Meaningful Use
Meaningful Use Interview
What is “meaningful use”?
Explain more about the “core measures” and some of the challenges.
Explain the attestation process to me.
When do I need to start and how?
What is my reimbursement potential?
How will the government know I’m in compliance?
What effect will the debt reduction program have on my payment incentives?
Is there a good source that can help me through the process?
I’m still reluctant. How will this really help me or, more importantly, my patients?
Jacqueline Rogers
Meaningful Use Analyst, Intuitive Medical Software
Credentialed Epic Trainer/Consultant
Pathways Certified Facilitator
Health Education, Liberty University
Respiratory Therapy, CRTT
Certified Etiquette Consultant
Springfield, Missouri
Transcription
Intro
My name is Jackie Rogers and I’m the meaningful use analyst with UroChart, which is part of Intuitive Medical Software here in Springfield, Missouri. My background involves travelling with Epic as an implementation consultant and trainer, so that is how I got started in the EMR, in particular in training and educating all over the country and then I came on at UroChart and got involved in meaningful use.
What is “meaningful use”?
Meaningful use is part of the HITECH Act which was signed into law in 2009 and that basically involves meeting some rules and requirements that are in place by the federal government. You have 15 core measures, which are required (those are not optional), and then along with those you have 10 menu items that you can actually choose five of those in which you would like to use as part of your criteria of meeting meaningful use.
Explain more about the “core measures” and some of the challenges.
With the core measures, what I have seen a pattern of—maybe being a little more difficult—is workflow changes in regard to vitals—the height, weight and blood pressure—which are required. Some specialty practices are not always used to taking the blood pressure, so that would be a change. Then also the clinical summaries is a change where 50% of the time you have to physically give that clinical summary to your patient within three business days. So that is a change in the work flow for most practices. And in regard to the five measures, I would also say that the security risk analysis is probably the biggest one of the measures that is the hardest for EMR vendors to convey the importance of, just because it is not software related. In regard to the security risk analysis, there are certain measures and things that are required by all providers to do in keeping patient information confidential and protected and so for bigger practices I would say that there’s a lot more involved than if I was a smaller practice; but the fact remains the same that you have to run a security risk analysis and attest to the fact that you have indeed done one before you can receive your incentive money.
Explain the attestation process to me.
The attestation process involves first you have to register and have all that information on file for CMS, so there is a registration process for each provider. Then you go through and meet all of your meaningful use requirements for your 90 days. That involves of course running your security risk analysis, meeting your 15 core measures, and then also five menu measures, so you’ve done all that. At the end of the 90 days you can go back to the CMS site and there is an attestation tab that you go to: so there is the registration and now we’re moving to the attestation tab. Putting in all of your information there, you start out and attest to the fact that you’ve done all of these measures, you’re putting in your data for your numerators and denominators for each one of the measures, or attesting to an exclusion, if that applies to you. Also you attested you’re going to submit your clinical quality measures. At the end of the attestation, you choose the clinical quality measures that you have collected the data on. You also add that information to the process of the attesting and, then at the end, the physician says there are several measures to check that you agree with that I have attested to this information being true and accurate—it is correct and I have done all of these things—and you submit your attestation and then you receive a confirmation page. We have seen our physicians that use UroChart receive their incentive monies in 30 to 45 days afterward and that’s a deposit of $18,000 per provider because we are in our first year of attesting.
When do I need to start and how?
In regard to starting out, if I’m a practice and I’ve just adopted my electronic medical records and am using it and want to go for receiving my incentive money, the requirement for that is your first year, which you can use 2011 or 2012 as your first year. You have a 90-day period that you can use to prove that you have met meaningful use and meeting those 15 core measures and the five menu measures. And when we go on to the CMS site and go to the attestation tab and through all those measures in putting in our numerators and denominators and verifying that we have indeed run a security risk analysis and have filled in all the required information, then we can submit that information and what we have seen is in about 30 to 45 days after we have attested that our physicians are receiving their incentive monies: for the first year it is $18,000 per provider.
For your first year you can either use 2011 or 2012 as your first initial year for meeting stage 1. Beyond stage 1, right now, stage 2 is being pushed out, so anything further down the road is undefined, if you will, but for right now, you can use 2011 if I attest to my 90 days in the period of 2011. If I start at the end of 2011, it will not go over into the beginning of 2012, I must use starting October 1st through the end of the year. That’s the last period in 2011 that I can use. If I don’t get everything together until say, November, I can’t say, “OK, November through February, I can use that for my 90 days.” It doesn’t work like that. So if I attest in 2011, then for 2012, I have to start a full year of capturing that data. So I have from January of 2012 through December of 2012, and then I would use that full entire year as my reporting period and I attest in the beginning of 2013 and hopefully in about 30 to 45 days in January of 2013 I would receive my incentive money and it is $18,000 per provider for Medicare. Medicaid, you go through the states, it is a little different. Your first year for Medicaid is $21,250.
So to begin the last reporting period for 2011, October 1st through the end of the year is your last chance to go ahead and get in your 90 days for attesting in the current year. If you decide to wait until January of 2012, that’s OK, you’re still going to get the full incentive amount of $18,000 for your first year. But, if you’re up and running and you see your workflows going OK and your numbers look good then I would get it in by October 1st.
What is my reimbursement potential?
For your first year of payment every provider will receive $18,000. Your second year of attesting to meaningful use you’re going to get a payment of $12,000. Your third year is $8,000, and so by end of five years you will receive $44,000 per provider, but it does decrease in payment per year as well as for Medicaid if you go that route; you start out at $21,250 for your first deposit and a total of being $64,000 for your full incentive return. However, if you choose to wait and decide “I’m not going to do this.” you do start getting penalties and down the road it’s a little gray as to how that will all roll out, it can be as much as 5% of your Medicare reimbursement or that can change in being dropped altogether. So some of those things down the road are a little gray, but you will be fined eventually down the road, and then if you choose to wait, you decrease the amount that you will receive, you will not get the full $44,000 total during a five year period after 2012, so if you say, OK I want to use 2013 as my first year, you’re not going to get the full $44,000, I believe you’re going to get about $36,000 after that.
How will the government know I’m in compliance?
If you get selected for an audit, you will be fined. You have a six-year period that’s open according to CMS and to those guidelines that they can come in and audit you up to six years after and you have to provide documentation that you ran a security risk analysis and that all of the information that you attested to for that 90 day period was true. So, I don’t imagine that it would be a light audit process; I think that they are serious about their audit process, and I think it’s all of our responsibility to protect private health information for the patient and that’s our responsibility to do that. So again with the adoption of an electronic medical record, I think in the initial changeover phase, it is uncomfortable, there is a lot to get used to, there’s some workflow changes that have to take place, but the end result, I think, is going to be efficiency for everyone and then just safety for the patient, in the long run that is just more efficient for us all. But, in that changeover we have to take responsibility of protecting private health information, run that security risk analysis and do our due diligence in the requirements that are put out by CMS to do that. And so, it’s not optional, it’s one of the core measures and it is required and so when you go to the CMS site and you have said, “Yes, I have a run a security risk analysis” that is your word as a provider, that you have overseen and actually made sure that was taken care of for your practice.
What effect will the debt reduction program have on my payment incentives?
Well, I think that there is always the chance with any administrative change that can take place where a new administration can come in and change or undo what is in place at this current time. So if I was a provider I would suggest that time is of the essence and I would attest just as quickly as I can if getting that $18,000 is important to me then I would get my 90 days in 2011 and start my year two of attestation or recording that data from January of 2012 to December of 2012 and attesting just as quickly as possible in 2013 because you never know the climate and the forecast of politics and some of this could all go away. In regard to just a change in the administration and of course, with the debt reduction and the financial forecast right now, it is a little shaky, so if I was a provider, I would get on it.
Is there a good source that can help me through the process?
This meaningful use glossary and requirements table is something that is put out by the AMA and it’s very thorough and it’s got a great explanation to every one of the measures and it has your definitions of what an eligible provider is, what a unique patient is. Because that is another thing people will say, “Well, OK, Mr. Jones comes in every four weeks, so he’s going to keep counting for my measures.” And the requirement is that it’s a unique patient. So a unique patient, even though Mr. Jones comes in six times during my 90-day reporting period, he’s only counted once, so you can’t double dip, basically. So the glossary goes through and explains all of those pieces of information for you and then it goes through one by one and tells you what the measures mean, the workflow of who is going to usually do those things and then also anything in yellow, you’ll see that there’s four bars that are in yellow. Those are the requirements that you can actually use paper charts for.
I’m still reluctant. How will this really help me or, more importantly, my patients?
I think for the smaller practices and maybe providers who are a little more reluctant to implementing and transferring over to an EMR, I certainly understand that, but I will say in the long run the benefits of it are advantageous to do so. You’re missing out on incentive money first of all that could actually help your practice. You know, $44,000 is nothing to balk at, for a small practice, and then I do think, whether you want to or not, we’re kind of in the warm fuzzy stages right now. But I think eventually, the fact of the matter is, you’re going to convert. Whether you want to or not, you’re going to have to make the transition, because, again, that health information exchange that’s coming, we want to be able to provide information whether I live in California or I move to Florida, those records can follow me and we have up-to-date accurate information no matter where I am. And again protecting that information and keeping it confidential is a high priority and I think that when we work together and realize the benefits of it for all, it just is a win-win. And, I think that’s important, because it is, bottom line at the end of the day, when all of this is over and maybe our whole mentality for meaningful use and we’re at the end of the growing pains, that it is about patient care, that it is about efficiency, that we are monitoring those drug seekers, that they’re not going be able to just hop from pharmacy to pharmacy or physician to physician and abuse the system. And so, I think with these things in place, it will prevent and prohibit those types of abuses from happening. It is beneficial for all.
So, again, you know one of the things, and I don’t want to ramble too much, in regard to this, at the HIMSS Conference there was a session that I sat in on from a pharmacist who had all of these scripts, ineligible scripts, “OK, how many of you think it is this, how many of you think it is that? Raise your hand. OK, actually the answer is C.” It wasn’t either of those things. And then he gave an example of a script that was written, that was dispensed and it was a lethal dose for an 18 month old. The child survived, thankfully, but he said “How many of you think that the pharmacist who wrote this and thought it was XYZ should have been fired?” Of course everyone raised their hand. And he said, “Well, that pharmacist was me. Here’s why electronic medical records are important and essential to where we are today because you don’t want to make the mistake of an order, you do not want to give a lethal dose or the wrong drug to someone and have an adverse reaction.” So from those things, from that perspective, it’s lifesaving. And I know as myself being a former clinician, having to wait my turn in line for a chart takes forever and so the efficiency that I can just go to any work station and put in my patient information of the treatment that was given and then go to my rounds and be done saves a huge amount of time so that the growing pain in the beginning, it is, we don’t like change. And so that’s difficult, and I understand that, I have witnessed it—I’ve been on the floor, I’ve been in the practices, I’ve seen physicians scream and yell and get uptight either at myself or the nurse, I understand. I don’t take it personal, but change is hard for all, it’s just the way we are. But, change is good in this regard and it’s necessary and it’s essential that we get the job done.
A couple of questions….
1) Is there a size requirement to qualify? What if a practice is just opening and is still building its patient population?
2) Does the practice have to be credentialed through Medicare to qualify? What about practices that do not submit to insurance?
3) Primary care only or all medical practices?
4) Seems to good to be true, is this only for MDs or can a NP qualify too?
Thanks for any info you can offer.
Hi Tammy,
Jackie sent us the following responses to your questions.
1) No, there’s no numerical requirement, just a percentage of Medicare filing (see #2). They have all of 2012 to generate more patient flow and can use the last 90 days of that year. Technically, they have a little time to get on their feet.
2) To qualify for Medicare, physicians can earn up to 75% ($44,000) of Medicare allowable charges, if they are utilizing the Medicaid option, close to $64,000 is available to practices who see more than 30% of Medicaid patients; for pediatricians that number is dropped to 20%. If a practice does not file through these two entities, then they cannot receive incentive monies. The program is only for Medicare or Medicaid Eligible Providers. Those who do not utilize either would not be eligible for the EHR Incentive Program.(http://www.cms.gov/MLNProducts/downloads/CMS_eHR_Tip_Sheet.pdf) I would suspect in the future though, that if they file any type of insurance for payment, that the insurance carriers are going to start their own set of Meaningful Use Requirements.
3) All medical practices qualify–general and specialty
4) NPs can qualify but only under Medicaid, not Medicare
Eligible professionals under the Medicare EHR Incentive Program include Doctor of medicine or osteopathy, Doctor of dental surgery or dental medicine, Doctor of podiatry, Doctor of optometry, Chiropractor
Eligible professionals under the Medicaid EHR Incentive Program include Physicians (primarily doctors of medicine and doctors of osteopathy), Nurse practitioner, Certified nurse-midwife, Dentist, Physician assistant who furnishes services in a Federally Qualified Health Center or Rural Health Clinic that is led by a physician assistant.