SoonerCare EHR Incentive Program

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Oklahoma

Electronic Health Record Incentive Program

Oklahoma

Health Care Authority

Board Retreat

Thursday, August 26, 2010

Carol McFarland, CPA, CGFM

Performance & Reporting Manager

Melody Anthony, M.S.

Provider Services Director

Adolph Maren Jr., M.A.

Senior Planning Coordinator

Oklahoma EHR Incentive Program

Origin: American Recovery &

Reinvestment Act of 2009

Health Information Technology provisions of the ARRA

• Title XIII, Division A, HIT

• Title IV of Division B,

Medicare and Medicaid HIT

"HITECH Act"

The Health Information Technology for Economic and

Clinical Health Act established programs under

Medicare and Medicaid to provide incentive payments for the "meaningful use" of certified EHR technology.

Oklahoma EHR Incentive Program

HITECH Legislation’s purpose:

To improve outcomes, facilitate access, simplify care, and reduce costs of health care nationwide by providing:

 Major financial support to provider and States;

 Learning opportunities created and leverages through technical assistance from CMS and others;

 Will establish sustainable data-driven infrastructure that will create a framework for improving healthcare quality and outcomes

Oklahoma EHR Incentive Program

 Federal Partner responsibilities

 Centers for Medicare & Medicaid Services

 incentive program and meaningful use (MU)

 Final Rule for EHR Incentives & MU - July 13, 2010

 www.cms.gov/EHRIncentivePrograms/

 Office of the National Coordinator of Health Information

Technology

 certification standards program for EHR technology

 temporary certification program –

 final rule published June 18, 2010

 effective June 24, 2010 permanent certification program is expected to be published this fall

 www.HealthIT.hhs.gov

Oklahoma EHR Incentive Program

Incentive to . . .

 Adopt ( acquire and install)

 Implement (commenced utilization, train staff, deploy tools, exchange data)

Or…

 Upgrade (expand functionality or interoperability)

 Meaningfully Use (meet specified criteria)

. . . a certified EHR System

Oklahoma’s Program begins January 2011

Oklahoma EHR Incentive Program

Provider Eligibility,

Registration and

Attestation

Oklahoma EHR Incentive Program

EHR Incentive Eligibility:

Qualifying Eligible Professionals (EP)

1 Current SoonerCare Provider Contract

2 Hospital-based EPs are

NOT eligible

90% or more of services are performed in a hospital inpatient or emergency room setting.

3 Provider Type Physicians (MD,DO)

Pediatricians

Dentists

Certified Nurse Midwifes

Nurse Practitioners

Physician Assistants (PA) practicing at a FQHC/RHC so led by a PA

4 Patient Volume over a 90 day period

30% SoonerCare

20-29% SoonerCare - Pediatricians = 2/3 of incentive payment

30% Needy Individuals* Medical EPs practicing predominantly in FQHC or RHC

*Needy individuals = SoonerCare members, patients receiving uncompensated care and patients receiving services at reduced or no cost based upon ability to pay

Oklahoma EHR Incentive Program

EHR Incentive Eligibility:

Qualifying Eligible Hospitals (EH)

1 Current SoonerCare Provider Contract

2 Hospital Types Acute Care Hospital

(includes CAHs & cancer hospitals)

Avg. length of stay < 25 days

CCN* last 4 of

0001 – 0879; 1300 – 1399

Children’s Hospital CCN* last 4 of 3300 – 3399

Not applicable to children’s wings of larger hospitals

3 Patient Volume over a

90 day period

Acute Care Hospital

Children’s Hospitals

10% SoonerCare

No Requirement

* CCN - CMS Certification Number

Oklahoma EHR Incentive Program

Patient Volume Calculation

 Based upon CMS final rule

 A Patient Volume Documentation worksheet will be provided as part of attestation process

 Provider defined 90 day period in the calendar year

Number of SoonerCare* member encounters

Number of total patient encounters

* or Needy Patient encounters for EPs providing services at a FQHC/RHC

Oklahoma EHR Incentive Program

Registration

 EPs and EHs are required to register with the Medicare and Medicaid registration and attestation system

 Name, NPI, business address, phone

Tax payer ID Number (TIN)

Hospitals must provide the CCN

 EPs must select Medicare or Medicaid

 May switch once between programs before 2015

 If Medicaid, must select one state

 May switch states annually

Oklahoma EHR Incentive Program

Registration

OHCA will:

Connect to federal repository to facilitate provider attestation

Continue verification of eligibility

Disburse payment after cross-checking for potential duplicative, inappropriate payments and verification of supporting documentation

Disburse payment to one eligible TIN

Notify the national repository upon payment

Oklahoma EHR Incentive Program

Electronic Attestation Process

Provider registers with CMS

CMS directs providers to the OHCA website for enrollment in the Oklahoma EHR incentive program

Providers fill out attestation

Identify your ONC-ATCB* certified EHR system

Complete patient volume worksheet

Electronically sign contract ammendment and fax requested documention to OHCA

*Office of the National Coordinator for Health Information

Technology

– Authorized Testing and Certificaiton Body

Oklahoma EHR Incentive Program

EP Electronic Attestation

 Provider is not a hospital based professional

 Provider must provide services in Oklahoma

 Provider is not receiving an incentive payment from another state for that calendar year

 Provider has adopted, implemented or upgraded a certified EHR

 Provider inputs the certification number for the ONC-ATCB certified

EHR system

 Provider list number of FTE jobs created by implementing a certified product

 Provider reports cash payments made for the certified EHR

 Provider confirms assignment of payment to a qualified TIN

 Providers percentage of SoonerCare patient volume is equal to or greater than the allowed

 Provider has specified the patient volume date range of 90 days during the calendar year

Oklahoma EHR Incentive Program

EH Electronic Attestation

 Hospital is not currently receiving an incentive payment from another state for that federal fiscal year

 Hospital must be located in Oklahoma

 Hospitals (Medicaid only) have adopted, implemented or upgraded a certified EHR, or meaningfully used a certified EHR

 ONC-ATCB EHR Certification number is included

 Hospital list number of FTE jobs created by implementing a certified product

 Hospital (acute care) percentage of SoonerCare discharges is at least 10%; Children's hospitals have no discharge percentage

Oklahoma EHR Incentive Program

Adopt / Implement / Upgrade

 Adopted – Acquired and Installed

 Implemented – Commenced Utilization

 Upgraded – Expanded Upgraded to certified EHR technology or added new functionality to meet the definition of certified

EHR technology

 Must be certified EHR technology capable of meeting meaningful use

No EHR reporting period

Only for first participation year

Oklahoma EHR Incentive Program

Meaningful Use (MU) of EHR

The Recovery Act specifies the following 3 components of Meaningful Use:

Use of certified EHR in a meaningful manner

Use of certified EHR technology for electronic exchange of health information to improve quality of health care

Use of certified EHR technology to submit clinical quality measures(CQM) and other such measures selected by the

Secretary

Oklahoma EHR Incentive Program

Meaningful Use of EHR –

Health Outcome Priorities

 Improve quality, safety, efficiency, and reduce health disparities

Engage patients and families in their health care

Improve care coordination

Improve population and public health

Ensure adequate privacy and security protections for personal health information

Oklahoma EHR Incentive Program

Meaningful Use of EHR

 3 Stages currently proposed

Stage 1

EP: 20 of 25 Objectives / Measures

EH: 19 of 24 Objectives / Measures

To meet certain objectives/measures, 80% of patients must have records in the certified EHR technology

Reporting Period –90 days for first year; one year subsequently

Oklahoma will adopt MU measures as published.

CMS intends to propose 2 additional stages through future rulemaking.

At this time, CMS plans on transitioning the Stage 12 menu set into the Stage 2 core set.

Oklahoma EHR Incentive Program

Eligible Professionals –15 Core Objectives

1.

Computerized Physician Order Entry (CPOE)

2.

E-Prescribing (eRx)

3.

Report ambulatory clinical quality measures to CMS/States

4.

Implement one clinical decision support rule

5.

Provide patients with an electronic copy of their health information, upon request

6.

Provide clinical summaries for patients for each office visit

7.

Drug-drug and drug-allergy interaction checks

8.

Record demographics

9.

Maintain an up-to-date problem list of current and active diagnoses

10.

Maintain active medication list

11.

Maintain active medication allergy list

12.

Record and chart changes in vital signs

13.

Record smoking status for patients 13 years or older

14.

Capability to exchange key clinical information among providers of care and patient-authorized entities electronically

15.

Protect electronic health information

Oklahoma EHR Incentive Program

Eligible Hospitals –14 Core Objectives

1.

CPOE

2.

Drug-drug and drug-allergy interaction checks

3.

Record demographics

4.

Implement one clinical decision support rule

5.

Maintain up-to-date problem list of current and active diagnoses

6.

Maintain active medication list

7.

Maintain active medication allergy list

8.

Record and chart changes in vital signs

9.

Record smoking status for patients 13 years or older

10.

Report hospital clinical quality measures to CMS or States

11.

Provide patients with an electronic copy of their health information, upon request

12.

Provide patients with an electronic copy of their discharge instructions at time of discharge, upon request

13.

Capability to exchange key clinical information among providers of care and patient-authorized entities electronically

14.

Protect electronic health information

Oklahoma EHR Incentive Program

Eligible Professionals –10 Menu Set Objectives

1.

Drug-formulary checks

2.

Incorporate clinical lab test results as structured data

3.

Generate lists of patients by specific conditions

4.

Send reminders to patients per patient preference for preventive/follow up care

5.

Provide patients with timely electronic access to their health information

6.

Use certified EHR technology to identify patient-specific education resources and provide to patient, if appropriate

7.

Medication reconciliation

8.

Summary of care record for each transition of care/referrals

9.

*Capability to submit electronic data to immunization registries/systems

10.

*Capability to provide electronic syndromic surveillance data to public health agencies

*At least 1 public health objective must be selected

Oklahoma EHR Incentive Program

Eligible Hospitals –10 Menu Set Objectives

1.

Drug-formulary checks

2.

Record advanced directives for patients 65 years or older

3.

Incorporate clinical lab test results as structured data

4.

Generate lists of patients by specific conditions

5.

Use certified EHR technology to identify patient-specific education resources and provide to patient, if appropriate

6.

Medication reconciliation

7.

Summary of care record for each transition of care/referrals

8.

*Capability to submit electronic data to immunization registries/systems

9.

*Capability to provide electronic submission of reportable lab results to public health agencies

10.

*Capability to provide electronic syndromic surveillance data to public health agencies

*At least 1 public health objective must be selected

Oklahoma EHR Incentive Program

Incentive

Payments

Oklahoma EHR Incentive Program

Eligible Professional Payments

 Paid in alignment with the Calendar year

First year amount consistent regardless of stage (AIU or MU)

Maximum incentives are $63,750 over 6 years

Incentives are same regardless of start year

The first year maximum payment is $21,250

Must begin by 2016 to receive incentive payments

No requirement for “consecutive years” participation

Incentives available through 2021

Only 1 incentive payment per year

Oklahoma EHR Incentive Program

Eligible Hospital Payments

Paid in alignment with the Federal Fiscal year (FFY)

First year amount consistent regardless of stage (AIU or MU)

$2M base + per discharge amount (based on Medicare/

Medicaid share)

Medicare Meaningful Use requirements may be deemed eligible for Medicaid payments

Payment is calculated, then disbursed over 3-6 years; we have proposed 3 year disbursement

No annual payment may exceed 50% of the total calculation; no 2-year payment may exceed 90%; we have proposed 50%

/ 40% / 10%

Hospitals cannot initiate payments after 2016 and payment years must be consecutive after 2016

States must use auditable data sources in calculating the hospital incentive (e.g., cost report)

Payments through 2021

Oklahoma EHR Incentive Program

Eligible Hospitals

Calculate total incentive in base year

Calculated on a 4 year payment basis

Payment over 3 years

 Year 1: 50%

 Year 2: 40%

 Year 3: 10%

Oklahoma EHR Incentive Program

Eligible Hospitals

(Overall EHR Amount) * (Medicaid Share)

Defined as

{Sum over 4 year of [(Base Amount)+ Discharge

Related Amount Applicable for Each Year) *

Transition Factor Applicable for Each Year]}

. . . multiplied by . . .

[Medicaid inpatient-bed-days / {(Total inpatient-beddays) * (estimated total charges – charity care charges) / (estimated total charges)}]

Oklahoma EHR Incentive Program

Monitoring,

Oversight

&

Audit

Oklahoma EHR Incentive Program

Monitoring / Oversight / Audit

Attest to specific requirements

Provide required documentation

Keep supporting documentation on file

Random sample and targeted sample reviews will be conducted

Oklahoma EHR Incentive Program

Thank You!

Adolph.Maren@okhca.org

Melody.Anthony@okhca.org

Carol.McFarland@okhca.org

www.okhca.org/EHR-incentive

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