GE Healthcare Camden Group Insights Blog

Stage 2 Guide for the EHR Incentive Programs Now Available

Posted by Matthew Smith on Oct 3, 2013 1:04:00 PM

CMS, EHR, Stage 2CMS has released a new resource, An Eligible Professional’s Guide to Stage 2 of the EHR Incentive Programs, which provides a comprehensive overview of Stage 2 of the EHR Incentive Programs to eligible professionals. The guide outlines criteria for Stage 2 meaningful use, 2014 clinical quality measure reporting, and 2014 EHR certification.

The guide is intended to provide eligible professionals (EPs) with an overview of Stage 2 of meaningful use. The guide discusses changes to meaningful use objectives and to Clinical Quality Measures (CQMs), and the overall goals of Stage 2 including:

  • Measures focused on more rigorous health information exchange (HIE)
  • Additional requirements for e-prescribing and incorporating lab results
  • Electronic transmission of patient care summaries across multiple settings
  • Increased patient and family engagement

As Stage 2 starts in January, 2014, CMS includes an important reminder – all providers must upgrade or adopt newly certified EHRs in 2014 and regardless of their stage of meaningful use,  are only required to demonstrate meaningful use for a three-month (or 90-day) EHR reporting period in 2014

View or download a PDF of the guide here.

Topics: EHR, Meaningful Use, CMS, HIT, Health IT, HITECH, Stage 2

CMS to Recoup All Meaningful Use Dollars if Audits Find Errors

Posted by Matthew Smith on Sep 16, 2013 12:49:00 PM

Meaningful Use, CMS, EHR, CMS AuditIt appears that hospitals and physicians will have to give back their entire meaningful use incentive payment if CMS auditors find any errors. That means their payments for the audit period are at risk unless their electronic health records show they kept every promise they made to the government when they accepted the money, experts say.

“There is kind of like a zero-tolerance policy,” says Austin, Tex., attorney Brian Flood, with Husch Blackwell. Usually after an audit, he notes, providers refund money for the mistakes they actually made. With meaningful use audits, “if you fail to document your security risk assessment but otherwise operated with a certified EHR system and documented everything else properly, they want all the money back.” That kind of all-or-nothing approach is tempting providers to forgo incentive payments, Flood says. “Some of my clients are withdrawing from the EHR meaningful use program,” he says.

However, CMS evidently won’t penalize providers for typos and other trivial errors in their documentation.

Incentives for meaningful use of EHRs are a creature of the HITECH Act in the 2009 stimulus law. Hospitals and physicians started receiving Medicare or Medicaid bonuses for using certified EHR technology in 2011 and will get around $20 billion over five years. The meaningful use incentive program requires hospitals and eligible professionals (e.g., physicians) to use EHRs to improve patient safety, quality of care and patient-provider communication. Providers must buy EHRs from vendors on the Certified Health IT Product List. If they don’t, they face a Medicare payment reduction after 2015.

Meaningful Use Funds Are at Risk

When providers accept incentives, they pledge — in signed attestations — to accomplish meaningful use objectives. There are 23 meaningful use objectives for hospitals, 18 of which must be met to qualify for the money. Of them, 13 are “core measures,” including clinical quality measures (e.g., reporting on hypertension, diabetes, heart failure), and hospitals also pick five from a list of 10 “menu set objectives” (e.g., generate lists of patients by specific conditions). Eligible professionals have to meet 19 of 24 meaningful use objectives; 14 are core, including clinical quality measurement, plus five out of 10 menu set objectives. “They are checking your answers now,” Flood says. “What appeared to be easy money isn’t.”

CMS hired a contractor — Figliozzi and Company of Garden City, N.Y. — to conduct the audits. “The purpose of auditing for the EHR Incentive Programs is to ensure that the attestation data submitted by providers is accurate and supports providers meeting the requirements of meaningful use,” a CMS spokesperson says. Some or all of the attestation data will be requested by the auditor. “Providers should retain a report from the certified EHR system to validate all clinical quality measure data entered during attestation, since all clinical quality measure data must be reported directly from the certified EHR system,” CMS says in a document on the audits.

Health care IT consultant Chris Apgar, president of Apgar and Associates in Portland, Ore., says the auditors are picky, like the HIPAA privacy and security auditors.

Small, medium and large hospitals and physician practices are facing audits, so there is no way to know who’s next. Recoupment letters come directly from CMS. One letter from the EHR HITECH Incentive Payment Center said a meaningful use audit had determined that “an overpayment of HITECH funds has been determined and is owed.” CMS gave the provider 30 days to repay the money, although it had the right to appeal.

“So far, more clients than not are having audit findings and owing the money back, often because they thought they met most of the core elements, but they didn’t get them all done, or they weren’t all properly documented,” he says. “If you miss a core element, they ask for all the money back.” He doubts most small and medium-sized providers will be able to keep their meaningful use money if they are audited.

Security Risk Analysis is Key

The security risk analysis is a problem area in meaningful use, Apgar and Flood say. Hospitals and physicians must attest that they conducted a risk analysis, which is a core measure as well as required by the HIPAA security regulation. “On more than one occasion where I am called to a large health system, they attested to but didn’t do a security risk analysis,” Apgar says.

Sometimes the EHR vendor screws the pooch, Apgar says. One of his physician-client’s got stuck with a system that continually updates information. Although the vendor was certified for meaningful-use EHRs, “it didn’t do its job and preserve the documentation or the attestation,” Apgar says. When the physician was audited, he was unable to prove that patients received information at discharge, as attested. The same thing happened with another of Apgar’s physician clients.

The risk of losing the entire incentive payment for the audit period based on one or a few mistakes is making some providers rethink its value, Apgar and Flood say. “Some providers realized the cost to them of the government oversight for their use of this money is too high and that it’s actually cheaper for them to invest in the technology themselves,” Flood says. As long as they adopt certified EHRs, they won’t face Medicare DRG penalties, he notes — or meaningful use audits. “You don’t have to participate in the EHR incentive program to have a qualified interoperable EHR. People misunderstand that,” Flood says. “If they would have known they’d be audited to a perfect standard, they would not have gotten into the program.”

EHR, Meaningful Use, Stage 2

Topics: EHR, Meaningful Use, CMS, HIT, Health IT, HITECH, CMS Audit

Infographic: Realizing the Value of Health IT

Posted by Matthew Smith on Aug 1, 2013 11:56:00 AM

Health IT, HIT, H.I.T.

The value of health information technology is demonstrated in many ways.  Many organization are seeing the positive influence HIT can bring to their health system.

For instance, El Camino Hospital dropped readmission rates by 25% by combining the use of data analytics and telecommunications.  

The infographic created by HIMSS highlights the five kinds of values health IT creates for patients, healthcare providers and communities:

  1. Satisfaction
  2. Treatment/Clinical
  3. Electronic Information/Data
  4. Prevention/Patient Education
  5. Savings

Topics: EHR, EMR, Meaningful Use, CMS, HIT, HealthIT, ONC, HITECH, Eligible Providers

Want to Avoid Meaningful Use Penalties in 2015? Attest Now

Posted by Matthew Smith on Jun 20, 2013 9:45:00 AM

Meaningful Use, EHR, EMR, CMSRob Anthony, health insurance specialist in the Office of E-Health Standards and Services at CMS, chatted with SearchHealthIT to help make sense of the deadlines providers must meet to avoid financial penalties. He also explained the rationale of basing the penalties on past performance and why 2015 might be a strange year for some providers.

Q: What is the most important date for providers to keep in mind to avoid meaningful use penalties?

A: There are multiple deadlines, and a lot of it depends upon when you began attesting. But the easiest thing to focus on is to tell people, if you've already attested, then 2013 is an important year for you to continue meaningful use because it will be the period we look back at for those payment adjustments in 2015. But it's not too late if you're not yet a meaningful user to avoid those payment adjustments.

I think the big deadline is October 1, 2014. For eligible professionals, that is the absolute last day to attest to being a meaningful user and be able to avoid the payment adjustments. However, I would encourage people to become meaningful users this year, because then you can at least get three years of incentive payments in 2013, 2014 and 2015. It's always better to get more of an incentive payment than less.

Q: There are many different deadlines depending on what type of provider you are and when you first attested. Have you seen providers who are having a hard time figuring out where they fit in and what deadlines are relevant for them?

A: Absolutely. Definitely. And that's why we're trying to do some outreach. We know that people have a general awareness of payment adjustments existing on the Medicare side. I think there is confusion about when those dates are and what they have to do. I think a lot of people may think that it is too late. It is not too late. But there certainly is confusion about what period applies to you. When you break it down and look at it, it's relatively simple.

We had a choice when we started doing payment adjustments: to look at the current period you were in or to look at a previous period, a prospective approach. We chose the prospective approach so that we wouldn't have to put providers through claims reprocessing, which is something of a nightmare. Instead we are focusing on an earlier period to figure out whether payment adjustments apply to you. So that earlier period is either 2013 or 2014, depending on when you become a meaningful user.

If you become a meaningful user in 2011 or 2012, then we're looking for a full year of meaningful use in 2013. If 2013 is your first year, then we're just looking for a 90-day period. You could also do the 90-day period in 2014, but we need some time to process your attestation to make sure you're not assigned that payment adjustment. We've essentially given ourselves a three-month period at the end of that year. That means you basically have nine months of the calendar year 2014 to get that 90 days in and avoid that payment adjustment.

Q: Because payment adjustments are based on what hospitals do in 2013, we could start seeing some weird scenarios where a hospital is penalized for 2013 performance but then receives incentives for their work in 2014. So, conceivably we could see hospitals that receive payment adjustments in the same year as incentive payments. Will that happen?

A: It is actually possible. If you began as a hospital in 2012, but if you missed meaningful use in 2013, that's the period we would look at for the 2015 payment adjustments. You could be given a payment adjustment for your failure to be a meaningful user in 2013, while being successful again in 2015 and receiving the last of your incentive payments.

But again, this is what happens when you look at it from a prospective period. The other choice was to look at everything from the same period, and it means that hospitals would have needed to resubmit claims for processing, and that would be a huge financial burden for them -- [it would expend] a lot of staff hours -- and it turns out to be a severe burden from an operations side, which means a higher cost for taxpayers. So, we went for that prospective period.

I will say, however, that most hospitals are definitely prepared to meet that 2013 goal. As we have looked at the performance of hospitals in their first year compared to their second year, we see that high performance holds pretty true from year to year, which gives us the indication that once you implement meaningful use and the use of an EHR in your clinical workflow, it becomes an established part of your workflow. It's less of managing to the measures and more of actually incorporating that as an important tool for managing patient care.

Q: Once the CMS starts assessing provider performance and determining the appropriateness of meaningful use penalties, how strict will you be in holding providers to meeting 100% of the measures?

A: Unfortunately, the way that meaningful use works is you have to meet all the measures in order to be deemed a meaningful user. That was true for receiving incentive payments and will also be true for payment adjustments.

We find, however, that while there are a small number of people who are close to those thresholds, by and large both eligible professionals and eligible hospitals are far outperforming what those thresholds are for the individual measures.

So I think that's a testament to once you implement, you implement everywhere and don't necessarily manage to the measures. We haven't seen a lot of evidence of that so far. We're much more concerned about providers not being prepared for their first 90 days of meaningful use.

Q: The incentive payments are front-loaded, with most of the money coming early in the program. For providers who missed out on the early portion of incentive payments, do you think the threat of penalties is going to be enough to get them to get started with EHR implementation?

A: It's a good point and we've heard that so far. There are some folks who are doing a return-on-investment analysis on that, and it makes sense for providers to do that. I will say we have some indications from talking with physicians that payment adjustments are a driver. So, I do think people are looking at those payment adjustments and looking at ways to avoid them.

I do think that -- what we've discovered in talking to a lot of practices -- while there's a learning curve; there are a lot of practices that are having success with that EHR. It's allowing them to manage their patient populations better and be more successful and see more patients, and that translates to efficiencies and reduced costs for them. So, even though the incentive payment may be reduced, there are certainly additional financial incentives to having an EHR. And then, of course, there's the incentive to having an EHR of providing better care.

Q: A lot of information on the meaningful use penalties talks about the program extending beyond the year 2020. Will the program still be run through the framework of meaningful use at that point?

A: When Congress put the HITECH Act in place, it didn't specify a particular end date for payment adjustments. It did specify a timeframe for incentive payments, but it did not specify an end to payment adjustments. So, there is a certain extent to which payment adjustments will continue and meaningful use will become the floor on which everyone will operate.

I think the use of certified EHRs and meaningful use in general will likely continue into the future, but what the future is going to look like, I think we'll get a better idea as we move into next year and start looking at some of the stage 3 notice of proposed rulemaking.

Topics: EHR, EMR, Meaningful Use, CMS, HITECH

Infographic: Federal Health IT Activity

Posted by Matthew Smith on Jun 14, 2013 3:50:00 PM

HealthIT, Infographic, Health DirectionsFrom electronic health records (EHRs), health information exchange, ICD-10 conversion, meaningful use mandates to data privacy and security regulations, healthcare organizations are slowly, but surely, making headway in implementing many different initiatives.

The opening months of 2013 saw the federal government offer providers a number of resources to ease the strain of new technology and workflow adoption, as well as implementing legislative measures to keep IT leaders accountable to policy.

This infographic summarizes what resources are available--from tools to improve HIE and meaningful use audits, to the final installment of the HIPAA omnibus rule and updated certification standards for EHRs. 

Federal Health IT initiatives 2013

Topics: EHR, EMR, Meaningful Use, CMS, HIT, HealthIT, ONC, HITECH, Eligible Providers

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