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Meaningful Use - Basics
Dr. Jose I. DelgadoTaino Consultants Inc.
Definitions Meaningful Use Attestation Core Objectives Menu Objectives Stages
Meaningful UseMeaningful use is using certified electronic health record (EHR) technology to:
Improve quality, safety, efficiency, and reduce health disparities
Engage patients and family Improve care coordination, and population
and public health Maintain privacy and security of patient
health information
ObjectivesAn Objective is a specific result that, in this case, CMS, expect Eligible Providers (EP) to achieve within the specified time frame Core – everyone must meet unless there is an exception and the EP can prove the same.Menu – a number of options that provider can select to meet requirements*
* While there are exclusions provided for some Menu Measures, EPs cannot select a Menu Measure and claim the exclusion if there are other Menu Measures that the EP could report on instead.
Attestation Legal Definition - The act of attending the
execution of a document and bearing witness to its authenticity, by signing one's name to it to affirm that it is genuine.
Meaningful Use - A healthcare organization must demonstrate meaningful use in order to be eligible for payments from the federal government under either the Medicare or Medicaid EHR incentive program.
Stages
2011-2012 2014 2016
Stage 1 Stage 2 Stage 3
Data capture and
sharing
Advance clinical
processes
Improved outcomes
Eligible Providers
Medicare Doctor of medicine Doctor of osteopathy Doctor of dental surgery Doctor of dental medicine Doctor of podiatric
medicine Doctor of optometry Chiropractor
Medicaid • Physicians• Dentists• Certified nurse midwives• Nurse practitioners• Physicians assistants (in
rural health clinic or FQHC led by a physician assistant)
Medicare vs MedicaidMedicare Medicaid
Starts in calendar year 2011 Starts in calendar year 2011
Up to $44,000 over five years Up to $63,750 over six years
Maximum of $18,000 on the first year if EP bills Medicare $24,000 or more.
based on up to 85% of state-calculated global average costs for EHR
For maximum reimbursement 1st year cost no later than 2012
1st yr cost no later than 2016
No payments made after 2015 No payments made after 2021 or more than 5 years
Penalties start in 2015 (1%) and increases by 1% every year until 2019 with a max of 5%.
No Medicaid penalty for failure to demonstrate Meaningful Use
Peculiarities Incentive Payment - Medicare payment is based on
75% of charges allowed for the first 10 months of that year as long as they do not exceed the maximum incentive for the year.
EPs may not receive EHR incentive payments from both the Medicare and Medicaid.
After an EP qualifies for an EHR incentive payment under one program but before 2015, an EP may switch between the Medicare and Medicaid programs one time.
Medicare IncentivePayment Amounts
Qualifies in 2011
Qualifies in 2012
Qualifies in 2013
Qualifies in 2014
Qualifies in 2015
2011 $18,000
2012 $12,000 $18,000
2013 $8,000 $12,000 $15,000
2014 $4,000 $8,000 $12,000 $12,000
2015 $2,000 $4,000 $8,000 $8,000
2016 $2,000 $4,000 $4,000
Total $44,000 $44,000 $39,000 $24,000
Medicaid Incentive
Qualifies in 2011
Qualifies in 2012
Qualifies in 2013
Qualifies in 2014
Qualifies in 2015
Qualifies in 2016
2011 $21,250
2012 $8,500 $21,250
2013 $8,500 $8,500 $21,250
2014 $8,500 $8,500 $8,500 $21,250
2015 $8,500 $8,500 $8,500 $8,500 $21,250
2016 $8,500 $8,500 $8,500 $8,500 $8,500 $21,250
2017 $8,500 $8,500 $8,500 $8,500 $8,500
2018 $8,500 $8,500 $8,500 $8,500
2019 $8,500 $8,500 $8,500
2020 $8,500 $8,500
2021 $8,500
Total$63,75
0$63,75
0$63,75
0$63,75
0$63,75
0$63,75
0
Applicable Laws American Recovery and Reinvestment Act (ARRA).
Title XIII Health Information Technology for Economic and Clinical Health Act (HITECH)
Health Insurance Portability and Accountability Act Omnibus Rule False Claims Act Mail and Wire Fraud (18 USC 1518) Criminal Penalties for Acts Involving Federal Health Care
Programs (42 USC 1320a-7b)
Audits
"Meaningful Use audit is a matter of when you will get audited, not whether.” - Anantachai (Tony) Panjamapirom, PhD, Senior Consultant at The Advisory Board Company
• The Centers for Medicare and Medicaid Services has awarded Figliozzi and Co., of Garden City, N.Y., a contract to audit payments and compliance with the agency’s EHR Incentive Program.
• Contract Award Date: April 16, 2012 • Dually-eligible providers will not be audited twice (although a hospital
could get audited by the State for eligibility and hospital calculation, and then audited by the CMS contractor for Meaningful Use).
Types of AuditsPre-payment Post Payment
Notes: 1. Take audits seriously.2. Discrepancy in attestation information and
information submitted for the audit may result in failure.
3. Failure to provide support documentation on any area may result in 100% re-payment of monies received.
What to expect1. Electronic letter from audit company from a CMS
e-mail address; Letter will be addressed to email address provided
during registration
2. Attachment with a request for support documentation
3. About four weeks to submit documentation
Key Items to keep in mind Proof of use Certified EHR.
Need Copy of licensing agreement with the vendor or invoices for the period.
List of office or outpatient facility where Provider sees patients. Identify if records are kept outside of EHR. Report showing compliance with specific Core
Measures must display vendor’s logo or step by step screenshots which demonstrate that the report was generated by the EHR.
Key Items to Keep In Mind (continuation) Core measure (Protect electronic health
information) Provide Proof that a security risk analysis was
performed prior to the end of the reporting period. If deficiencies were noted provide implementation
plan with completion dates. Menu Set Objective Measures
Measures must display vendor’s logo or step by step screenshots which demonstrate that the report was generated by the EHR.
Note: Verify that information used to respond to the audit matches the numbers submitted on the CMS attestation form.
HIPAA Every CE must have a Risk Assessment
Completed with all components covered Every Covered Entity (CE) must have a Security
Management Plan with dates Every CE entity must be in compliance with the
final HIPAA Omnibus Rule A covered entity can be fined $1,000 to $50,000
per patient record up to $1,500,000 if patient records are breached
Data and Retention Information used to respond to the audit
must match the numbers submitted on the CMS attestation form.
Keep all information regarding Meaningful Use Attestation for a minimum period of 6 years.
Key Items to Remember Policies and Procedures not enough Documentation is key
◦ Evidence book Follow the steps
◦ Risk Assessment◦ Risk Management◦ Training
ACT NOW!!
