Meaningful Use: Roadmap for Successful Attestations

Presented by:Darlene Creech, MPH

Assistant Program ManagerHealth Information Technology

NC Division of Medical Assistance

6/23/12

EHR Incentive Program Timeline

• 10-year program: 2011-2021

• EPs may participate in any 6 years (consecutive or non)

• Year 1: adopt, implement, or upgrade (AIU) to certified EHR technology

• Year 2: meaningfully use for a continuous 90-day period

• Year 3 and beyond: demonstrate MU for the entire year

2016 - Last year to begin program and receive full incentive payments

2021 -Program ends

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EPs under the NC Medicaid EHR Incentive Program include: Physicians (MDs and DOs); Nurse practitioners; Certified nurse midwives; Dentists; and, Physician assistants who furnish services in a

Federally Qualified Health Center or Rural Health Clinic led by a physician assistant.

EP Types

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Incentive payments for EPs are tied to individual practitioners, however a third party can attest on his/her behalf (EP must personally sign attestation)

Each EP is eligible for only one incentive payment per payment year, regardless of how many practices or locations at which he or she provides services

Hospital-based professionals are not eligible

EP Attestation

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To qualify for an incentive payment under the NC Medicaid EHR Incentive Program, an EP must meet one of the following criteria:

Have a minimum 30% Medicaid patient volume; Have a minimum 20% Medicaid patient volume (pediatrician);

or, Practice predominantly in a Federally Qualified Health Center

or Rural Health Center and have a minimum 30% patient volume attributable to needy individuals.

EP Patient Volume Requirements

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Medicaid PV Percentage:

Medicaid PV = All encounters paid in part or whole by Medicaid in 90-day periodTotal PV = All encounters, regardless of the payment method in same 90-day period

Paid encounters, not billed claims

An encounter is service(s) rendered to a unique individual on any one day

Date of service (not date of payment) within the 90-day period Pay attention to ‘attending provider’ and ‘billing provider’ issues

Make State aware of any unusual billing issues

EP Patient Volume Formula

Progress! Eligible in NC:

• 3,524 EPs• 92 EHs

Paid to date: $41 million• 1,133 EPs• 21 EHs

EPs Participating To DateType Specialty #

Individual physician PEDIATRICS 505GENERAL/FAMILY PRACTICE 161OBSTETRICS/GYNECOLOGY 139INTERNAL MEDICINE 115PSYCHIATRY 64

1,152 ANESTHESIOLOGY 21NEUROLOGY 20INFECTIOUS DISEASE 17GENERAL/THORACIC SURGERY 13RADIOLOGY/NUCLEAR MED 12CARDIOLOGY 11Various Specialties 74

Individual dentist GENERAL DENTIST 6464

Hospitals HOSPITALS (general, acute, critical access) 25

25Nurse practitioner NURSE PRACTITIONER 156

156Nurse midwife NURSE MIDWIFE 33

33Mental health provider MENTAL HEALTH NURSE PRACT 19

191449

PARTICIPANTS BY TYPE AND SPECIALTY

TOTAL (AS OF 6/19/12)

Welcome to the NC-MIPS 2.0 Portal

MIPS 2.0 Changes Status Page

Allows you to see past attestation years Shows you where you are in the current attestation

process In process, submitted, awaiting provider response,

validating, approved, paid, denied Demographics Page

Shows both CMS and NC information so you can see if there is a matching problem

Shows provider and payee MPN and asks if that is correct (gives link for where to go correct)

MIPS 2.0 Changes - Patient Volume Yes/No questions you will be asked for INDIVIDUAL methodology:

Did you enter only those encounters attributable to the individual EP in the numerator and denominator, NOT the patient volume numbers for the entire group?

Did you list the billing MPNs from ALL practices you included in the patient volume numbers?

Did you include in the numerator all encounters covered by Medicaid, even where Medicaid paid for only part of a service?

Did you exclude from the numerator denied claims that were never paid at a later date?

Did you include encounters in the denominator where services were provided at no charge?

Are your patient volume numbers based on date of service and not date of claim or date of payment?

Do the numbers you entered represent encounters and not claims?

MIPS 2.0 – Patient Volume

Additional for group methodology: Did you include all encounters?

Can’t be limited in any way (count non-EPs such as phlebotomists and RNs encounters)

Did you include all associated MPNs? Provide any/all MPNs associated with the group

(even if an MPN is no longer being used but was used during the 90-day reporting period)

MU Overview

The information in this presentation: Is relevant for Stage 1 MU Primarily applies to EPs Stage 2 MU: Finalized after the NPRM (published March 7,

2012) is determined

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Electronic capture of health information Use the electronic information to track key clinical

conditions Communicate electronic information for care

coordination Implement clinical decision support tools for disease

and medication management Engage patients and families Report Clinical Quality Measures (CQMs) and public

health information

What is the Goal of Stage 1 MU?

MU Overview

Reporting period is 90 days for the first year and 365 days thereafter

Measures are reported by attestation for Stage 1 Must meet all the measures to receive a MU

payment To meet certain measures, 80% of patients must have

records in the certified EHR technology (at locations with certified EHR technology)

MU Overview

If an EP works at more than one location: Not required to have certified EHR at all locations Must have 50% of total patient encounters at locations

where certified EHR is available

If locations have multiple certified EHRs, add together the numerator, denominators and exclusions

Exclusions

Count as ‘meeting the measure’ in Stage 1 Allowed if the measure is not relevant to the

provider’s scope of practice Allowed if the provider is unable to perform a

measure, such as submission of public health data

Exclusions, cont’d

Two automatic exclusions currently exist: Submission of data to NC Immunization Registry

http://www.immunize.nc.gov/providers/ncirdataexchange.htm Submission of syndromic surveillance data to PH

http://epi.publichealth.nc.gov/cd/meaningful_use/syndromic.html

Patient Volume Period

Medicaid patient volume period: Exactly 90 days, not 3 months Within the previous calendar year for EPs

Year 2012 payment – 90 continuous days between January 1, 2011 – December 31, 2011

MU Reporting Period

MU Reporting Period Exactly 90 days, not 3 months Within the current calendar year for EPs

Year 2012 payment – 90 continuous days between January 1, 2012 – December 31, 2012

MU Measure Denominators Depends on the individual situation Can be all the unique patients seen by the EP

during the reporting period (one location with EHR technology) OR

Those unique patients seen at locations during the reporting period where certified EHR technology is available (multiple locations with certified EHR technology for 80 percent of their patient encounters)

MU Structured Data

Data entered into a specified field as opposedto free text in a chart note

MU Structured Data, cont’d

The following core MU measures require structured data:

Record demographics Maintain an up-to-date problem list Maintain active medication list Maintain active medication allergy list Record and chart changes in vital signs

Meaningful Use Reporting Requirements

15 + 5 + 6 = MU Core Menu CQMs Meaningful Measures Measures Use

Adopt, Implement, Upgrade (AIU) or Meaningful Use (MU)

AIU or Meaningful Use Selection *Indicates a required field

*EHR Certification Number: 129456789AX1

*Please indicate your approach:

Adopt, Implement, or Upgrade Meaningful Use

Measure Selection Home PageMeasure Selection

Measure Set Actions CompleteValidMeaningful Use Core Measures Begin Review X √Meaningful Use Menu Measures Begin Review X √Core Clinical Quality Measures Begin Review X √Alternate Clinical Quality Measures Begin Review X √Additional Clinical Quality Measures Begin Review X √

Core MU MeasureQuestion 1 of 15

(*) Red asterisk indicates a required field.Objective: Use computerized provider order entry (CPOE) for medication orders

directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local and professional guidelines.

Measure: More than 30% of all unique patients with at least one medication in their medication list seen by the EP have at least one medication order entered using CPOE.

Exclusion: Based on all patient records, any EP who writes fewer than 100 prescriptions during the EHR reporting period would be excluded from this requirement. Exclusion from this requirement does not prevent an EP from achieving meaningful use.

Does this exclusion apply to you? Yes No

Core MU MeasureQuestion 1 of 15, continued

*Patient Records: Please select whether the data used to support the measure was extracted from all patient records or only from patient records maintained using certified EHR technology. This data was extracted from all patient records, not just those maintained using certified EHR technology. This data was extracted only from patient records maintained using certified EHR technology.

*Numerator: The numerator is the number of patients in the denominator that have at least one medication order entered using CPOE.

*Denominator: The denominator is the number of unique patients with at least one medication in their medication list seen by the EP during the EHR reporting period.

Core MU MeasureQuestion 2 of 15

(*) Red asterisk indicates a required field.

Objective: Implement drug-drug and drug-allergy interaction checks.

Measure: The EP has enabled this functionality for the entire EHR reporting period.

*Have you enabled the functionality for drug-drug and drug-allergy interaction checks for the entire EHR reporting period?

Yes No

Core MU Measure Question 3 of 15

(*) Red asterisk indicates a required field.

Objective: Maintain an up-to-date problem list of current and active diagnoses.

Measure: More than 80% of all unique patients seen by the EP have at least one entry or an indication that no problems are known for the patient recorded as structured data.

*Numerator: The numerator is the number of patients in the denominator who have at least one entry or an indication that no problems are known for the patient recorded as structured data in their problem list.

*Denominator: The denominator is the number of unique patients seen by the EP during the EHR reporting period.

Core MU Measure Question 11 of 15

(*) Red asterisk indicates a required field.

Objective: Implement one clinical decision support (CDS) rule relevant to specialty or high clinical priority along with the ability to track compliance with that rule.

Measure: Implement on CDS rule.

*Have you implemented one CDS rule relevant to specialty or high clinical priority along with the ability to track compliance to that rule?

Yes No

*Enter the CDS rule that was implemented:

Menu MU MeasureQuestion 2 of 10

(*) Red asterisk indicates a required field.

Objective: Incorporate clinical lab-test results into EHR as structured data.

Measure:More than 40% of all clinical lab test results ordered by the EP during the EHR reporting period whose results are in either a positive/negative or numerical format are incorporated in certified EHR technology as structured data.

Exclusion: Based on all patient records, any EP who orders no lab tests whose results are either in a positive/negative or numeric format during the EHR reporting period would be excluded from this requirement. Exclusion from this requirement does not prevent an EP from achieving meaningful use.

Does this exclusion apply to you?Yes No

Menu MU MeasureQuestion 2 of 10, continued

*Numerator: The numerator is the number of lab tests whose results are expressed in a positive or negative affirmation or as a number which are incorporated as structured data.

*Denominator: The denominator is the number of lab tests ordered during the EHR reporting period by the EP whose results are expressed in a positive or negative affirmation or as a number.

Menu MU MeasureQuestion 6 of 10

(*) Red asterisk indicates a required field.

Objective: Use certified EHR technology to identify patient-specific education resources and provide those resources to the patient if appropriate.

Measure: More than 10% of all unique patients seen by the EP during the EHR reporting period are provided patient-specific education resources.

*Numerator:The numerator is the number of patients in the denominator who are provided patient education specific resources.

*Denominator: The denominator is the number of unique patients seen by the EP during the EHR reporting period.

CQMs Overview

Focus on disease conditions and help measure if a patient gets the right treatment, in the right amount, at the right time

EPs must report a total of 6 CQMs*

*The total could be as high as 9 depending on how many core CQMs have zeros

CQMs Overview, cont’d

CQM Core Requirements: 3 core or alternate core CQMs Note: For each core measure with a zero denominator,

EPs must report an alternate core measure. CQM Additional Requirement: 3 from a list of 38

additional CQMs

CQMs All CQMs for 2012 are NQF-endorsed There is no requirement to meet a certain value

for any of the CQMs For Stage 1 MU, CQM reporting will be by

attestation CMS is working on aligning CQMs across

programs (PQRI, CHIPRA) JCAH, NCQA, and AMA are also aligning standards

CQMsQuestion 1 of 3

(*) Red asterisk indicates a required field.

Instructions: All three Core Clinical Quality Measures (CQMs) must be submitted. For each Core CQM that has a denominator of zero, an Alternative CQM must also be submitted.

NQF 0013 - Hypertension: Blood Pressure Management

Description: Percentage of patient visits for patients aged 18-years and older with a diagnosis of hypertension who has been seen for at least two office visits with blood pressure recorded.

*Numerator: *Denominator:

Lessons Learned from 2011 Attestations Ensure that information in CMS Registration agrees with

Medicaid information on file Enter the same payee in CMS Registration as for Medicaid

(can change if desire) Wait until receipt of a welcome email from Medicaid before

attesting Processing the attestation won’t begin until a signed copy is

received Respond to outreach – after 45 days a denial of eligibility

occurs

Lessons Learned, cont’d For group methodology, include all encounters in the

group FQHC/RHC can count core as well as other services Make sure vendor contracts include ongoing

maintenance and upgrades FQHC EPs who are part-timers may have matching issues

(address from other practice location is in Medicaid system) – communicate with Medicaid!

When calling for assistance, have EP’s SS# and NPI ready

Stage 2 MU Proposed Changes

More emphasis on patient engagement More emphasis on actual exchange of

information rather than simply testing Patient volume – recent 12 months preceding

attestation instead of prior year Would include encounters not paid by Medicaid Would include MCHIP encounters

Stage 2 MU Proposed, cont’d MU measures remain at 20 total but include 17

core and 3 menu Compliance rates increased on many measures EPs would report 12 CQMs electronically Data standardization would be required (for

certifying EHRs) Implementation of Stage 2 criteria would be

delayed until 2014 calendar year for EPs

Moving Forward . . .

Establish all practice workflows affected by EHR implementation

Perform the security risk analysis and address any deficiencies

Implement policies and procedures outlining staff responsibilities

Implement workflow changes as necessary Implement documentation methods and maintain

relative documents for 6-years post-attestation

Contact For questions about the program or process, contact:

919-855-4200 NCMedicaid.HIT@dhhs.nc.gov

To see the Medicaid Special Bulletin, visit http://www.ncdhhs.gov/dma/bulletin/June2012-Special-Bulletin-EHR.pdf

To access the NC-MIPS Portal, visit https://ncmips.nctracks.nc.gov/