Meaningful Use Basics for Healthcare Professionals and Organizations

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  1. 1. Meaningful Use - Basics Dr. Jose I. Delgado Taino Consultants Inc.
  2. 2. Definitions Meaningful Use Attestation Core Objectives Menu Objectives Stages
  3. 3. Meaningful Use Meaningful use is using certified electronic health record (EHR) technology to: Improve quality, safety, efficiency, and reduce health disparities Engage patients and family Improve care coordination, and population and public health Maintain privacy and security of patient health information
  4. 4. Objectives An Objective is a specific result that, in this case, CMS, expect Eligible Providers (EP) to achieve within the specified time frame Core everyone must meet unless there is an exception and the EP can prove the same. Menu a number of options that provider can select to meet requirements* * While there are exclusions provided for some Menu Measures, EPs cannot select a Menu Measure and claim the exclusion if there are other Menu Measures that the EP could report on instead.
  5. 5. Attestation Legal Definition - The act of attending the execution of a document and bearing witness to its authenticity, by signing one's name to it to affirm that it is genuine. Meaningful Use - A healthcare organization must demonstrate meaningful use in order to be eligible for payments from the federal government under either the Medicare or Medicaid EHR incentive program.
  6. 6. Stages 2011-2012 2014 2016 Stage 1 Stage 2 Stage 3 Data capture and sharing Advance clinical processes Improved outcomes
  7. 7. Eligible Providers Medicare Doctor of medicine Doctor of osteopathy Doctor of dental surgery Doctor of dental medicine Doctor of podiatric medicine Doctor of optometry Chiropractor Medicaid Physicians Dentists Certified nurse midwives Nurse practitioners Physicians assistants (in rural health clinic or FQHC led by a physician assistant)
  8. 8. Medicare vs MedicaidMedicare Medicaid Starts in calendar year 2011 Starts in calendar year 2011 Up to $44,000 over five years Up to $63,750 over six years Maximum of $18,000 on the first year if EP bills Medicare $24,000 or more. based on up to 85% of state- calculated global average costs for EHR For maximum reimbursement 1st year cost no later than 2012 1st yr cost no later than 2016 No payments made after 2015 No payments made after 2021 or more than 5 years Penalties start in 2015 (1%) and increases by 1% every year until 2019 with a max of 5%. No Medicaid penalty for failure to demonstrate Meaningful Use
  9. 9. Peculiarities Incentive Payment - Medicare payment is based on 75% of charges allowed for the first 10 months of that year as long as they do not exceed the maximum incentive for the year. EPs may not receive EHR incentive payments from both the Medicare and Medicaid. After an EP qualifies for an EHR incentive payment under one program but before 2015, an EP may switch between the Medicare and Medicaid programs one time.
  10. 10. Medicare Incentive Payment Amounts Qualifies in 2011 Qualifies in 2012 Qualifies in 2013 Qualifies in 2014 Qualifies in 2015 2011 $18,000 2012 $12,000 $18,000 2013 $8,000 $12,000 $15,000 2014 $4,000 $8,000 $12,000 $12,000 2015 $2,000 $4,000 $8,000 $8,000 2016 $2,000 $4,000 $4,000 Total $44,000 $44,000 $39,000 $24,000
  11. 11. Medicaid Incentive Qualifies in 2011 Qualifies in 2012 Qualifies in 2013 Qualifies in 2014 Qualifies in 2015 Qualifies in 2016 2011 $21,250 2012 $8,500 $21,250 2013 $8,500 $8,500 $21,250 2014 $8,500 $8,500 $8,500 $21,250 2015 $8,500 $8,500 $8,500 $8,500 $21,250 2016 $8,500 $8,500 $8,500 $8,500 $8,500 $21,250 2017 $8,500 $8,500 $8,500 $8,500 $8,500 2018 $8,500 $8,500 $8,500 $8,500 2019 $8,500 $8,500 $8,500 2020 $8,500 $8,500 2021 $8,500 Total $63,750 $63,750 $63,750 $63,750 $63,750 $63,750
  12. 12. Applicable Laws American Recovery and Reinvestment Act (ARRA). Title XIII Health Information Technology for Economic and Clinical Health Act (HITECH) Health Insurance Portability and Accountability Act Omnibus Rule False Claims Act Mail and Wire Fraud (18 USC 1518) Criminal Penalties for Acts Involving Federal Health Care Programs (42 USC 1320a-7b)
  13. 13. Audits "Meaningful Use audit is a matter of when you will get audited, not whether. - Anantachai (Tony) Panjamapirom, PhD, Senior Consultant at The Advisory Board Company The Centers for Medicare and Medicaid Services has awarded Figliozzi and Co., of Garden City, N.Y., a contract to audit payments and compliance with the agencys EHR Incentive Program. Contract Award Date: April 16, 2012 Dually-eligible providers will not be audited twice (although a hospital could get audited by the State for eligibility and hospital calculation, and then audited by the CMS contractor for Meaningful Use).
  14. 14. Types of Audits Pre-payment Post Payment Notes: 1. Take audits seriously. 2. Discrepancy in attestation information and information submitted for the audit may result in failure. 3. Failure to provide support documentation on any area may result in 100% re-payment of monies received.
  15. 15. What to expect 1. Electronic letter from audit company from a CMS e-mail address; Letter will be addressed to email address provided during registration 1. Attachment with a request for support documentation 2. About four weeks to submit documentation
  16. 16. Key Items to keep in mind Proof of use Certified EHR. Need Copy of licensing agreement with the vendor or invoices for the period. List of office or outpatient facility where Provider sees patients. Identify if records are kept outside of EHR. Report showing compliance with specific Core Measures must display vendors logo or step by step screenshots which demonstrate that the report was generated by the EHR.
  17. 17. Key Items to Keep In Mind (continuation) Core measure (Protect electronic health information) Provide Proof that a security risk analysis was performed prior to the end of the reporting period. If deficiencies were noted provide implementation plan with completion dates. Menu Set Objective Measures Measures must display vendors logo or step by step screenshots which demonstrate that the report was generated by the EHR. Note: Verify that information used to respond to the audit matches the numbers submitted on the CMS attestation form.
  18. 18. HIPAA Every CE must have a Risk Assessment Completed with all components covered Every Covered Entity (CE) must have a Security Management Plan with dates Every CE entity must be in compliance with the final HIPAA Omnibus Rule A covered entity can be fined $1,000 to $50,000 per patient record up to $1,500,000 if patient records are breached
  19. 19. Data and Retention Information used to respond to the audit must match the numbers submitted on the CMS attestation form. Keep all information regarding Meaningful Use Attestation for a minimum period of 6 years.
  20. 20. Key Items to Remember Policies and Procedures not enough Documentation is key Evidence book Follow the steps Risk Assessment Risk Management Training ACT NOW!!
  21. 21. Dr. Jose I Delgado Tel 904-794-7830