CMS Incentive Programs for Eligible Professionals David Nilasena MD CMS Region VI NM HFMA/HIMA April 13, 2012 Medicare EHR Incentive Program Overview of the Program for Eligible Professionals Who is Eligible to Participate? • Medicare Eligible Professionals include: • • • • • Doctors of medicine or osteopathy Doctors of dental surgery or dental medicine Doctors of podiatric medicine Doctors of optometry Chiropractors • Specialties are eligible if meet one of above criteria • EPs may not be hospital-based Who is Eligible to Participate? • Eligibility determined in law • Hospital-based EPs are NOT eligible for incentives • DEFINITION: 90% or more of their covered professional services in either an inpatient (POS 21) or emergency room (POS 23) of a hospital • Definition of hospital-based determined in law • Incentives are based on the individual, not the practice How Much Are the Incentives? • Medicare Incentive Payments Detail • Columns = first calendar year EP receives a payment • Rows = Amount of payment each year if continue to meet requirements CY 2011 CY 2012 CY 2013 CY2014 CY 2015 and later CY 2011 $18,000 CY 2012 $12,000 $18,000 CY 2013 $8,000 $12,000 $15,000 CY 2014 $4,000 $8,000 $12,000 $12,000 CY 2015 $2,000 $4,000 $8,000 $8,000 $0 $2,000 $4,000 $4,000 $0 $44,000 $39,000 $24,000 $0 CY 2016 TOTAL $44,000 In order to get a payment Medicare • Meaningfully use of certified EHR technology • Attest to all program requirements, Meaningful Use requirements • Get EHR certification number from Office of National Coordinator of Health IT technology’s CHPL website Medicaid • Meaningful use* of certified EHR technology • Attest to all program eligibility requirements • Attest to meaningful use* requirements • Get EHR certification number from Office of National Coordinator of Health IT technology’s CHPL website *Medicaid eligible hospitals may adopt, implement, upgrade, or meaningfully use certified EHR technology in the first participation year. 26 Register for the EHR Incentive Program • Visit the CMS EHR Incentive Program website • Click on the Registration tab • Complete your registration https://www.cms.gov/EHRIncentivePrograms/ 27 What are the Requirements/ Meaningful Use? • Meaningful Use is using certified EHR technology to • Improve quality, safety, efficiency, and reduce health disparities • Engage patients and families in their health care • Improve care coordination • Improve population and public health • All the while maintaining privacy and security • Meaningful Use mandated in law to receive incentives What are the Requirements/ Meaningful Use? • Established 3 stages of meaningful use: 2011, 2013 and 2015 Data capture and sharing Advanced clinical processes Improved outcomes What are the Requirements/ Meaningful Use? • Basic Overview of Stage 1 Meaningful Use: • Stage 1 • Reporting period is 90 days for first year and 1 year subsequently • Reporting through attestation • Objectives and Clinical Quality Measures • Reporting may be yes/no or numerator/denominator attestation • To meet certain objectives/measures, 80% of patients must have records in the certified EHR technology What are the Requirements/ Meaningful Use? • Stage 1 Objectives and Measures Reporting • Must complete: • 15 core objectives • 5 objectives out of 10 from menu set • 6 total Clinical Quality Measures (3 core or alternate core, and 3 out of 38 from menu set) What are the Requirements/ Meaningful Use? • A Medicare Eligible Professional who does NOT demonstrate meaningful use by 2015 will be subject to payment reductions in their Medicare reimbursement schedule • Medicaid-only EPs are not subject to payment reductions • Payment reductions may apply for any EP who accepts Medicare, even if you only participate in the Medicaid EHR incentive program What You Need to Participate • All providers must: • Register via the EHR Incentive Program website: https://ehrincentives.cms.gov/ • Be enrolled in Medicare FFS, MA, or Medicaid (FFS or managed care) • Have a National Provider Identifier (NPI) • Use certified EHR technology • Medicaid providers may adopt, implement, or upgrade in their first year • All Medicare providers and Medicaid eligible hospitals must be enrolled in PECOS What You Need to Participate • Certified EHR Technology: • Required in order to achieve meaningful use • Standards and certification criteria announced on July 13, 2010. See http://healthit.hhs.gov/standardsandcertification for more information • ONC has authorized 6 “testing and certification bodies” (ATCBs) for temporary certification program as of December 2010 • Certified products are available. (~800 complete EHRs) • List of certified EHRs and EHR modules are posted on ONC web site: http://onc-chpl.force.com/ehrcert • Visit http://healthit.hhs.gov/certification for more information • Email ONC.Certification@hhs.gov with questions Proposed Rule Everything discussed in this presentation is part of a notice of proposed rulemaking (NPRM). We encourage anyone interested in Stage 2 of meaningful use to review the NPRM for Stage 2 of meaningful use and the NPRM for the 2014 certification of EHR technology at CMS Rule: http://www.gpo.gov/fdsys/pkg/FR-2012-03-07/pdf/2012-4443.pdf ONC Rule: http://www.gpo.gov/fdsys/pkg/FR-2012-03-07/pdf/2012-4430.pdf Comments can be made starting March 7 through May 7 at www.regulations.gov What is in the Proposed Rule • • • • • • • • Minor changes to Stage 1 of meaningful use Stage 2 of meaningful use New clinical quality measures New clinical quality measure reporting mechanisms Appeals Details on the Medicare payment adjustments Minor Medicare Advantage program changes Minor Medicaid program changes 37 Stages of Meaningful Use Stage of Meaningful Use 1st Year 2011 2012 2013 2014 2015 2016 2017 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 1 1 1 2 2 3 3 TBD TBD TBD TBD 1 1 2 2 3 3 TBD TBD TBD TBD 1 1 2 2 3 3 TBD TBD TBD 1 1 2 2 3 3 TBD TBD 1 1 2 2 3 3 TBD 1 1 2 2 3 3 1 1 2 2 3 38 Payment Adjustments • The HITECH Act stipulates that for Medicare EP, subsection (d) hospitals and CAHs a payment adjustment applies if they are not a meaningful EHR user. • An EP, subsection (d) hospital or CAH becomes a meaningful EHR user when they successfully attest to meaningful use under either the Medicare or Medicaid EHR incentive program • As adopt, implement and upgrade does not constitute meaningful use, a provider receiving a Medicaid incentive for AIU would still be subject to the Medicare payment adjustment. 39 EP Payment Adjustments % ADJUSTMENT ASSUMING LESS THAN 75 PERCENT OF EPs ARE MEANINGFUL EHR USERS FOR CY 2018 AND SUBSEQUENT YEARS 2015 2016 2017 2018 2019 2020+ EP is not subject to the payment adjustment for e-Rx in 2014 EP is subject to the payment adjustment for e-Rx in 2014 99% 98% 97% 96% 95% 95% 98% 98% 97% 96% 95% 95% % ADJUSTMENT ASSUMING MORE THAN 75 PERCENT OF EPs ARE MEANINGFUL EHR USERS FOR CY 2018 AND SUBSEQUENT YEARS 2015 2016 2017 2018 2019 2020+ EP is not subject to the payment adjustment for e-Rx in 2014 EP is subject to the payment adjustment for e-Rx in 2014 99% 98% 97% 97% 97% 97% 98% 98% 97% 97% 97% 97% 40 EP EHR Reporting Period EP who has demonstrated meaningful use in 2011 or 2012 Payment Adjustment Year 2015 2016 2017 2018 2019 2020 Full Year EHR Reporting Period 2013 2014 2015 2016 2017 2019 EP who demonstrates meaningful use in 2013 for the first time Payment Adjustment Year 90 day EHR Reporting Period Full Year EHR Reporting Period 2015 2016 2017 2018 2019 2020 2013 2014 2015 2016 2017 2019 41 EP EHR Reporting Period EP who demonstrates meaningful use in 2014 for the first time Payment Adjustment Year 90 day EHR Reporting Period Full Year EHR Reporting Period 2015 2016 2017 2018 2019 2020 2014* 2014 2015 2016 2017 2019 *In order to avoid the 2015 payment adjustment the EP must attest no later than Oct 1, 2014 which means they must begin their 90 day EHR reporting period no later than July 2, 2014 42 EP Hardship Exemption Proposed Exemptions on an application basis • Insufficient internet access two years prior to the payment adjustment year • Newly practicing EPs for two years • Extreme circumstances such as unexpected closures, natural disaster, EHR vendor going out of business, etc. Applications need to be submitted no later than July 1 of year before the payment adjustment year; however, we encourage earlier submission 43 Resources to Get Help and Learn More • Get information, tip sheets and more at CMS’ official website for the EHR incentive programs: www.cms.gov/EHRIncentivePrograms • Learn about certification and certified EHRs, as well as other ONC programs designed to support providers as they make the transition: http://healthit.hhs.gov Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) Competitive Bidding Program Medicare covers Part B medical equipment and supplies Examples: walkers, power wheelchairs, hospital beds, CPAPs, enteral nutrition and various other medical supplies and accessories. New competitive bidding program Initially, became effective 1/1/11 in 9 areas around the country Medicare beneficiaries must use contract supplier In certain areas (based on zip codes) For certain products Or, it won’t be covered by Medicare • Applies to beneficiaries who have Original Medicare That reside in a Competitive Bidding Area (CBA) and/or Must obtain a competitive bid item while visiting a CBA To see if ZIP Code is in a Competitive Bidding Area Call 1-800-MEDICARE Visit www.medicare.gov Medicare Advantage enrollees will not participate in this program and must use their plan suppliers What’s Coming? Round 2!!! The Competitive Bidding Program expands in 2013 to: 91 Metropolitan Statistical Areas For New Mexico – Albuquerque will be the CBA Round 2 product categories include: 1. 2. 3. 4. 5. 6. 7. 8. Oxygen, oxygen equipment, and supplies Standard (power and manual) wheelchairs, scooters, and related accessories Enteral nutrients, equipment, and supplies Continuous Positive Airway Pressure (CPAP) devices and Respiratory Assist Devices (RADs) and related supplies and accessories Hospital beds and related accessories Walkers and related accessories Negative Pressure Wound Therapy pumps and related supplies and accessories Support Surfaces (Group 2 mattresses and overlays) There will also be a National Mail Order Diabetic Supplies Contract Anyone receiving their diabetic supplies via a national or local mail carrier must obtain them from the national mail order diabetic supplies contractor in order for Medicare to pay for the product or service. For more info, please visit www.cms.gov/DMEPOSCompetitiveBid/ Medicare Shared Savings Program The Shared Savings Program is a new approach to the delivery of health care aimed at reducing fragmentation, improving population health, and lowering overall growth in expenditures by: Promoting accountability for the care of Medicare fee-for-service beneficiaries Requiring coordinated care for all services provided under Medicare Parts A and B Encouraging investment in infrastructure and redesigned care processes http://www.cms.gov/sharedsavingsprogram 48 http://www.cms.gov/sharedsavingsprogram 49 Questions? David Nilasena MD Chief Medical Officer, CMS Region VI (214)-767-4449 david.nilasena@cms.hhs.gov