physicians Quality Reporting Initiative and EHR incentive programs at the same time if eligibility requirements met

Participation in Other CMS programs

Medicare versus Medicaid

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are $44,000 over 5 years

(plus health professional shortage bonuses)

$44,000 over 5 years (plus health professional shortage bonuses)

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aid $63,750 over 6 years

Exception: Pediatricians with more than 20%, but less than 30%, Medicaid patient volume will receive 2/3 of the maximum amount

$63,750 over 6 years

Exception: Pediatricians with more than 20%, but less than 30%, Medicaid patient volume will receive 2/3 of the maximum amount

Maximum Incentive Payment*

*Based on average allowable costs

Medicare versus Medicaid

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are 5 payment years are

successive

If program criteria not met in any year, that year still counts as a payment year, regardless of whether an incentive payment is made

5 payment years are successive

If program criteria not met in any year, that year still counts as a payment year, regardless of whether an incentive payment is made

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aid 6 payment years may

be non-consecutive

If program criteria not met in any year, EP may skip that year and still be eligible for a maximum of 6 annual incentive payments

6 payment years may be non-consecutive

If program criteria not met in any year, EP may skip that year and still be eligible for a maximum of 6 annual incentive payments

Continuity of Payments

Medicare versus Medicaid

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are 20142014

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aid 20162016

Last Year To Initiate Participation In Incentive Program

Medicare versus Medicaid

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are 20162016

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aid 20212021

Last Payment Year

Medicare versus Medicaid

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are Decrease after

CY2012Decrease after CY2012

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aid No decrease at

any timeNo decrease at any time

Total Incentive Payment Reductions

Medicare Incentive Payments

CY 2011 CY 2012 CY 2013 CY 2014 CY2015 and later

CY 2011 $18,000 - - - -CY 2012 $12,000 $18,000 - - -CY 2013 $ 8,000 $12,000 $15,000 - -CY 2014 $ 4,000 $ 8,000 $12,000 $12,000 -CY 2015 $ 2,000 $ 4,000 $ 8,000 $ 8,000 $0CY 2016 - $ 2,000 $ 4,000 $ 4,000 $0TOTAL $44,000 $44,000 $39,000 $24,000 $0

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Column = first calendar year EP receives a paymentRow = amount of annual payment if requirements continue to be met

Medicaid Incentive Payments

CY 2011 CY 2012 CY 2013 CY 2014 CY2015 CY 2016

CY 2011 $21,250 - - - - -

CY 2012 $8,500 $21,250 - - - -

CY 2013 $8,500 $8,500 $21,250 - - -

CY 2014 $8,500 $8,500 $8,500 $21,250 - -

CY 2015 $8,500 $8,500 $8,500 $8,500 $21,250 -

CY 2016 $8,500 $8,500 $8,500 $8,500 $8,500 $21,250CY 2017 - $8,500 $8,500 $8,500 $8,500 $8,500CY 2018 - - $8,500 $8,500 $8,500 $8,500CY 2019 - - - $8,500 $8,500 $8,500CY 2020 - - - - $8,500 $8,500CY 2021 - - - - - $8,500TOTAL $63,750 $63,750 $63,750 $63,750 $63,750 $63,750

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Column = first calendar year EP receives a paymentRow = amount of annual payment if requirements continue to be met

Medicare versus Medicaid

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are Year 1: 90 days

meaningful use

Each subsequent year: full year meaningful use

Year 1: 90 days meaningful use

Each subsequent year: full year meaningful use

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aid Year 1: Adopt,

Implement, UpgradeYear 2: 90 days meaningful useTheoretical years 3–6: full year meaningful use

Year 1: Adopt, Implement, UpgradeYear 2: 90 days meaningful useTheoretical years 3–6: full year meaningful use

Reporting

Medicare versus Medicaid

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are Payment reductions

begin in 2015 if no meaningful use

Start at 1% and increase up to 5% for every year that meaningful use not demonstrated

Payment reductions begin in 2015 if no meaningful use

Start at 1% and increase up to 5% for every year that meaningful use not demonstrated

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aid No fee schedule

reductions as mandated by statute

No fee schedule reductions as mandated by statute

Fee Schedule Adjustments

Medicaid versus Medicare?

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How to decide which program?

CMS flowchart handout

2nd box on top left - answer ‘No’ to find Medicare

eligibility

Medicaid &

Meaningful Use

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EHR Is More Than Just A System: Meaningful Use

• HITECH Act requires:– Certified EHR technology used in a meaningful manner

(example: electronic prescribing)– Certified EHR technology connected in a manner that

provides for the electronic exchange of health information to improve the quality of care

– In using certified EHR technology, the provider submits to the Secretary information on clinical quality measures and such other measures selected by the Secretary.

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Medicaid Requisites For Payment

• NH DHHS must verify/audit:– Year 1: certified EHR technology has been

adopted, implemented, and upgraded– Year 2: 90-day reporting period in which Stage

1 meaningful use has been demonstrated– ‘Theoretical’ Years 3 - 6: meaningful use

demonstrated on a full year basis for each year that payment is requested

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Meaningful UseObjectives and Measures

• Some criteria are optional; others required– Core objectives – mandatory; must be met– Menu set – select from a list of options with at least one

population and public health measure

• If an objective/measure is not applicable, providers can present ‘exception criteria’ to remove it from MU qualifying criteria

• Refer to CMS website for more information: http://www.cms.gov/EHRIncentivePrograms

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Meaningful Use Stage 1 Objectives (Final Version)*

• Goal: build a strong foundation– Establish functionalities in certified EHR technology to allow for

continuous quality improvement and ease of information exchange

• Criteria:– Electronically capture health information in a structured format– Use information to track key clinical conditions– Communicate information to coordinate care

• CMS to publish meaningful use clarifications ‘shortly…’

40*The Final Rule addresses stages of MU only through 2014

Stage 1 Meaningful Use Criteria

• 15 core objectives – Examples: CPOE, e-prescribing, record

demographics, clinical quality measures• 5 of 10 menu set objectives

– Examples: drug-formulary checks, incorporate clinical lab test results as structured data, generate lists of patients by specific conditions

• 6 Clinical Quality Measures – 3 core and 3 of 38 from menu set

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Meaningful UseStages 2 & 3 (Draft Versions)

• Stage 2 expected by 2011– Intent: Stage 1 optional criteria will be required as Stage 2 core

criteria– Goal: expand on Stage 1 to encourage use of health IT to have

‘information follow the patient’– Focus: structured information exchange and continuous quality

improvement at point of care

• Stage 3– Focus: promote improvements in quality, safety, and efficiency

leading to improved health outcomes; access to comprehensive patient data through robust, patient-centered health information exchange

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For More Information…

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EHR Incentive Program Information

• CMS website: program information, tip sheets, educational materials: – http://www.cms.gov/EHRIncentivePrograms

• ONC (Office of the National Coordinator) website: certification and certified EHR systems, programs designed to support providers as they make the transition:– http://healthit.hhs.gov

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EHR Incentive Program Information

• Massachusetts eHealth Collaborative (MAeHC) website: Regional Extension Center; offers assistance and support to providers in adopting health information technology to achieve meaningful use goals– http://www.maehc.org/index.html

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EHR Incentive Program Information

• New Hampshire Department of Health and Human Services Medicaid Health Information Technology website: NH Medicaid EHR incentive program updates – http://www.NHMedicaidHIT.org

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EHR Incentive Program Information

• New Hampshire Department of Health and Human Services Medicaid EHR incentive program email address: – info@NHMedicaidHIT.org

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Questions?

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