ONC_Certification_HIT_2014Edition

 

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2015 marks the fourth year in which funding is available for Eligible Professionals (EPs) to acquire or upgrade Certified EHR Technology (CEHRT), and the second year for which Stage 2 funding is available for EPs who have already completed two years in Stage 1. This document describes the process of qualifying and applying for funding in both active stages, as well as the specific ways in which both Office Practicum and you need to change in order to establish and continue Meaningful Use. Connexin’s goal is to ensure that you understand all of the requirements in sufficient detail to qualify for the full cycle of three stages over six program years, if your practice’s Medicaid population meets the minimum statutory thresholds.


What is “Meaningful Use”?

In an effort to improve healthcare delivery, integration and costs, the Office of the National Coordinator (ONC) has made clear that it is not enough just to implement EHR technology; healthcare providers must demonstrate on an annual basis that the technology is being used “meaningfully.” There has been a multistage process involving multiple stakeholders to determine the evolution of Meaningful Use standards. Stage 1 began in 2011 and established the baseline. Stage 2 began in 2014 for providers who had already completed two years in Stage 1. Modified Stage 2 takes effect in July 2015 and unifies every participant around a common set of reduced requirements through 2017. Stage 3 will begin as an option in 2017 and become mandatory in 2018. Public funding for the entire MU process is projected to end in 2021.

The stated goal of Stage 1 was to enable data capture and sharing; in other words, to get health care providers comfortable with collecting medical data electronically. Stage 2 has more ambitious goals centered around improving patient care through advanced clinical processes and true data exchange. This involves better clinical decision support, care coordination, and patient engagement in the form of more robust communications and a truly shared chart.

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Do I Qualify?

Good question, and one that is not always easily answered. Since most Office Practicum users are pediatricians, this is focused on the Medicaid qualification requirements. Contact us directly if you believe your basis for qualification is more likely focused on your Medicare patient population.

If you have already received Stage 1 funding, it is likely – but not automatic – that you will continue to qualify for Stage 2 funding. The reason for the uncertainty is that you must continue to meet minimum Medicaid patient visit thresholds to stay in the funding cycle, and states have discretion over which submission stages (primary, secondary, etc.) qualify. If your practice has experienced a significant change in its volume of Medicaid encounters, you might find that you no longer qualify, or that you now qualify when you didn’t before. (With Medicaid payment parity a fact of life in many states, you might have opened and/or expanded your Medicaid panel.) In addition, as of 2014 you may include CHIP encounters for Title 19 and 21 expansion (previously only Title 19 was allowed), as well as zero-pay claims. Standalone CHIP is still excluded. The only way to know for certain is to code your patients’ insurance policies accurately and do the math.

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How Much Funding is Available for Qualified Providers?

Eligible Providers whose Medicaid patient visit volume is at least 30% of total visits qualify for the following amounts:

  • Year 1 $21,250
  • Years 2-6 $8,500 per year

If you qualify during the entire six-year cycle, that is a total of $63,750. Eligible Providers whose Medicaid patient visit volume is between 20% and 30% of total visits qualify for 2/3 of those amounts:

  • Year 1 $14,167
  • Years 2-6 $5,667 per year

If you qualify at this second tier for the entire period, that is a total of $42,500. In both cases, ARRA funding is classified as income. Unless you are organized as a non-profit corporation – and don’t all pediatricians feel that way at some point during their careers? – you will need to report it on your tax returns and find sufficient expenses to offset it, lest it be taxed away. If you are acquiring an EHR for the first time, that is relatively easy. If you are upgrading a system you bought prior to the Meaningful Use process, you might want to talk to your accountant about the implications of receiving a large lump sum. Depending on the age of your system, it might be time to invest in some new hardware.

Unfortunately for pediatricians in areas with low Medicaid populations, there is no Meaningful Use funding available for providers who conduct less than 20% of their visits with Medicaid patients. However, keep in mind that funding and Meaningful Use measures are calculated on a per-provider basis, not at the practice level. If you are part of a larger group that sees at least 10% Medicaid patients, you may find that by concentrating your Medicaid visits to a specific provider or providers, you can get at least part of your group to qualify for funding. Something is better than nothing!

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When Does Funding Start?

The Medicaid side of the Meaningful Use process is based on “program years.” Unlike Medicare, there is no rush to “use it or lose it” by a particular date. If you have not already started, you can apply anytime between now and the end of 2016, and you will qualify for the full six-year funding cycle described above. In addition, you do not need to provide Meaningful Use measures for the first program year of Stage 1 funding. You simply need to attest that you have acquired and implemented Certified EHR Technology (trained staff, deployed tools, exchanged data), or that you have upgraded and/or expanded functionality or interoperability of a certified EHR that you already owned. Again, states are given discretion, so how they implement these rulings may vary slightly. For specific details, contact your state Medicaid office and consult the website where you apply for funding.

After the first program year, you will move into Modified Stage 2 until 2017 or 2018. The version of Office Practicum certified to 2014 standards is capable of supporting you until December 31, 2017, by which time you will be required to move up to a future version to be certified to Stage 3 standards.

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Is Office Practicum a “certified EHR”?

Office Practicum Version 11 was certified in May 2011 as a Complete Ambulatory EHR under the 2011 MU standards. Office Practicum Version 14 was certified in October 2014 as a Complete Ambulatory EHR under 2014 guidelines.

If you participated in the MU program prior to 2014, you used OP 11 to meet the requirements from 2011 to 2013. The certificate for OP 11 expired on December 31, 2013, because new standards came into effect as of January 1, 2014. However, in August 2014, ONC published a Revised Final Rule to allow products certified under 2011 guidelines to remain in use through the end of 2014. As such, you may have kept using OP 11 to compile and submit MU statistics for the 2014 program year. All 2015 statistics must be compiled and submitted using OP 14.

View Office Practicum Certification Information

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What Can I Do to Ensure Success in 2015?

The final rule published on October 6, 2015, reduced the 2015 reporting period to 90 days, which means you must have upgraded to a full implementation of OP 14 no later than October 1, 2015 to generate at least three months of supporting data for the 2015 program year. Based on the requirement of using OP 14.1 to produce and submit ICD-10 claims as of October 1, all active OP 14 users met that deadline. New participants in 2016 and 2017 will also be able to report on 90-periods in their first year of eligibility, but all other users will be required to compile and submit full years in 2016 and 2017.

Take inventory of what features you already own. Aside from the main program, a certified Office Practicum 14 installation will be required to contain the following elements:

  • e-Prescribing
  • Patient Portal (not optional under 2014 criteria)
  • Interface to your state’s Immunization Registry
  • Results interface to at least one lab (may be optional; details below)
  • DIRECT secure email account for inbound/outbound transitions of care
  • Meaningful Use report bundle for the QIC module

As always, the core Office Practicum program is covered by your Support Level Agreement, and there is no charge for the upgraded features that make it “Meaningful Use capable.” If you already have the 2011 MU report bundle, then the upgrade to the 2014 edition is included at no extra charge.

The final preparatory step is to read the rest Meaningful Use Roadmap carefully and start a conversation in your practice about how to implement the changes that some of these measures require. Many of the changes to support Meaningful Use are driven by office procedures, not Office Practicum. Regardless of which EHR vendor you use, you need to rethink certain processes that may be ingrained but are incompatible with Meaningful Use requirements. We hope the remainder of this roadmap will give you plenty to think about and decide before you begin (or continue) this journey.

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