Stage 2 Meaningful Use – Delayed to 2014

HHS announced today that eligible professionals (“EPs”) and hospitals who begin participating in the EHR Incentive Program in 2011 will not have to meet the Stage 2 Meaningful Use standards until 2014.  Therefore, those EPs and hospitals  participating in the Medicare EHR Incentive Program in 2011 will be able to show Stage 1 meaningful use in 2011, 2012, and 2013.  Those participating in the Medicaid EHR Incentive Program in 2011 will show Adopt, Implement or Upgrade in 2011, and Stage 1 meaningful use 2012 and 2013.

If you have questions on achieving meaningful use or the Medicare and Medicaid EHR Incentive Programs please contact Elana Zana.

CMS Issues Stage 1 Info Sheets on Meaningful Use (updated July 2013)

CMS has issued information sheets on the meaningful use requirements.  Releasing one sheet for eligible professionals and another for eligible hospitals, these sheets are designed to explain each meaningful use objective and its respective measure.  The sheets provide links to each meaningful use objective and then explains the numerator and denominator requirements, attestation requirements and relevant additional information.  To access the information sheets click on the links below:

Stage 1 EHR Meaningful Use Specification Sheets for Eligible Professionals or view the table of contents.

Stage 1 EHR Meaningful Use Specification Sheets for Eligible Hospitals

CMS is also offering a National Provider call regarding meaningful use on August 18th.  To register for the call click here.

Understanding the meaningful use measures and objectives is sometimes complicated.  For assistance with meaningful use or the EHR Incentive Programs in general contact Elana Zana.

Washington Makes Changes To Patient Volume Calculation for Medicaid EHR Incentive Payments

Washington State recently announced a change to the Medicaid patient volume calculation related to the Medicaid EHR Incentive Program.  Previously, Washington announced that it would provide all eligible professionals and hospitals with ProviderOne data on their respective Medicaid encounters for the time period chosen by the provider.  Pursuant to the Medicaid EHR Incentive Program eligible professionals must show that they have at least a 30% Medicaid patient volume to qualify for the incentive payments (pediatricians can show 20% Medicaid patient volume), hospitals must show that they  have a 10% Medicaid patient volume.  The primary equation for calculating patient volume for eligible professionals is as follows (there is a second equation regarding managed care patients that is not discussed by this blog post, nor is the calculation for hospitals):

Total Medicaid Patient Encounters x 100 ≥ 30%
Total Patient Encounters

Washington, rather than providing the exact number of Medicaid encounters, is allowing the eligible professional to perform the calculation itself.  Due to the eligible professional’s inability to differentiate between Medicaid, State Only payments, and CHIP, the state is providing a multiplier to calculate these ineligible encounters (note that rural health clinics and FQHCs may include CHIP patients in their patient volume calculations).  Based on its analysis of  ProviderOne historical paid fee for service claims and managed care encounter data for 2010 the average proportion of CHIP encounters equals 1% and State Only encounters equals 4%.  Accordingly, the revised formula for eligible professionals will look as follows:

Total Medicaid Patient Encounters * .95 x 100 ≥ 30%
Total Patient Encounters

This new formula will reduce the percentage of Medicaid encounters and may make those eligible professionals who are on the cusp of meeting the 30% requirement ineligible.  In response the state has offered an alternative, which allows any provider to request assistance from the state staff to analyze and report their actual data from ProviderOne.  In addition, those eligible professionals who are audited and who use the multiplier will only be assesed as to whether the total Washington Medicaid encounters were accurately represented, and will not evaluate whether the CHIP and State Only encounters were correctly excluded.

Washington has since modified its State Medicaid Health Information Technology Plan to reflect this change.  In addition, the state has offered an updated webinar on registration and calculation of patient volume, which can be accessed here.

Calculating patient volume can be complicated, especially when attempting to qualify for the incentive payments  using the group practice calculation.  For more information regarding the patient volume calculations or the Medicaid/Medicare EHR Incentive Program in general please contact Elana Zana.

Delay of Stage 2 of Meaningful Use

The Office of the National Coordinator announced yesterday at the HIT Policy Committee meeting its agreement that the Stage 2 meaningful use requirements should be delayed until 2014.  This would mean that eligible professionals and hospitals participating in the Medicare EHR Incentive Program can attest to the Stage 1 meaningful use requirements in 2011, 2012, and 2013 and will only have to begin attesting to the Stage 2 requirements in 2014.  This shift does not necessarily have an effect on participants in the Medicaid EHR Incentive Program, considering the advantage of attesting to “adopt, implement or upgrade” during the first year of the program.

To see the proposed Stage 2 requirements by the HIT Policy Committee click here.

Hospital Deadline for Medicare EHR Incentive Payments Near

For those hospitals interested in applying for the Medicare EHR Incentive Payments for 2011, the last day to begin the 90-day reporting period is July 3rd.  Hospitals and CAHs must demonstrate meaningful use for 90-days during the 2011 fiscal year (which ends September 30, 2011).  Hospitals and CAHs have until November 30, 2011 to register and attest to meaningful use.

Health Data Privacy Protections to Increase

As we wait for the HITECH Act updates to HIPAA to be finalized, yet another article signals the administration’s intent to strengthen privacy protections for health data– http://www.nytimes.com/2011/05/31/business/31privacy.html

Impact of “Big Data” in Health Care

A Recent report from McKinsey & Company on the evolution of information technology focuses on health care as a sector to watch: “For instance, if US health care could use big data creatively and effectively to drive efficiency and quality, we estimate that the potential value from data in the sector could be more than $300 billion in value every year, two-thirds of which would be in the form of reducing national health care expenditures by about 8 percent.” Full report at http://www.mckinsey.com/mgi/publications/big_data/index.asp

Proposed Rule on Accounting of Disclosures Issued

Following much anticipation, the Office of Civil Rights released today the proposed rules on HIPAA Accounting of Disclosures implementing the new HITECH provisions.  To access the proposed rules click here.  The proposed rules were printed in the federal register on May 31st and comments will be accepted for sixty days thereafter.

CMS Issues Medicare EHR Incentive Checks

Beginning this week, CMS will begin issuing Medicare EHR Incentive Payments to those providers who have successfully attested to meeting meaningful use.  Eligible Professionals who have met the meaningful use requirements can expect payment of $18,000.  (Note, Eligible Professionals that have not yet met the $24,000 Medicare allowed charges threshold will not receive a check until that threshold is met).  Eligible Hospitals that have attested to meaningful use can also begin to expect their incentive payments.

CMS will issue incentive payments in the same manner as providers receive payments for Medicare services, via electronic funds transfer or check. Payments will be made to the TIN selected during registration for the Medicare EHR Incentive Program.

For those providers who have not yet registered for the EHR Incentive Program there is still plenty of time in 2011 to do so.  The Medicaid EHR Incentive Programs have launched in some states, with other expecting to launch later this Summer.

For assistance with registering for the Medicare EHR Incentive Program or understanding meaningful use please contact Elana Zana.

HHS Says Push for EHRs Overlooks Security Gaps

It seems HHS is laying the groundwork for the issuance of the updates to HIPAA privacy and security rules under the HITECH Act.  As reported May 16th in the Washington Post:

“The nation’s push to computerize medical records has failed to fully address longstanding security gaps that expose patients’ most sensitive information to hackers and snoops, government investigators warn.”

http://www.washingtonpost.com/politics/hhs-inspector-general-says-push-for-electronic-medical-records-overlooks-some-security-gaps/2011/05/16/AFpaH54G_story.html