Meaningful Use program definition as of August 2010 for physician practices

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© 2010 The Hill Group, Inc.
August 25, 2010
Preparing for
Meaningful Use

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Agenda
• Introduction
• Timetable of Meaningful Use Announcements
• Definition of Meaningful Use
• Achieving Meaningful Use
• Incentive Timetable
• HIPAA/HITECH Control Environment
• Q&A

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Introduction – Firm
• The Hill Group, Inc. has provided strategy and management
consulting services to clients across sectors since 1953.
• Practice areas:
– Strategy
– Operations and Process Improvement
– Survey and Diagnostic Measurement
– Organizational Development
• Healthcare Industry:
– Preferred HIPAA Vendor for Vale-U-Health
– Main strategy firm for many healthcare organizations including
insurance plans, health systems, and physician offices – including
developing strategies to ensure compliance

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Introduction - Presenter
• Scott A. Rogerson, Consultant
– Supervised multiple audits for clients across various
industries in the areas of HIPAA, PCI, and SOX-404
– Assisted in development and execution of critical data
analysis strategy for large regional health system
– Strong background in strategy development and process
improvement
– Guest lectured at Duquesne University on system analysis
and developing a robust control environment
– Certified Information Systems Auditor (ISACA)
– Certified Associate in Project Management (PMI)
– Serving on Duquesne University ISM Undergraduate and
Graduate Advisory Board

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Background
• American Recovery and Reinvestment Act
(ARRA) – February 2009
• Medicare and Medicaid Electronic Health Record
(EHR) Incentive Program
– Notice of Proposed Rulemaking (NPRM) – January
13, 2010
– NPRM Comment Period Closed – March 15, 2010
– Final Rule on Display – July 13, 2010
– Final Rule Published – July 28, 2010

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Purpose of Meaningful Use
• Availability
• Integrity
• Confidentiality

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ARRA-defined Components of
Meaningful Use
1. Use of certified EHR technology in a meaningful manner
2. Use of certified EHR technology for electronic exchange of health
information to improve quality of health care
3. Use of verified EHR technology to submit clinical quality measures
(CQM) and other such measures selected by the Secretary
Data
capture
and
sharing
Advanced
clinical
processes
Improved
outcomes

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Stages
• CMS plans to implement in three stages
– Stage 1 requirements have been defined
– Guidance has been given that Stage 2 and 3 will build upon
Stage 1
• Health Outcome Priorities for Stage 1:
– Improve quality, safety, efficiency, and reduce health disparities
– Engage patients and families in their health care
– Improve care coordination
– Improve population and public health
– Ensure adequate privacy and security protections for personal
health information (HIPAA/HITECH)

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Incentive Programs and Eligibility
• Medicare Fee-For-Service (FFS)
– Eligible Professionals (EPs)
– Eligible hospitals and critical access hospitals (CAHs)
• Medicare Advantage (MA)
– MA EPs
– MS-affiliated eligible hospitals
• Medicaid
– EPs
– Eligible Hospitals
• NOTE: Eligible Professionals must select either the Medicare or
Medicaid EHR incentive programs – no individual provider may
participate in both
– An EP may change his/her EHR incentive payment program election
once before 2015

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Eligibility
Fee-for-service (FFS) Medicare-advantage (MA)
Eligible Professionals
Doctor of Medicine of Osteopathy
Doctor of Dental Survery or Dental Medicine
Doctor of Podiatric Medicine
Doctor of Optometry
Chiropractor
Must furnish, on average, at least 20 hours/week of patient-care
services and be employed by a qualifying MA organization
OR
Must be employed by, or be a partner of, an entity that through
contract with the qualifying MA organization furnished at least
80% of the entity's Medicare patient care services to enrollees
of the qualifying MA organization
Eligible Hospitals
Acute Care Hospitals
Critical Access Hospitals (CAHs)
Will be paid under the Medicare Fee-for-service EHR incentive
program
Medicare
Eligible Professionals
Physicians
Nurse Practicioners (NPs)
Certified Nurse-Midwives (CNMs)
Dentists
Physician Assistants (Pas) working in a
Federally Qualified Health Center (FQHC) or
rural health clinic (RHC) that is so led by a PA
Eligible Hospitals
Acute Care Hospitals Inoe includeing CAHs)
Children's Hospitals
Medicaid NOTE: Hospital-based EPs
(those performing 90% or
more of their services in either
the inpatient or emergency
department of the hospital)
DO NOT QUALIFY for
Medicare or Medicaid EHR
incentive payments

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Incentive Schedule – Medicare EPs
NOTE: Additional incentive payments (up
to $4,400) are available for Medicare EPs
participating in Health Professional
Shortage Areas (HPSAs)

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Incentive Schedule – Medicaid EPs

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Tale of the Tape – EHR Programs

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Evidencing Meaningful Use
• Stage 1 (2011 and 2012)
• To meet certain objectives/measures, 80% of patients must
have records in certified EHR technology
• EPs have to report on 20 of 25 MU objectives (15 core and 5/10
menu set-including at least 1 public health objective)
• Clinical Quality Measures
• 6 total measures (3 core and 3 alternate measures)
• If core measures cannot be submitted, may be substituted
for alternate measures
• 2011 – submit via attestation
• 2012 – electronic submission
• Reporting period – 90 days for first year; one year subsequently

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Meaningful Use Denominators
• Two types of percentage-based measures are
included to address the burden of demonstrating MU
1. Denominator is all patients seen or admitted
during the EHR reporting period
• Regardless of whether records are kept
using certified EHR technology
2. Denominator is actions or subsets of patients
seen or admitted during EHR reporting period
• Only includes patients, or actions taken on
behalf of those patients, whose records are
kept using certified EHR technology

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Considerations when Applying
Objectives and Measures
• Some MU objectives are not applicable to every provider’s
clinical practice and therefore are excluded from having to
meet the measure
• Does not count against the 5 deferred measures
• Example:
• Dentists that do not perform immunizations
• Chiropractors that do not e-prescribe
• States can seek CMS approval to require 4 MU objectives to
be core for their Medicaid providers
• EPS must have 50% of total patient encounters at locations
where certified EHR technology is available (all measures
would be based only on these locations)

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Timetable for Meaningful Use
http://www.cms.gov/EHRIncentivePrograms

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EHR Certification
• HITECH Act – Required National Coordinator of
Health IT to keep or recognize a program or
programs for the voluntary certification of health
IT
• The purpose of certification is to provide
assurance to the providers that the EHR
technology they adopt will allow for achieving
meaningful use

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State of EHR Certification
• March 10, 2010 – NPRM for temporary and
permanent programs to test and certify EHR
• June 24, 2010 – HHS published final rule for
temporary program
• Currently reviewing proposals from certifying
organizations
• Fall 2010 expected final rule for permanent
certification program
• Expected to begin in 2012

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Next Steps
• Fall 2010 – CMS Outreach and Education Campaign
• CMS to issue State Medicaid Director Letter with policy guidance on
implementation of Medicaid EHR Incentive Program
• Early 2011- EPs and eligible hospitals can register for the Medicare
and Medicaid EHR Incentive Programs
• Enrolled in Medicare FFS, MA, or Medicaid
• National Provider Identifier (NPI)
• PECOS registered – attest in EHR Incentive potion (available in 2011)
• States will announce additional registration requirements
• Continued CMS guidance on alignment with other CQM reporting
requirements (e.g. CHIPRA)

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HIPAA/HITECH Compliance
•Goal:
• Comply with applicable
regulations
• Minimize operational
burden of integrating
compliance activities
• Mitigate liability to extent
possible
• Considerations:
• Extent of PHI
environment
• Current controls in-place
• Potential for PHI breach

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Resources
• CMS EHR Incentive Program
• http://www.cms.gov/EHRIncentivePrograms
• Office of the National Coordinator for Health IT
• http://healthit.hhs.gov

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© 2010 The Hill Group, Inc.
The Hill Group, Inc
2 East Main St.
Carnegie, PA 15106
412-722-1111
Scott A. Rogerson, Consultant
srogerson@hillgroupinc.com