Turn Up the Volume
Changes to patient volume in the Medicaid EHR Incentive Program
Roberta Mullin, managing partner of HITECH Answers, wrote a great article yesterday on the changes to patient volume in the Medicaid EHR Incentive Program. These changes will affect participants in the Medicaid program, regardless of which stage they are in. You won’t want to miss this information.
“Medicaid Changes in Stage 2 EHR Incentive Programs”
Dissecting Stage 2 of EHR adoption
The CMS Medicare and Medicaid Programs; Electronic Health Record Incentive Program–Stage 2 final rule outlines the path for meaningful use for eligible professionals and eligible hospitals in both the Medicare and Medicaid programs. Even though the States are the administrators of the Medicaid programs, they must work within the framework established in the final rules. There are important changes to the Medicaid EHR Incentive Program for stage 2. Click HERE to keep reading.
First Impressions: Stage 2 Meaningful Use
Stage 2 Meaningful Use yields positive changes for behavioral health eligible professionals
Everyone is buzzing about the final rules for stage 2 Meaningful Use that were released last week – so many, many blog comments and articles from Meaningful Use subject matter experts sharing their viewpoints on what significant changes we can look forward to. Here’s my two cents on seven positive changes behavioral health eligible professionals are likely to see:
1. First, one item in the plus column that will appeal to all EPs. The total number of measures an EP must meet has stayed the same, although there has been some change in the makeup: 15 core and 5 of 10 menu is now 17 core and 3 of 6 menu measures. CMS has made the change to allow a batch reporting process for meaningful use so that groups can submit attestation information for all of their individual EPs in one file. Whether or not the state Medicaid systems will also have this capability is yet to be seen, but, if they do, this is a big positive for system administrators overseeing the MU programs in your agencies.
2. There is also a change in the definition of an encounter for the patient volume calculation of eligibility. Beginning with stage 2, $0 claims can also be included in the numerator when calculating Medicaid patient volume. This may help more EPs meet that required patient volume threshold for eligibility.
3. EPs can continue to use the Stage 1 final rules for EHR technology through the year 2013. So, if you have been working hard to fully understand the stage 1 rules and the features in the certified technology that support them, you can find some comfort in the fact that you have the option to continue to use this functionality for a couple of more years. I think this is a good thing: many of the stage 2 rules expand on the stage 1 workflows, thus mastering the workflows for stage 1 may go a long way toward preparing EPs for much of what is coming in stage 2. Also, please note that all EP must meet the stage 1 rules before before moving to Stage 2.
4. A new Core Measure for EPs requires the EP to use secure electronic messaging to communicate with patients on relevant health information. It’s a contribution to the “patient engagement” domain. I envision such a feature allowing a client to send a communication to a provider between visits (e.g., needing greater clarification on information found on their client portal) and the provider being able to respond in real time.
5. A new Menu measure for EPs in stage 2 is the requirement to enter at least one electronic progress note created, edited and signed by an EP for more than 30% of unique patients. This seems like an easy win for behavioral health and AOD EPs as this is standard practice for an EP already using a certified EHR.
6. The EP has to submit data for nine Clinical Quality Measures, but the proposed list of CQMs now includes more measures that are relevant to behavioral health and addiction disorder populations. The final specification sheets for the CQMs for stage 2 are targeted to be released in October 2012. Presumably, these more relevant CQMs for BH/AOD will be there. This could be another positive for our specialty EPs because so many of the stage 1 CQMs were really primary care oriented and difficult to get any value greater than 0.
7. In the stage 2 final rules, CQMs are no longer a separate measure. In stage 2, the CQMs are now part of the measure for the clinical decision support rules. Bullet one of the clinical decisions support rule measure reads, “Implement 5 clinical decision support interventions related to 4 or more clinical quality measures, if applicable, at a relevant point in patient care for the entire EHR reporting period.”
This coupling of the CQMs with the clinical decisions support rules makes the fact that the CQMs are more relevant to BH/AOD services even more important. I can foresee the integration of the CQMs into the clinical decision support rules bringing greater value to the clinical delivery process then the two measures existing separately, as they do in stage 1. Once the EPs fully understand this measure, they will be able to tell us if this is really the case.
Some final thoughts:
- As expected, some of the percentage-based measures have increased what it’s going to take to meet the measure. But, many had a low threshold to start with, so I don’t envision these changes in percentages being devastating to any EP who can meet the measures for stage 1.
- There are a few new measures, but again, none seem far removed from business processes BH and AOD EPs already have in place in their practices.
- The ability and requirement to exchange health information in a timely manner with other providers and settings of care (particularly at the point of transition) has become more prevalent in stage 2, but that is a key reason for moving to an EHR so I’m sure we can all appreciate the value in that capability and practice.
In summary, as much as I understand the final rules of stage 2 at this point (and, admittedly, I have much more reading to do in order to get through all of the pages and pages of stage 2), I am in favor. The new rules build nicely on stage 1 and, more importantly, the measures are attainable for BH/AOD EPs. The key for us now, as a vendor, is to make the additions and changes to the application as smart as possible in terms of efficiency and intuitiveness of use for the end user, and we are looking forward to receiving that wisdom from our “user voices.”
Please take a moment to look at the “Stage 1 vs. Stage 2 Comparison Table for Eligible Professionals” posted on the CMS website.
By the Numbers
We are thrilled to be listed on the recently released Inc. 5000. Appearing at #1461 on the list, Qualifacts is the top behavioral health EHR provider on this exclusive ranking of the nation’s fastest-growing private companies with 205% growth over three years.
By the numbers …
Overall rank: 1461
In the Software industry: 116
Among Nashville companies: 15
Among Behavioral Health EHR providers: 1
Thank you to all of our customers, employees and partner organizations that have made this significant and sustained growth possible. David Klements, president and CEO of Qualifacts, says it best:
“Since introducing CareLogic Enterprise in 2008, our efforts have been singularly focused on making our customers successful, and they in turn have helped us grow. I’m extremely proud of what we’ve accomplished thus far, but there is plenty more to be done. As the behavioral health and human service providers we serve engage in the major system changes – including those resulting from healthcare reform – we look forward to tackling these challenges and opportunities together.”
Imagine the Possibilities: Standardizing Clinical Service Delivery
Monica Oss, chief executive officer of OPEN MINDS, has written a series of articles on the hot topic of standardizing clinical service delivery, the most recent being called, “The Elephant in the Room.”
The articles are chock full of great information, including references to other research articles and discussions on this timely topic. The debate on whether or not standardization in clinical service delivery is really possible – or would such a practice do the more complex consumers a great disservice – is a hot one and one that deserves a lot of discussion.
I found Monica’s assembling of the facts on this topic really helpful, and her bottom line is absolutely worth repeating. Regardless of where you stand on this issue, Monica’s advice is sound:
“If you are an executive of a service delivery organization and you don’t have defined organizational standards of clinical practice, or you don’t know the variance in application of those standards by your professional staff, now is the time to start on that process.”
In addition to sound advice, in today’s edition of “The Open Minds Circle,” Monica shares with us approaches for standardizing clinical practices and provides a toolkit her team has developed for doing so.
You’ll want to check out this series of articles and the toolkit.
Eligible Professionals Who Work in Multiple Locations and the 50% Rule
Now that the Eligible Professionals have attested to A/I/U and collected that first year’s incentive payment from the Medicaid EHR Incentive Program, they are thinking about year 2 and beyond. One topic that comes up often is the 50% rule for eligible professionals who practice in multiple locations.
It is common practice for many of our community mental health agencies to use part-time psychiatrists who work both at their agency and somewhere else. These are the EPs and agencies that need to understand the 50% rule and how it applies to them.
When an EP is ready to demonstrate meaningful use (meet the measures), one of the additional requirements that were established in the final rules for the Medicare and Medicaid EHR Incentive Program, “EPs Practicing in Multiple Practices” (Federal Register July 28, 2010, Final Rules Part II , page 44329), is that EPs provide at least 50% of their services in a location equipped with a certified electronic health record.
When an EP calculates the encounters for the measures, they must include encounters that occur in any practice equipped with a certified EHR at the start of the reporting period. “Equipped” is defined as the EHR technology being available at the beginning of the reporting period for a given geographic location.
In addition, if the EP provides at least 50% of their encounters in a practice that is equipped with a certified EHR, all measures should be limited to actions taken at practices/locations equipped with certified EHR technology.
So what does this mean?
- If your agency/group has EPs who only work with your agency/group (full-time or part-time), this rule does not apply to them. It applies only to EPs who work in multiple locations.
- If your EP works with your agency/group as well as one or more additional agencies/groups, then they will need to determine if at least 50% of their encounters (collectively between all agencies/groups) occur in a location with certified EHR Technology. If they meet this 50% rule, then they can move forward with demonstrating meaningful use in the agency(cies) with the certified EHR since the beginning of the reporting period.
If your agency has a certified EHR, and it is determined that the EP who works among multiple locations can meet the 50% rule, and no other locations where he/she works has a certified EHR, that EP can limit the measures to the encounters that occur at your agency/location.
I have included below some additional sources for understanding this and other rules of the EHR Incentive Programs of Meaningful Use:
- CMS Meaningful Use Stage 1 Requirements Overview PowerPoint
- CMS Electronic Health Record Incentive Program FAQs
Feel free to ask any questions you might have about your specific scenario regarding EPs practicing in multiple locations.
Health IT for You
A new, short, animated video for consumers explains how widespread adoption of electronic health records and other health information technology is giving our health care system a 21st century upgrade: improving the way we communicate with our doctors, making sure health information is available when and where’s it’s needed, and helping us manage our health and wellness outside the doctor’s office. Watch the video to learn more about the benefits of health IT and other consumer e-health tools and the value of having secure, electronic access to your health information.
We love how this video simplistically shows the technological changes in the healthcare landscape and how EHR’s are helping people adopt to this change. Consider showing this in your agency lobby or sharing with your staff!
Identifying Roadblocks for Stage 2 of Meaningful Use
In this blog post from iHT2, Dr. Russell Leftwich, Chief Medical Information Officer from the Office of eHealth Initiatives State of Tennessee, shares what he sees as the biggest roadblocks for stage 2 as well what he would change (if it were up to him) about the Meaningful Use criteria for stage 2. This is a must-read!
Docs Crush Feds’ EHR Goal
Overall, the federal government has spent more than $5.7 billion on EHR incentive payments between January 2011 and the end of May, 2012 (more than $3 billion was paid by Medicare and more than $2.6 billion by Medicaid)…thereby exceeding their program goals much earlier than expected.
Empty pockets? Meaningful Use funds minimize roadblock to Behavioral Health EHR adoption
The National Council’s recent “HIT Adoption and Readiness for Meaningful Use in Community Behavioral Health“ report on the 2012 National Council survey was fascinating. The key findings of the report cite that “behavioral health organizations are eager to move forward with implementing EHRs” (page 4), but when the responders were asked what the barriers to implementation were, 30% of respondents identify “upfront financial costs” as the leading roadblock, followed by 12% who identify “ongoing maintenance costs.”
Upfront financial costs have always been the barrier to allowing nonprofit community behavioral health organizations to implement an EHR. The EHR Meaningful Use incentive programs can be the answer for many of these organizations when an essential part of their services are delivered by rendering providers who qualify as Eligible Professionals (EPs).
As a vendor, Qualifacts feels it is our responsibility to assist our user community in understanding the final rules around eligibility for (primarily) the Medicaid EHR incentive program, including the rules that allow rendering EPs “to reassign their incentive payments to their employer or to an entity with which they have a contractual arrangement allowing the employer or entity to bill and receive payment for the EP’s covered professional services” (CMS FAQ). In fact, 35% of EPs at Qualifacts customers have already collected over $4.6 million in first-year incentive payments.
Qualifacts even goes one step further: for agencies who decide CareLogic Enterprise if the best EHR for their business, we will do a pre-contract consult to help the agency determine if and how many potential EPs they may have providing services for their community mental health agency. If they are one of the many agencies that employ physicians (psychiatrists, DOs) and nurse practitioners, they can take advantage of our Meaningful Use Assurance program.
In short, if your agency employs or contracts with providers who meet the requirements of the Medicaid EHR incentive program, Qualifacts will allow you to defer 75% of the upfront implementation services cost until that first EP collects his/her incentive payment AND we will work with you and your EPs to determine eligibility, register at CMS and attest at your state Medicaid EHR incentive program website.
If you’re interested in learning more about the Qualifacts MU Assurance program, you can email me at meaningfuluse@qualifacts.com or join our 30-minute webinar on August 21st when I will answer all of your questions.
And if you have already selected an different certified EHR but are worrying about how your agency is going to be able to pay for it, maybe you should ask your vendor to “put their money where their mouth is.” Qualifacts is.
EHR Meaningful Use Incentive Audits Have Begun
The EHR Incentive Program Audits have begun, and HIMSS has some firsthand info on what to expect and what to ask during an audit.
The auditors will request information from providers via a letter of inquiry asking for specific, non-identifiable patient information from the EHR system.
According to the law firm acting on behalf of CMS, letters have begun getting sent to providers requesting them to send documentation to support their attestation and asking for four types of information. Find out what that information is and what else to expect with attesting to meeting the meaningful use requirements.
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