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Rural Health Information Technology Conference
May 2010
Theresa RogersSenior Vice President
HITECH Components
• Incentives/penalties related to Meaningful EHR Use
• Certification and Standards• Regional Extension Centers • State Medicaid support including HIT• Comparative Effectiveness Research• Broadband Expansion and Innovation• Privacy and Security beyond HIPAA• State designated entity HIE support
CMS Proposed Rule on “Meaningful Use”
“Meaningful Use” Rule• Proposed rule published January 13, 2010• Final comments received March 15, 2010• Expect final rule sometime in June 2010
Outlines provisions governing EHR incentive programs
Defines “meaningful use”• Requires use of “certified” EHR• Requires functional measures• Requires clinical quality measures to be reported from EHR
“Meaningful Use” Vision for 2015
Prevention, and management, of chronic diseases• A million heart attacks and strokes prevented• Heart disease no longer the leading cause of death in the US
Medical errors• 50% fewer preventable medication errors
Health disparities• The racial/ethnic gap in diabetes control halved
Care Coordination• Preventable hospitalizations and re-admissions cut by 50%
Patients and families• All patients have access to their own health information• Patient preferences for end of life care are followed more often
Public health• All health departments have real-time situational awareness of outbreaks
MHA Comments to CMS “Meaningful Use”
• Timeline is too aggressive and unrealistic
• Need a glide path to achievable “meaningful use”
• Delay automated quality reporting until EHR quality measures have been tested and validated for EHR reporting
• As proposed wrongfully excludes too many physicians as “hospital-based”
Meaningful Use for 2011
• For EPs• 25 Objectives and Measures• 8 yes/no; 17 numerator/denominator• Clinical reporting
• Hospitals• 23 Objectives and Measures• 10 yes/no; 13 numerator/denominator• Clinical reporting
MHA Comments to CMS “Meaningful Use”
• Unfairly excludes critical access hospitals as “eligible” for Medicaid incentives
• Too restrictive in what qualifies as “reasonable costs” for CAHs
• As a plus, deems those who are “meaningful users” under Medicare to have met “meaningful use” requirements for Medicaid
• Agree with CMS that “meaningful use” is not the appropriate tool to ensure HIPAA privacy and security compliance
Consumer Reaction to “Meaningful Use”
• Proposed rules don’t include sufficient patient privacy protections
• Rules should ensure that consumers have control over their personal health information
Potential Incentive Dollars* – Missouri Hospitals
Medicare
$369 million
Medicaid
$17 million
*Estimated by BKD; data from Medicare cost report and HIDI 2008 data; must meet "meaningful use" criteria using a certified EHR to qualify for incentives; hospitals must have 10% Medicaid utilization to qualify for Medicaid incentive
Funding and IncentivesMedicare Hospital Incentives Timeline
Year of Adoption 2011 2012 2013 2014 2015 2016 2017 Payment for adopting in FY 2011 or before
100% 75% 50% 25%
If first adopting in FY 2012: 100% 75% 50% 25% If first adopting in FY 2013: 100% 75% 50% 25% If first adopting in FY 2014: 75% 50% 25% If first adopting in FY 2015: 50% 25% Penalties begin if not adopting by FY 2015: Three-quarters of the applicable market basket update is reduced by:
33.33% 66.66% 100%
Incentive Eligibility: Medicare
• Subsection (d) hospitals
• Critical Access Hospitals (CAH)
• Non Hospital-based Physicians• Doctor of Medicine, Osteopathy, Doctors of dental
surgery or dental medicine, podiatry, optometry or a chiropractor
PPS Hospital Incentives: Medicare
• Formula as stated in legislation• “Medicare Share” of “Initial Amount” multiplied by “Transition Factor”
adjusted for “Charity Care”
• Based on CMC Certification Number (CCN) not TIN
• Discharges:• Taken from hospital FY ending prior to FY serving as payment year
for preliminary payment; final payment determined using cost report for FY ending during the payment year using discharges from that reporting period
CAH Incentives: Medicare
• Excluded from Medicaid payments
• Up to four years of Medicare incentives• “Reasonable acquisition costs, excluding depreciation and
interest expenses” for computers and associated hardware and software
• “Medicare Share” of “Reasonable Costs” and may depreciate in first year
• Medicare Share bumped 20 percentage points from calculation• Subject to adjustments if not “meaningful user” by 2015
(exemptions up to 5 years)
Incentive Eligibility: Medicaid
• Acute care hospitals• Average stay < 25 days and Medicare CCN within range of 0001-0879• 10 percent Medicaid
• Children’s hospitals• Physicians, nurse midwives, nurse
practitioners, physician assistants, dentists
Medicaid Incentives
• Needn’t demonstrate MU in first year• CAHs don’t qualify under proposed rule• EPs cannot take both incentives *• EP payments higher• Formulas very similar• States paid 100% providers, 90% admin cost
* EPs and Hospitals are allowed a one time “switch” between Medicare and Medicaid programs
Medicare / Medicaid Differences
Medicare MedicaidImplemented at federal level Voluntary State implementation
MBU reductions in 2015 No fee reductions
Must achieve MU in Year 1May adopt, implement or upgrade
Year 1
Up to $44,000 for EPs Up to $63,750 for EPs
Common MU definition States may add requirements
Last year EP may start is 2014; Last payment 2016; Penalties start 2015
Last year EP may start is 2016; Last payments in 2021
Physicians, CAHs, subsection (d) hospitals
Additional EP types and three hospital types
MHA Outreach/Advocacy
• Issue brief(s) on rules• Regular MHA board agenda items• Newsletter updates on HIT and HIE• MHA HIT Advisory Committee• Multi-stakeholder/provider task forces• Educational programming/Webinars• Full participation in MO-HITECH work groups• Seat on Mo-HITECH Advisory Board• Seat on KCBHIE Board• Ongoing discussions with bordering states
Missouri HIT Assistance Center
• University of Missouri Columbia awarded REC grant for Missouri
• Core Support - outreach and educational activities, grants and program mgmt., local workforce support, best practices
• Direct Assistance Support - providing direct onsite technical assistance to providers
REC Priority Providers
• Individual and small group (10 or fewer prescribers) primarily focused on primary care
• Small rural and Critical Access Hospitals • Community Health Centers and Rural Health
Clinics; and • Other settings that predominantly serve
uninsured, underinsured and medically underserved populations.
REC Supplemental Expansion Grant
• Two-year expansion supplement to original REC grant awards
• Intended to ensure the provision of services to CAHs and rural hospitals
• HIDI will be the REC partner to provide and coordinate REC services to hospitals
Potential REC Services for Small Rural and CAHs
Outreach and Education • HIT Web site• Newsletter updates• Meaningful Use Summit
HIT Web Resources Toolkit
Fee-based Services through Group Purchasing Organization (GPO)
Meaningful Use SymposiumAugust 11 – 12, 2010
2-day summit with concurrent sessions • Understanding “meaningful use” basics• EHR functional requirements• Clinical reporting requirements• Incentive calculations• Understanding the vendor certification process• Working sessions with vendors and customer peers• Developing a project plan to meet “meaningful use”• Rural Assistance Center introduction• Missouri statewide HIE update
HIT Web Resources Toolkit
• EHR readiness assessment – tool to learn where you are in the EHR implementation cycle
• EHR Connector – tool to connect you to other customers using your EHR platform
• EHR Selection basics – step-by-step guide to selection of an EHR
• EHR evaluation tool – electronic template organizer to match EHR requirements against vendor capabilities
HIT Web Resources Toolkit
Implementation tutorials including• Project management – timeline, milestones,
risk assessment• Stakeholder engagement• Communication plan• How to manage your vendor• Workflow redesign basics• Parallel testing• “Go live” day management
HIT Web Resources Toolkit
• Physician engagement – how to engage and secure physician buy-in
• Security basics• Technical support requirements outline
Optional Discounted Fee-based Services through GPO
Technical Assistance for• Vendor Selection• Project Management• Shoulder to Shoulder Implementation Management• Practice Workflow Redesign• Assistance with Interoperability and HIE• Implementation of Privacy & Security Best Practices• Technical Infrastructure Support• Data Center Hosting
Ready, Set, Go!
• Implement technology for the right reasons
• Steer the organization toward that vision
• Stay educated and be mindful of “meaningful use” requirements – develop a “meaningful use” roadmap
• Plan for change
Thank you!