Navigating Meaningful Use Rapids Physician Onboarding

Transcription

1 Navigating Meaningful Use Rapids Physician Onboarding April 14, 2015 Karen Wilding / Director of Operations / University Of Maryland Medical System Anantachai (Tony) Panjamapirom / Senior Consultant / The Advisory Board Company DISCLAIMER: The views and opinions expressed in this presentation are those of the author and do not necessarily represent official policy or position of HIMSS.

2 EHR4ALL," The Legacy of Robin Raiford Health IT Enthusiast and Advocate Robin "sang the gospel" of the meaningful use program. She was a tireless advocate of its aims. One of her crowning achievements was the White Board Story, which "told the story" of all the meaningful use-related regulations in one huge "poster." Robin Stillings Raiford February 4, June 26, 2014 To say Robin commanded a room when she spoke about health IT, is an understatement. Her dedication for this industry and its hope for transformative change exuded from her every cell. We carry on Robin's vision for that future where everyone uses the systems she believed would change the way we provide healthcare, and for the better.

3 Conflict of Interest Karen Marie Wilding Salary: University Of Maryland Medical System, Community College of Baltimore County Other: Board of Directors, Maryland HIMSS, Chair of Program Planning Anantachai (Tony) Panjamapirom Salary: The Advisory Board Company HIMSS 2015

4 Learning Objectives 1. Identify at least three components to assess when onboarding a provider into an existing organization's meaningful use program. 2. Recognize two elements of risk in the meaningful use program that can arise in the EHR incentive program that are beyond the scope of the regulation in the circumstance of a provider changing practices, or in the situation of an acquired practice. 3. State the year and stage of meaningful use that a provider would be in if he/she was acquired by an practice that was currently in Stage 2, Year 1 of meaningful use - but previously in the same reporting period that provider was demonstrating Stage 1, Year 1 objectives and measures.

5 An Introduction to the Benefits Realized for the Value of Health IT S T E P S Satisfaction Treatment/ Clinical Electronic Information/Data Prevention and Patient Education Savings Increase provider satisfaction by reducing administrative burdens Assist operational teams with actionable guidance Ensure all providers, especially in an acquisition or new hire situation, achieve meaningful use, which provides better quality of care Develop tools and checklists to ensure operational consistency Generate a high level of data integrity, useful for performance evaluation Maintain program status by meeting and exceeding the critical patient objectives of VDT, patient education, clinical reminders etc. Reduces risk of payment adjustments Provides consistency in processes, reducing operational inefficiencies Identifies Total Cost of Ownership, more accurately

6 Roadmap Tracking EP meaningful use statistics and trending provider mobility and practice changes Identifying potential unintended consequences/risks of provider mobility Operationalizing successful practices in physician onboarding preparation for meaningful use success

7 EP Registration, Attestation, and Payment Break Down as of February 2015 Registration Attestation Incentive Payments 145, , , ,000 22% Registered only Registered only 14% 46% AIU 32% MU Medicaid Total: $11,117,356,994 4% 32% 64% Medicare Estimated Medicaid Actual Medicare 86% MU Medicare Medicaid Medicare Advantage Source: February 2015: EHR Incentive Program Centers for Medicare and Medicaid, available at Guidance/Legislation/EHRIncentivePrograms/Downloads/February2015_SummaryReport.pdf (accessed April 8, 2015); Data Analytics Update: Health IT Policy Committee Meeting, The Office of National Coordinator for Health Information Technology, available at The Advisory Board research and analysis.

8 Growing Larger, Hospital-Owned Practices Changes in Physician Practice Size 41% Business Complexity Increasing Operating Costs Declining Reimbursements Sequestration cuts Regulations such as the ACA Potential Shortage of Physicians Market Consolidation 33% 13% 18% 12% 10% 3% 4% >50 Medical Group Ownership 69% 58% 39% 26% Physician Owned Hospital Owned Source: MGMA, 2012 MGMA Physician Compensation and Production Survey Report, available at: mgma.com; Center for Studying Health System Change, and The Advisory Board research and analysis.

9 UMMS Experiencing High Influx New Service Line Acquisition Change in Number of Hospitals Business Drivers Population Health Management Change in Number of Employed Physicians Regulatory Drivers Affordable Care Act Maryland HSCRC

10 Roadmap Tracking EP meaningful use statistics and trending provider mobility and practice changes Identifying potential unintended consequences/risks of provider mobility Operationalizing successful practices in physician onboarding preparation for meaningful use success

11 Key Areas to Watch with Moving EPs Financial Legal Operational Issues Issues Issues Source: The Advisory Board research and analysis.

12 Financial Issues Incentive Payments Payment Adjustments Questions to Consider for both Incoming and Departing Providers Average Incentives Received as of February 2015 $25,833 $25,348 $29,831 Per Medicaid Eligible Professional Potential Industry Payment Adjustments in 2015 $1,110 Internal Medicine (Income 2 : $185K) Per Medicare Eligible Professional $1,668 $2,430 Oncology (Income 2 : $278K) Per Medicare Advantage Eligible Professional Orthopedics (Income 2 : $405K) 1. Who should receive an incentive payment? EP, the previous employer, or the current employer? Majority of time rule? 2. Who is responsible for payment adjustment of the EP s past performance? EP, the previous employer, or the current employer? Shared responsibility? Assume 60% Medicare Reimbursements Source: February 2015:: EHR Incentive Program Centers for Medicare and Medicaid, available at Guidance/Legislation/EHRIncentivePrograms/Downloads/February2015_SummaryReport.pdf (accessed April 8, 2015); The Advisory Board research and analysis.

13 Legal Issues Legal and Compliance Must Be Engaged to Ensure Onboarding and Departing Agreements Contract Development Partnership with Finance Collaboration with the Meaningful Use Team Screening questionnaires embedded into hiring process Consider incorporating provisions to address financial and operational risks incurred by an EP s inability to meet MU Identify potential financial risks of a non meaningful user status Understand the risks in the total acquisition cost and consider negotiation Keep an ongoing pulse check of an individual provider status Provide advisory support for an unprecedented issue Source: The Advisory Board research and analysis.

14 Operational Issues Incoming Eligible Provider Departing Eligible Provider Successful coordination with the previous and next employer is key! Identify Provider Meaningful Use Status Retrieve Performance Data and Reporting Request Audit Documentation Source: The Advisory Board research and analysis.

15 Roadmap Tracking EP meaningful use statistics and trending provider mobility and practice changes Identifying potential unintended consequences/risks of provider mobility Operationalizing successful practices in physician onboarding preparation for meaningful use success

16 Addressing 6 Critical Components z z z Governance and Skillsets Onboarding Process Eligibility and Registration z z z Performance Monitoring and Improvement Attestation Process Departing Process

17 Component 1: Governance and Skillsets Building a Robust Team Setting Up a Meaningful Use Governance and Identifying Staff with Specific Skills for EP Onboarding Success 1 2 Team Structure Executive Steering Committee Core Meaningful Use Team Committee o Operational/Program team o Practice manager Skillsets Policy analysis EHR workflow coordination IT implementation Communications and training Case in Brief: University of Maryland Medical System s Meaningful Use Governance Reported to Executive Steering Committee Led by an executive sponsor, CMIO Enterprise program manager oversees day-to-day MU operations Assigned a dedicated, site-specific MU lead for tracking and coordination Separate, collaborating teams for: 1) financial and compliance matters; 2) documentation oversight; and 3) EP affiliate compliance

18 Component 1: Governance and Skillsets Strong Collaboration between MU Steering Committee and Local Leadership Case in Brief: UMMS Governance Components Divided by Communities/EHR Vendors Local Executive leadership engaged in specific community steering committee EHR Director/Coordinator connected with local medical group/practice leadership Centralized compliance, financial and program standards

19 Component 2: Onboarding Process If You Fail to Plan, You Are Planning to Fail Accepting Risks with New EPs means understanding and preparing your team and program infrastructure for: Off-cycle eligibility and enrollment EHR vendor competency misalignment with existing reporting periods Prior documentation (Book of Evidence) Unsuccessful audits from prior employers (reminder penalty is attached to an EP NPI) Requests from an EP s previous employer

20 Component 2: Onboarding Process Create an Onboarding Shield 1 2 Understand how providers enter your organization, create a process flow Partner with multiple internal stakeholders on information gathering Legal/Provider Contracting Compliance Finance Information Technology Ownership of payments, documentation, and potential audits for shared reporting periods Identification of enrollment and status of all federal and state programs Identification of received payments and potential penalties Timeline to be live on EMR; map with reporting period requirements

21 Component 3: Eligibility and Registration Determining Eligibility to Identify Specific Program Opportunity 1 2 Medicare or Medicaid Program Mine data for any 90-day period within the 12-month preceding the EP s attestation to determine Medicaid patient volume Work with the state to review the data for eligibility Medicaid Volume via Group Proxy Identify an EP s opportunity to participate in the Medicaid program Eligibility Considerations

22 Component 3: Eligibility and Registration Ensure Accuracy of an EP s Data across Multiple Systems Flow of Data in Registration Systems Identity & Access Management System (I&A) Medicare Provider Enrollment, Chain, and Ownership System (PECOS) EHR Medicaid Incentive Payment Program (emipp) National Plan & Provider Enumeration System (NPPES) EHR Incentive Program Registration and Attestation System Create One Proxy Access fro an authorized official to attest on an EP behalf Ensure a provider approval of the request for proxy access in the I&A system Confirm each provider has an assigned NPI Confirm online enrollment in PECOS Reassign an incentive payment to a specific NPI or TIN in the Registration and Attestation System Confirm Medicaid eligibility before registering in emipp

23 Component 4: Performance Monitoring and Improvement Performance Monitoring and Improvement Learning Curve Workflow Compliance Data Integrity Learning how to use an EHR system can take time. There will likely be multiple issues during the initial period where the curve is steep, especially for new providers - experienced with the same EHR or not Providers may be familiar with the objectives, but every organization has workflow variations that must be taught and adhered to. Providers must understand how these workflows impact objectives and reporting Certifying the data is true and accurate means ensuring attestation data is accurate and truly reflect their performance, volumes and utilization of the EHR

24 Component 4: Performance Monitoring and Improvement Ensure Data Integrity and Compliance Improve Performance through Close Monitoring and Ongoing Support 6 Ensure data accuracy and performance compliance 5 Form a SWAT team to target a specific group of underperforming EPs 4 Identify outliers based on individual performance 3 Validate accuracy of performance reports/ Perform positive-negative test 2 Set acceptance tolerance to field provider adherence 1 Build new mindset as a foundation and gradually raise the bar

25 Component 5: Attestation Process Attestation Checklist and Buddy System Authorized Official Provider Acknowledgement Understand, identify and support authorized officials (they may need a new job description) Implement a provider acknowledgement process and documentation to payment turnover to employer Attestation Sign Off Buddy System Ensure provider sign off on the certified performance reports prior to attestation Utilize Buddy System when entering & submitting data to CMS and state

26 Component 6: Departing Process Prevent Departure Gone Wrong! Support the next employer and supply documentation Copy of certified performance report Summary of payments received by the organization and the provider s meaningful use timeline Contact information in the event of an audit Case in Brief: A health system in Southern California Issue: CMS sent an incentive payment after the provider has changed the PECOS and registration information Solution: Collaborate with the Finance to track incentive payments Engage the Legal and Compliance office Create an incentive payment request letter and send to the provider and the new employer Provide any support documentation to the provider should there be any tax implication

27 Takeaways Three Key Actions for Organizations to Support Transitioning Providers on Achieving Meaningful Use Evaluate Your Infrastructure and Resources Keep Up the Pulse Check Form Your Defense Instill skillsets among practice managers Leverage existing policy and procedures for further adjustments Align efforts to optimize the governance structure Secure leadership buyin and involvement Engage stakeholders from various departments Get a pulse check on their commitment to meaningful use success Document, document, document! Develop Book of Evidence and form centralized structure Enhance your documentation to denote specific issues

28 An Review of Benefits Realized for the Value of Health IT S T E P S Satisfaction Treatment/ Clinical Electronic Information/Data Prevention and Patient Education Savings Increase provider satisfaction by reducing administrative burdens Assist operational teams with actionable guidance Ensure all providers, especially in an acquisition or new hire situation, achieve meaningful use, which provides better quality of care Develop tools and checklists to ensure operational consistency Generate a high level of data integrity, useful for performance evaluation Maintain program status by meeting and exceeding the critical patient objectives of VDT, patient education, clinical reminders etc. Reduces risk of payment adjustments Provides consistency in processes, reducing operational inefficiencies Identifies Total Cost of Ownership, more accurately

29 Questions Thank You! Karen Marie Wilding Director of Operations, Information Services & Technology University of Maryland Medical System (UMMS) Office: Anantachai (Tony) Panjamapirom Senior Consultant, Research and Insights The Advisory Board Company Office: