The Minnesota Medicaid Electronic Health Record Incentive Program of Meaningful Use (MEIP)

Presenter: Mary Givens, Program Manager for Meaningful Use , Qualifacts Systems, Inc.

July 25, 2012

The Minnesota Medicaid Electronic Health Record IncentiveProgram of Meaningful Use (MEIP)

MN EHR INCENTIVE PROGRAM

Agenda Overview of Meaningful Use Program Timelines for the MN Medicaid EHR

Incentive Program for Eligible Professionals

What can an eligible professional do to get ready for MEIP?

Important Links


Overview of the Meaningful Use Programs

• The Meaningful Use Incentive Programs are part of the Health Information Technology for Economic and Clinical Health (HITECH) Act , which is under the American Recovery and Reinvestment Act (ARRA)

• The goals of using a certified EHR in a meaningful way are to– Reduce medical errors;– Improve health care outcomes;– Ensure quality; and – Reduce health care costs


Types of Meaningful Use Programs

• Medicare EHR Incentive Program– Eligible Professionals–Hospitals•Medicaid EHR Incentive Program– Eligible Professionals–Hospitals* If you are an EP who is eligible for both, choose the Medicaid EHR Incentive program

Medicaid vs. Medicare EHR Incentive Programs: A side by side comparison.


The Recovery Act specifies three main components of meaningful use that correspond with the 3 stages

Capture & Share Data

Exchange of clinical dataAdvancement of processes

Improved outcomes


Stage 1: The use of a certified EHR in a meaningful manner, such as e-prescribing (2011-2013).Stage 2: The use of certified EHR technology for electronic exchange of health information to improve quality of health care (2014).Stage 3: The use of certified EHR technology to submit clinical quality and other measures (2015).


Payments across the Program Incentive Paid In

Meaningful Use of a Certified EHR

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


Important Dates for MN Medicaid EHR Incentive Program

NOVEMBER 2011 CMS approved the MN State Medicaid HIT Plan (SMHP

OCTOBER 2012Target date for Providers to be able to submit applications to MEIP


MN Medicaid Electronic Health Record Incentive Program Website LINK

What can we do to get ready for the MEIP right now?To get ready for MEIP, follow the steps below:1. Learn more about the Medicaid and Medicare EHR Incentives for Eligible Providers from

the CMS EHR website by clicking on the CMS EHR Incentive icon at the top of this page.2. Adopt, implement or upgrade to a certified EHR system (site allows you to check if your

EHR is certified; if it is not, ask your EHR vendor when they expect their product to be certified).

3. Determine if you may be eligible.4.Review CMS Registration User Guides for eligible professionals (PDF) and

eligible hospitals (PDF), and gather necessary documentation. 5. Register for the Medicaid or Medicare incentive program on the CMS Registration and

Attestation System. 6. Keep up-to-date with latest news and information about the Medicaid EHR Incentive

Program. Save this page and the CMS EHR website as a favorite in your browser and come back frequently for updates.

7 . Sign up for the MEIP email list

http://www.dhs.state.mn.us/main/idcplg?IdcService=GET_DYNAMIC_CONVERSION&RevisionSelectionMethod=LatestReleased&dDocName=dhs16_145261

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

http://www.cms.gov/EHRIncentivePrograms/15_Eligibility.asp

http://www.cms.gov/EHRIncentivePrograms/Downloads/EHRMedicaidEP_RegistrationUserGuide.pdf

https://www.cms.gov/EHRIncentivePrograms/Downloads/EHRHospital_RegistrationUserGuide.pdf


MN Medicaid EHR Incentive Program

• Year 1 can attest to ADOPT/IMPLEMENT/or UPGRADE– Adopted > acquired, purchased or secured access to

– Implemented > installed or commenced utilization of

– Upgraded to certified EHR technology

• Eligibility– Cannot be a hospital based provider– Must be a Medicaid Provider in good standing – Must be one of these Medicaid Provider types

• Physicians (primarily doctors of medicine and doctors of osteopathy)• Nurse practitioner• Certified nurse-midwife• Dentist• Physician assistant who furnishes services in a Federally Qualified Health Center or Rural Health

Clinic that is led by a physician assistant.– Must meet Medicaid patient volume requirement


Cannot be a hospital based provider

“hospital based”, defined as 90% or more of the provider's encounters taking place at an inpatient (POS 21) or emergency room (POS 23) practice location.


Must be a Medicaid Provider in good standing

• Each eligible professional must have their own, individual Medicaid Provider ID– If rendering providers do not have one, they will need to

get one

– Medicaid uses the Medicaid ID to validate patient volume and track payments

– Provider Enrollment, MEIP, will need to know that the new providers have been providing services under an already defined group Medicaid provider ID .


Must meet Medicaid patient volume requirement

To qualify for an incentive payment under the Medicaid EHR Incentive Program, an eligible professional must meet one of the following criteria:

• Have a minimum 30% Medicaid patient volume• Have a minimum 20% Medicaid patient volume, and is

a pediatrician• Practice predominantly in a Federally Qualified Health

Center or Rural Health Center and have a minimum 30% patient volume attributable to needy individuals


Patient Volume

• A patient encounter is defined as a distinct patient, date-of-service, and place-of-service combination.

• A Medicaid patient encounter is any patient encounter (as defined above) where a Medicaid (not CHIP) fee-for-service claim or managed care organization paid for all or part of the services provided, or the co-pays, cost sharing or premiums for the services provided.

• When determining patient, must use a representative 90 consecutive day period in the previous calendar year


Calculating Patient Volume


Additional information for calculating patient volume

• There are no restrictions on hours worked or eligible professional employment type (e.g., contractual, permanent, temporary).

• An EP is allowed to aggregate or separate patients across practice sites and places of service; however, one location that meets the applicable payment year's EHR technology incentive payment eligibility criteria (Adopt, Implement, or Upgrade or Meaningful Use) MUST BE INCLUDED in the provider's patient volume measurement.

• An EP is allowed to aggregate patients across States. – The eligible professional must be able document their out-of-state patient

volume.

• All patient volume information entered into the MEIP System may be subject to audit that could result in payment recoupment.


Group by proxy conditions

• Providers may use a clinic or group practice’s patient volume as a proxy for their own under three conditions:– The clinic or group practice’s patient volume is appropriate as a patient volume

methodology calculation for the EP (for example, if an EP only sees Medicare, commercial, or self-pay patients, this is not an appropriate calculation).

– There is an auditable data source to support the clinic’s patient volume determination.

– So long as the practice and EPs decide to use one methodology in each year (in other words, clinics could not have some of the EPs using their individual patient volume for patients seen at the clinic, while others use the clinic-level data). The clinic or practice must use the entire practice’s patient volume and not limit it in any way.

EPs may attest to patient volume under the individual calculation or the group/clinic proxy in any participation year.

Furthermore, if the EP works in both the clinic and outside the clinic (or with and outside a group practice), then the clinic/practice level determination includes only those encounters associated with the clinic/practice.


Auditable for 6 years following payment : pre-payment audit and monitoring

Pre Payment The provider is enrolled in Minnesota Medicaid. The provider is licensed and was licensed for the applicable time frame with

no suspensions or revocations (including pharmaceutical prescribing licensure).

The provider is not deceased. The provider has not been sanctioned The provider’s Tax Identification Number (TIN) has been verified by

matching with an IRS TIN From a check of claims volume and the supporting information submitted,

the minimum patient volume threshold is achieved. No previous year payment was made, for providers claiming incentives

based on adoption, implementation, or upgrading of EHR technology. The provider has adopted certified EHR technology.


Auditable for 6 years following payment : post payment audit and monitoring

• Includes onsite audits

• Types of documents that will be required include:– documents that support the patient and claims volumes

• Paper encounter forms– invoices or contracts that support the adoption, implementation or

upgrading of certified EHR technology– Reports used for calculating patient volume

• If an audit determines that an error in payment has been made, a written notification will be created and sent, informing the provider of the intent to recover funds. • The recovery process will follow current New Jersey Division of Medical Assistance

and Health Services recovery practices and guidelines.


Additional things to consider in prep for audits

• Assemble an “audit package”– Include documentation to support all eligibility requirements

• Non hospital based• Patient volume• Reassignment agreement• Certified EHR documents

• Other possible documents to include:– EP did not participate in Medicare program or Medicaid in anther

state for same year– EP was in good standing with Medicaid

Note: Medicaid may review MU as part of regular audits and investigations


Details on audit strategy from theMN State Medicaid HIT Plan • MN HITPLAN PAGE 6: D. Audit Strategy The SMA will build on its existing audit program and

automated MMIS system checks to assure that MEIP is effectively administered and that payments are made only to providers enrolled in the program and who are using it as intended. Pre-payment controls include 100 percent verification of applicants’ licensure and EHR certification numbers and cross-checking all providers against the federal and state debarment and suspension lists and OIG and Master Death lists. Additionally, hospitals’ Medicare costs reports, providers’ uploaded proofs-of-purchase and MMIS claims information will be used. Post-payment controls include verifying any EP patient volume if reported volume is within two percentage points of the threshold value and a random sample methodology for all others. All EH patient volumes will be verified using Medicare cost reports. Additionally, the SMA will confirm that through the NLR that an EP does not receive a Medicare and Medicaid incentive payment for the same payment year. Our audit strategy will also combine a risk-based approach with random sampling audits of attested denominator volumes.

• MN HIT PLAN PAGE 54: M. Post-payment controls: The SMA will verify any EP patient volume within two percentage points of the threshold value and randomly sample all others. All EH patient volumes will be verified using Medicare cost reports. Additionally, the SMA will confirm that a provider did not receive a Medicare payment and combine a risk-based approach with random sampling audits of attested denominator volumes.

http://www.dhs.state.mn.us/main/idcplg?IdcService=GET_FILE&RevisionSelectionMethod=LatestReleased&Rendition=Primary&allowInterrupt=1&noSaveAs=1&dDocName=dhs16_167677



Professionals who work in flat rate per day programs

• It comes down to an objective , auditable data source.• Is there a service document that can show

date of service, begin and end time of service, person who delivered to service, what type of service was provided, service notes, signature of provider?


Reassignment of incentive dollars

• EPs may reassign their incentive payment to the taxpayer identification number (TIN) of their employer (including group practices or clinics), if they so choose. – Each agency should have a discussion about reassignment with each

EP and put a formal written agreement in place.– Sample “reassignment of benefit” agreement: one of our other

Qualifacts customers, Gail Lawson of Sound Community Services of CT, graciously offered to allow us to share their agencies reassignment of incentive dollars agreement to be used as a sample.

***Please note that Gail shares this as a sample only and your agency will want your legal advisor to review your final agreement as there may be specific state laws, employment laws, etc. that need to be considered for your agency. This sample is available on Qualifacts Connect.


How does year 1 differ from years 2 – 6?

Non Hospital Based

Meet eligibility

Attest to A/I/U

Non Hospital Based

Meet eligibility

50 % or more EPs patient encounters during the reporting period at a practice/location or practices/locations equipped with certified EHR technology

Demonstrate meaningful use of an EHR for 90 consecutive days

Non Hospital Based

Meet eligibility

50 % or more EPs patient encounters during the reporting period at a practice/location or practices/locations equipped with certified EHR technology

Demonstrate meaningful use of an EHR for full calendar year

YEAR ONE

YEAR TWO

YEARS THREE-

SIX


Stage 1 EHR Meaningful Use Specification Sheets for Eligible Professionals

CORE1. *CPOE2. Drug : drug and drug : allergy checks3. Up to date problem list4. *eRx5. Active Medication list6. Active Medication Allergy list7. Demographics8. *Vital Signs9. *Smoking Status10. Clinical Quality Measures11. Clinical Decision support rule12. *Electronic copy of Health Info upon request13. *Clinical Summaries after each visit14. Exchange Key Clinical Information15. Protect Health Information

MENU1. *Implement drug formulary checks2. *Incorporate Lab test results3. Generate patient lists4. *Patient Reminders5. *Provide patients Electronic Access6. Patient Specific Education Resources7. *Medication Reconciliation8. *Summary of Care record upon transition9. *Submit Electronic data to immunization

registry10. *Submit syndromic surveillance data to public

health agencyMEASURES that have exclusions

IMPORTANT LINK: Specification sheets for measures of meaningful use for eligible professionals.

https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/downloads/EP-MU-TOC.pdf




Questions?


Important Links• MN State Medicaid HIT plan• MINNESOTA MEDICAID EHR INCENTIVE PROGRAM

(MEIP) • Sign up for email updates from MEIP >

Electronic Health Records Sign Up For Mailing List• CMS Final Rules: Medicare and Medicaid Electronic

Health Record Incentive Program (pdf)

• MN eHealth “ A Practical Guide to Effective Use of EHR Systems”

• CMS SPECIFCATION SHEETS TO MEASURES OF MU FOR ELIGIBLE PROFESSIONALS





http://www.gpo.gov/fdsys/pkg/FR-2010-07-28/pdf/2010-17207.pdf




http://www.health.state.mn.us/ehealth/summit/g4effectiveuse2009.pdf






Qualifacts can help

Please contact us for help. Our Meaningful Use Program Manager, Mary Givens is available to ensure every customer receives their incentive payments.

Mary was our lead project manager for the Meaningful Use certification process. Because of her expertise and experience we decided to make her a dedicated Meaningful Use and incentive payment resource to customers.

Mary and her team can help you:

• Calculate your maximum number of EPs• Register and attest for the Medicaid and Medicare programs• Analyze workflows and make modifications for meeting MU criteria• Answer all questions

Mary Givens | [email protected] | 615.493.5221 [email protected]

mailto:[email protected]

mailto:[email protected]


DisclaimerIt is important that each individual eligible professional and their surrogates take responsibility for understanding of the final rules and regulations of the Medicaid and Medicare EHR Incentive Programs. Qualifacts Systems Inc offers these free webinars as a service and makes every effort to provide accurate information. We make no claim that our information is complete or contains no inaccuracies.

Under no circumstances shall anyone associated with Qualifacts Systems Inc. Be liable for any incidental, indirect, consequential or special damages or loss of any kind including those resulting from the expected incentives themselves.

Qualifacts Systems, Inc in no way considers itself the ultimate authority or expert on the final rules and regulations of the Medicare and Medicaid EHR Incentive Programs and expects that each individual will consult the state specific Medicaid EHR Incentive Program website for their specific states rules and/or the CMS website for the EHR Incentive Program Rules.

It is important that each Eligible Professional note that CMS views the EP as ultimately responsible for the numerator and denominator and their Medicaid Encounter volume as well as the data used for attestation on the measures of Meaningful Use. CMS has announced there will be audits. “There are numerous pre-payment edit checks built into the EHR Incentive Programs’ systems to detect inaccuracies in eligibility, reporting and payment. Post-payment audits will also be completed during the course of the EHR Incentive Programs.”

Documents

The Minnesota Medicaid Electronic Health Record Incentive Program of Meaningful Use (MEIP)