1. Susan Clark, BS, RHIT, CHTS-IM, CHTS-PW HIT Solutions Executive, eHealthcare Consulting sclark@ehealthcareconsulting.com Meaningful Use And The

2. ▪ Introduction ▪ Meaningful Use program as it has existed and what led to prompts for change. ▪ 2015-2017 Modification Rule impacts the 2016 Meaningful Use reporting year. ▪ Introduction to the Merit-Based Incentive Payment Program (MIPS) ▪ Recommendations to begin programmatic preparations prior to the MIPS rule becoming final. Introduction & Agenda

3. This presentation contains information currently available from Center for Medicare and Medicaid Services (CMS). The intent of this presentation is to facilitate dialogue and is for informational purposes and is current at the time of presentation. Please be aware that changes occur within this program frequently, and without notice. Contact CMS resources for the most current set of regulations and updates. Disclaimer

4. ▪ George W. Bush – 2004 Established ONC (Office of National Coordinator through HHS) Mission: “to support the widespread, meaningful use of health IT.” ▪ President Obama – 2009 – HITECH Act (ARRA/Stimulus) Established the EHR incentive-penalty programs ▪ MU has been a program of continual change ▪ Initiation of program activity (2010) ▪ 2015 – 2017 Meaningful Use Final Rule (October, 2015) ▪ MACRA (Medicare Access & CHIP Reauthorization Act) (April, 2015) ▪ MIPS (Merit Based Incentive Payment System) ▪ NPRM (Spring 2016) History of Meaningful Use

5. Stages of Meaningful Use

6. Incentives vs. Penalties Medicare no longer yields incentive payments, only assesses “payment adjustments” Medicaid is still paying incentives. This is the last year for which the first year payment of $21,250 may be obtained for AIU. There is no Medicaid penalty.

7. The Cost of Non-participation…or failing MU If the average provider billed Medicare FFS claims of $250,000 in 2015 = $7500 PENALTY in 2017 *Note – EP hardship exception applications for 2015 are accepted until July.

8. Reporting Periods 2015-2017 2015 ALL EP - Any Continuous 90 days 2016 NEW EP - Any continuous 90 days in the calendar year RETURNING EP - Full calendar year 2017 & Beyond ALL EP – Full calendar year

9. 1.Protect Electronic Health Information 2.Clinical Decision Support 3.CPOE 4.E-Prescribe 5.Summary of Care 6.Patient Specific Education 7.Medication Reconciliation 8.Patient Electronic Access 9.Secure Electronic Messaging 10. Public Health Reporting Requirements at a Glance 10 Objectives

10. ▪ January 11 th,2016 CMS Acting Director is quoted as saying: “The Meaningful Use program as it has existed, will now be effectively over.” Meaningful Use is DEAD!!!

11. No. It’s Not.

12. ▪ “Technology must be user-centered and support physicians, not distract them.” ▪ “…the focus will move away from rewarding providers for the use of technology and towards the outcome they achieve with their patients.” ▪ “And finally, we are deadly serious about interoperability.” Using the word “deadly” – coincidence?? The rest of the story…….

13. The Audits Continue

14. Medicaid Audits Too

15. ▪ Storage medium – mobile media, cloud, paper ▪ Establish Information Governance, ▪ Roles and Responsibilities ▪ Identify data owner, but should not be the only one with data access ▪ Retention period 6 years post attestation ▪ Includes Hardship Exception applications ▪ Documentation for EHR Certification/Vendor Issues (CEHRT Issues) or Lack of Control over CEHRT Availability Maintaining Documentation

16. ▪ Medicaid eligibility encounter data, detailed patient specific reports ▪ Hospitals should maintain documentation that supports their payment calculations. ▪ Proof of certified EHR software ▪ More than 50% of patients recorded in CEHRT “If it wasn’t documented, it wasn’t done.”

17. ▪ Reports must be from CEHRT, vendor logo displayed ▪ Consideration when switching EHRs and maintaining archived legacy data ▪ Display provider or hospital name, time period of report ▪ eRx – permissible and/or available for controlled substance ▪ If have upgraded the product, cannot reproduce the reports accurately to match what was reported. Calculated Measures

18. ▪ Screen shots with dates that the functionality is available, enabled, and active in the system for the duration of the EHR reporting period. ▪ Medicaid audit has additional open-ended questions – e.g. what formulary does your EHR use? Describe workflow for CDS and how the EHR tracks compliance ▪ Vendor documentation ▪ Patient list actual list of patients PER provider Non-Calculated Measures

19. ▪ Letter from ISDH portal ▪ Registration is completed during the 1st 60 days of the reporting period ▪ Exclusions – e.g. state does not do syndromic ambulatory, registry does not accept applicable day (GI – colonoscopy and EGD data from ASC, not ambulatory). ▪ Submitting providers via hospital feeds Public Health Measures CMS FAQs 14393, 14397, 14401

20. Public Health - ISDH Portal

21. ▪ To qualify as a valid specialized registry in 2016, the registry must do the following: ▪ Publically declare readiness to accept data (by 1/1/16 or by day 1 of EPs reporting period) and be able to accept electronic submissions – manual data entry into a website does not count ▪ Be able to support the registration/onboarding and production processes ▪ Be able to provide documentation as evidence of data submission Specialized Registry Requirements CMS FAQs 13657, 14117, 13653

22. ▪ Most common audit failure point ▪ Completed yearly within reporting year. ▪ Must show date, person completing assessment ▪ Show at least one item mitigated and plan for remaining items ▪ May be audited by OCR, OIG as well for this, along with HIPAA Privacy Assessment ▪ Assure BAAs in place for all outside companies Security Risk Assessment

23. ▪ Selection of audit subject is based on a risk profile that CMS does not disclose. However, likely factors include: Red Flags Skipping program years, or only attesting once Numerator values of zero Denominator inconsistencies. E.g. unique patient measures. Previously failed audit

24. ▪ MACRA, MIPS – the latest acronyms ▪ NPRM Status, expected final rule ▪ CMS Attestation website actively under construction MIPS – It’s coming

25. ▪ Components ▪ VBM-measured quality (up to 30 points) – [PQRS] ▪ VBM (Value Based Modifier) - measured resource use (30 points) ▪ MU (25 points) – Meaningful Use ▪ Clinical Practice Improvement (15 points) ▪ Alternative Payment Model ▪ Qualified vs non-qualified ▪ Numerators now matter MIPS Basics

26. ▪ The MACRA legislation only addresses Medicare physician and clinician payment adjustments. ▪ The approach to meaningful use under MACRA won’t happen overnight. In the meantime, our existing regulations – including meaningful use Stage 3 – are still in effect. ▪ Medicaid expected 2021, other payers also following suit. ▪ How are hospitals impacted? Is there a place to hide for non EP’s?

27. ▪ MIPS scores and individual category scores will be available on the Physician Compare website. Physician Compare website ▪ Consumers will now be able to see their providers rated on a scale of 0 to 100 and how their providers compare to peers locally and nationally. Quality Scores Go Public

28. Gasp! Panic! What do we do now??

29. Implement certified EHR technology Meet Meaningful Use requirements Maximize PQRS quality performance scores Attain and maintain PCMH Best Practices to Qualify For Maximum Reimbursement?

30. ▪ Program management ▪ MU ▪ PQRS ▪ PCMH ▪ ACO (APM) ▪ Maintain tracking and audit documentation by provider ▪ Information Governance This is NOT just another task……..

31. Medicare & Medicaid EHR Incentive Program Basics CMS https://www.cms.gov/regulations-and- guidance/legislation/ehrincentiveprograms/basics.htmlhttps://www.cms.gov/regulations-and- guidance/legislation/ehrincentiveprograms/basics.html Medicare Registration & Attestation (includes links to the Medicare & Medicare attestation user guides (page-by-page screen shots): https://www.cms.gov/regulations-and- guidance/legislation/ehrincentiveprograms/registrationandattestation.htmlhttps://www.cms.gov/regulations-and- guidance/legislation/ehrincentiveprograms/registrationandattestation.html CMS Supporting Documentation for Audits https://www.cms.gov/regulations-and- guidance/legislation/ehrincentiveprograms/downloads/ehr_supportingdocumentation_audits.pdfhttps://www.cms.gov/regulations-and- guidance/legislation/ehrincentiveprograms/downloads/ehr_supportingdocumentation_audits.pdf CHPL-Certified Product List http://oncchpl.force.com/ehrcerthttp://oncchpl.force.com/ehrcert 2015 – 2017 Meaningful Use Final Rule https://www.federalregister.gov/articles/2015/10/16/2015-25595/medicare-and-medicaid- programs-electronic-health-record-incentive-program-stage-3-and-modifications https://www.federalregister.gov/articles/2015/10/16/2015-25595/medicare-and-medicaid- programs-electronic-health-record-incentive-program-stage-3-and-modifications Resources

32. Andy Slavitt speech 1/11/16 https://blog.cms.gov/2016/01/12/comments- of-cms-acting-administrator-andy-slavitt-at-the-j-p-morgan-annual-health-care- conference-jan-11-2016/https://blog.cms.gov/2016/01/12/comments- of-cms-acting-administrator-andy-slavitt-at-the-j-p-morgan-annual-health-care- conference-jan-11-2016/ CMS FAQ https://questions.cms.gov/https://questions.cms.gov/ CMS MACRA-MIPS https://www.cms.gov/Medicare/Quality-Initiatives-Patient- Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and- APMs/MACRA-MIPS-and-APMs.htmlhttps://www.cms.gov/Medicare/Quality-Initiatives-Patient- Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and- APMs/MACRA-MIPS-and-APMs.html More Resources

33. Questions?