Presentation - North Carolina Community Health Center Association

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Meaningful Use: Roadmap for
Successful Attestations
Presented by:
Darlene Creech, MPH
Assistant Program Manager
Health Information Technology
NC Division of Medical Assistance
6/23/12
EHR Incentive Program Timeline
• 10-year program: 2011-2021
• EPs may participate in any 6 years (consecutive or non)
•Year 1: adopt, implement, or upgrade (AIU) to certified
EHR technology
•Year 2: meaningfully use for a continuous 90-day period
•Year 3 and beyond: demonstrate MU for the entire year
2016 - Last year to begin
program and receive full
incentive payments
2021 Program
ends
EP Types

EPs under the NC Medicaid EHR Incentive Program
include:
 Physicians (MDs and DOs);
 Nurse practitioners;
 Certified nurse midwives;
 Dentists; and,
 Physician assistants who furnish services in a
Federally Qualified Health Center or Rural Health
Clinic led by a physician assistant.
4
EP Attestation

Incentive payments for EPs are tied to individual
practitioners, however a third party can attest on his/her
behalf (EP must personally sign attestation)

Each EP is eligible for only one incentive payment per
payment year, regardless of how many practices or
locations at which he or she provides services

Hospital-based professionals are not eligible
5
EP Patient Volume Requirements

To qualify for an incentive payment under the NC Medicaid EHR
Incentive Program, an EP must meet one of the following
criteria:



Have a minimum 30% Medicaid patient volume;
Have a minimum 20% Medicaid patient volume
(pediatrician); or,
Practice predominantly in a Federally Qualified Health Center
or Rural Health Center and have a minimum 30% patient
volume attributable to needy individuals.
6
EP Patient Volume Formula
Medicaid PV Percentage:
Medicaid PV = All encounters paid in part or whole by Medicaid in 90-day period
Total PV = All encounters, regardless of the payment method in same 90-day period

Paid encounters, not billed claims

An encounter is service(s) rendered to a unique individual on any one
day

Date of service (not date of payment) within the 90-day period

Pay attention to ‘attending provider’ and ‘billing provider’ issues

Make State aware of any unusual billing issues
7
Progress!

Eligible in NC:
• 3,524 EPs
• 92 EHs

Paid to date: $41 million
• 1,133 EPs
• 21 EHs
EPs Participating To Date
PARTICIPANTS BY TYPE AND SPECIALTY
Type
Specialty
Individual physician PEDIATRICS
GENERAL/FAMILY PRACTICE
OBSTETRICS/GYNECOLOGY
INTERNAL MEDICINE
PSYCHIATRY
1,152
ANESTHESIOLOGY
NEUROLOGY
INFECTIOUS DISEASE
GENERAL/THORACIC SURGERY
RADIOLOGY/NUCLEAR MED
CARDIOLOGY
Various Specialties
Individual dentist
GENERAL DENTIST
64
Hospitals
HOSPITALS (general, acute,
critical access)
25
Nurse practitioner NURSE PRACTITIONER
156
Nurse midwife
NURSE MIDWIFE
33
Mental health provider MENTAL HEALTH NURSE PRACT
19
TOTAL (AS OF 6/19/12)
#
505
161
139
115
64
21
20
17
13
12
11
74
64
25
156
33
19
1449
Welcome to the NC-MIPS 2.0 Portal
MIPS 2.0 Changes

Status Page


Allows you to see past attestation years
Shows you where you are in the current attestation
process


In process, submitted, awaiting provider response,
validating, approved, paid, denied
Demographics Page


Shows both CMS and NC information so you can see if
there is a matching problem
Shows provider and payee MPN and asks if that is
correct (gives link for where to go correct)
MIPS 2.0 Changes - Patient Volume

Yes/No questions you will be asked for INDIVIDUAL methodology:







Did you enter only those encounters attributable to the individual EP in
the numerator and denominator, NOT the patient volume numbers for
the entire group?
Did you list the billing MPNs from ALL practices you included in the
patient volume numbers?
Did you include in the numerator all encounters covered by Medicaid,
even where Medicaid paid for only part of a service?
Did you exclude from the numerator denied claims that were never
paid at a later date?
Did you include encounters in the denominator where services were
provided at no charge?
Are your patient volume numbers based on date of service and not
date of claim or date of payment?
Do the numbers you entered represent encounters and not claims?
MIPS 2.0 – Patient Volume
Additional for group methodology:

Did you include all encounters?


Can’t be limited in any way (count non-EPs such as
phlebotomists and RNs encounters)
Did you include all associated MPNs?

Provide any/all MPNs associated with the group
(even if an MPN is no longer being used but was
used during the 90-day reporting period)
MU Overview
The information in this presentation:
 Is relevant for Stage 1 MU
 Primarily applies to EPs
Stage 2 MU:
 Finalized after the NPRM (published March 7,
2012) is determined
What is the Goal of Stage 1 MU?






Electronic capture of health information
Use the electronic information to track key clinical
conditions
Communicate electronic information for care
coordination
Implement clinical decision support tools for disease
and medication management
Engage patients and families
Report Clinical Quality Measures (CQMs) and public
health information
15
MU Overview




Reporting period is 90 days for the first year and 365
days thereafter
Measures are reported by attestation for Stage 1
Must meet all the measures to receive a MU
payment
To meet certain measures, 80% of patients must
have records in the certified EHR technology (at
locations with certified EHR technology)
MU Overview

If an EP works at more than one location:



Not required to have certified EHR at all locations
Must have 50% of total patient encounters at
locations where certified EHR is available
If locations have multiple certified EHRs, add
together the numerator, denominators and
exclusions
Exclusions



Count as ‘meeting the measure’ in Stage 1
Allowed if the measure is not relevant to the
provider’s scope of practice
Allowed if the provider is unable to perform a
measure, such as submission of public health
data
Exclusions, cont’d

Two automatic exclusions currently exist:

Submission of data to NC Immunization Registry


http://www.immunize.nc.gov/providers/ncirdataexchange.htm
Submission of syndromic surveillance data to PH

http://epi.publichealth.nc.gov/cd/meaningful_use/syndromic.html
Patient Volume Period
Medicaid patient volume period:
 Exactly 90 days, not 3 months
 Within the previous calendar year for EPs

Year 2012 payment – 90 continuous days between
January 1, 2011 – December 31, 2011
MU Reporting Period
MU Reporting Period
 Exactly 90 days, not 3 months
 Within the current calendar year for EPs

Year 2012 payment – 90 continuous days between
January 1, 2012 – December 31, 2012
MU Measure Denominators



Depends on the individual situation
Can be all the unique patients seen by the EP
during the reporting period (one location with
EHR technology) OR
Those unique patients seen at locations during
the reporting period where certified EHR
technology is available (multiple locations with
certified EHR technology for 80 percent of their
patient encounters)
MU Structured Data
Data entered into a specified field as opposed
to free text in a chart note
MU Structured Data, cont’d
The following core MU measures require structured
data:
 Record demographics
 Maintain an up-to-date problem list
 Maintain active medication list
 Maintain active medication allergy list
 Record and chart changes in vital signs
Meaningful Use Reporting
Requirements
15
+
5
Core
Menu
Measures
Measures
+
6
CQMs
=
MU
Meaningful
Use
Adopt, Implement, Upgrade (AIU) or
Meaningful Use (MU)
AIU or Meaningful Use Selection
*Indicates a required field
*EHR Certification Number: 129456789AX1
*Please indicate your approach:
Adopt, Implement, or Upgrade
Meaningful Use
Measure Selection Home Page
Measure Selection
Measure Set
Actions
Meaningful Use Core Measures
Meaningful Use Menu Measures
Core Clinical Quality Measures
Alternate Clinical Quality Measures
Additional Clinical Quality Measures
Begin
Begin
Begin
Begin
Begin
Review
Review
Review
Review
Review
Complete
X
X
X
X
X
Valid
√
√
√
√
√
Core MU Measure
Question 1 of 15
(*) Red asterisk indicates a required field.
Objective: Use computerized provider order entry (CPOE) for medication orders
directly entered by any licensed healthcare professional who can enter
orders into the medical record per state, local and professional
guidelines.
Measure:
More than 30% of all unique patients with at least one medication in
their medication list seen by the EP have at least one medication order
entered using CPOE.
Exclusion: Based on all patient records, any EP who writes fewer than 100
prescriptions during the EHR reporting period would be excluded from
this requirement. Exclusion from this requirement does not prevent an
EP from achieving meaningful use.
Does this exclusion apply to you?
Yes
No
Core MU Measure
Question 1 of 15, continued
*Patient Records: Please select whether the data used to support the measure was
extracted from all patient records or only from patient records maintained using
certified EHR technology.
This data was extracted from all patient records, not just those maintained using
certified EHR technology.
This data was extracted only from patient records maintained using certified EHR
technology.
*Numerator:
The numerator is the number of patients in the denominator that have at least one
medication order entered using CPOE.
*Denominator:
The denominator is the number of unique patients with at least one medication in
their medication list seen by the EP during the EHR reporting period.
Core MU Measure
Question 2 of 15
(*) Red asterisk indicates a required field .
Objective: Implement drug-drug and drug-allergy interaction checks.
Measure: The EP has enabled this functionality for the entire EHR reporting
period.
*Have you enabled the functionality for drug-drug and drug-allergy
interaction checks for the entire EHR reporting period?
Yes
No
Core MU Measure
Question 3 of 15
(*) Red asterisk indicates a required field.
Objective: Maintain an up-to-date problem list of current and active diagnoses.
Measure: More than 80% of all unique patients seen by the EP have at least one entry or an
indication that no problems are known for the patient recorded as structured data.
*Numerator:
The numerator is the number of patients in the denominator who have at least one entry or an
indication that no problems are known for the patient recorded as structured data in their
problem list.
*Denominator:
The denominator is the number of unique patients seen by the EP during the EHR reporting
period.
Core MU Measure
Question 11 of 15
(*) Red asterisk indicates a required field.
Objective: Implement one clinical decision support (CDS) rule relevant to specialty
or high clinical priority along with the ability to track compliance with that rule.
Measure: Implement on CDS rule.
*Have you implemented one CDS rule relevant to specialty or high clinical priority
along with the ability to track compliance to that rule?
Yes
No
*Enter the CDS rule that was implemented:
Menu MU Measure
Question 2 of 10
(*) Red asterisk indicates a required field.
Objective: Incorporate clinical lab-test results into EHR as structured data.
Measure:More than 40% of all clinical lab test results ordered by the EP during the
EHR reporting period whose results are in either a positive/negative or numerical
format are incorporated in certified EHR technology as structured data.
Exclusion: Based on all patient records, any EP who orders no lab tests whose results
are either in a positive/negative or numeric format during the EHR reporting period
would be excluded from this requirement. Exclusion from this requirement does not
prevent an EP from achieving meaningful use.
Does this exclusion apply to you?
Yes
No
Menu MU Measure
Question 2 of 10, continued
*Numerator:
The numerator is the number of lab tests whose results are expressed in a
positive or negative affirmation or as a number which are incorporated as
structured data.
*Denominator:
The denominator is the number of lab tests ordered during the EHR
reporting period by the EP whose results are expressed in a positive or
negative affirmation or as a number.
Menu MU Measure
Question 6 of 10
(*) Red asterisk indicates a required field.
Objective: Use certified EHR technology to identify patient-specific education
resources and provide those resources to the patient if appropriate.
Measure: More than 10% of all unique patients seen by the EP during the EHR
reporting period are provided patient-specific education resources.
*Numerator:
The numerator is the number of patients in the denominator who are provided
patient education specific resources.
*Denominator:
The denominator is the number of unique patients seen by the EP during the EHR
reporting period.
CQMs Overview

Focus on disease conditions and help measure
if a patient gets the right treatment, in the
right amount, at the right time

EPs must report a total of 6 CQMs*
*The total could be as high as 9 depending on how many core
CQMs have zeros
CQMs Overview, cont’d

CQM Core Requirements: 3 core or alternate core
CQMs


Note: For each core measure with a zero
denominator, EPs must report an alternate core
measure.
CQM Additional Requirement: 3 from a list of 38
additional CQMs
CQMs





All CQMs for 2012 are NQF-endorsed
There is no requirement to meet a certain value
for any of the CQMs
For Stage 1 MU, CQM reporting will be by
attestation
CMS is working on aligning CQMs across
programs (PQRI, CHIPRA)
JCAH, NCQA, and AMA are also aligning standards
CQMs
Question 1 of 3
(*) Red asterisk indicates a required field.
Instructions: All three Core Clinical Quality Measures (CQMs) must be submitted.
For each Core CQM that has a denominator of zero, an Alternative CQM must also
be submitted.
NQF 0013 - Hypertension: Blood Pressure Management
Description: Percentage of patient visits for patients aged 18-years and older with a
diagnosis of hypertension who has been seen for at least two office visits with blood
pressure recorded.
*Numerator:
*Denominator:
Lessons Learned from 2011
Attestations





Ensure that information in CMS Registration agrees with
Medicaid information on file
Enter the same payee in CMS Registration as for Medicaid
(can change if desire)
Wait until receipt of a welcome email from Medicaid
before attesting
Processing the attestation won’t begin until a signed copy is
received
Respond to outreach – after 45 days a denial of eligibility
occurs
Lessons Learned, cont’d





For group methodology, include all encounters in the
group
FQHC/RHC can count core as well as other services
Make sure vendor contracts include ongoing
maintenance and upgrades
FQHC EPs who are part-timers may have matching issues
(address from other practice location is in Medicaid
system) – communicate with Medicaid!
When calling for assistance, have EP’s SS# and NPI ready
Stage 2 MU Proposed Changes





More emphasis on patient engagement
More emphasis on actual exchange of
information rather than simply testing
Patient volume – recent 12 months preceding
attestation instead of prior year
Would include encounters not paid by Medicaid
Would include MCHIP encounters
Stage 2 MU Proposed, cont’d





MU measures remain at 20 total but include 17
core and 3 menu
Compliance rates increased on many measures
EPs would report 12 CQMs electronically
Data standardization would be required (for
certifying EHRs)
Implementation of Stage 2 criteria would be
delayed until 2014 calendar year for EPs
Moving Forward . . .





Establish all practice workflows affected by EHR
implementation
Perform the security risk analysis and address any
deficiencies
Implement policies and procedures outlining staff
responsibilities
Implement workflow changes as necessary
Implement documentation methods and maintain
relative documents for 6-years post-attestation
Contact

For questions about the program or process, contact:
 919-855-4200
 NCMedicaid.HIT@dhhs.nc.gov

To see the Medicaid Special Bulletin, visit
http://www.ncdhhs.gov/dma/bulletin/June2012-SpecialBulletin-EHR.pdf

To access the NC-MIPS Portal, visit
https://ncmips.nctracks.nc.gov/
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