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1 /CHUG ARRA Overview /
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GE Healthcare
Meaningful Use Part 1: Overview of the Regulations and Their Implications
Mark Segal, PhD and Joann Kern, RN
Centricity Healthcare User Group
April 30 , 2010
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The HITECH Act and Meaningful Use
HITECH Act•
Part of American Recovery and Reinvestment Act of 2009 (ARRA) –
February 2009
•
$36+B for HIT Infrastructure and EHR Adoption/Use
Meaningful Use•
Eligible Professionals (EP) and Hospitals demonstrate Meaningful Use of Certified EHR to receive Medicare and Medicaid EHR incentives
Major Policy Issues
Certification & Standards
Quality Reporting
Meaningful Use
HIT Policy/ Standards
Committees
HIT Policy/ Standards
Committees
GE, EHRA, eHI, HIMSS, Customers
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Briefing on the ONC AgendaBriefing on the ONC AgendaDavid Blumenthal, MD, MPPDavid Blumenthal, MD, MPPNational Coordinator for Health Information Technology , December 15, 2009
Meaningful Use and Other Medicare and Medicaid Incentive Policies: NPRM
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Three Regulations•
CMS: Meaningful Use and Payment Policies–
Notice of Proposed Rulemaking (NPRM)–
60-day comment period from January 13, 2010: March 15, 2010–
Final Rule expected by June 2010
•
ONC: Standards and Certification–
Interim Final Rule (IFR)–
Effective 30 days after publication date (January 13 +30)–
60-day comment period from January 13, 2010: March 15, 2010–
Final Rule expected by June 2010
•
ONC: Testing and Certification Program–
NPRM published March 10, 2010–
Temporary and Permanent certification programs–
30 (Temporary) and 60-day (Permanent) comment periods–
Multiple certifying bodies: ONC rules/criteria and NIST testing methods–
Final Rule expected by June 2010
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Evolution of Meaningful Use
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Meaningful Use Criteria and Reporting
Objectives/MeasuresOverall•
Few changes
from Policy Committee•
Each objective has a measure•
Must meet all objectives & measures
Eligible Professionals (EP)•
25 Objectives/Measures•
By NPI and TIN
EHR Use•
EP MU: 50%+ encounters in period must be at location(s) w/ certified EHR
Reporting2011•
Attestation
2012•
Attestation•
Quality: Direct submit via “EHR technology” to CMS/state directly or via HIE/registry
Medicare and Medicaid•
Common definition•
Minimum for Medicaid but criteria for HHS to accept state requirements
•
Additional state requirement cannot require additional EHR functionality
Meaningful Use Grid –
Page 1
Medicare and Medicaid Programs; Electronic Health Record Incentive Program; Proposed Rule, January `3, 2010, Federal Register, pp. 1844-2011
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Clinical Quality Measure Reporting
•
HHS not ready to accept quality data electronically•
2011: One time attestation to CMS–
CMS portal or claims as for MU generally–
Submit summary calculated measures–
Attest EHR used to capture data elements and calculate results
•
2012: Submit quality measures electronically–
Whether 2012 is first or second payment year
•
If HHS cannot accept in 2012, stay with attestation•
Quality measures for Medicare apply to Medicaid–
Alternative Medicaid measures for hospitals
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Clinical Quality Measure Reporting: EP
•
HHS proposes extensive
list (90) of EP core and specialty-specific measures for 2011-12–
Many from PQRI
–
Only some electronic specifications–
Numbers likely to be reduced
•
2011-12: each EP submits two groups–
Core measures group
–
Specialty group: subset of clinical measures–
Some specialties exempt from non-core
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Clinical Quality Measure Reporting: EP
Medicare and Medicaid Programs; Electronic Health Record Incentive Program; Proposed Rule, January `3, 2010, Federal Register, pp. 1844-2011
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Demonstrating Meaningful Use
•
Common for Medicare and Medicaid–
States can apply to add to base definition
•
Stage 1: Attestation–
One-time
secure attestation per reporting period
–
Via claims submission or CMS portal–
Specifics TBD
–
Indicate certified EHR technology used–
Use same method for quality for 2011
•
CMS/States to pilot EHR-based submission
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When Can/Must 2011 MU be Shown to Receive Full Medicare Payment?
For First Payment Year
(2011+) in which MU shown, reporting period
is 90 continuous days
in payment year
2011
First Start
Last Start
Eligible Professionals
1/1/2011 10/1/2011
Hospitals
10/1/2010 7/1/2011
Note: Above monthly
timing applies to all post-2011 first payment years
to get full payment for that year
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The Path to 2015: Stages by Start Year Stage Timing Compressed for Post-2011 Starts
First Payment
Year
2011 2012 2013 2014 2015 and later**
2011 Stage 1 Stage 1 Stage 2 Stage 2 Stage 32012 Stage 1 Stage 1 Stage 2 Stage 32013 Stage 1 Stage 2 Stage 32014 Stage 1 Stage 32015 and later*
Stage 3
*Avoids payment adjustments only for EPs in Medicare EHR Incentive Program
**Stage 3 criteria of meaningful use or a subsequent update to criteria if one is established
Medicare and Medicaid Programs; Electronic Health Record Incentive Program; Proposed Rule, January `3, 2010, Federal Register, pp. 1844-2011
Medicare Incentive Policies: EPCalendar
Year
First CY in which the EP Receives an Incentive Payment
2011 2012 2013 2014 2015 and
subsequent
years
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 $0
2016 $2,000 $4,000 $4,000 $0
TOTAL $44,000 $44,000 $39,000 $24,000 $0
Medicare Penalties: % of allowed charges: 2015 (1%), 2016 (2%), 2017+ (3%)
Medicare and Medicaid Programs; Electronic Health Record Incentive Program; Proposed Rule, January `3, 2010, Federal Register, pp. 1844-2011
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Medicare Incentive Policies: EP
•
EP: MD/DO, DDS/M, DPM, DO, DC •
Payment year: calendar year (CY)
•
Incentives for up to five years, starting CY 2011•
Payment schedule per start year (not actual year)
•
Medicare maximum: $44,000 (HPSA = $48,000)•
Incentive: 75% Medicare allowable charges in year–
Annual caps (e.g., $18K in first payment year: 2011-12)
•
Qualifying EP: Show MU for “EHR reporting period”
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Medicare Incentive Policies: EP
•
Must meet all objectives and measures•
Hospital-based EPs ineligible–
EP furnishing 90%+ Medicare covered services in hospital inpatient, outpatient, and ED (place of service 21, 22, or 23)
–
27% of Medicare physicians
•
Single annual incentive payment for EPs -
electronic•
Payments by Medicare Carrier to TIN given by EP
•
Payments on rolling basis•
Can reassign entire incentive to one employer/entity
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Medicaid Incentive Policies: EPs
•
State Medicaid programs administer•
Must select between Medicare or Medicaid
•
Enroll via single provider election repository•
EPs in multiple states must choose one
•
One TIN for EP incentive payments per EP•
MU shown by HHS-approved state method
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Medicaid Incentive Policies: EPs
•
EPs–
Physicians, dentists, NP, CNMs
–
PAs practicing predominantly in PA-directed FQHC/RHC
–
Cannot be hospital-based (FQHC/RHC exempt)
–
Medicaid managed care EPs eligible for Medicaid incentives
•
Must annually
meet patient volume thresholds–
30% of encounters for 90 days in prior year
–
20% for pediatricians
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Medicaid Incentive Policies: EPs
•
Up to $63,750 over six years and must start by 2016–
Pediatricians with Medicaid volume of 20-29%: $42,500
•
Maximum of $21,250 in first payment year–
Adopt, implement or upgrade certified EHR or MU
•
In later years, annual max of $8,500 for most EPs•
Up to $29K from others as initial contribution to EHR –
Up to $10.6K per year in later years
–
Without incentive reduction
–
No cap for State or local government contributions
•
Can assign to employers or state-designated entities
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Medicaid Incentive Policies: EPs
•
State Medicaid programs administers•
Must select between Medicare or Medicaid
•
Enroll via single provider election repository•
Medicaid EPs in multiple states must choose 1
•
One TIN for EP incentive payments per EP•
MU demonstrated by State method (HHS to ok)
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Medicaid Incentive Policies: EPs
•
EPs–
Physicians, dentists, NP, CNMs
–
PAs practicing predominantly in PA-directed FQHC/RHC
–
Cannot be hospital-based (FQHC/RHC exempt)
–
Medicaid managed care EPs eligible for Medicaid incentives
•
Must annually
meet patient volume thresholds–
30% of encounters for 90 days in prior year
–
20% for pediatricians
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Medicaid Incentive Policies: EPs
•
Up to $63,750 over six years and must start by 2016–
Pediatricians with Medicaid volume of 20-29% -$42,500
•
Maximum of $21,250 in first payment year–
Adopt, implement or upgrade certified EHR or MU
•
In later years, annual max of $8,500 for most EPs•
Up to $29K from others as initial contribution to EHR –
Up to $10.6K per year in later years
–
Without incentive reduction
–
No cap for State or local government contributions
•
Can assign to employers or state-designated entities
Standards and Certification Criteria: Interim Final Rule
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Standards and Certification Criteria•
Interim Final Rule (IFR) effective 2/12/2010–
60-day comment period
•
Final Rule likely by June 2010•
Certification
criteria: minimum capabilities and
standards for certified EHRs to support Stage 1 MU •
Standards, certification criteria basis for testing and certification of “complete EHRs” and “EHR Modules”–
Process proposed in 3/10/2010 NPRM
–
Multiple certifying organizations likely
–
Note: Modules
address 1+ certification criteria
–
NIST: ONC consults, define test methods and processes
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Certification Criteria
Medicare and Medicaid Programs; Electronic Health Record Incentive Program; Proposed Rule, January `3, 2010, Federal Register, pp. 1844-2011
GE Comments
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GE ARRA Regulation Comments
•
Earlier timing for Stage 2 NPRMs: by end of 2010•
Greater clarity for providers and vendors
•
Reduce "opportunities for providers to fail“•
Refine “all or nothing approach”
•
Reduce # of quality measures/focus on EMR specifications•
Eliminate (RCM) or scale back (lower/no %) MU criteria
•
Refine certification criteria•
Provide more robust approaches to HIE
•
Refine/strengthen standards proposals
Certification Process: Notice of Proposed Rule Making
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• One NPRM – Two Final Rules– Two Proposed Programs
• Temporary Certification Program– Operational for Meaningful Use Stage 1– Anticipate publishing final rule synchronously with final rules for
meaningful use and standards and certification criteria• Permanent Certification Program
– Operational for Meaningful Use Stage 2– Anticipated final rule early fall
• Two Comment periods:– 30 days for temporary certification program proposals– 60 days for permanent certification program proposals
9
Beginning of Proposed Meaningful Use Stage Stage 1 Stage 2
Quarter Q2/10
Q3/10
Q4/10
Q1/11
Q2/11
Q3/11
Q4/11
Q1/12
Q2/12
Q3/12
Q4/12
Q1/13+
Certification Program
TemporaryPermanent
ONC Certification NPRM
Source: HIMSS 2010 ONC HIMSS Town Hall Presentation
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NPRM: Temporary Certification
•
Application to ONC•
Organizations capable of testing and certification
•
Organizations able to test and certify Complete EHRs, EHR Modules, or both
•
Stage 1 focus•
Use NIST testing methods
•
Certification only valid for two years–
If start Stage 1 in 2013 will need Stage 2 certified EHRs
33
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NPRM: Permanent Certification
•
Testing and certification separated–
Per HIT Policy Committee and NIST
•
Testing: EHR (Module) can meet specific, predefined, measurable, quantitative requirements
•
Certification: Complete EHR or Module has met all applicable HHS certification criteria
•
Accreditation required–
ONC to approve accreditor for certification bodies
–
NVLAP (NIST) would accredit testing labs
•
Can certify Complete EHRs, EHR Modules, or both
34
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Authorized Testing/Certification Methods
•
Primary: Must have capacity to [test] and certify Complete EHRs and/or EHR Modules at their facility
•
Secondary: Must also have capacity to [test] and certify Complete EHRs and/or Modules via secondary means/location –
Site (i.e., location) where Complete EHR or EHR Module has been developed (e.g., at Complete EHR developer’s facility); or
–
Site where Complete EHR or EHR Module resides (e.g., hospital where HIT installed); or
–
Remotely (i.e., through other means, such as secure electronic transmissions and automated web tools, or location other than certifying body facilities)
35
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Temporary Certification Program
36
Testing:Tools/Data/Scripts
TestReport
Complete EHR/EHR Module Submitted
CertificationApplication and Agreement
Reports Certified Product Info
Publishes
Authorizes
NIST
ONC-Authorized Testing & Certification Bodies
Vendors/Self-Developers
Technical Requirements
12 3
4
5 Certified HIT Products List
National Coordinator
Source: HIMSS 2010 ONC HIMSS Town Hall Presentation
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Permanent Certification Program
37
Technical Requirements
Testing:Tools/Data/Scripts
TestReport
Complete EHR/EHR Module Submitted
CertificationApplication and Agreement
Reports Certified Product Info
Publishes
Authorizes
NIST National Coordinator
ONC-Authorized Certification Bodies
Vendors/Self-Developers
1 2 3
4
5 Certified HIT Products List
NVLAP-Accredited Testing
Laboratories
NVLAP
ONC-AA
Approves
Accredits
Accredits
Source: HIMSS 2010 ONC HIMSS Town Hall Presentation
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NIST Will Provide Test Methods
Source: NIST -
http://xw2k.nist.gov/healthcare/use_testing/index.htm
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NIST Will Provide Test Methods
Source: NIST -
http://xw2k.nist.gov/healthcare/use_testing/index.htm
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NIST Will Provide Test Methods
Source: NIST -
http://xw2k.nist.gov/healthcare/use_testing/index.htm
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For More Information …
•
HHS Office of the National Coordinator for Health Information Technology
www.hhs.gov/healthit/
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