ARRA and Meaningful Use Incentives

What?When?How?

Presentation for the Executive Director’s Consortium

April 14th, 2011

ARRA February 2009• $787 Billion, $50 Billion for Health Information

Technology (HIT)

• Includes about $27 Million for Meaningful UseIncentives

• Title XIII of ARRA

• Health Information Technology for Economic andClinical Health Act (HITECH Act)

• Corrective Legislation would add more fundingopportunities for BH – Still pending

HITECH Act – 3 Parts

• Create Standards, Implementation Specifications andCertification Criteria

• Implement the HIT Infrastructure and HER’s throughgrants, loans and incentives for the Meaningful Use ofCertified EHR’s.

• Encourage the use of HIT Infrastructure by improvinginformation privacy and security.

HITECH ACT – Key Goals

• Improve quality, safety & efficiency

• Engage patients and their families

• Improve care coordination

• Improve population and public health; reduce disparities

• Ensure privacy and security protections

HITECH Act – Incentives

• Medicare Incentives – Eligible Professionals up to $44Kover a 5 year period (Fewer years & $$ if starting CY2013 or later)

• Medicaid Incentives – Eligible Professionals up to $63Kover a 6 year period

HITECH Act – Eligible Professionals

• Physicians

• Nurse Practitioners

• Corrective Legislation (if/when passed) would addLCSW’s

HITECH Act – Patient VolumeRequirements - MEDICAID

• 30% Patient Volume (20% Pediatricians)

• Option 1 – Based on patient encounters over a 3 fullconsecutive months. Each EP measuredindepedently

• Option 2 – Based on Patient Panels (intended formanaged care PCP’s only)

• Option 3 – Based on patient encounters for a full 3consecutive months at the group or practice level.

Clinic Volume Proxy for EP Eligibility - NEW

• Applies under three conditoins

• The clinic volume is an appropriate proxy for the clinician (e.g. ifthe EP only sees commercial clients, it would not be appropriatefor Medicaid Volume)

• There is an auditable data source to support the clinic volumecalculation

• The clinic and the clinician can only use one methodology peryear

• Not sure if this is in addition, replacement, or clarification to Option 3noted above.

Clinic Volume Proxy - Example

• Using EP Volume Calculation, 2 EP’’s would qualify

• Using Clinic Volume Proxy Calculation, 5 EP’s qualify

Patient Volume Requirements - Medicaid

• Basic Formula for Patient Volume

• Denominator = Total Documented Unduplicated PatientEncounters

• Numerator = Total Documented Unduplicated MedicaidPatient Encounters

• (Numerator / Denominator) x 100 = Medicaid Volume %

Patient Volume Requirements – MedicaidSubsequent Years

• Same options and formula – But for 12 consecutivemonths of the calendar year

Medicaid Incentives – The Details

• Example from Option 1

$63,750 x Two (2) EP’s - $127,500

• Example from Option 2

$63,750 x Two (5) EP’s - $318,750

• Waiting to Long to Start Can Cost Your Center

Meaningful Use Stages - Medicaid

• Stage 1

• Capture and Share Data (Typically RequiresStructured Data)

• Stage 2

• Advanced Care Processes

• Decision Support

• Stage 3

• Improved Outcomes

When are Stages Required?

• First Payment Received in 2011

• Stage 2 Required in 2013

• Stage 3 Required in 2015

• First Payment Received in 2012

• Stage 2 Required in 2014

• Sage 3 Required in 2015

• First Payment Received in 2014

• Stage 3 Required in 2015

IMPORTANT – Payments are ONLY madeto Eligible Professionals (EP’s)

• EP’s May Assign Incentive to an organization (Employer)

• EP’s may ONLY Assign Incentive to One (1) Organization perCalendar Year.

• EP’s working for 2 organizations at the same time

• EP’s working for an organization and self employed

• EP’s Can Only Participate in One (1) State’s Incentive Program

• EP’s working in 2 States.

• EP’s typically will not have the expertise or resources to achieve thetechnical aspects of MU

• EP’s will need their Center and Centers will need their EP’s in orderto obtain incentives.

• There must be cooperation between EP’s and Center to ObtainIncentives. Will likely require some formal agreement between EPand Center

Medicare Incentives – The Details

• These are maximum limits

• Incentive is based on $75% of Reimbursed MedicareClaims for that EM up to the amounts noted.

• Examples:

Medicare Incentives – What Phases?

• EP’s (and their organization) Must be at the Equivalentof Stage 3 Before the First Incentive is Claimed

Incentives – Medicare vs. MedicaidSummary

• EP’s may switch between the Medicare and Medicaid IncentiveProgram, but only once.

• Incentive Amounts

• Medicaid Incentive Amount is based on full amounts in eachyear.

• Medicare Incentive Amount is based on 75% of ReimbursedMedicare Claims up to the limits prescribed in the program

• Meaningful Use Implementation

• Medicaid has a phased in or staged approach to MeaningfulUse.

• Medicare requires that EP’s be at the equivalent of Stage 3before making application for the first year’s incentive dollars.

Where Do We Start?

• Do we have Qualified Eligible Professionals

• EP Credentials

• Medicare

• Equivalent of Stage 3 Meaningful Use

• Medicaid

• 30% Patient Volume (20% Pediatricians)

• Stage 1 Meaningful Use

Eligible Providers – More Details

• ARRA HITECH Meaningful Use Issues/Question List (Handout)

• Number of Eligible Providers on Staff or Contract

• Do these EP’s work for other provider entities. Will they re-assign their incentivepayments to you?

• Have you implemented an EMR system for EP’s. Is it ONC-ATC “certified”?

• If not certified, will it be? When?

• Do your EP’s meet the Medicaid volume requirements?

• If your EP’s don’t qualify for the Medicaid incentives, do they qualify for theMedicare Incentives?

• Are your EP’s located in a HPSA (Health Professional Shortage Area)? If yes,they may qualify for up to 10% more. http://hpsafind.hrsa.gov/HPSASearch.aspx

• What are the steps to claim the incentive dollars? Handout: TMHP document“Prerequisites to Participate in the Electronic Health Record (EHR) IncentiveProgram.http://www.tmhp.com/TMHP_File_Library/HealthIT/Prerequisite%20checklist%20for%20EHR%20enrollment.pdf

Define ARRA/HITECH Project Team

• Clinical Operations

• Medical Staff Leader

• Financial Leader

• Human Resources Leader

• IS Leader

• Medical Records Leader

• QM Leader

Project Plan – Core and Menu SetRequirements

• Functional Objectives/Requirements Sets (Core/Menu)

• Determine if your organization meets each of the CORErequirements

• If not yet met, determine if/when it will

• Choose at least 5 from the Menu Set of Requirementsand determine if your organization meets those corerequirements

• If not yet met, determine if/when it will

Get Eligible Providers Registered

• NPI Registry https://nppes.cms.hhs.gov/NPPES/Welcome.do

• CMS – EHR Incentive Registryhttps://ehrincentives.cms.gov/hitech/login.action

• Texas Provider Identifier (Most probably have this)http://www.tmhp.com/Provider_Forms/Provider%20Enrollment/Texas%20Medicaid%20Provider%20Enrollment%20Application.pdf

• EP’s must have an individual account with TMHPhttp://www.tmhp.com/TMHP_File_Library/Provider_Manuals/TMHP_Portal_Security/TMHP_PortalSecurityManual.pdf

Keep Eligible Provider Engaged

• EP’s will need to assign their incentive dollars to the Center

• This will likely require some negotiation between HR and EP’s andLegal

• HR Consortium

• TX Council Attorney

• Develop a plan to handle

• EP’s working for multiple entities

• EP’s working in multiple states (if applicable)

• EP’s that are also self employed

• EP’s that have already assigned Incentive Benefit to anotherprovider entity

• EP’s that want to keep some of the incentive money

Budgeting – Incentives (And Costs)

• Review Qualifying EP’s and project Incentive Revenue

• Medicaid Projections

• First Payment Year and Beyond

• Stage I and Beyond

• New EP’s in subsequent years

• Medicare Projections

• Only after organization has achieved theequivalent of Stage III MU

• First Payment Year and Beyond

• New EP’s in Subsequent Years.

Easy Part Checklist

• Eligible Providers

• Qualified Eligible Providers

• Eligible Providers Registered in all the Right Places

• Software is Certified

What’s Left?

• Meaningful Use

• Implementing New or Existing Features of a CertifiedSoftware Product typically requires changes to howan organization operates.

• These changes are rarely just an IT task. It will requireplanning, leadership, expertise and effort of theARRA/HITECH project team.

• Planning Stage II and Stage III Implementation

Remember

• Incentives are for Meaningful Use

• Meaningful Use of Certified Software by appropriatelyRegistered, Qualified, Eligible Providers

• Incentives are NOT:

• Grant Funds to Purchase Hardware and Software

• Centers cannot get incentive dollars without the EP’sand the EP’s cannot get incentive dollars without theCenters (in most cases)

Thank You

• Ralph Whaite – Helen Farabee Centers

• Larry Jonczak – Lakes Regional MHMR Center