GE Healthcare Camden Group Insights Blog

When the Centers for Medicare and Medicaid Services (CMS) launched their EHR Incentive Programs back in January 2011, the main goal was to reward healthcare practitioners for adopting electronic health records and increasing efficiency within their practice. But one question everyone still finds themselves asking is whether or not the incentives have actually encouraged EHR adoption?

November 30, 2014 is an important date for the 2014 Medicare EHR Incentive Program for eligible hospitals and critical access hospitals (CAHs).

Attestation Deadline

Eligible hospitals and CAHs must successfully attest to demonstrating meaningful use by November 30 to receive a 2014 incentive payment. Hospitals participating in the Medicaid EHR Incentive Program need to refer to their state deadlines for attestation.

The CMS Attestation System is open and fully operational, and now includes the 2014 Certified EHR Technology (CEHRT) Flexibility Rule options. Medicare eligible hospitals can attest any time to 2014 data until 11:59 p.m. ET on November 30, 2014.

Reminder: Medicare eligible hospitals must attest to demonstrating meaningful use every year to receive an incentive and avoid a payment adjustment.

eCQM Submission Deadline

Eligible hospitals and CAHs who are electronically submitting clinical quality measures to qualify for that requirement of meaningful use must submit to qualify for that requirement of meaningful use must submit to Quality Net by November 30 to successfully meet the deadline to be evaluated for a 2014 incentive payment. Hospitals participating in the Medicaid EHR Incentive Program need to refer to their state deadlines.

2015 Hardship Exception Deadline

CMS reopened the submission period for hardship exception applications for eligible hospitals to avoid the 2015 Medicare payment adjustments for not demonstrating meaningful use of CEHRT. The new deadline is 11:59 PM ET November 30, 2014.

Eligible hospitals that have never met meaningful use before may apply during this reopened hardship exception application submission period if they were unable to attest by July 1, 2014 AND were unable to fully implement 2014 Edition CEHRT due to delays in 2014 Edition CEHRT availability.

2016 Payment Adjustments

Payment adjustments will be applied at the beginning of FY 2016 (October 1, 2015) for Medicare eligible hospitals that have not successfully demonstrated meaningful use in 2014. Read the eligible hospital payment adjustment tipsheet to learn more.

Note: CAHs have a different payment adjustment schedule. Review the CAH Payment Adjustment and Hardship Exception Tipsheet.

The notion of healthcare informatics began in 1949 and rapidly evolved over the next 65 years. In 2013, nearly 75% of physicians used tablets to maintain electronic health records (EHRs), according to a new infographic from Adelphi University.

This infographic chronicles the history of healthcare informatics and details the road to healthcare digitization. To view a full-size image, please click here.

A new survey by Accenture claims that more than half of people with chronic conditions say the ability to get their electronic medical records online outweighs the potential privacy risks.

Two-thirds, meanwhile, believe patients should have the right to access all of their healthcare information.

The results of the poll suggest a public increasingly frustrated by lack of ownership over their own health data.

The vast majority people surveyed (87%) say they want to control their health data. But 55% report they don't have very much or any control over their medical information.

Accenture polled 2,011 individuals – 918 of them healthy, and 1,093 with either asthma, arthritis, cancer, chronic obstructive pulmonary disease, depression, diabetes, heart disease, hypertension, clinically diagnosed obesity, osteoporosis and stroke.

The survey found chronic patients to be less concerned about the privacy of their electronic health records, 65%, than they were about other personal information stored digitally, such as online banking (70%), in-store credit card use (69%) and online shopping (68%).

Still, although they're eager to have access to their records online, roughly half of those with chronic conditions said the top barrier to seeing the data was not knowing how to do so.

Accenture's findings also suggest, depending on the type of chronic illness they have, there are differences in a patient's ability to exercise control over his or her healthcare data. For example, 65 percent of consumers with heart disease reported having some level of control, compared to just 49 percent of individuals with COPD.

The U.S. Centers for Disease Control and Prevention estimates that 47% of Americans have at least one chronic disease, but they account for 76% of all physician visits.

Nonetheless, these individuals are some of the most actively engaged patients at most stages of patient care, according to the poll – including:

• during medical diagnosis (91%);
• managing treatment (87%); and
• maintaining general health on a day-to-day basis (84%).

Access the Accenture report here.

Eligible Professionals Must Start Medicare EHR Participation in 2014 to Earn Incentives

If you are an eligible professional for the Medicare EHR Incentive Program, 2014 is the last year you can start participation in the Medicare EHR Incentive Program in order to receive incentive payments.

Eligible professionals who begin participation in the Medicare EHR Incentive Program after 2014 will not be able to earn an incentive payment for that year or any subsequent year of participation.

If you choose to participate in the Medicare EHR Incentive Program for the first time in 2014, you should begin your 90-day reporting period no later than July 1, 2014 and submit attestation by October 1, 2014 in order to avoid the payment adjustment in 2015.

Note: October 1 is the attestation deadline for eligible professionals in their first year of participation to avoid the payment adjustment. However, eligible professionals who miss this deadline can still demonstrate meaningful use during the last 90-day reporting period of the year (October - December 2014) and earn an incentive payment for 2014.

Providers Who First Begin Participation in 2014 must:

• Demonstrate Stage 1 of meaningful use
• Meet 2014 EHR certification criteria
• Select any 90-day reporting period to demonstrate meaningful use, but must start no later than July 1, in order to avoid the adjustment

To Earn Your Maximum Medicare Incentive

• Demonstrate 90 days of Stage 1 of meaningful use in 2014 to earn up to $11,760.
• Demonstrate a full year of Stage 1 of meaningful use in 2015 to earn up to $7,840.
• Demonstrate a full year of Stage 2 of meaningful use in 2016 to earn up to $3,920.

If you successfully demonstrate meaningful use each year beginning in 2014, your total payment amount could be as much as $23,520.

Additional Resources
The EHR Incentive Program website offers several helpful tools and resources so you can successfully begin participation:

• An Introduction to the Medicare EHR Incentive Program for Eligible Professionals
• Interactive Eligibility Assessment Tool
• The Stage 1 Meaningful Use Attestation Calculator
• My EHR Participation Timeline

To keep you updated with information on the Medicare and Medicaid EHR Incentive Programs, CMS has recently added three new FAQs and five updated FAQs to the CMS FAQ system.

CMS encourages you to stay informed by taking a few minutes to review the new information below.

New FAQs:

1. For Eligible Professionals (EP) in the Medicaid EHR Incentive Program using the group proxy method of calculating patient volume, how should the EPs calculate patient volume using the “12 months preceding the EP’s attestation” approach, as not all of the EPs in the group practice may use the same 90-day period. Read the answer.
2. Can a hospital count a patient toward the measures of the “Patient Electronic Access” objective in the Medicare and Medicaid EHR Incentive Programs if the patient accessed his/her information before they were discharged? Read the answer.
3. When demonstrating Stage 2 meaningful use in the EHR Incentive programs, would an eligible professional (EP) be required to report on the “Electronic Notes” objective even if he or she did not see patients during their reporting period? Read the answer.

Updated FAQ:

1. Do States need to verify the "installation" or "a signed contract" for adopt, implement, or upgrade (AIU) in the Medicaid EHR Incentive Program? Read the answer.
2. For Stage 1 and 2 meaningful use objectives of the Medicare and Medicaid EHR Incentive Programs that require submission of data to public health agencies, if multiple eligible professionals (EPs) are using the same certified EHR technology across several physical locations, can a single test or onboarding effort serve to meet the measures of these objectives? Read the answer.
3. For the Stage 2 meaningful use objective of the Medicare and Medicaid EHR Incentive Programs that requires the successful electronic exchange of a summary of care document with either a different EHR technology or the CMS designated test EHR, if multiple eligible professionals (EPs) are using the same certified EHR technology across several physical locations, can a single test meet the measure? Read the answer.
4. In calculating the meaningful use objectives requiring patient action, if a patient sends a message or accesses his/her health information made available by their eligible professional (EP), can the other EPs in the practice get credit for the patient’s action in meeting the objectives? Read the answer.
5. When reporting on the Summary of Care objective in the EHR Incentive Program, which transitions would count toward the numerator of the measures? Read the answer.

Want more information about the EHR Incentive Programs?
Make sure to visit the Medicare and Medicaid EHR Incentive Programs website for the latest news and updates on the EHR Incentive Programs.

Medicare EPs Must Attest by Next Monday, March 31 at 11:59 pm ET to Receive 2013 Incentive.

Due to the large volume of providers attesting, CMS encourages you to please submit your data as soon as possible and during non-peak hours to avoid system delays.

If you are an eligible professional, the last day you can register and attest to demonstrating meaningful use for the 2013 Medicare EHR Incentive Program is March 31, 2014. You must successfully attest by 11:59 p.m. Eastern Daylight Time on March 31, to receive an incentive payment for your 2013 participation.

CMS extended the deadline for eligible professionals to attest to meaningful use for the Medicare EHR Incentive Program to allow more time for providers to submit their meaningful use data and receive an incentive payment for the 2013 program year.

Medicaid Eligible Professionals
Eligible professionals participating in the Medicaid EHR Incentive Program need to refer to their state deadlines for attestation information.

Payment Adjustments
Payment adjustments for eligible professionals will be applied beginning January 1, 2015, to Medicare participants that have not successfully demonstrated meaningful use. For more information, visit the payment adjustment tipsheet for eligible professionals.

You must attest to demonstrating meaningful use every year to receive an incentive and avoid a payment adjustment.

If you are only eligible to participate in the Medicaid EHR Incentive Program, you are not subject to payment adjustments.

Resources

• Meaningful Use Attestation Calculator
• Attestation Worksheet for Eligible Professionals
• Attestation Guide for Medicare Eligible Professionals
• Stage 2 Payment Adjustment Tipsheet for Eligible Professionals

Plan Ahead
Review important dates for the EHR Incentive Programs and all CMS eHealth programs using this Interactive Timeline.

If You’re Not Meeting Meaningful Use, You May Be Leaving Money on the Table

Eligible providers who meet Meaningful Use criteria may receive up to $24,000 (Medicare) or may receive up to $63,750 (Medicaid). That’s a lot of incentive dollars to leave behind—especially if you’re already operating on an Electronic Health Records (EHR) system.

This complimentary download from Health Directions will help you to:

• Learn how to optimize your EMR and successfully participate in the CMS EHR Incentive Program
• Understand the differences between Stage 1 and Stage 2 requirements
• Prepare for the 2014 changes, including how to engage your patients

Have you invested a significant amount of time and money into your practice’s transition to electronic health records? Then you want to make sure that you are using them as effectively as possible.The Centers for Medicare and Medicaid (CMS) want to make sure as well.

The use of electronic health information technology became a national objective in 2009, with passage of the Health Information Technology Economic and Clinical Health Act (HITECH). In addition to promoting the benefit of maintaining an electronic copy of the patient’s medical record, the goal was to define benchmarks for effective, or “meaningful use” of those records.

CMS outlined a set of standards, and allows eligible providers and hospitals to earn incentive payments as they demonstrate meaningful use of certified EHR technology. Eligible professionals may qualify for up to $44,000 over five years through the Medicare EHR Incentive Program and up to $63,750 over six years through the Medicaid. As of December 31, 2012, over $10.5 billion in incentive payments have been issued.

However, if physicians have not adopted certified EHR systems or cannot demonstrate meaningful use by the CMS 2015 deadline, Medicare reimbursements will be reduced by 1%. In subsequent years, that rate increases to 2% in 2016, 3% in 2017 and 4% in 2018. Practices need to prepare now to avoid such penalties.

What Are the Benefits of Meaningful Use?

The benefits of meeting these benchmarks go beyond financial. Meaningful use of EHRs can help practices and hospitals by:

1. Improving the quality, safety and efficiency of care, while reducing disparities
2. Engaging patients and families in their care
3. Promoting public and population health
4. Improving care coordination through greater access to patient information in a timely manner
5. Promoting privacy and security of electronic health records.

What Must I Do to Qualify for EHR Incentives?

1. Choose a program:  According to CMS, although most hospitals will be able to receive a payment from both programs, eligible professionals must choose whether they want to join the Medicare or Medicaid incentive program. (The two programs are similar in many ways.)  The Medicaid incentive program is currently available in 43 states and territories. For more information about your state, see https://www.cms.gov/apps/files/statecontacts.pdf
2. Determine your eligibility:  In order to be considered an “eligible professional”, one must provide at least 90% of services on an outpatient basis. Acceptable credentials differ between Medicare and Medicaid programs, with Medicaid approving nurse practitioners and physician assistants.
3. Register:  Registration and attestation is required here: https://ehrincentives.cms.gov/hitech/login.action In the first three years of participation, attestation requirements differ and require an increase in the volume of data reported in subsequent years. CMS has revised the attestation process to also allow for group practice reporting (GPRO). PLEASE NOTE that any eligible professional may be subject to an audit at any time. Therefore, you will want to save all supporting electronic or paper documentation.
4. Report on measures:  There are 23 meaningful use objectives and 18 of these must be met. Core measures are mandatory; menu measures are selected as those that are specific to the practice. There are 13 core objectives and a list of 10 menu objectives from which five must be chosen. In addition, eligible professionals must report on six total clinical quality measures: three required core measures (or three alternate core measures) and three additional measures (selected from a set of 38 clinical quality measures).In 2014 and in subsequent years, Medicare eligible providers must also electronically report their CQM data. Of the 64 approved CQMs, nine must be reported. For a list of these measures, see http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/2014_ClinicalQualityMeasures.html.
5. Comply with stages:  Both the Medicare and Medicaid programs are staged in three steps with increasing requirements for participation.

• All providers begin participating by meeting the Stage 1 requirements for a 90-day period in their first year of meaningful use
• Then providers are required to meet Stage 1 requirements for a full year in their second year of meaningful use.
• After meeting Stage 1 requirements, providers will then have to meet Stage 2 requirements for two full years. Stage 2 has additional thresholds that need to be met.

What Must I Measure?

Core measures include:

• CPOE for medication orders
• Drug interaction checks
• Maintain problem list
• e-prescribing
• Active medication list
• Medication allergy list
• Record demographics
• Record vital signs
• Record smoking status
• Clinical decision support rule
• Electronic copy of health information
• Clinical summaries
• Protect electronic health information

Menu measures include:

• Drug formulary checks
• Clinical lab test results
• Patient lists
• Patient reminders
• Patient electronic access
• Patient-specific education resources
• Medication reconciliation
• Transition of care summary
• Immunization registries data submission
• Syndromic surveillance data submission

Practices can begin to prepare for Stage 2 by:

• Incorporating lab test results as structured data into the patient record
• Sending patient reminders for preventive services or follow-up care
• Performing medication reconciliations for new patients or patients transitioning into care from another care setting
• Providing transition of care summaries for patients transitioning to providers outside of the organization
• Sending immunization data to the state immunization registry I-CARE
• Implementing a patient portal with basic functionality

Meaningful Use Reporting:  Doing It Well

Meaningful use is an ongoing, long-term project. At Health Directions, we recommend that you assign a project leader who will ensure that you are tracking your measures monthly. You will also want to upgrade your EHR to a 2014 version, and make certain that you are capturing data in the correct fields; otherwise, you will not qualify for incentive payments. Select your CQMs wisely, and you can discover early “wins” as they relate to patient care quality. Finally, don’t forget to take advantage of other pay-for-performance incentives that require the same measures--and get more bang for your buck!

About the Author

Dr. William K. Faber, Chief Medical Officer for Health Directions, is a physician executive with progressive senior leadership experience. He most recently served as Senior Vice President of the Rochester General Health System in New York, where he guided the development of the system’s Clinical Integration program and assisted more than 150 providers at 44 sites through the conversion process from paper records to an Electronic Health Records system (Epic). Dr. Faber formerly participated in the governance of the Advocate Physician Partners (APP) Clinical Integration program and directed APP’s Quality Improvement Collaborative.

Electronic health record incentive payments to eligible docs and hospitals continue to climb into the new year. The "inexorable progress" of the federal EHR incentive program continues, with payments to providers moving ever closer to $20 billion.

As of the end of November, more than 436,000 hospitals and health professionals have registered for the Medicaid andMedicare EHR incentive program, and the federal government has made more than $17.7 billion in payments, the Centers for Medicare and Medicaid Services told the Health IT Policy Committee in an update.

Of the $17.7 billion, almost $11 billion has gone to 4,300-plus hospitals who have achieved meaningful use status, while $4 billion has gone to about 210,000 physicians and health professionals qualifying under Medicare and $2.5 billion has gone to 107,000 professionals qualifying under Medicaid.

All of that has translated in a majority of American providers now using digital health record systems, the data showing the "inexorable progress made every month," as policy committee chair Paul Tang, MD, the chief innovation and technology officer at the Palo Alto Medical Foundation, said on Tuesday during the HIT Policy meeting.

CMS eHealth specialist Robert Anthony also highlighted some other data showing attestation rates for core objectives, with high percentages in many areas but lags for others, such as syndromic surveillance.