Meaningful Use

1. How can providers combine the 3 Core Clinical Quality Measures (CQMs), 3 Alternate Measures, and 3 Menu CQMs?
2. Can you provide information on the Meaningful Use (MU) Core Set Objective on “Implementing one clinical decision support rule”?
3. What is “clinical summary”? (MU Core Set Objective: Provide clinical summaries for patients for each office visit)

EHR Incentives

4. What documentation is required in order to receive EHR incentive payments?
5. Are FQHCs required to have PECOS?
6. How can I verify if I have an enrollment record in PECOS?
7. Will eligible professionals working with pharmacies who do not have the capability to accept electronic prescriptions be able to participate in the ePrescribing measurement?
8. Is unidirectional exchange accepted as meeting the laboratory reporting measurement?
9. How does the incentive payment get from the provider to the FQHC? Can the provider file paperwork to have the funds go directly to the FQHC?
10. How can ophthalmologists apply for incentives?
11. Is there a state rule on whether or not FTEs can participate in Medicaid reimbursements?
12. For Medicaid, what documentation does Hawaii require to show "evidence of installation" to receive the first year of payments?
13. How do dentists and other providers that meet the Eligible Professional criteria, but do not record data on most of the Core Measures, apply for incentives?
14. Can a facility attest for all of its providers under Medicaid or does each individual provider attest separately?
15. How can I find out if my EHR software has been certified by the Office of the National Coordinator for Health Information Technology (ONC)?
16. How do I apply for incentive payments?

Hawaii Pacific Regional Extension Center

17. What is the Hawaii Pacific Regional Extension Center (HPREC) and how does it help physicians?
18. What services does the HPREC offer?
19. Where is the Hawaii Pacific REC located and how long has it been organized?
20. Is the Hawaii Pacific REC a government agency?
21. How do I know it is safe to let you see my records?
22. Will the Hawaii Pacific REC work with my staff personally?
23. How large is your typical client practice?
24. What is the definition of a priority primary care provider (PPCP)?
25. What is the fee for working with the HPREC?
26. Will the HPREC still support my work toward Meaningful Use if I choose an EHR vendor not on the pre-qualified list?

Answers

Meaningful Use

1. Eligible professionals must report from the table of 44 clinical quality measures which includes, 3 Core, 3 Alternate Core, and 38 additional CQMs. Core CQMs - EPs must report on 3 required core CQMs, and if the denominator of 1 or more of the required core measures is 0, then EPs are required to report results for up to 3 alternate core measures. EPs also must also select 3 additional CQMs from a set of 38 CQMs (excluding the core/alternate core measures). It is acceptable to have a '0' denominator provided the EP does not have an applicable population. In sum, EPs must report on 6 total measures: 3 required core measures (substituting alternate core measures where necessary) and 3 additional measures. A maximum of 9 measures would be reported if the EP needed to attest to the 3 required core, the three alternate core, and the 3 additional measures.
http://www.cms.gov/QualityMeasures/03_ElectronicSpecifications.asp

2. Providers are required to implement one clinical decision support rule relevant to specialty or high clinical priority along with the ability to track compliance with that rule. Providers are also required to implement one clinical decision support rule. There are no exclusions. CMS will not issue additional guidance on the selection of appropriate clinical decision support rules for Stage 1 Meaningful Use. This determination is best left to the EP taking into account their workflow, patient population, and quality improvement efforts. Drug-drug and drug-allergy interaction alerts cannot be used to meet the meaningful use objective for implementing one clinical decision support rule. EPs must implement one clinical decision support rule drug-drug in addition to drug-allergy interaction checks.
http://www.cms.gov/EHRIncentivePrograms/Downloads/EP-MU-TOC-Core-and-MenuSet-Objectives.pdf
Core Measure 11 of 15
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3. Providers must provide clinical summaries for patients for each office visit. Clinical summaries are to be provided to patients for more than 50% of all office visits within 3 business days. Any EP who has no office visits during the EHR reporting period is excluded. An after-visit summary that provides a patient with relevant and actionable information and instructions containing the patient name, provider’s office contact information, date and location of visit, an updated medication list, updated vitals, reason(s) for visit, procedures and other instructions based on clinical discussions that took place during the office visit, any updates to a problem list, immunizations or medications administered during visit, summary of topics covered/considered during visit, time and location of next appointment/testing if scheduled, or a recommended appointment time if not scheduled, list of other appointments and tests that the patient needs to schedule with contact information, recommended patient decision aids, laboratory and other diagnostic test orders, test/laboratory results (if received before 24 hours after visit), and symptoms.

Office Visit – Office visits include separate, billable encounters that result from evaluation and management services provided to the patient and include: (1) Concurrent care or transfer of care visits, (2) Consultant visits, or (3) Prolonged Physician Service without Direct (Face-To-Face) Patient Contact (tele-health). A consultant visit occurs when a provider is asked to render an expert opinion/service for a specific condition or problem by a referring provider.
http://www.cms.gov/EHRIncentivePrograms/Downloads/EP-MU-TOC-Core-and-MenuSet-Objectives.pdf
Core Measure 13 of 15

EHR Incentives

4. Make sure you have enrollment records in the appropriate systems. You'll need:

• A National Provider Identifier (NPI)--All eligible professionals, eligible hospitals, and critical access hospitals (CAHs) must have a National Provider Identifier (NPI) to participate in the Medicare and Medicaid EHR Incentive Programs.
• An enrollment record in the Provider Enrollment, Chain and Ownership System (PECOS)--All eligible hospitals and Medicare eligible professionals must have an enrollment record in PECOS to participate in the EHR Incentive Programs. (Note: Eligible professionals who are only participating in the Medicaid EHR Incentive Program are not required to be enrolled in PECOS.)
  If you do not have an enrollment record in PECOS, you should still register for the Medicare and Medicaid EHR Incentive Programs.

For more information on eligibility, registration, and attestation, please visist www.cms.gov/EHRIncentivePrograms.
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5. Eligible professionals who are only participating in the Medicaid EHR Incentive Program are not required to be enrolled in PECOS.
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6. If you are concerned or uncertain about whether you have an enrollment record in PECOS, you can review the Ordering and Referring Report, on the Centers for Medicare & Medicaid Services (CMS) website under the Downloads section.
http://www.cms.gov/MedicareProviderSupEnroll/06_MedicareOrderingandReferring.asp
Left upper hand corner: Internet based PECOS
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7. Yes. Participating EPs should transmit prescriptions electronically using a qualified eRx system and report this action on claims using the appropriate G-code per the measure specification. If the pharmacy network converts an eRx into a fax because the pharmacy cannot receive eRx transmittals, this still counts as eRx. If the eRx system is only capable of sending a fax directly from the eRx system to the pharmacy, the system is not a qualified eRx system. EPs located in rural areas and who use local pharmacies should make sure the eRx system they choose is capable of two-way transmission of prescription data.
http://questions.cms.hhs.gov/app/answers/detail/a_id/9553
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8. Is unidirectional exchange okay for reporting on laboratories?
Yes. More than 40 percent of all clinical lab test results ordered by the EP during the EHR reporting period whose results are either in a positive/negative or numerical format are incorporated in certified EHR technology as structured data.  Structured data does not need to be electronically exchanged in order to qualify for the measure of this objective. The EP is not limited to only counting structured data received via electronic exchange, but may count in the numerator all structured data entered through manual entry through typing, option selecting, scanning, or other means.
(http://www.cms.gov/EHRIncentivePrograms/Downloads/EP-MU-TOC-Core-and-MenuSet-Objectives.pdf) 
Menu Set Measures, 2 of 10
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9. The EPs are legally attesting that they meet the requirements in order to receive payments. States could consider a model similar to that used for tax preparation, where a preparer (accountant) completes the information, but the individual still signs the forms. We recommend consulting with your legal department about your current rules for claims submissions, and ensuring that the EPs remain liable under the False Claims Act and other fraud, waste and abuse provisions. Furthermore, we want to ensure providers know that an attestation is being submitted on their behalf—as there may be EPs in multiple practices that want to direct the incentive to one particular practice.
http://www.cms.gov/MLNProducts/downloads/Medicaid_Qs-EHRIP_Final_Rule.pdf
Question 20
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10. All MDs or DOs may be eligible, so long as they meet the state’s scope of practice requirements. Typically this means that a state will require licensure, board certification, and specific medical training. Ophthalmologists currently billing Medicaid should not have any trouble with this hurdle. There are exclusions to the Core Measures.
http://www.cms.gov/EHRIncentivePrograms/Downloads/EP-MU-TOC-Core-and-MenuSet-Objectives.pdf
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11. No. “Full or part-time status does not affect patient volume calculations. . . There is no mention of requisite number of hours in the statute or this final rule as a pre-condition for eligibility.” Patient volume is calculated as a proportion and there is no minimum denominator or minimum full-time equivalency in order to qualify. Therefore yes, a part-time provider could be eligible. Likewise, there are no restrictions on employment type, e.g., contractual, permanent, temporary, in order to be an eligible professional.
http://www.cms.gov/MLNProducts/downloads/Medicaid_Qs-EHRIP_Final_Rule.pdf
Question: 30
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12. The new changes allow CMS to estimate the average payment that Medicaid providers will receive from other (non-governmental) sources.  Rather than requiring each eligible professional to calculate payments received from outside sources, each will use the average amount established by CMS.  After conducting the required studies, CMS has determined the average contribution from outside sources will remain at $29,000. Under the recent change, as long as the State can verify that no more than 85% of the net average allowable cost was paid to the provider as an incentive payment, a provider is determined to have met the remaining 15% of the cost.
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13. Dentists must meet the same requirements as other eligible professionals in order to qualify for the EHR incentive payments under Medicaid. That means that they must demonstrate all 15 of the core meaningful use objectives and 5 from the menu set of their choosing. The core set includes reporting of a total of 6 clinical quality measures (3 core and 3 from the menu set of their choosing). Several meaningful use objectives have exclusion criteria that are unique to each objective. EPs will have to evaluate whether they individually meet the exclusion criteria for each applicable objective. Each dentist/oral surgeon would need to look at the clinical quality measures him/herself to determine which ones s/he has applicable patient populations in their certified EHR system. There is not a blanket exclusion by type of EP.
http://www.cms.gov/MLNProducts/downloads/Medicaid_Qs-EHRIP_Final_Rule.pdf
Question: 41
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14. Yes. The EPs are legally attesting that they meet the requirements in order to receive payments. States could consider a model similar to that used for tax preparation, where a preparer (accountant) completes the information, but the individual still signs the forms. We recommend consulting with your legal department about your current rules for claims submissions, and ensuring that the EPs remain liable under the False Claims Act and other fraud, waste and abuse provisions. Furthermore, we want to ensure providers know that an attestation is being submitted on their behalf—as there may be EPs in multiple practices that want to direct the incentive to one particular practice.
http://www.cms.gov/MLNProducts/downloads/Medicaid_Qs-EHRIP_Final_Rule.pdf
Question: 20
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15. Please visit http://onc-chpl.force.com/ehrcert which provides a current list of certified EHR vendors. We also suggest you contact your software vendor directly and inquire about their certification.
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16. To register for incentive payments, visit https://ehrincentives.cms.gov/hitech/login.action.

Hawaii Pacific Regional Extension Center

17. RECs were created by the Federal Government under the Health Information Technology Act (HITECH) of 2009 to provide technical assistance, guidance and information to healthcare professionals to accelerate efforts to achieve meaningful use of certified Electronic Health Records (EHRs) and enhance the quality and value of health care.
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18. Prequalified list of certified EHR vendors, EHR adoption readiness assessment, workflow analysis, meaningful use assessment and much more.
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19. The Hawaii Health Information Exchange was awarded the Regional Extension Center grant in April 2010. The Hawaii HIE office is located at 900 Fort Street Mall, Suite 1300, Honolulu, HI.
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20. No. We are not a government agency. We are an experienced healthcare subcontractor working under the direction of Hawai‘i Health Information Exchange (Hawai‘i HIE) who is the recipient of the Hawai‘i Pacific Regional Extension Center grant. Hawai‘i HIE is the State Designated Entity (SDE) funded by the Federal Government to develop a statewide network for the exchange of healthcare information.
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21. As part of the Provider Agreement, safeguards for the privacy and security of all patient records are provided as an important aspect and concern of transitioning to EHRs.
While no one can guarantee absolute safety, there will be redundant checks and balances in place for the safe and secure exchange of patient health information.
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22. Yes. I will be your personal HIT Consultant and work closely with you and your staff throughout the process. There may be times when another HIT Consultant will work alongside me, but you will be notified in advance.
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23. Under the Federal Guidelines of the grant, the HPREC is limited to working with providers in groups from 1 to 10 members. The focus of CMS is to concentrate our efforts on providers in individual or small practices and medically underserved areas. Typically, our client provider practice is 1 to 3 providers.
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24. A provider must meet the following requirements in order to be considered a PPCP:

• Credentials must be MD, DO, NP, PA, or CNMW
• Specialty must be Adolescent Medicine, Family Practice, General Practice, Internal Medicine, OB, GYN, Geriatrics, or Pediatrics
• Practice must be a Private Practice of 1-10 Providers, Rural Health Clinic, Community Health Center, Critical Access Hospital, Public Hospital, or Other Underserved Setting
  

25. For providers who meet the PPCP requirements, the fee per provider is $500.
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26. Yes. The HPREC will work with any certified EHR vendor in order to make sure you are meeting the requirements needed to meet the meaningful use criteria and access the incentive funds.