Medicaid EHR Provider Incentive Payment Program

September 26, 2011

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– Electronic Health Record (EHR)*-An electronic record of health-related information on an individual that conforms to nationally recognized interoperability standards and that can be created, managed, and consulted by authorized clinicians and staff across more than one health care organization. (Individual Focused)

– Health Information Exchange (HIE)*-The electronic movement of health-related information among organizations according to nationally recognized standards.

– Health Information Technology (HIT)-allows comprehensive management of medical information and its secure exchange between health care consumers and providers. Broad use of HIT has the potential to improve health care quality, prevent medical errors, increase the efficiency of care provision and reduce unnecessary health care costs, increase administrative efficiencies, decrease paperwork, expand access to affordable care, and improve population health.*

Definitions

*Definitions-National Alliance for HIT and authorized by ONC for Health IT- www.nahit.org

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■ Basics of the HIT Governance Structure in Massachusetts

■ Basics of the Medicaid EHR Incentive Payment Program

■ Steps Massachusetts has taken to plan and implement that Medicaid Incentive Program

■ High Level Overview of Application Process

Presentation Overview

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■ HITECH Act was passed in February 2009 as part of the American Recovery and Reinvestment Act (ARRA)

■ Establishes as a goal - the utilization of an electronic health record (EHR) for each person in the United States by 2014

■ Creates reimbursement incentives through Medicare and Medicaid for providers who demonstrate they are “meaningful users” of federally certified EHR systems through the Office of the National Coordinator (ONC)

The Health Information Technology for Economic and Clinical Health (HITECH) Act

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Background on MeHI

■ MeHI was established through an Act of the Massachusetts Legislature- Chapter 305

■ MeHI is a division of the Massachusetts Technology Collaborative (MTC)

■ MeHI is responsible for advancing the dissemination of health information technology (HIT) across the Commonwealth, including the deployment of electronic health records (EHR) systems in all health care provider settings that are networked through a statewide health information exchange (HIE).

■ HIT Council which is the governing board of MeHI is chaired by the Secretary of EOHHS and the Medicaid Director is member of HIT Council

Collaboration between MeHI and MassHealth

■ Ensuring that there is complete alignment and coordination with statewide and MassHealth/EOHHS HIT initiatives

■ MeHI will have a unit that will be dedicated to supporting key operational functions of the Medicaid Incentive Payment Program

Massachusetts eHealth Institute (MeHI)

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■ Eligible Professionals (EPs) who do not practice predominately at a FQHC or RHC

■ Eligible Professionals (EPs) who do practice predominately at a FQHC or RHC

■ Short-term Stay Acute Care Hospitals, Children’s Hospitals and Critical Access Hospitals

Medicaid Incentive Program Eligible Providers

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– Non-hospital based Physicians (MDs and ODs), Dentists, Certified Nurse Mid-Wives, and Nurse Practitioners

– “Hospital Based” EPs are excluded from receiving incentive payments

• ―Hospital Based‖- if 90% or more of an EP’s services take place at a setting of “Inpatient Hospital” or “Emergency Room”

• Must meet minimum patient volume thresholds

– 30% Medicaid Patient Volume Threshold for non-Pediatricians

– 20% Medicaid Patient Volume Threshold for Pediatricians (2/3 of the incentive payment)

– A CHIP Reduction Factor will be developed by MassHealth and must be applied to the Medicaid encounters in order to meet a CMS requirement that CHIP encounters can not be included in Medicaid patient encounters

– EPs must waive rights to Medicare Incentive Payments in order to receive Medicaid Incentive Payments

– EPs can only receive Medicaid Incentive Payment from one state per year

Eligible Professionals (EP)-not FQHC/RHC

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– Physicians, Dentists, Certified Nurse Mid-Wives, Nurse Practitioners, and Physician Assistants who practice at a FQHC/RHC that is led by a Physician Assistant

– ―Practicing Predominately” at a FQHC or RHC means 50% or more of their patient encounters at the FQHC or RHC.

– Must meet minimum patient volume thresholds

• 30% ―Needy Individuals‖ Patient Threshold for providers who practice at FQHCs or RHC

• ―Needy Individual” means an individual receiving care from any of the following (1) Medicaid, Medicaid Waiver, CHIP, Dually Eligible for Medicare and Medicaid (2) Uncompensated Care (3) No cost or reduced cost services on a sliding scale based on the individual’s ability to pay

– EPs must waive rights to Medicare Incentive Payments in order to receive Medicaid Incentive Payments

– EPs can only receive Medicaid Incentive Payment from one state per year

Eligible Professionals (EP)- Predominately FQHC/RHC

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– Acute Care Hospitals, Cancer Hospitals and Critical Access Hospitals that are considered short-term stay hospitals (less than 25 days ALOS)

• Must meet or exceed 10% minimum Medicaid patient volume thresholds

• Must have a CCN with the last 4 digits that fall in the range of (0001 through 0879) or (1300-1399)

• A CHIP Reduction Factor will be developed by MassHealth and applied to the Medicaid encounters in order to meet a CMS requirement that CHIP encounters can not be included in Medicaid patient encounters

– Children’s Hospitals- No minimum Medicaid patient volume threshold

• Must have a CCN with the last 4 digits that fall in the range of (3300-3399)

– Hospitals can receive both Medicaid and Medicare EHR Incentive Payments

– If a hospital is approved by CMS for Medicare Incentives, they are ―deemed‖ eligible for Medicaid Incentives. The hospital still must show that they are eligible for their Medicaid incentives each year (example: 10% Medicaid patient encounter threshold information)

Short Stay Acute Care and Children’s Hospitals (based on CCN)

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Criteria for Receiving Medicaid EHR Incentives in First Payment Year

■ First Payment Year Only- Medicaid Providers demonstrate the following:

■ Adopted –Acquired, purchased or secured access to an ONC certified EHR system

■ Implemented –Commenced Utilization (example: Staff training, data entry of patient demographic information into EHR)

■ Upgraded –Expanded the available functionality of certified EHR technology capable of meeting meaningful use requirements at the practice site or upgraded from existing EHR technology to certified EHR technology per the ONC EHR certification criteria

■ Must be ONC certified EHR technology capable of meeting meaningful use

■ No EHR reporting period

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Criteria for Receiving Medicaid Incentives Payment Years 2-6

■ In Payment Years 2 through 6 - Medicaid EP and Hospitals must demonstrate Meaningful Use of an ONC Certified EHR systems

■ Stage 1 Meaningful Use Criteria

■ 15 Core Objectives (examples: CPOE, e-prescribing, record demographics, clinical quality measures, etc.) plus

■ 4-5 Objectives from menu set (examples: drug-formulary checks, incorporate clinical lab test results as structured data, generate lists of patients by specific conditions, etc.)

■ 6 Clinical Quality Measures for EPs and 15 Clinical Quality Measures for Hospitals

■ MU Reporting period 90 days for participation year 2

■ MU Reporting period 365 days for participation beyond year 2

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Medicaid EHR Incentive Payments -EPs

Calendar Year

2011

2012

2013

2014

2015

2016

2011 $21,250

2012 $8,500 $21,250

2013 $8,500 $8,500 $21,250

2014 $8,500 $8,500 $8,500 $21,250

2015 $8,500 $8,500 $8,500 $8,500 $21,250

2016 $8,500 $8,500 $8,500 $8,500 $8,500 $21,250

2017 $8,500 $8,500 $8,500 $8,500 $8,500

2018 $8,500 $8,500 $8,500 $8,500

2019 $8,500 $8,500 $8,500

2020 $8,500 $8,500

2021 $8,500

Total

$63,750

$63,750

$63,750

$63,750

$63,750

$63,750

Note: 1) Pediatricians with a minimum 20% patient volume may qualify for up to a

maximum of $14,167 in the first incentive payment year and to up a maximum of $5,667 in each of the 5 subsequent incentive payment years for no more than a total of $42,500 over the maximum 6 year period.

2) If a Pediatrician meets or exceeds the 30% patient volume threshold they

are eligible for the full incentive payment amounts.

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Medicaid EHR Incentive Payments – Hospitals

The aggregate EHR incentive calculation for Medicaid eligible hospitals is represented mathematically as follows to be paid over 3 to 6 years:

(Overall EHR Amount) X (Medicaid Share)

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■ Medicaid EHR Incentive Payments to providers are administered by the states but are reimbursed at 100% by CMS

■ Planning, administrative and oversight expenses for states to carry out the Medicaid Incentive Payment provisions are reimbursed at 90% by CMS and 10% by state funds

Funding Sources for Medicaid EHR Incentive Payments

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CMS required Planning Activities

■ January 2010 - MassHealth submitted its HIT Planning Advanced Planning Document (HIT PAPD) to CMS for approval

■ May 2010 - CMS approved MassHealth’s request to begin planning activities associated the Medicaid EHR Incentive Payment Program

■ May 2010 thru February 2011 - MassHealth developed its State Medicaid HIT Plan (SMHP) and submitted the Plan to CMS on March 11, 2011

■ June 2011 - CMS approved MassHealth’s SMHP—available on the www.mass.gov/masshealth/ehrincentives

■ July 13, 2011 - Submitted the HIT Implementation Advance Planning Document (HIT IAPD) which focused on the EHR incentive program operational staffing model and budget to CMS.

■ August 26, 2011 - CMS approved the HIT IAPD which allowed Massachusetts to take steps to implement the incentive program.

■ September 19, 2011 - CMS approved Massachusetts request to launch the Medicaid Incentive Program on October 3, 2011!!!!

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MassHealth Specific Plan Options

■ Massachusetts will not have state specific Meaningful Use criteria-standard, standard, standard to federal CMS requirements!

■ Massachusetts is paying the hospital incentives over a 3 year payment period

■ 50% in the first payment year

■ 30% in the second payment year

■ 20% in the third payment year

■ Providers can include FFS claims and MCO encounters when they are establishing their Medicaid Patient Volume Thresholds. They should include encounters for following MassHealth and Medicaid 1115 Waiver Populations: MassHealth Standard, MassHealth Breast/Cervical Cancer Treatment, MassHealth CommonHealth, MassHealth Family Assistance, MassHealth Basic, MassHealth Essential, MassHealth Limited, MassHealth Prenatal, MassHealth Insurance Partnership, Commonwealth Care, MSP, Health Safety Net and Healthy Start

■ Grace periods for applying for first year Medicaid EHR incentive payment:

■ Eligible hospitals will have until December 30, 2011 to apply for their FFY2011 payments

■ Eligible professionals will have until March 30, 2012 to apply for their CY2011 payments

■ Massachusetts is one of thirteen states to collaborate on the development of a system called the Medical Assistance Provider Incentive Repository (MAPIR). MAPIR is a system that will support the following activities:

■ Receive providers’ incentive payment registrations from CMS Registration and Attestation System (R&A) electronically on a daily basis

■ Allow providers to apply for Massachusetts Medicaid incentives through the EOHHS Provider Online Service Center (POSC)

■ Will interface with the MassHealth claims system for disbursement of the incentive payments

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Providers Eligible for Medicaid Incentives:

Hospital, Physician, Dentist, Nurse Practitioner,

Cert Nurse Midwife

MAPIR/MMIS

Hospital

sEP

Step 1

Register at the

CMS Registration and Attestation

Website (CMS R&A)

Provider selects Medicaid and

Massachusetts when Massachusetts

Launches

Step 3

MassHealth Virtual Gateway

Provider Registration and

Attestation

Provider Enter Eligibility Information, AIU/MU Attestations

Incentive

Payment to

Providers

Incentive Payment Staff

Step 5

Incentive Payment Staff

Okays Payment

Step 7

MassHealth Reports

Incentive Payments

Back to CMS

Step 2

CMS sends

Files to

MassHealth on Daily

Basis

Step 4

Incentive Payment Staff

Validates Information

Step 1 Step 3 Step 6

MassHealth System

Pays Incentive to

Provider

CMS R&A

High Level Flow of Medicaid Incentive Payment Program

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Initial Estimates of Medicaid EHR Provider Incentive Payments

■ Hospitals Incentive Payments at 100% FFP-

■ Many of the 65 Massachusetts short-term acute care and Critical Access Hospitals will meet 10% Medicaid Patient Threshold including Children’s Hospital

■ Approximately $100,000,000-$120,000,000* in total Medicaid Incentive Payments paid to Massachusetts eligible hospitals from 2011-2021.

■ Important note: All hospitals must receive their first Medicaid Incentive Payment by 2016.

*Hospital Estimates are very preliminary – charitable care adjustment not included

■ Eligible Providers Incentive Payments at 100% FFP-

■ Using national estimates 20% of Massachusetts EPs may be eligible for Medicaid Incentive

■ Approximately 5,000 – 6,000 eligible providers in Massachusetts may receive up to $63,750 in Medicaid Incentive Payments

■ Approximately $320,000,000-$382,500,000 in total Medicaid Incentive Payments paid to Massachusetts EPs from 2011-2021.

■ Important note: All EPs must receive their first Medicaid Incentive Payment by 2016.

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Links to Key HITECH Websites

• Basic information about the Massachusetts Medicaid EHR Incentive Payment

Program

www.mass.gov/masshealth/ehrincentives

• Massachusetts eHealth Institute (MeHI)

www.maehi.org

• General CMS Incentive Payment Program Website for both Medicare and

Medicaid EHR Incentive Programs

http://www.cms.gov/ehrincentiveprograms

• The CMS Registration and Attestation Website—‖First Stop‖ in applying for all

incentives

https://ehrincentives.cms.gov/hitech/login.action

• U.S. Department of Health & Human Services Office of the National Coordinator

(ONC)

http://healthit.hhs.gov

• Listing of ONC Certified Health IT Products including EHRs (CHPL)

http://onc-chpl.force.com/ehrcert