Lessons Learned From Medicare EHR Registration and Attestation for Eligible Providers (EPs)

Size 120 providers with over 550 employees Multi-specialty group in various locations with career physicians, new physicians, and everything in between Over 400 customized encounter forms Numerous work flow differences Various degrees of interest and buy in

Need a Meaningful Use Team to prepare for the work ahead Need to select which EHR Program to participate Need various publications and reports to Understand program requirements Analyze your compliance and make adjustments to forms, reports, processes, and workflows Track your progress Need to Develop and Implement Training Select a Reasonable Go-Live Date

Don t delay, this is likely to take far more time than expected and involve members across the organization. This is not simply an IT function. Most organizations will need an assessment period to analyze current EMR functions and organizational workflows. The analysis assessment will likely reveal the need to revise or develop new workflows, implement training, and assign responsibility.

Successful meaningful use implementation will require individuals from across the organization and commitment to the project from the governing body Assign a Project Manager from the Executive Team to coordinate and organize all efforts strong knowledge of clinical operations and care delivery ability to effectively communicate with a diverse group of individuals ability to analyze data, define goals, assign tasks, and meet deadlines

Team should consist of a committee of representatives from: Information Technology Clinical Operational Financial Physician(s) for advice and beta testing Team must commit to a routine schedule of meetings.

Need a Meaningful Use Team to prepare for the work ahead Need to select EHR Program Need various publications and reports to Understand program requirements Analyze your compliance and make adjustments to forms, reports, processes, and workflows Track your progress Need to Develop and Implement Training Select a Reasonable Go-Live Date

Source: CMS

MEDICARE MEDICAID Must be a Physician (MD, DO, DDM/DDS, optometrist, podiatrist) Must have Part B Medicare allowable charges Incentive is 75% of max allowable Part B charges up to $24,000 (or a total of $18,000) for 1 st year Must not be hospital based Required enrollment in Provider Enrollment, Chain and Ownership System(PECOS) Must be a Physician, NP, Certified Nurse-midwife, or Physician Assistants in a FQHC or RHC Must meet patient volume requirements of 30% for 1 st year payment of $21,250 Pediatricians eligible at 20% for a reduced 1 st year payment of $14,167 Must not have 90% or more encounters in a hospital or ED

MEDICARE Pays up to $44,000 over a 5 year period Program spans 2011-2016 Must meet meaningful use measures in year one Must participate in consecutive years Year 1 Stage One: 90 consecutive days Year 2 Stage One: Full calendar Year Stage Two and Three: Expected in 2013 & 2015 Medicare payment reductions MEDICAID Pays up to $63,750 over a 5 year period Program spans 2011-2021 Does not have to be consecutive year participation Year 1: Adopt, Implement or Upgrade Meaningful Use in later years No Medicaid payment reductions

Choose program carefully, Medicaid has higher incentives and less requirements. Once you have submitted Attestation you are locked into that specific program for the year. May switch between programs once after having received an incentive payment, but the switch must occur before 2015.

Start with CMS Website for EHR Incentives https://www.cms.gov/ehrincentiveprograms EHR Timeline Stage 1 EHR Meaningful Use Specification Sheets for Eligible Professionals Medicare Registration User Guide for Eligible Providers Attestation User Guide for Eligible Professionals Medicare and Medicaid EHR Incentive Program Webinar for Eligible Professionals Clinical Quality Measures Webinar

Contains critical information for each objective Describes what each Eligible Provider (EP) has to do to demonstrate Meaningful Use Now provides links to FAQs 25 Meaningful Use Objectives Required to meet 20 of the objectives 15 required core set (all) Includes Clinical Quality Measures CQMs 5 menu set, that may be chosen from a list of 10, one must be a public health measure

Specification Sheet For Core Measure 1 Source: CMS

Specification Sheet Core Measure 1 Page Two Source: CMS

Q&A from the Link on Specification Sheets Source: CMS

GE Using Centricity Electronic Medical Record Meaningful Use Reports v 9.5 (9/2011) Used a combination of GE reports Custom Reports Enabled us to capture data /obs terms from numerous customized forms Ability to run reports on our own database which is a copy of the MLO (EMR) database Crystal Reports to run the reports by physician Created an Excel spreadsheet to consolidate the data for comparison and tracking (Physician Scorecard) Created Weekly Self Assessment Tool

Source: GE

Internal Self Assessment Tool Team meet weekly to review and analyze our progress Identify each measure and the ability of the system to report on the data. Conduct assessments frequently. What do the reports reveal how close are you to achieving the measures needed? Are changes needed to the encounter forms, to the reports? Who should be capturing the data required (registration, MA, nurse, physician, IT dept)? Are changes are needed to workflows in the clinics?

Meaningful Use Self Assessment 1/14/11

Develop training and implement company-wide On-line training tool with quiz for all employees Frequent e-mails about a specific Meaningful Use Measures with Tips & Tricks Posted training materials on the Meaningful Use Section of our Intranet Indentified EMR Super Users at every location that were available to assist with new encounter forms, new features, and new processes Departmental Training Individual Training

On Line Training

On Line Training: Sample Question for Measure 1. Each Measure has information and important points to recall

One of several screen shots for on line training. Measure 1 CPOE

Each Measure has one simple quiz question.

Need a Meaningful Use Team to prepare for the work ahead Need to select which EHR Program to participate Need various publications and reports to Understand program requirements Analyze your compliance and make adjustments to forms, reports, processes, and workflows Monitor your progress Need to Develop and Implement Training Select a Reasonable Go-Live Date

Pick a Go-Live Date that is Reasonable Well-supported by all members of the MU Team as well as administration and physician leadership Each provider will qualify individually for a 90 day consecutive reporting period

Develop a tool to assess progress and to indentify continued areas of need for additional training and support We developed a Physician Scorecard which reported on the percentage scores for each measure by each provider Posted results every two weeks Enabled the team to identify the measures that presented the most challenges by specialty or by location and provide more customized training and assistance Friendly competition

Meaningful Use Physician Scorecard

Use Comment box to state measure objectives and tips

Core Measures in Green, Menu Measures in Blue Tracked an overall Pass/Fail Percentage Score for each measure Pass/Fail by each measure

Register early allows you work out issues so you are prepared for Attestation when you reach compliance Decide if provider or 3 rd party designee will be Registering and Attesting on the provider s behalf If using 3 rd party designee, they need to register in the Identity & Access (I&A) System and be issued a User ID / Password and be linked to each eligible provider (EP) Designee will request access to EP s account, an email is sent to the EP to approve access request, notification is sent to designee that access has been approved

Email stating your request to assign EP to 3 rd party designee was approved.

National Provider Identifier (NPI) National Plan and Provider Enumeration System (NPPES) User ID/Password Must be enrolled in Provider Enrollment, Chain and Ownership System (PECOS) Payee Tax Identification Number if you are reassigning benefits Payee NPI if you are reassigning benefits EHR Certification Number (may register without this number but required at attestation) http://onc-chpl.force.com/ehrcert

Carefully select individual(s) for I&A privileges. Great deal of responsibility to Register and Attest correctly. For large groups, may wish to choose several employees to obtain I&A privileges. Decide which program you are likely to participate in Medicare or Medicaid. May modify your registration prior to attestation but once you submit for attestation you are locked in the program selected for that year. Print Registration Page for records.

Source: CMS

All your hard work has paid off! EHR reports reflect that provider(s) have met all Stage One Meaningful Use Requirements for a consecutive 90 day reporting period You are ready for Attestation

Use EMR reports to determine when each eligible provider has met all Meaningful Use measure requirements for a consecutive 90 day reporting period We entered data directly from Physician Scorecard CMS provides an Attestation Worksheet Does not include Clinical Quality Measures (CQMs)

Source: CMS

During Attestation, Core Measure 10 will ask if you plan to record CQMs. The reporting section for CQMs will appear after you have completed all core and menu measures. Required to report on 3 core set CQMs up to 3 alternate core set CQMs and 3 additional set CQMs If you report a zero denominator for any of the 3 core measure, you then report on an alternate core CQM to supplement. Report a minimum of 6 CQMs and up to maximum of 9 It is acceptable to report zero in the denominator provided that is the value displayed on a report calculated by the certified EHR. Download NQF Measures from http://www.qualityforum.org

Source: CMS

Source: CMS link to Quality Forum

Source: CMS Link to Quality Forum

Meaningful Use Core Measures Meaningful Use Menu Measures Clinical Quality Measures Attestation Statements Attestation Disclaimer Submission Receipt Accepted Attestation print receipt for records Rejected Attestation choose Summary of Measures to review your entries, correct issues, resubmit attestation information You may submit an attestation for a different reporting period during the first payment year. It may be one day later 90 day consecutive reporting period. Recalculate N/D.

Source: CMS

Typically 4 8 weeks after Attestation is accepted We successfully Attested to 90 physicians on 7/15 Received Payment on 9/29/11 for 85 physicians Five physician payments were held with a status of provider has not reached the max threshold amount Payment was sent once the condition was met If a physician doesn t reach the max threshold amount of $24,000 in Allowable Medicare Part B Charges by the end of the calendar year, CMS will pay 75% of the amount of charges around Feb of the following year. Example: $20,000 allowable charges, CMS will provide incentive bonus of $15,000 ($20,000 x 75%) Monitor Payment Status on line by provider