meaningful use regulation unraveled dchima annual conference

TOGETHER. COLLABORATE FOR RESULTS

Meaningful Use Regulation UnraveledDCHIMA Annual ConferenceJune 11, 2010

Tori E. Sullivan, MHA, RHIA, PMP

Manager, Healthcare Sector

Capgemini


Agenda

Legislative Overview Meaningful Use RegulationEHR CertificationHITECH Workforce Education in Our Area ResourcesDiscussion

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Legislative Overview

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Acronym Soup…

• ARRA – American Recovery & Reinvestment Act (PL 111-5)• HITECH – Health Information Technology for Economic and Clinical health Act (Title XIII of ARRA)• BLS – Bureau of Labor Statistics• DOL – Department of Labor• EHR – Electronic Health Record• HRSA – Health Resources and Services Administration• Meaningful Use – Title IV of ARRA – Medicare and Medicaid Incentive Payments for HIT • Title VII – Public Health Law Title VII – Allied Health

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Regulatory overview

ARRA codified ONC● Established HIT Policy Committee

– Meaningful Use– Certification & Adoption– Information Exchange– Nationwide Health Information Network (NHIN)– Strategic Plan– Privacy & Security Policy

● Established HIT Standards Committee– Clinical Operations– Clinical Quality– Privacy & Security– Implementation

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Health & Human Services (HHS)

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Legislative overview – ARRA and HITECH Act

Meaningful Use (MU)EHR Certification programsHealth Information Technology Research

Center (HITRC) Health Information Technology Regional

Extension Centers (REC)Privacy and Security

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Meaningful Use

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Background - Meaningful Use

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In 2008, the National Priorities Partnership, convened by the National Quality Forum (NQF), released a report entitled “National Priorities and Goals” which identified a set of national priorities to help focus performance improvement efforts

February 2009 – ARRA HITECH created an incentive program for meaningful use (MU) of an electronic health record (EHR)

●Meaningful use of certified EHR technology●Information exchange●Reporting on measures using EHR


Background cont…

The Office of the National Coordinator (ONC) held meetings and testimony through its HIT Policy and Standard Committee to define meaningful use

December 2009 - The Centers for Medicare & Medicaid (CMS) published a Notice of Proposed Rulemaking (NPRM) to define meaningful use

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Medicare and Medicaid incentive program developed for the adoption and meaningful use of certified EHR technology

●Meaningful use of certified EHR technology●Electronic exchange of health information to improve

the quality of health care●Reporting on measures using EHR

Program begins 2011 and ends at the completion of 2015 In order to receive full payments the process of EHR adoption needs to start in 2010 and

actual use by January 2011 (for at least at 3 month consecutive period) and will continue with full usage by 2012

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Meaningful Use


Meaningful Use cont…

Improving quality, safety, efficiency, and reducing health disparities

• Engage patient and families in their health care

• Improve care coordination • Improve population and public health• Ensure adequate privacy and security

protections for personal health information

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Quality measure reporting ● HIT Functionality measures

– Eligible professionals and hospitals ~25 measures

● Clinical quality measures – Physician Quality Reporting Initiative (PQRI) and Reporting

Hospital Quality Data for Annual Payment Update (RHQDAPU) measures are included

– Eligible professionals - Core group and specialty group of measures

– Eligible hospitals – 35 measures

● To receive incentive payment, must successfully report on all measures, all or nothing approach.

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Meaningful Use cont…


Meaningful Use – Quick facts

Eligible Hospitals Eligible Professional - Medicare● A physician as defined in section

1861(r) of the Social Security Act*, which includes the following five types of professionals: – Doctor of medicine or osteopathy – Doctor of dental surgery or

medicine – Doctor of podiatric medicine – Doctor of optometry – Chiropractor

Eligible HospitalsEligible Professional - Medicaid● Physicians ● Dentists ● Certified nurse-midwives ● Nurse practitioners ● Physician assistants who are

practicing in Federally Qualified Health Centers (FQHCs) or Rural Health Clinics (RHCs) led by a physician assistant.

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2011 Objectives and Measurements for Hospitals

1.Use CPOE – 10% all orders

• order types listed

2.Implement drug to drug, drug allergy and formulary checks

• Real time alerts in CPOE

3.Maintain up to date problem list and current active diagnosis based on ICD-9 or SNOMED CT

• Longitudinal Problem List over multiple visits

4.Maintain active medication list

• At least 80% of unique patients seen have at least one entry recorded as structured data

5.Maintain active medication allergy list

• 80% unique patients

6.Record demographics as structured data, include data of birth and death and cause of death

• 80% of all unique patients

7.Record smoking status for patients over 13

• At lease 80% of unique patients over 13 have smoking status recorded

8.Incorporate lab tests into the EHR as structured data

• At lease 50% of lab tests in positive/negative numeric format incorporated into EHR technology as structured data

9.Generate lists of patients by specific conditions for use with quality improvement, outreach, etc

• Generate at least one report listing patients by specific condition

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10.Report hospital quality measures to CMS or states

• For 2011 provide aggregate numerator and denominator via attestation.

• For 2012 submit electronically• CMS PQRI 2008

11.Send reminders to patients per patient preference for preventive / follow-up care

12.Implement 5 clinical decision support rules related to a high priority condition included diagnostic test ordering

• Relevant to the clinical quality metrics the Hospital is responsible for

13. Check insurance eligibility electronically from public and private payers

• 80% unique patients admitted to a hospital

14.Submit claims electronically to public and private payers

• At least 80% of unique patients claims filed electronically

15.Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication list, allergies, discharge summary, procedures) upon request

• 80% of all patients who request an electronic copy of their health information are provided it within 48 hrs

• AHIMA will comment that this may be very difficult to meet the timeframe

• Copies must be in human readable format and in accordance with standards (HL-7 CDA R2 CCD or ASTM CCR

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16. Provide patients with an electronic copy of their discharge instructions and procedures at time of discharge, upon request

• 80% of all discharge patients from hospital and who request an electronic copy

• Human readable format

17. Provide patients with timely electronic access to their health information (including lab results, problem list, medication lists, allergies) within 96 hours of the information being available to the EP

• 10% of unique patients have timely electronic access to their health information

18.Provide clinical summaries for patients for each office visit

• Clinical summaries provided for 80% of office visits

19.Capability to exchange key clinical information (i.e. discharge summary, procedures, problem list, meds, allergies, diagnostic test results) among providers of care and patient authorized entities electronically

• Perform at least one test of certified EHR technology’s capability to exchange key clinical information

• Receive a patient summary in HL-7 CDA R2 CCD or ASTM CCR

• Enable a user to transmit a patient summary to other provider organizations

20.Provide summary of care for each transition of care and referral

• Summary of care record for at least 80% of transitions of care and referrals

• Electronically receive and transmit a patient summary record

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21. Perform medication reconciliation at relevant encounters and each transition of care

• 80% medication reconciliation at transitions of care

• Compare and merge at least 2 medication lists into one and electronically display in real time

22. Capability to submit electronic data to immunization registries

• Perform at least one certified EHR test of capacity to send immunization data

• HL-7 2.3.1 or HL-7 2.5.1

23.Capability to provide electronic submission of reportable lab results (as requested by state or local law) for public health

• Perform at least one test (HL7)

24.Protect electronic health information created or maintained by certified EHR technology through the implementation of appropriate technical capabilities

• Conduct a security risk review per 45 CFR 164.308(a)(1) and implement security updates as necessary

25.Capability to provide electronic surveillance data

• Perform at least one test (HL7)

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2011 Objectives and Measurements for EPs

1. Generate and transmit ePrescibing• 75%+ of all permissible prescriptions written by EP are

transmitted electronically using EHR technology

2. Maintain active medication list• 80% unique patients

3. Maintain active medication allergy list• 80% unique patients

4. Record changes in vital signs and BMI• 80%+ for unique patients over age 2 seen, growth charts for

children ages 2-20

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Clinical Measures - Reporting

3 Core measures and 90+ specialty measures

EP decides which specialty measures to report on

Projected EPs have to report on up to 5 clinical quality measures

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AHIMA Engagement

April 2009 hearings AHIMA statement to the National Committee on Vital and Health Statistics (NCVHS)

● http://www.ahima.org/dc/documents/AHIMA2pageStmtonMeaningfulUsetoNCVHS42909final.pdf

June 2009 RFI AHIMA response to ONC● http://www.ahima.org/dc/documents/

AHIMACommentsonONCMeaningfulUseDraftDefinition.pdf

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AHIMA Engagement

November 2009 - A call for volunteers was issued to develop a response team and prepare comments

Shortly after NPRM was published on December 30, 2009 the “Meaningful Use Response Team” was kicked off

● Comprised of approximately 25 AHIMA member volunteers● Met on a weekly basis● Divided into 6 teams (domain areas) to review and prepare

comments for CMS

Comments submitted to CMS March 12, 2010 ● http://www.ahima.org/dc/documents/

AHIMAEHRIncentiveProgramResponse_100312.pdf

Expect a Final Rule late spring/early summer 201022

EHR Certification

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EHR Certification

Companion to MU – to become a meaningful user, participants must use “certified” EHR technology

Interim Final Rule (IFR) - HIT: Initial Set of Standards, Implementation Specifications, and Certification Criteria for EHR Technology published December 30, 2009

● Comments submitted to ONC March 12, 2010● Regulation is effective February 12, 2010● http://www.ahima.org/dc/documents/

AHIMAStandardsCertIFRResponseLetter_Final.pdf● http://www.ahima.org/dc/documents/AHIMAA4DComment20100312.pdf

NPRM - Proposed Establishment of Certification Programs for Health Information Technology published March 10, 2010

● Comments due temporary program April 9, 2010● Comments due permanent program May 10, 2010

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Incentive Payments for Certified EHR Adoption

Eligible professionals (Physicians) for Meaningful Use of Certified EHRs– Reimbursement = $44,000 over 5 years ($65,000 for some

Medicaid providers)

Hospitals incentives, $2,000,000 base dollars up to $10+ million per site

Meaningful Use criteria have been presented by HIT Policy Committee but not by HHS (due Dec 31, 2009)

http://healthit.hhs.gov/portal/server.pt/gateway/PTARGS_0_10741_878092_0_0_18/Proposed%20Revisions%20to%20Meaningful%20Use_08142009.pdf

CCHIT certification body for EHRs HIPAA Privacy and Security violations result in hold on

incentive payments

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HITECH Workforce Education in Our Area

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ONC Workforce Funding

• Community College Consortia to Educate HIT Professionals

• Assistance for University-Based Training

• Curriculum Development Centers

• Competency Training Toward Completion of Non-Degree Training

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Workforce Education Grant Programs

In April 2010, ONC awarded an estimated $36 million in cooperative agreements to five regional recipients Establish a multi-institutional consortium within each designated

region. Includes 70 community colleges to each create non-degree

training programs that can be completed in six months or less by individuals with appropriate prior education and/or experience.

First year grant awards are estimated at $36 million. An additional $34 million is available for year two funding of these programs.

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Community College Consortia

Provide assistance to institutions of higher education to establish or expand health information technology (health IT) education programs (traditional on-campus, distance learning modalities, or combinations)

Training is designed to be completed within six months or less.

VA, MD and DC are in Region E

Tidewater Community College (lead awardee) $8,492,793

Baltimore City Community College

Community College of DC

Northern Virginia Community College

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Curriculum Development Centers Program

Provide funding to institutions of higher to support health information technology curriculum development. The materials developed under this program will be used by the member colleges of the regional Community College Consortia as well as be available to institutions of higher education across the country.

Awardees included:Johns Hopkins University $1,820,000

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Program of Assistance for University-Based Training

Designed to rapidly and sustainably increase the availability of individuals qualified to serve in specific health IT professional roles requiring university-level training.

The colleges and universities listed are charged with promptly establishing new and/or expanded training programs as rapidly as possible while assuring their graduates are well prepared to fulfill their chosen health IT professional roles.

Many of these programs can be completed by the trainee in one year or less. All of the programs are expected to remain once established with the support of this grant.

George Washington University $4,612,313

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Competency Examination Program

Support the development and initial administration of a set of health IT competency examinations.

Examinations assess basic competency for two types of individuals who are seeking to demonstrate their competency in certain health IT workforce roles integral to achieving meaningful use of electronic health information.

In April 2010, ONC awarded $6 million in a single two-year cooperative agreement to Northern Virginia Community College

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How it all fits together

Diagram from: Blumenthal, David, New England Journal of Medicine, December 30th, 2009

ICD-10

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Resources

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AHIMA Resources

• Publications• eAlert• Journal of AHIMA • Advance • Perspectives in HIM

• AHIMA Website: www.ahima.org• Advocacy Assistant: www.ahima.org/dc• Position Statements, Practice Briefs, and Analysis • Comments and Testimony• Communities of Practice

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Don Asmonga MBA, CAEDirectorGovernment [email protected]

Sue BowmanRHIA, CCSDirectorCoding Policy & [email protected]

Dan RodeMBA, CHPS, FHFMAVice [email protected]

Allison ViolaMBA, RHIADirectorFederal [email protected]

AHIMA Policy & Government Relations Staff

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Tori E. Sullivan, MHA, RHIA, PMP

Manager, Healthcare Sector

Capgemini

[email protected]

571-336-1668

meaningful use regulation unraveled dchima annual conference

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