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.

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.

Attestation for EHR Incentive Programs Available

Earlier this month, CMS launched the attestation portion of the EHR Incentive Payment Program.  Beginning on April 18th, eligible professionals and hospitals are now able to attest to meaningful use (or adopt, implement or upgrade for Medicaid).  Along with the attestation itself, CMS launched its Meaningful Use Attestation Calculator, a wizard which walks eligible professionals and hospitals through the meaningful use objectives and enables the entity to determine if it can successfully meet the meaningful use standards prior to filling out the registration form. 

For those providers that are able to begin the registration and attestation process, access to registration and attestation is available here.  The CMS website also has a user guide that is helpful when registering as well as FAQs.  To be eligible for either the Medicare or Medicaid EHR Incentive Programs an eligible professional or hospital must be using certified EHR technology.  The ONC provides a list of which EHR systems are “certified.”

In addition, CMS is offering teleconferences regarding registration and attestation:

  • Tuesday, May 3, 2:00 – 3:30 p.m. ETRegister to join this call if you are an eligible hospital or CAH who wants to learn more about the attestation process for the Medicare EHR Incentive Program.
  • Thursday, May 5, 1:30 – 3:00 p.m. ETRegister to join this call if you are an EP who wants to learn more about the attestation process for the Medicare EHR Incentive Program.

Some states are also offering webinars about the Medicaid EHR Incentive Payment Program and how to register.  Registration for the Medicaid EHR Incentive Program requires both registration with CMS and on the state level.  However, eligible professionals and hospitals will not be able to register with CMS for the Medicaid EHR Incentive Program until their state is ready to start its Medicaid EHR Incentive Program.  Washington expects to go-live in June 2010; California plans to go-live this Summer for eligible professionals. 

If you have questions regarding the Medicare or Medicaid EHR Incentive Programs or would like some assistance with understanding meaningful use or calculating patient volume (Medicaid) please contact Elana Zana or Dave Schoolcraft.

Washington Announces Medicaid EHR Incentive Program Training Webinars

Yesterday, Washington State announced upcoming training webinars for the Medicaid EHR Incentive Programs.  These webinars are designed to help hospitals and eligible professionals prepare for their participation in the Medicaid EHR Incentive Programs.  Washington anticipates rolling out the Medicaid EHR Incentive Program in June. 

Program Planning & Implementation Update (WSHA specific)

Wed., March 23

10-11 AM

https://www2.gotomeeting.com/register/638732130

Program Planning & Implementation Update

Wed., April 13th

10-11 AM

https://www2.gotomeeting.com/register/727138786

Qualifying For Incentives & Meeting Required Patient Volume Thresholds  

Wed., April 27th

10-11 AM

https://www2.gotomeeting.com/register/212646515

Overview Of Adopting, Implementing & Upgrading EHR Systems (AIU) & Meaningful Use

Wed., May 11th

10-11 AM

https://www2.gotomeeting.com/register/183445538

Registering for the Medicaid EHR Incentive Program

Wed., May 25th

10-11 AM

https://www2.gotomeeting.com/register/332772211 

Incentive Payments & Reassignment Process

Wed., June 8th

10-11 AM

https://www2.gotomeeting.com/register/518246379 

Attestation & the Audit Trail

Wed., June 22nd

10-11 AM

https://www2.gotomeeting.com/register/592783331

For more information regarding the Washington Medicaid EHR Incentive Program click here.

Medicaid providers are eligible for up to $63,750 in Incentive Payments over the six years of the program.  If you would like more information about determining your hospital’s or practice’s eligibility, meaningful use, or calculating your estimated incentive payments please contact Elana Zana.

Modification in Medicaid EHR Incentive Program Calculation – Net Average Allowable Cost

In December 2010, Congress passed the Medicare and Medicaid Extenders Act of 2010.  Along with a variety of other changes, Congress modified one of the inputs in calculating the incentive amount under the Medicaid EHR Incentive Program, specifically the Net Average Allowable Cost calculation.

In the original enactment of the ARRA, the Medicaid EHR Incentive Payments were based on a formula which required that the Secretary of HHS determine the average allowable cost for certified EHR technology, and allow eligible professionals to collect incentive payments in an amount not to exceed 85% of the net average allowable cost, or $21,250 (in the first year or $8,500 in subsequent years) whichever amount is smaller.  Determining the net average allowable cost, per the HHS Final Rule, was not an easy feat.  HHS determined that the average allowable cost for certified EHR technology for the first year was $54,000 and therefore a provider was allowed to collect up to $29,000 of cash gifts towards the certified EHR technology without seeing a reduction in their EHR Incentive Payment.  The Net Average Allowable Cost was calculated as follows:

 1st Year Incentive = ($54,000 – cash gift for EHR) * 85% or $21,250 (whichever is smaller)

2nd-6th Year Incentive = ($20,610 – cash gift for EHR) * 85% or $8,500 (whichever is smaller)

Providers were also responsible for showing that they have contributed at least 15% of the net average allowable cost to the purchase or utilization of certified EHR technology.  The Final Rule created a detailed description of what items may be included and excluded from the 15% calculation, as well as any gifts for EHR technology. 

 Congress has since changed these complicated calculations, making it easier on eligible professionals. 

The new change recently passed by Congress relating to the incentive calculation is the assumption that the provider has expended at least 15% of the net average allowable cost provided that the EHR Incentive Payment to the provider is not in excess of the 85% of the net average allowable cost.  In other words, Congress will now assume that as long as the Medicaid EHR Incentive Payment does not exceed $21,250 in the first year and $8,500 thereafter, the eligible professional is assumed to have paid the remaining 15% and is therefore eligible for the entire Medicaid EHR Incentive amount.

These changes are still subject to HHS releasing new rules interpreting Congress’s enactment and accordingly modifying the Final Rule issued this summer.  However, in light of Congress’s intent it appears that the change will ease the confusion on how to compute the net average allowable cost and to determine whether a Medicaid provider has adequately paid for certified EHR technology.

Registration for Medicare EHR Incentive Payments Starts January 3rd

Starting on January 3rd, 2011, registration for the HITECH Electronic Health Record Medicare Incentive Payments will open.  This registration is available for both eligible professionals and eligible hospitals, including Critical Access Hospitals.  The registration link will be available starting on January 3rd and can be accessed here.  Registration for the Medicaid EHR Incentive Payments will be available for the following states:  Alaska, Iowa, Kentucky, Louisiana, Oklahoma, Michigan, Mississippi, North Carolina, South Carolina, Tennessee, and Texas.  In February, registration will likely open in California, Missouri, and North Dakota.  It is anticipated that other states, including Washington, will  launch their Medicaid EHR Incentive Programs during the spring and summer of 2011.

For mor information regarding the Medicare Incentive Payments see the CMS press release.  For a general overview of the HITECH incentive payments please read our previous blog posts for physicians and hospitals.  As a disclaimer, these blog posts were written prior to the issuance of the Final Rules but provide a good overview of the statutory requirements.

CMS has also issued tip sheet regarding Stage 1 Meaningful Use for hospitals, and Critical Access Hospitals, click here to access the tip sheet.  The tip sheet for eligible professionals can be accessed here.  Additional information may be obtained by contacting CMS or your State directly (CMS and State Medicaid Contact List & Information).

If you would like further information regarding achieving Meaningful Use, registering for the Medicare Incentive Payments, or assistance calculating the Medicare or Medicaid incentive payments please contact Dave Schoolcraft or Elana Zana.