Meaningful Use for Eligible Professionals (EPs) Q&A

VITL Staff

06-16-2011 (updated 6-17-2011) V6.0

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Notes

Not legal advice

CMS and State of Vermont rules may change

Check vitl.net for updates

Medicaid

Medicare

Medicare/Medicaid

Carol Kulczyk ckulczyk@vitl.net

Paul Forlenza pforlenza@vitl.net

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Medicaid: Is reimbursement still based on 85% of EHR implementation costs?

• Originally CMS required that eligible professionals prove spending at least 15% of the total cost of EHR technology

• CMS now assumes EPs attesting to MU have met the 15% requirement

• No proof is necessary for attestation but invoices should be kept for audit purpose

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Medicaid: If we implemented an EHR in 2010, does that mean we have met meaningful use for 2011?• Adopting, implementing or upgrading (A/I/U)

to a certified EHR will qualify you to receive an incentive payment for 2011

• Does not matter when the system was originally implemented. However, incentives are only available for certified systems

• Patient volume thresholds must be met in any consecutive 90-day period from the previous 12 months from the date of attestation.

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Medicaid: How do we calculate patient volume since we see patients with primary and secondary Medicaid coverage and Catamount MVP or BC?• All Medicaid encounters will count including

secondary and Catamount• Medicaid % of unique patient encounters is

calculated by dividing the Medicaid related encounters by total patient encounters for the reporting period

• The state of Vermont will be issuing detailed rules for calculating patient encounters.

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Medicaid: Does an EHR implementation need to be completed in 2011 to qualify for incentive payment? • EP does not have to install certified EHR

technology – acquire, purchase or secure access to certified

EHR– install or commence using certified EHR– expand functionality of certified EHR – upgrade to certified EHR

• Signed contract indicating that the provider has adopted or upgraded would be sufficient

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Medicare: What determines whether or not EP gets the maximum incentive payment?• Incentive Payments based on 75% of Part B

allowable charges• To receive $18,000 (maximum in year 1), EP

must have $24,000 in allowable charges• Medicaid does not have this requirement

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Medicare: Incentive Payment

• When an EP has attested to MU and has $24,000 in allowable charges for a calendar year, CMS will send a payment

• If $24,000 is not reached in the calendar, CMS will make payment = 75% of allowable charges after February of the next calendar year– If $12,000 in 2011 allowable charges, CMS will

make payment after February 2012 calculated as $12,000 x 75% = $9,000

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Medicare/Medicaid: What are reporting periods for EPs?

• Reporting period based on calendar year• Medicare:

– 1st year: any consecutive 90 days for 1st year– 2nd year: one full calendar year

• Medicaid:– 1st year: no reporting period; demonstrate A/I/U– 2nd year: any consecutive 90 days – 3rd year: one full calendar year

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Medicare/Medicaid: Important Dates

• Medicare– October 3, 2011 last day to begin 90-day reporting

period for 2011 – February 29, 2012 last day to register and attest

for MU to receive an incentive payment for 2011• Medicaid

– October 3, 2011 State of Vermont scheduled to open Medicaid incentive program

– Check www.vitl.net for updates

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Medicare/Medicaid: Definition of exchange of key clinical information – part I

• Electronic transmission and acceptance of key clinical information using the capabilities and standards of certified EHR technology

• Format– if information available in structured format, must

be exchanged in structured format– if available only in unstructured electronic formats

(e.g., free text/scanned images), unstructured information exchange would satisfy the measure

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Medicare/Medicaid: Definition of exchange of key clinical information – part II

• Following would not utilize the certification capability of certified EHR technology to electronically transmit the information and would not meet the measure of this objective– physical media such as CD-ROM, USB, hard drive

• Using the method your EHR vendor utilized to certify your EHR will meet the requirements

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Medicare/Medicaid: How do I attest to Meaningful Use?

• Medicare– Attest using the CMS web based system

• Medicaid– Check www.vitl.net for future announcements

– VITL will help you be prepared for meeting MU and attest

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VITL Services

• Workflow analysis• Technology

assessment vendor selection

• Practice culture assessment

• Project management

• EHR vendor selection• EHR deployment and

implementation• Implementing privacy

policies consistent with HIPAA

• Achieving meaningful use of the EHRs

Meaningful Use for Eligible Professionals (EPs) Q&A

VITL Staff

06-16-2011 V5.0