Medicare and Medicaid EHR Incentive Programs Presented by Jessica Kahn, MPH Centers for Medicare & Medicaid Services Center for Medicaid, CHIP, and Survey & Certification

What is not in the CMS EHR Incentives Final Rule? EHR standards and certification requirements Procedures to become a certifying body Information about grants (e.g., RECs, State HIE Cooperative Agreements, and broadband access) Changes to HIPAA 2

AIU & MU: Overview Adopt, implement, upgrade (AIU) – First participation year only – No EHR reporting period Meaningful use (MU) – Successive participation years; and – Early adopters and some dually-eligible hospitals in year 1 Medicaid Providers’ AIU/MU does not have to be over six consecutive years 3

AIU Adopted: Acquired and installed - e.g., evidence of installation prior to incentive Implemented: Commenced utilization of - e.g., staff training, data entry of patient demographic information into EHR Upgraded: Expanded - e.g., upgraded to certified EHR technology or added new functionality to meet the definition of certified EHR technology 4

The Reach of Meaningful Use Providers Healthcare partners (labs, pharmacies, pharmacy hubs, health information exchanges, registries, etc) EHR vendors State Medicaid IT systems CMS IT systems 5

States’ Flexibility to Revise MU States can seek CMS prior approval to require 4 MU objectives be core for their Medicaid providers: Generate lists of patients by specific conditions for quality improvement, reduction of disparities, research or outreach (can specify particular conditions) Reporting to immunization registries, reportable lab results and syndromic surveillance (can specify for their providers how to test the data submission and to which specific destination) 6

Notable Differences Between Medicare & Medicaid MedicaidMedicare Voluntary for States to implementFeds will implement No Medicaid fee schedule reductionsMedicare fee schedule reductions begin in 2015 for physicians who are not MUers AIU option is for Medicaid onlyMedicare must begin with MU in Y1 Max incentive for EPs is $63,750Max incentive for EPs is $44,000 States can make adjustments to MU (common base definition) MU will be common for Medicare May appeal decisionsAppeals process yet to be developed Program sunsets in 2021; last year a provider may initiate program is 2016 Program sunsets in 2016; fee schedule reductions and market basket update begin in 2015 Five EPs, two general types of hospitals (includes CAHs) Only physicians, subsection(d) hospitals, and CAHs 7

Conditions for State Participation Prior approval for reasonable administrative expenses (P-APD, I-APD) Establish a State Medicaid HIT Plan (SMHP) State may receive 90% FFP to implement the program and 100% FFP for the incentives 8

State Medicaid HIT Plans Key elements: As-Is landscape (results of the environmental scan) Plans for implementing the program Incremental approach allowed Timeline and key benchmarks To-Be Vision and HIT Roadmap Incremental approach allowed with future updates Meant to be an iterative document Accompanied by IAPDs to request CMS funding 9

State Medicaid HIT Plans Finals submitted by: OK, LA, SC, WI, TN, IA, AL Accompanied by a HIT Advanced Planning Document that requests CMS 90/10 matching funds CMS issued a “Dear State Medicaid Director” letter on August 17 th about the 90/10 funding - IT infrastructure; interfaces, etc. Clear expectation for coordination with Public Health and other Federally-funded HIT partners/entities 10

Issues for State Immunization Programs Your website: – Your registry or registries’ ability or lack thereof to receive HL7-compliant message – How will providers know how to submit a test? Where to call? If their test was successful or not? Are you coordinating with the State Medicaid Agency and the RECs on provider messaging around demonstrating MU via your IR? 11

Not Your “Water” Not your issue: testing all EHR products so that they can be certified for MU Not your issue: endorsing any particular EHR technology/vendor Not your issue: answering questions about the EHR Incentive programs, who is eligible or not, what’s going to be in Stage 2 or not 12

Partnering with Medicaid Will the State Medicaid Agency use their flexibility with Stage 1 for the immunization registry objective? Make it core? Direct which IR to test with? Direct how to test? – You should have a very strong role in making this decision Whether or not your State just received the new CDC funding – what are the IT gaps for bidirectional exchange of immunization data between providers and the IR (a la Stage 2)? Can Medicaid help pay for that assessment? Help pay for any of the costs to implement solutions? What’s Medicaid’s “fair share” of those costs? 13

Action Steps: From PHII’s August Presentation (so you already know this, right?): Work closely with state Medicaid program Appoint a senior-level Meaningful Use Coordinator Identify protocols for processing test submissions Coordinate with epi. on lab and syndromic reporting Assess readiness/compliance of IIS with meaningful use requirements Build capacity in HL7; move toward v2.5.1 Work closely with the state HIT Coordinator Engage in state HIE planning and operations Share questions and lessons learned 14

Additional Questions? 15 General questions on the Medicaid EHR Incentive Program: – – Your CMS Regional Office State Medicaid Agencies’ Websites August 17 th State Medicaid Directors Letter on the 90/10 HITECH and MMIS funding: