PowerPoint Presentation

Series 1: Meaningful Use for Behavioral Health Providers9/2013From the CIHS Video Series Ten Minutes at a Time

Module 7: Meeting the PBHCI Grant HIT-Related Expectations for the Meaningful Use Standard and Understanding the Eligible Professional Incentive Program

Welcome to the SAMHSA-HRSA Center for Integrated Health Solutions video series Ten Minutes at a Time. This information on how to meet the standards for Meaningful Use and how to select and successfully implement an electronic health record system is organized into brief, convenient modules targeted to behavioral health providers. This is Series 1: Meaningful Use for Behavioral Health Providers Module 7, Meeting the PBHCI Grant HIT-Related Expectations for Meaningful Use. It is targeted to the PBHCI grantees in all Cohorts, but it is also helpful to any Behavioral Health provider interested in the Eligible Professional Incentive Program. The goal of this module is to support understanding of the grant expectations and also this incentive program.1Module 7 Outline Review of the grant expectations around meeting the standards for Meaningful Use

Review of the Eligible Professional (EP) Incentive Program

How to meet the grant expectations for Meaningful Use regardless of EP Incentive Program participation

We will begin by exploring the grant requirements related to Meaningful Use, making a distinction between meeting these standards for the grant and participating in the Eligible Professional Incentive Program. We will also make a distinction between the requirement to meet the Meaningful Use standard and implementing the bulleted list of related requirements they are not the same thing! Finally, we will go into some detail around how the Meaningful Use standard can be met by all grantees. Please note that this presentation assumes that the listener has covered Modules 1 and 2 in this series, or has a good understanding of those topic areas. 2Grant Expectations*SAMHSA expects PBHCI grantees to achieve Meaningful Use Standards, as defined by CMS, by the end of the grant period; to that end, applicants must propose how they will develop and demonstrate the ability to:Submit at least 40% of prescriptions electronically (as allowable given state-specific laws regarding the use of e-prescriptions for controlled substances);Receive structured lab results electronically; Share a standard continuity of care record between behavioral health providers and physical health providers; andParticipate in the regional extension center program.

*Page 9 of Request for Applications (RFA), No. SM-12-008, PBHCI

The grant requires all of the grantees to achieve the standards for Meaningful Use as defined by the Center for Medicaid/Medicare Services (CMS). Achieving these standards does not automatically mean the grantee will be able to develop and demonstrate the ability to perform the tasks in the bulleted list of requirements (See Module 8 on this topic). It is important to understand that the HIT-related grant expectation is actually a set of expectations the grantee must first meet the standard for Meaningful Use, then demonstrate they have met the standard by implementing the activities in the list. This module concerns the grant requirement for achieving the standard for Meaningful Use. Module 8 addresses the bulleted list of requirements.

3Meaningful Use Standard (Stage 1)Set of standards and specific criteria (15 Core and 5 of 10 Menu Objectives and Measures)*Defined by CMS specifically for the Eligible Professional (EP) Incentive ProgramMeasures are calculated by each Eligible professionalDenominator = all of the patients they have seenNumerator = all of the patients who received the Meaningful Use related serviceProduces a percent that is compared to the Measure requirements

http://www.healthit.gov/

It is important to understand that the standard for Meaningful Use is actually designed for use in the Eligible Professional Incentive Program. When the Eligible Professional (or EP) meets the standards specified for each of the Measures, they know they have met the overall standard for Meaningful Use. This is explored in detail in Modules 1 and 3.

Click this link for more information about Meaningful Use Objectives and Measures: http://www.healthit.gov/

4What the Grant Requires for Meaningful UseGrant does not require participation in the Eligible Professional Incentive Program

Grant does require that the project achieve the standards for Meaningful Use for patients enrolled in the PBHCI initiative and their data is entered into the certified Complete EHR

The grant does not require participation in the Eligible Professional Incentive Program. It does require that the PBHCI patients receive the standard of care identified in Meaningful Use. Meeting this requirement can be challenging, especially if the Behavioral Health Provider does not employ EPs, or their EPs are not participating in the incentive program. SAMHSA and CIHS identified paths to success for all of the grantees in the PBHCI project, so that any grantee can meet the requirements.5Eligible Professional Incentive ProgramAs noted in Module 1, this series refers to the standards for the Medicaid EP Incentive Program, and Stage 1 of Meaningful Use

Eligible to register*:Physician; nurse practitioner; certified nurse (midwife); dentist; physicians assistant, but only under specific conditions related to Federally Qualified Health Centers (FQHC) and Rural Health Centers (RHC)30% Medicaid patient volume OR practice predominantly in an FQHC or RHC

* https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/downloads/EHRMedicaidEP_RegistrationUserGuide.pdf

Lets make the distinction between meeting the grant standard and participating in the EP incentive program by looking a little more closely at how the incentive program is structured. To register as an EP, a health care professional must meet the federal statutory definition for Eligible Professional. For the Community Behavioral Health Center, psychiatrists and psychiatric nurse practitioners meet that definition. In addition, 30% of the professionals patient volume must be Medicaid patients. A federally qualified health center or rural health center accepts many indigent patients who may not qualify for Medicaid there are exceptions for professionals working in these types of health settings.

A link is provided to more detailed information: https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/downloads/EHRMedicaidEP_RegistrationUserGuide.pdf

6Incentive Payments*Registered EP must meet measure threshold for each applicable Core and Menu ObjectiveStage 1, Year 1, Acquire, Implement, Use (AIU) Stage 1, Year 2, 12 months continuous at full implementationOrganization attests that EP has met threshold and receives the incentive (usually not pocketed by the EP)Max $63,750 per EP over 6 years (Stages 1, 2 & 3)*Please note that these are the requirements for the Medicaid track. The Medicare track has slightly different requirementshttp://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/index.html?redirect=/ehrincentiveprograms/

The EP meets the Meaningful Use standard for each Objective and receives the incentive payment. The EP and the provider organization confirm this goal has been attained through a process called attestation. The organization is allowed to accept the incentive payment as revenue on behalf of the EP. Over a six year period, it is possible for the organization to earn revenue for up to $63,750 per EP.

Once again, a link is provided for more detailed information: http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/index.html?redirect=/ehrincentiveprograms/ 7Meeting the Meaningful Use Standard:Grantee Employs EPs Participating Incentive ProgramEXAMPLE Core Objective #5 Active Medication ListMeaningful Use StandardMore than 80 percent of all unique patients seen by the EP have at least one entry (or an indication that the patient is not currently prescribed any medication) recorded as structured data. Denominator = unique patients seen by EP, entered into the EHR. Denominator includes PBHCI enrollees.Numerator = unique patients seen by the EP, entered into the EHR, and have at least one entry recorded as structured data.

If the EP employed by the grantee is providing services to the PBHCI enrollees and is also enrolled in the EP Incentive Program, the grantee has met the grant requirements. For an example, we once again refer to Core Objective #5 concerning the Active Medication List. For the participating EP, the denominator is all of their unique patients. The numerator is all of the patients who have at least one entry recorded as structured data. If the denominator includes PBHCI enrollees then for the purposes of the grant, the Meaningful Use standard has been met.

8Meeting the Meaningful Use Standard:Grantee Does Not Employ EPs, or EPs Not ParticipatingScenario 1: No EPs employed by the grantee, solutionConsult with GPO Grantee will still be required to meet the standard. Use population-based measuresAll PBHCI enrollees entered into the EHR are the denominatorPBHCI enrollees receiving the service are the numerator The necessary data is entered into the Behavioral Health provider certified EHRNote: If Primary Care Partner is EP in the Incentive Program Enters PBHCI enrollee data into the PCP EHR? Does NOT meet the PBHCI grant requirements!

But for many grantees, there are various scenarios where the professionals they are working with are not eligible professionals, or they are not participating in the incentive program. In this case, the grantee must still meet the standard, but only in regard to the PBHCI enrollees receiving services. The PBHCI enrollees they are treating comprise the denominator and the enrollees receiving the service would populate the numerator.

The grantee can either calculate this by professional (the individual who has primary responsibility for the patient Behavioral Health record) or they can combine all of the professionals with this responsibility and treat them as though they are one EP. All of the enrollees would comprise the measure denominator and the enrollees receiving the service would constitute the numerator.

If the grantee does not employ an EP, they should consult with their GPO, but they will still be able to meet most of the Meaningful Use standard. Please note that the primary care provider EHR data is not considered in meeting the grant requirements. The grantee must enter the Continuity of Care patient health information minimum data set into their certified Behavioral Health EHR and ensure that each PBHCI enrollee is receiving services that meet the measure. Modules 8 and 9 discuss this in further detail.

9Meeting the Meaningful Use Standard:Grantee Does Employ One or More EPs, Not ParticipatingScenario 2: EP or EPs are employed by grantee (either as staff or via contract) but not participating in the incentive program

Act as if the EPs are in the incentive program BUT Solution A: Use the PBHCI enrollees assigned to them as the denominator. The number of PBHCI enrollees receiving the service is the numerator ORSolution B: Consider all EPs collectively as one single EP, with all of the PBHCI enrollees in the denominator. The total number of PBHCI enrollees receiving the services is the numerator.

Here is the scenario for when EPs are employed by the Behavioral Health provider, but not participating in the incentive program. It is similar to Scenario 1 in that the requirements can be met by ensuring that the PBHCI enrollees are receiving the services that meet the individual measures calculated either by individual EP or by considering all of the EPs as a single provider, and all of the enrollees as the denominator. 10SummaryAll PBHCI grantees must ensure that the services enrollees in the project receive meet the standard for Meaningful Use. SAMHSA does not require grantee EPs to participate in the Eligible Professional Incentive ProgramIf the EP(s) employed by the grantee and seeing PBHCI enrollees is participating in the incentive program, this assures the project meets the grant requirement (as part of their participation in the incentive program)If the PCP is not an employee of the grant recipient, or is not participating in the program, SAMHSA will accept one of three possible approaches to meeting this requirement

So, here are the important things to keep in mind. The grant expectations allow several approaches to meeting the standards for Meaningful Use. The first is actual participation in the incentive program, where the EP is employed by the grantee and the PBHCI enrollees are included in the EPs patient population represented in the measure denominator. If the EP attests to Stage 1 Year 1 or 2 (or even Stage 2) Meaningful Use, the grantee will have met the Meaningful Use requirement in the grant.

The second addresses situations where incentive program participation is not on the table. SAMHSA has approved these approaches which essentially treat the professional as though they are a registered EP, with the PBHCI patients they are treating considered as their patient panel for calculating the measures. If the grantee does not employ any EPs, they will still need to meet the Meaningful Use standard of care, and can do so by ensuring that the data is appropriately entered into the grantee record. For example, they may not be able to ePrescribe, but they can still create the Active Medications and Active Medications Allergy lists by entering the patients information into the Behavioral Health certified electronic health record. This flexibility is intended to support grantee success in meeting this grant requirement. 11We Have Solutions for Integrating Primary and Behavioral Healthcare

Contact CIHS for all types of primary and behavioral health care integration technical assistance and training needs

1701 K Street NW, Ste 400 Washington DC 20006

Web: www.integration.samhsa.govEmail:integration@thenationalcouncil.orgPhone:202-684-7457

Prepared and presented by Colleen ODonnell, MSW, PMP, CHTS-IM for the Center for Integrated Health Solutions

Our thanks go to SAMHSA and to HRSA for providing support to the Center for Integrated Health Solutions (CIHS) for this and many other forms of training and technical assistance related to the integration of primary and behavioral health care. Please visit our web site at www.integration.samhsa.gov, email us at integration@thenationalcouncil.org, or just pick up the phone and give us a call at 202-684-7457.

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