Meaningful Use for Eligible Professionals (EPs) Q&A

VITL Staff

06-16-2011 (updated 6-17-2011) V6.0

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Notes

Not legal advice

CMS and State of Vermont rules may change

Check vitl.net for updates

Medicaid

Medicare

Medicare/Medicaid

Carol Kulczyk ckulczyk@vitl.net

Paul Forlenza pforlenza@vitl.net

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Medicaid: Is reimbursement still based on 85% of EHR implementation costs?

• Originally CMS required that eligible professionals prove spending at least 15% of the total cost of EHR technology

• CMS now assumes EPs attesting to MU have met the 15% requirement

• No proof is necessary for attestation but invoices should be kept for audit purpose

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Medicaid: If we implemented an EHR in 2010, does that mean we have met meaningful use for 2011?

• Adopting, implementing or upgrading (A/I/U) to a certified EHR will qualify you to receive an incentive payment for 2011

• Does not matter when the system was originally implemented. However, incentives are only available for certified systems

• Patient volume thresholds must be met in any consecutive 90-day period from the previous 12 months from the date of attestation.

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Medicaid: How do we calculate patient volume since we see patients with primary and secondary Medicaid coverage and Catamount MVP or BC?

• All Medicaid encounters will count including secondary and Catamount

• Medicaid % of unique patient encounters is calculated by dividing the Medicaid related encounters by total patient encounters for the reporting period

• The state of Vermont will be issuing detailed rules for calculating patient encounters.

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Medicaid: Does an EHR implementation need to be completed in 2011 to qualify for incentive payment? • EP does not have to install certified EHR

technology – acquire, purchase or secure access to certified

EHR– install or commence using certified EHR– expand functionality of certified EHR – upgrade to certified EHR

• Signed contract indicating that the provider has adopted or upgraded would be sufficient

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Medicare: What determines whether or not EP gets the maximum incentive payment?

• Incentive Payments based on 75% of Part B allowable charges

• To receive $18,000 (maximum in year 1), EP must have $24,000 in allowable charges

• Medicaid does not have this requirement

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Medicare: Incentive Payment

• When an EP has attested to MU and has $24,000 in allowable charges for a calendar year, CMS will send a payment

• If $24,000 is not reached in the calendar, CMS will make payment = 75% of allowable charges after February of the next calendar year– If $12,000 in 2011 allowable charges, CMS will

make payment after February 2012 calculated as $12,000 x 75% = $9,000

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Medicare/Medicaid: What are reporting periods for EPs?

• Reporting period based on calendar year• Medicare:

– 1st year: any consecutive 90 days for 1st year– 2nd year: one full calendar year

• Medicaid:– 1st year: no reporting period; demonstrate A/I/U– 2nd year: any consecutive 90 days – 3rd year: one full calendar year

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Medicare/Medicaid: Important Dates

• Medicare– October 3, 2011 last day to begin 90-day reporting

period for 2011 – February 29, 2012 last day to register and attest

for MU to receive an incentive payment for 2011

• Medicaid– October 3, 2011 State of Vermont scheduled to

open Medicaid incentive program– Check www.vitl.net for updates

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Medicare/Medicaid: Definition of exchange of key clinical information – part I

• Electronic transmission and acceptance of key clinical information using the capabilities and standards of certified EHR technology

• Format– if information available in structured format, must

be exchanged in structured format– if available only in unstructured electronic formats

(e.g., free text/scanned images), unstructured information exchange would satisfy the measure

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Medicare/Medicaid: Definition of exchange of key clinical information – part II

• Following would not utilize the certification capability of certified EHR technology to electronically transmit the information and would not meet the measure of this objective– physical media such as CD-ROM, USB, hard drive

• Using the method your EHR vendor utilized to certify your EHR will meet the requirements

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Medicare/Medicaid: How do I attest to Meaningful Use?

• Medicare– Attest using the CMS web based system

• Medicaid– Check www.vitl.net for future announcements

– VITL will help you be prepared for meeting MU and attest

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VITL Services

• Workflow analysis• Technology

assessment vendor selection

• Practice culture assessment

• Project management

• EHR vendor selection• EHR deployment and

implementation• Implementing privacy

policies consistent with HIPAA

• Achieving meaningful use of the EHRs

Meaningful Use for Eligible Professionals (EPs) Q&A

VITL Staff

06-16-2011 V5.0