assistance in attesting & meeting meaningful use · 2018. 7. 19. · meaningful use • since...
TRANSCRIPT
Assistance in Attesting & Meeting Meaningful Use
• Since 2011, the S.C. Medicaid EHR Incentive Program has been administered by the SC Department of Health and Human Services’ Health Information Technology (HIT) Division.
• 2016: The last program year that an eligible professional could have begun participation in the Medicaid EHR Incentive Program.
• 2021: The last program year for which a provider can attest to receive an incentive payment
Notable Years
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Payments Made5,746 payments $82,180,878 2,833 individual providers
173 payments $88,353,290 60 hospitals
Payments By Provider Types4,121 physicians 81 certified nurse midwives1,188 nurse practitioners 33 physician assistants
303 dentists 20 optometristsA maximum of 6 payments totaling up to $63,750 are available.
Pediatricians: reducedMedicaid volume
• $21,250 in their 1st year $ 14,167• $ 8,500 each of 2nd – 6th years $ 5,667
* Updated weekly at scdhhs.gov/hit
Impact to Date *
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Provider Eligibility
• The following are provider types eligible to participate in the S.C. Medicaid EHR Incentive Program
Physician (including MD, DO, and Optometrist)DentistNurse PractitionerCertified Nurse MidwifePhysicians Assistant (must practice in a FQHC or RHC for which the PA is the medical director or owner)
• Minimum Percentage of Medicaid (Needy) Patient Encounters
>29.5% of total encounters; > 19.5% if Pediatrician
Needy is an option available to providerwho practices predominantly in an FQHC or RHC.
Provider Eligibility
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At least one incentive payment made to the provider or designee prior to PY 2017:
• for services at current practice; or• for services at another practice in SC; or• for services at another practice another state or US territory.• submit provider name and NPI to find out – we’ll check and let
you know
Not Hospital-Based in current program year.• Greater then 90% of provider’s Medicaid claims have place of
service code of 21 (ER) or 23 (Hospital) as determined by SCDHHS.• Has nothing to do with being hospital employed.• Each year can be different determination so submit attestation
without assumption of your own claims history.
Provider Eligibility
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An EP who initially meets the definition of hospital-based EP but who can demonstrate the following may be determined to be a nonhospital-based EP by the HIT Division:
• EP funds the Certified EHR Technology without reimbursement from an eligible hospital, and
• EP uses such Certified EHR Technology in the inpatient or emergency department of the hospital (instead of the hospital's Certified EHR Technology)
If the above is applicable, please contact the HIT Division as soon as possible for more information, or with questions.
Not Hospital-Based But EP Funds/Uses Other Certified EHR Technology
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Patient Volume Requirement
3 Decisions for Each Provider/Group to Make
1. Medicaid or Needy Encounters
2. Individual or Group Volume
3. Encounters or Panel Methodology
Consider Decisions While CheckingAlternate Patient Volume Reporting Periods
Any consecutive 90-day period• in the prior calendar year; or
• 12 months prior to submitting the attestation.
How to Calculate Your Patient Volume
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Definition of A Medicaid Patient Encounter
Services rendered on any one day to an individual enrolled in a Medical Assistance program regardless of payment liability. Can include:
• Medicaid paid encounters• Medicaid zero-paid encounters (includes denials because
beneficiary maxed out; service was not covered, another payer’s payment exceeded Medicaid payment; claim not submitted timely)
• Medicaid managed care plan encounters • Medicaid is primary or secondary • CHIP encounters.
Multiple procedures in the same day for the same individual rendered by the same provider count as only ONE encounter.
Encounter Types
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Definition of A Needy Patient Encounter
• EP who practices predominantly in an FQHC or RHCMore than 50% of their total patient encounters occurred at FQHC/RHC or Tribal Health Clinic during a provider selected 6-month period in either the 12 months prior to attestation or within the calendar year prior to the program year (2016 if attesting to PY17).
• Encounters that qualify as Needy:
State only funds or CHIP Uncompensated care; or Care furnished at no cost; or Care at cost based on a sliding scale.
Encounter Types - continued
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Individual or Group Patient Volume
• Patient encounters from one (or more) clinical sites of practice. Does not need to be across all of a EP’s sites of practice
• At least one site must be where EP is meaningfully using certified EHR technology
• Can include Medicaid patients seen outside South Carolina
Individual Patient Volume
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• Example 1: Dr. Campbell, a non-hospital based OBGYN, had 80 Medicaid patient encounters out of 200 total patient encounters in a continuous 90-day period duringthe prior calendar year
• With 40% patient volume, Dr. Campbell meets the 30% patient volume threshold.
Patient Volume Calculation
80 Medicaid Patient EncountersX 100 = 40%
200 Total Patient Encounters
Calculating Medicaid IndividualPatient Volume
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• Example 2: Dr. Johnson, a non-hospital based Pediatrician, had 120 Medicaid patient encounters out of 500 total patientencounters in a continuous 90-day period during the priorcalendar year
• With 24% patient volume, Dr. Johnson meets the 20%patient volume threshold for pediatricians.
Patient Volume Calculation
120 Medicaid Patient EncountersX 100 = 24%
500 Total Patient Encounters
Calculating Medicaid IndividualPatient Volume
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• If appropriate for the EP (i.e., if an EP only sees Medicare, commercial, or self-pay patients, this is not an appropriate calculation)
• Includes those who are not EP types. Must use patient volume for all of the providers in the clinic/group (Tax Identification Number (TIN)) and not limit it in any way.
• If one does not agree to use the group calculation, then everyone has to use the individual patient volume calculation.
• If the entire clinic reaches the 30 percent paid Medicaid encounter threshold, all EPs in the clinic will have met the threshold.
Group Proxy Patient Volume
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• Example 3: Sum the Medicaid patient encounters and total patient encounters for all Medicaid providers in the group (even those not designated as EPs) in a continuous 90-day period during the prior calendar year
Group Proxy Patient Volume Calculation
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Provider Name Category EP Status
Medicaid Patient
Encounters
Total Patient
Encounters
Dr. Smith MD Yes 80 200Sandy Buck NP Yes 50 100Kim Jones RN No 150 200Leslie Dee PharmD No 80 100Dr. Shaw DDS Yes 30 300Dr. Wong DDS Yes 5 100Dr. Toby MD Yes 20 200
Total 415 1200
• Example 3: The practice had 415 Medicaid patient encounters and 1,200 total patient encounters during the 90-day period resulting in a group proxy patient volume of 35%.
Group Proxy Patient Volume Calculation
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Patient Volume Calculation
415 Medicaid Patient EncountersX 100 = 35%
1,200 Total Patient Encounters
• Example 3: With 35% aggregate patient volume, Dr. Smith, Sandy Buck, Dr. Shaw, Dr. Wong, and Dr. Toby are EPs who meet the 30% patient volume threshold.
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Provider Name Category EP Status
Medicaid Patient
Encounters
Total Patient
Encounters
Dr. Smith MD Yes 80 200
Sandy Buck NP Yes 50 100
Kim Jones RN No 150 200
Leslie Dee PharmD No 80 100
Dr. Shaw DDS Yes 30 300
Dr. Wong DDS Yes 5 100
Dr. Toby MD Yes 20 200
Total 415 1200
[ Medicaid patients assigned to the provider in the patient volume 90-day period with at least one encounter in the calendar year preceding the start of the 90-day period ]
+[ Unduplicated Medicaid encounters
in that same 90-day period ]DIVIDED BY
[ Total patients assigned to the provider (all payers) in the same 90-day period with at least one encounter in the
calendar year preceding the start of the 90-day period ]+
[Total unduplicated encounters (all payers) in same 90-day period.]
Patient Panel Method (for Managed Care)
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MEANINGFUL USE
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Stage 2 Selected Objectives: Actions Allowable Beyond 90-Day EHR Reporting Period
• Objective 1 - Protect Patient Health Information
• Objective 5 - Health Information Exchange
• Objective 6 - Patient-Specific Education
• Objective 8 – Patient Electronic Access
• Objective 9 - Secure Electronic Messaging
Actions Available Beyond 90-Day EHR Reporting Period
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Objective 1 - Protect PHI
Conducting a security risk analysis is required when certified EHR technology is adopted in the first reporting year. It is acceptable for the security risk analysis to be conducted outside the EHR reporting period; however, the analysis must be unique for each EHR reporting period, the scope must include the full EHR reporting period, and must be conducted within the calendar year of the EHR reporting period (January 1st –December 31st).
In subsequent reporting years, or when changes to the practice or electronic systems occur, a review must be conducted. The review must be conducted on an annual basis prior to the date of attestation.
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Eligible professionals (EPs) must attest YES to conducting or reviewing a security risk analysis as necessary and implementing security updates as necessary and correcting identified security deficiencies to meet this measure.
This provider action may occur before, during, or after the 90-day MU reporting period.
Must occur within the calendar year in which the EHR MU reporting period occurs to count in the numerator
Objective 5 - Health Information Exchange
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• The EP that transitions or refers their patient to another setting of care or provider of care must—(1) use CEHRT to create a summary of care record; and (2) electronically transmit such summary to a receiving provider for more than 10 percent of transitions of care and referrals.
This provider action may occur before, during, or after the 90-day MU reporting period.
No earlier than the start of the same calendar year as the EHR reporting period and no later than the date of attestation to count in the numerator.
DO YOU STILL HAVE TIME TO PROVIDE MATERIALS TO PATIENTS SEEN DURING THE EHR REPORTING PERIOD UP
BEFORE THE SUBMISSION DEADLINE?
Objective 6 - Patient-Specific Education
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Patient-specific education resources identified by CEHRT are provided to patients for more than 10 percent of all unique patients with office visits seen by the EP during the EHR reporting period.
Objective 8 – Patient Electronic Access
For Measure 2, patient action may occur before, during, or after the 90-day MU reporting period.Must occur within the calendar year in which the MU reporting period occurs to count in the numerator.• Count if a patient elects to "opt out" of participation, that
patient must still be included in the denominator.• “Opt out” patients must be provided all necessary
information to subsequently access their information or opt-back-in without further action required by the provider.
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More than 5 percent of unique patients seen by the EP during the EHR reporting period (or his or her authorized representatives) view, download or transmit to a third party their health information during the EHR reporting period.
Objective 9 - Secure Electronic Messaging
This provider action may occur before, during, or after the 90-day MU reporting period but must occur within the calendar year in which the MU reporting period occurs to count in the numerator.
• Count interactions with a patient-authorized representative• Provider-to-provider communications if the patient is
included. • Patient-initiated communication only if the provider
responds to the patient.
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More than 5 percent of unique patients seen by the EP during the EHR reporting period, a secure message was sent using the electronic messaging function of CEHRT to the patient.
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Q & A
A. NO.
If a provider or a practice used individual or needy volume in the past, they are NOT locked in to using that method for future program years.
Decide which method will help the most providers qualify.
You are strongly encouraged to compare the two.
Do I have to use the same Patient Volume method each year?
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Meaningful Use:
EP demonstrating MU must have at least 50 percent of his/her patient encounters during the EHR reporting period at a practice/location or practices/locations equipped with certified EHR technology capable of meeting all of the MU objectives.
When providers work at more than one clinical site of practice, are they required to use data from all sites of practice to support their demonstration of minimum patient volume thresholds and MU for the Medicaid EHR Incentive Program?
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Patient Volume:
EPs may choose one or more clinical sites of practice in order to calculate their patient volume.
• PV does not need to be across all of an EP’s sites of practice.
• At least one of the locations EP uses certified EHR technology
• Using individual patient volume calculation (i.e., not using the group/clinic proxy option), an EP may calculate across all practice sites, or just at the one site.
A: CMS considers these two separate, but related, issues.
Meaningful Use:
EP demonstrating MU must have at least 50 percent of his/her patient encounters during the EHR reporting period at a practice/location or practices/locations equipped with certified EHR technology capable of meeting all of the MU objectives.
When providers work at more than one clinical site of practice, are they required to use data from all sites of practice to support their demonstration of minimum patient volume thresholds and MU for the Medicaid EHR Incentive Program?
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A: CMS considers these two separate, but related, issues.
A: Yes
A nonhospital-based EP who sees patients in an in-patient setting can include the in-patient encounter in their Medicaid patient volume calculation.
Both an eligible hospital and an EP can include an encounter from the same patient in their Medicaid patient volume calculations, respectively. The services performed by the EP are distinct from those performed by the eligible hospital.
Can a nonhospital based eligible professional (EP) include their in-patient encounters for purposes of calculating Medicaid patient volume even if the patient is included in the eligible hospital's patient volume for the same 90-day period?
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A.NO.
Location should not be used to calculate the EP’s outpatient encounters, nor would it be included in the calculations of the EP’s MU measures.
This is true even if the location does possess ambulatory certified EHR technology covering the relevant MU objectives but does not implement the functionalities.
Can consider location only if EP has access to certified EHR technology certified to fills the gaps between the technology implemented by the location and the certified EHR technology necessary to meet the relevant meaningful use objectives.
If the EP chooses to equip the location with certified EHR technology with the applicable criteria, the EP must then include.
If an EP practices at an outpatient location that has not implemented all the functionalities necessary for the EP to meet MU, is that location considered equipped with certified EHR technology?
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A.YES. EPs are required to demonstrate a patient volume of at least 30 percent of Medicaid patients and EHs are required to demonstrate a patient volume of at least 10 percent of Medicaid patients over a 90-day period in the prior calendar year or in the 12 months before attestation.
Rounding Allowed• 29.5 percent and higher to 30 percent for EP• 19.5 percent and higher to 20 percent for EP pediatricians• 9.5 percent and higher to 10 percent for EH
Can EPs or EHs round their patient volume percentage when calculating patient volume in the Medicaid EHR incentive program?
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• Services rendered to an individual on any one day where Medicaid paid for part or all of the service; or paid all or part of the individual's premiums, copayments and cost-sharing.
A.Yes. Multiple providers may include a Medicaid encounter for the same individual seen by each of the providers on the same day.
What is an unduplicated Medicaid Encounter?
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When a patient has multiple encounters on the same day with different providers, may all encounters be used for calculating patient volume?
Yes.
EP would add these to instate Medicaid encounters for the numerator and add out-of-state total patient encounters to instate total patent encounters for the denominator.
Can I use out-of-state Medicaid encounters when calculating patient volume?
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NO.
This is a common misconception. It is relevant that a Medicaid beneficiary received service, but it is not relevant that Medicaid paid any part of the claim.
Does Medicaid need to pay any part of the claim for me to include a service to a Medicaid beneficiary?
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A.An EP whose date of hire by a clinic/group falls after the 90-¬day period selected for the clinic/group patient volume calculation may utilize the clinic/group patient volume as a proxy for his or her own patient volume, as long as it is appropriate as a patient volume methodology calculation for the EP
A newly hired EP may only utilize clinic needy patient volume if the EP meets the requirement of having practiced predominantly in an FQHC or RHC (as determined by practice activity in the previous calendar year).
Note Using group volume for Needy encounters is allowed.
What if my practice has a provider who didn’t begin working at the practice until after the date we selected to use for group patient volume?
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A. Yes.
All providers who have a Medicaid encounter within a group practice can be included in the Medicaid group patient volume calculation.
Are we able to include Medicaid encounters for our Medicare EPs in the Medicaid patient volume calculation when attesting as a group?
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3 potential ways to qualify for an incentive payment. For illustrative purposes, assume the EP in the below example joined the practice in CY 2017. Can attest prior to June 30, 2018, after the EP establishes his/her individual 90-day patient volume period as an EP from:1. the prior calendar year (2017); or 2. the 12-month period prior to attestation; or
3. If he/she is part of a group using the group 90-day patient volume and it is appropriate (i.e. he/she sees or will see Medicaid patients). It is not a requirement that he/she was in the group for the period that is the basis for the proxy (for example if the EP joined the practice in December 1, 2017 and the practice’s group patient volume start date is March 1, 2017).
How can an EP who is new to a practice meet the patient volume/practice predominantly criteria to be eligible for the Medicaid Electronic Health Records (EHR) Incentive Program?
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A.NO.
However, all the providers, regardless of eligibility or participation status in the Medicaid EHR Incentive Program, must be included in that TIN group’s patient volume.
This volume can be across one TIN location or multiple locations but all providers at any included location must have their patient volumes included.
The same volume should be used for all participating providers for the program year they are attesting to.
If you are not able to use the same patient volume due to an error in the SLR, please contact 803-898-2996 – this may be due to a technical issue and you need to speak with us asap.
If a provider chooses to use a TIN’s group patient volume, do all the providers under the TIN have to participate in the Medicaid EHR Incentive Program?
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S.C. Medicaid EHR Incentive Program Resources
SCDHHS HIT E-mail Contact:
SCDHHS HIT Division: (803) 898-2996
SCDHHS HIT Web page: www.scdhhs.gov/hit
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S.C. Medicaid EHR Incentive ProgramState Level Repository (SLR)
Designed for eligible professionals (EP) and eligible hospitals (EH) to attest to meeting the requirements for the S.C. Medicaid Electronic Health Record (EHR) Incentive Program.
www.scdhhs.gov/slr
THANK YOU
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