General Disclaimer:
The views reflected here are not necessarily those of Genius Solutions, it is an article based on the most current information available and the best interpretation of that data available to give you a starting point for your research and understanding of these government programs. You will see me continually give you links back to the CMS and other government web sites and resources with the direction to go back to the source for information. Currently the information is coming fast, it’s changing often, and it’s not always easy to understand or interpret. My intention is not to give you the definitive answer to anything, honestly they may not be down to an ultimate definitive answer to some questions themselves , yet. The point is to do our best to keep you informed and direct you to sources you can use for complete information and for answers to questions for you and your offices. This is a rough cut resource so you know what you need to look in to. We can help guide you to the source, but we are not the source, that would be the Federal Government, as it is their program.
General Information:
There is a lot of information, even this month’s CMS calls didn’t answer all of my questions, but it did give me both a better understanding and a bit more confidence in the program and the proposed payouts. I am still having a hard time identifying some of the “hows” and “how muchs”. Hopefully these questions will continue to be asked and cleared up further with each of their teleconferences. The following information comes straight from their teleconferences and the slides presented, obviously with my best understanding of them.
**8/19/10 - I received a special request to see charts of the incentive payments, here is a .pdf that will show you the Medicare, Medicaid, and special incentive for Medicare providers in Health Shortage areas.
For the CMS slides used for this presentation (as well as to go to the slides when mentioned in this article, please download them from CMS at: http://www.cms.gov/EHRIncentivePrograms/Download/EHR_Incentive_Program_Agency_Training_081010.pdf
(I apologize. I just checked this link and between Monday 8/16 and today 8/18 CMS has pulled down the presentation slides that they had posted here and I couldn't find them again. I don't think that I can post their information without receiving their wrath- so at this point, you will have to search the CMS website and try to glean the information- they have updated some of their sections-or maybe they will post the slides again later for the Aug 10, 2010 Eligible Professionals tele-conference. )
Also, stay tuned to the CMS web site to see when the calls will be posted, if you would like to listen to it for yourself. CMS said to allow up to 3 weeks for the call to be posted, they also said transcripts of the calls would be available. You can also sign up at the CMS web site to be on the list to receive info on future calls.
The number 1 most important item they said was the purpose of meaningful use and the incentive programs:
“Our goal is to pay incentives!”
Now how are they showing their sincerity? Well first off they did seem to take into account all of the comments made about what meaningful use should entail and how it might be best implemented into your offices with the least amount of burden to you the individual physicians and offices. They took their lofty goal and broke it down into three phases: Phase 1 “data capture” (2011 implementation), Phase 2 “advanced clinical processes” (2013 implementation), and Phase 3 “improved outcomes” (2015 implementation). You can see from this (and guess) that they are starting out easy and then they will be getting progressively tougher and more complicated with the standards as they go. They have also given more flexibility to their phase 1 implementation to make it easier for everyone to participate by giving additional leeway and flexibility to the measures. They did specifically mention in the Q&A session, after the presentation, that the associated measures may change over the phases, but the objectives required will not. Per CMS, more detailed information on the measures will be forth coming. Hopefully this will also include better discussions, details, and understanding on their numerator/denominator/exclusion reporting for measurement items, because there was no detail, and their explanations seemed rather confused and confusing.
What you will be reporting on for both Medicare and Medicaid
- There are 15 core items that are to be met by all Eligible Professionals (EPs). [see slides 23-24]
- Next you will choose an additional 5 of 10 “Menu Objectives” options to report on. [see slides 25-26]
- Third, there are 6 Clinical Quality Measures and you need to report on 3 of the core or alternate core measures. [see slides 31-32]
- Then, you will need to report on 3 of 38 additional Clinical Quality Measures (CQM). [see slides 33-39]
Now, at this point things may diverge a bit between Medicare and Medicaid. You need to know that the Medicare program will be administered by the Federal government, BUT the Medicaid incentive programs will run by the individual states, so, states can get prior approval from CMS to require some additional measurement objectives, per their state, for payout. These may therefore vary from state to state.
80% of your patients must be in and reporting out of your EHR
For payment: the first year (2011) you only need to register and report for 90 consecutive days. For the second year (2012) you will be reporting for the entire year.
Again for more detailed information, please be sure to check out the actual presentation slides [as noted] from CMS (or search their web site).
You need to choose:
You need to either participate in Medicare or Medicaid for stimulus. You cannot do both at the same time. Which one you choose may also affect what other stimulus programs you can participate in with either program. For example: You can’t participate in both the Medicare EHR stimulus program and Medicare e-prescribing at the same year, but you can mix the Medicaid EHR stimulus program with the Medicare e-prescribing and get paid for both in the same year.
There are also some additional restrictions on Medicaid EHR stimulus like Medicaid has a 30% patient volume threshold requirement or they need to practice in a RHC and FQHC (pediatricians only need to meet a 20% patient volume threshold). See the CMS slides for details.
Medicare Payment (Slim Facts)
- Max of $44,000 over 5 years
- Based on Fee-for-Service allowable charges
- Must begin by 2014 (to receive any of the stimulus funding)
- Last payment year 2016
- Penalties will be possible if you are not using EHR by 2015
- A bonus is available for providers working in a Health Shortage Area (a max of $4400 over 5 years is possible)
- Payments to one TIN (tax id number), like PQRI (it may be possible to re-direct this money under very specific CMS guidelines). This is all despite CMS specifically stating that “incentives are based on the individual, not the practice” (slide #4).
- One payment per year, like PQRI, although they were saying in the follow-up (8/12) that it would be continuous and revolving. (I think this “revolving and continuous” thing may only be the first year (2011), where you only have to report for a 90-continuous day period only, versus the remaining years will you will have to report for the entire year.)
Medicaid Payment (Slim Facts)
- Max of $63,750 over 11 years
- Incentives are the same, whichever year you start (where they are decreasing after 2ys for Medicare)
- Must begin by 2016 (to receive any of the stimulus funding)
- Last payment year 2021
- No mention of Penalties for not using EHR by a certain date, but it will probably be coming
- No Bonus available for this program, for providers working in a Health Shortage Area
- Payments to one TIN (tax id number), like PQRI (this was in the discussion of both MR and MD, so I believe this to be the plan for Medicaid as well.)
Ok, some wrinkles in the programs and my best understanding
EPs (Eligible Professionals)
For Medicare see Slide #5
- Doctors of medicine or osteopathy
- Doctors of dental surgery or dental medicine
- Doctors of podiatric medicine
- Doctors of optometry
- Chiropractors
For Medicaid see Slide #7
- Physicians
- Nurse practitioners
- Certified nurse-midwives
- Dentists
- Physicians assistants working in a Federally Qualified Health Center (FQHC) or rural health clinic (RHC) that is so led by a physician’s assistant
A question was asked by a dermatology office about "What if we don’t have or do any of the items on the list, can we still report and apply for the program money?" The answer was basically “yes, you may be reporting zero numbers for things and be excluded from other things, but you can report and comply”, this would apply to other specialist such as podiatrists and chiropractors. Again, hopefully they will give more specific information about this when they clarify the numerator /denominator/exclusion measurement reporting. I am still lacking in my understanding of the money that will be paid, as to whether it is just complying with the above listed measures, a percentage on what you actually can report on, or what. I don’t feel satisfied trying to give a solid answer based on the information as currently given, because I don’t see one.
Hospital Professionals
You cannot be a hospital based provider and cash in on either the Medicare or Medicaid options, that I can tell. They are defining a hospital professional as one who spends 90% of their professional time in in-patient, emergency room, etc. practice; as determined in the law. The downside for you is, no stimulus payment for you, individually, from this program. However, there is an upside: you don’t have to purchase the EHR or suffer future penalties for not having one, as that will fall under your hospital’s purview. If you are unsure, in any way, you should check into the stimulus rules for yourself.
Medicare Advantage Professionals
This is a whole other cans of worms and specifics, some of which I honestly “didn’t get”, possibly because they weren’t well documented or explained. The biggest thing I got out of this is that there are percentage thresholds you have to meet (like with Medicaid). Also, you, the professional, do not seem to apply for or receive the money directly, the program gets the money and distributes it. If you fall into this area, I strongly recommend that you take extra time out to know and understand how these things will apply to you.
Implementation Helper for Medicaid Program Choosers
This is a wrinkle smoother, another difference between the Medicare and Medicaid programs: If you are doing Medicare, you must meet the Meaningful Use criteria from the beginning; if you are doing Medicaid, they are more flexible. If doing Medicaid, you do NOT have to be using the complete meaningful use with EHR criteria the first year, you can: adopt, implement, or upgrade and still qualify (for the first year only). Again, you will need to check into the specifics for application in your office if you feel this may apply to you.
Can you use the program overlaps?
Even though you must choose to participate in either Medicare or Medicaid, you are allowed to switch your decision one time by 2015. (P.S. You can only work the Medicaid program in one state, not multiple states at a time.) So, here’s the wrinkle: You need to begin the Medicaid program by 2016, so I am wondering if you can work Medicare 2011-2014 or 15, make the switch to Medicaid (if you can meet the threshold patient volumes to qualify) and then get the Medicaid money. So far I have not been able to find out or get my question in to have it answered. I’m betting they are going to say, one or the other, but I don’t think they’ve specified, and it sure looks like they arranged it so it may possible to do both. (If someone out there knows for certain, I would love to hear about it.)
As always, we will continue to strive to stay current on this topic and report back to you as we learn more; I always hope you will share information back with us as well if you come across any good nuggets. In the end you will still need to be active in inquiring about this information for your office.
Here are some additional sources:
CMS Incentive Programs web page
http://www.cms.gov/EHRIncentivePrograms/
US Department of Health and Human Services, Health Information Technology (HIT) web site:
http://healthit.hhs.gov
The New England Journal of Medicine has a great article with some charts. One of the article's authors is David Blumenthal, National Coordinator for Health Information Technology.
http://healthpolicyandreform.nejm.org/?p=3732&query=home
The Federal Register is a good place to keep in touch with current government happenings also
http://www.federalregister.gov/health-and-public-welfare
1 comment:
Excellent post.
can you give a break down of payments each year.
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