Meaningful Use (Government Funding Compliance)

Meaningful Use

What is Meaningful Use?

The American Recovery and Reinvestment Act (ARRA) of 2009 authorizes the Centers for Medicare & Medicaid Services (CMS) to provide incentive payments to eligible professionals (EPs) and hospitals who adopt, implement, upgrade, or demonstrate Meaningful Use of certified electronic health record (EHR) technology.

The Meaningful Use program is about using a certified EHR to:

Improve quality, safety, efficiency
Reduce health disparities
Engage patients and families
Improve care coordination and public health
Maintain privacy and security of patient health information

The intent is for Meaningful Use compliance to result in:

Better clinical outcomes
Improved population health outcomes
Increased transparency and efficiency
Empowered individuals
More robust research data on health systems

Meaningful Use sets specific objectives that EPs and hospitals must achieve to qualify for the CMS Incentive Programs.

ClinicTracker’s status as a certified EHR, under both the 2011-2012 criteria (since retired) and current 2014 criteria, gives its users access to the pool of $831 billion in Stimulus Funds created by the ARRA. Part of the ARRA is the Health Information Technology for Economic and Clinical Health Act, also known as HITECH. It allocates $19 billion to hospitals and physicians who demonstrate Meaningful Use of certified EHRs.

If you adopt the ClinicTracker Connect Meaningful Use version, the program can report, in real time, the extent to which your agency is meeting eligibility requirements. It also calculates how much in incentive reimbursements you might receive based on your EP’s activities. Our Meaningful Use Dashboard tracks all the indicators and objectives required for attesting to Meaningful Use with CMS. You will find more information about the Meaningful Use Objectives on the CMS website.

Not sure whether your agency would qualify for funds under the Meaningful Use program? Click on Path to Stimulus Funding, or navigate to the other tabs for more information.

What is the Amount of Incentive Payment?

The Meaningful Use program has one version for Medicaid and another for Medicare. Each program carries its own reimbursement structure:

Medicaid

According to CMS rules, EPs are eligible for the Medicaid incentives if, over at least 90 days in the previous year, 30% of their encounters came from Medicaid. The percent of encounters can be calculated in one of two ways: 1) the EP’s number of Medicaid patient encounters divided by the EP’s total number of patient encounters; or 2) the number of Medicaid enrollees on the panel assigned to that EP divided by the total number of patients assigned to the EP (for managed care or health home arrangements).

	Adoption 2011	Adoption 2012	Adoption 2013	Adoption 2014	Adoption 2015	Adoption 2016
2011 ($)	$21,250	0	0	0	0	0
2012 ($)	$8,500	$21,250	0	0	0	0
2013 ($)	$8,500	$8,500	$21,250	0	0	0
2014 ($)	$8,500	$8,500	$8,500	$21,250	0	0
2015 ($)	$8,500	$8,500	$8,500	$8,500	$21,250	0
2016 ($)	$8,500	$8,500	$8,500	$8,500	$8,500	$21,250
2017 ($)	0	$8,500	$8,500	$8,500	$8,500	$8,500
2018 ($)	0	0	$8,500	$8,500	$8,500	$8,500
2019 ($)	0	0	0	$8,500	$8,500	$8,500
2020 ($)	0	0	0	0	$8,500	$8,500
2021 ($)	0	0	0	0	0	$8,500
TOTAL	$63,750	$63,750	$63,750	$63,750	$63,750	$63,750

Medicare

According to CMS rules, EPs are eligible to receive reimbursement for up to 75% of their allowable Medicare charges, subject to limitations displayed in the table below.

	Adoption 2011	Adoption 2012	Adoption 2013	Adoption 2014
2011 ($)	$18,000	0	0	0
2012 ($)	$12,000	$18,000	0	0
2013 ($)	$8,000	$12,000	$15,000	0
2014 ($)	$4,000	$8,000	$12,000	$12,000
2015 ($)	$2,000	$4,000	$8,000	$8,000
2016 ($)	0	$2,000	$4,000	$4,000
TOTAL	$44,000	$44,000	$39,000	$24,000

Who is Eligible?

According to the Meaningful Use criteria set by the government, the term “Eligible Professional” includes the following:

a doctor of medicine or osteopathy
a doctor of oral surgery or dental medicine
a doctor of podiatric medicine
a doctor of optometry
a chiropractor
a nurse practitioner (only eligible under the Medicaid plan)

These professionals are eligible for incentive payments for the Meaningful Use of certified EHR technology, assuming that they meet all other program requirements. EPs who furnish 90% of their services in hospital inpatient or emergency room settings are not eligible for reimbursement because they are considered hospital based.

EPs may not receive EHR incentive payments from both the Medicare and Medicaid programs in the same year. In the event an EP qualifies for EHR incentive payments from both the Medicare and Medicaid programs, the EP must elect to receive payments from only one program. After an EP qualifies for an EHR incentive payment under one program before 2015, an EP may switch between the Medicare and Medicaid programs one time. Upon switching programs, the EP will be placed in the payment year the EP would have been in had the EP not switched programs. For example, if an EP decides to switch after attesting to Meaningful Use of certified EHR technology for a Medicare Fee-for-Service (FFS) incentive payment for the second payment year, then the EP would be in the third payment year for purposes of the Medicaid incentive payments.

Click here for the Eligible Provider Decision Tool to see if you are eligible for stimulus funds.

Stage 1 Certified for Meaningful Use

On 5/24/2012, the Drummond Group awarded ClinicTracker Connect version 7.0 ONC-ATCB certification as a complete ambulatory EHR under the 2011-2012 criteria, which have since been retired and replaced with the 2014 criteria. As this was the first Stage of the Meaningful Use program, there were many unknowns. Given the uncertainty, we had to first decide if we even wanted to participate in the program. As behavioral healthcare was specifically excluded from the original definition of an Eligible Provider, it made it a far more difficult decision. However, after a detailed analysis and much deliberation, we decided it was our responsibility to our loyal customers to start down this path to ensure they were able to use software that was keeping pace with regulations and offered the most recent technology. We also wanted them to access stimulus funding for the subset of their staff who were considered Eligible Providers.

The process was a long and difficult one. It required increasing our staff, analyzing hundreds of pages of documentation, developing thousands of lines of computer code, identifying and contracting with an Authorized Certification and Testing Body (ACTB), and preparing for an exacting certification process. Thanks to incredibly hard work, we achieved certification with relative ease. Soon after, our clients were able to begin participating in the Meaningful Use program and seeking stimulus funding.

CMS-Required Certification Information

This Complete EHR certification is 2011/2012 compliant and has been certified by Drummond Group Inc., an ONC-ATCB, authorized to conduct complete and modular EHR testing and certification in accordance with the applicable certification criteria adopted by the Secretary of Health and Human Services. This certification does not represent an endorsement by the U.S. Department of Health and Human Services or guarantee the receipt of incentive payments.

Vendor Name: JAG Products, LLC
Date Certified: 5/24/2012
Product Version: ClinicTracker Connect 7.0
Certification ID: 05242012-1571-8
Clinical Quality Measures Tested: NQF0013, NQF0024, NQF0028, NQF0038, NQF0041, NQF0059, NQF0061, NQF0064, NQF0421
Additional Software Used: DrFirst Rcopia for ePrescribing

The Path to Stimulus Funding

We present below some of the key elements of the government reimbursement program to incentivize use of an electronic health record. You can find a detailed version of this summary by clicking here:

1. Determine how many EPs you have on staff: The types of EPs that behavioral health organizations employ most commonly are psychiatrists and nurse practitioners. Under the Medicaid Incentive Program, each EP can receive a total of $63,750 over the course of six years, until 2021. See the Schedule of Incentive Payments for details on the payment schedule.

2. Confirm that at least 30% of your EPs’ encounters are from Medicaid: According to CMS rules, EPs are eligible for the Medicaid incentives if, over at least 90 days in the previous year, 30% of their encounters came from Medicaid. CMS rules state that encounters may be calculated in one of two ways: 1) the EP’s number of Medicaid patient encounters divided by the EP’s total number of patient encounters; or 2) the number of Medicaid enrollees on the panel assigned to that EP divided by the total number of patients assigned to the EP (as in the case of managed care or health homes).

3. Know that ClinicTracker Connect is a fully certified electronic health record (EHR): Your organization does not need to have your certified EHR technology fully implemented to register for the Incentive Program. However, you must adopt, implement, upgrade, or successfully demonstrate Meaningful Use of certified EHR technology in order to receive the Medicaid Incentive Payments.

4. Register your EPs at the CMS website and reassign the EP’s payments to your organization: EPs must register for the Incentive Program with CMS as well as related agencies within their respective states. During the registration, EPs will enter their National Provider Identification (NPI) Number and indicate to what taxpayer ID number they want their incentive dollars to be reassigned. Some states may also request this information during the state registration process. This reassignment process is the critical step in transferring the payments from your EPs directly to your organization.

a. Sharing incentives with staff: Organizations planning to take advantage of the incentive payments should be sure to have discussions with staff about the registration process. It is also important to begin thinking about how you will share the incentives with your EPs.

b. Executing employment agreements: If you have existing employment agreements with your staff, your arrangements for the sharing of EHR incentive payments should be addressed in these agreements as well. To promote a clear understanding of those incentives, The National Association of Community Health Centers has provided some sample language for employment agreements.

c. Limiting payments to one agency: EPs may not split their incentive payments among the facilities where they provide services. Incentives can only be paid to one Tax ID#.

d. Getting more information about the CMS registration process: CMS has published a Registration User Guide for Eligible Professionals that walks you through the process of registration, including instructions on how to reassign the EP’s payments to another facility and use the online registration tool.

5. Attest that your eligible professionals are meeting Meaningful Use criteria. To get your EHR incentive payment, your EPs must attest through your state’s Medicaid agency website that they have met all of the eligibility criteria, including having adopted, implemented, or upgraded the Meaningfully Used Certified EHR technology.

a. Meeting Stage 1 Meaningful Use criteria: For meeting Stage 1 Meaningful Use criteria, CMS has outlined a total of 25 Meaningful Use Objectives. Objectives include such practices as recording patient gender, race, preferred language, height, weight, smoking status, and blood pressure into EHRs. To qualify for an incentive payment, 20 of 25 identified objectives must be met: all 15 required core objectives and five from a list of ten menu set objectives. EPs are also required to report on six total clinical quality measures.

b. Timeframe for attesting to Stage 1, Stage 2, and Stage 3 criteria: During the first year, EPs must only demonstrate that they have adopted, implemented, or upgraded their technology for at least 90 days. EPs must meet the criteria for all 365 days in the subsequent year of payments. Beginning in 2014, organizations that have already received their payments for Stage 1 Meaningful Use must begin meeting the Stage 2 requirements. This requirement was recently changed by CMS to incentivize providers to adopt early on. Stage 3 is currently scheduled to be implemented in 2015. Future rulemaking from HHS will outline how Stages 2 and 3 will build on Stage 1 criteria.

c. Getting more information about meeting Meaningful Use criteria: ClinicTracker provides a Meaningful Use Dashboard to help you determine whether your EPs are meeting Meaningful Use Criteria.

6. Receive payments!

Stage 2 Certified for Meaningful Use

On 6/16/14 ClinicTracker achieved Stage 2 Meaningful Use Certification according to requirements set forth by the Secretary of the U.S. Department of Health and Human Services. As such, our program achieved the highly level currently established for EHRs.

ClinicTracker Connect MU Edition became one of the few dedicated Behavioral Healthcare EHR’s to be ONC-ACB certified. Because the Stage 2 criteria are far more rigorous than they were for Stage 1, the number of certified vendors has dropped significantly. Companies without our level of technical expertise have found it very difficult to achieve certification. The Drummond Group’s Electronic Health Records Office of the National Coordinator Authorized Certification Body (ONC-ACB) program evaluated ClinicTracker and certified it as meeting the criteria.

With ClinicTracker Connect MU Edition, you can apply for Meaningful Use funds and receive up to $63,750 in reimbursement per Eligible Provider. That’s too much income to ignore. And we can even point you to resources that will help you navigate the process of attesting for those funds.

In addition to Meaningful Use Stage 2, ClinicTracker Connect is fully HIPAA-compliant and can handle DSM-5 and ICD10 coding standards.

Now that it meets all Federal standards and guidelines, ClinicTracker becomes even more powerful in its ability to maximize your clinic’s income and service quality. Some of the many new features include:

Support for HIPAA requirements regarding Direct Secure Messaging
A Patient Portal that allows a client to view medical data, access upcoming scheduled appointments, see account balance, pay online, and more
The ability for a patient to securely transmit their medical record (C-CDA) to an outside provider
Secure Messaging between provider and patient
A Meaningful Use Dashboard that tracks compliance with attestation requirements
Secure messaging of Transition of Care records (via Direct) for incoming and outgoing referrals
NIST Time Synchronization to ensure your audit logs are always properly recorded and secure
Compliance with regulations requiring designated diagnostic and billing codes
Partnership with DrFirst’s Attest Easy program which helps to navigate the attestation process

The Meaningful Use Dashboard tracks an agency’s status in regard to Meaningful Use requirements.

Frequently Asked Questions

Question: What is the difference between a Complete EHR and a Modular EHR?
Answer: The governmental agency that oversees the Meaningful Use program (CMS) relaxed the requirement in Stage 2 that every EHR had to meet every possible criterion, even if it had no relevance to the software’s users. ClinicTracker certified on all criteria required for a Complete EHR except for one related to transmitting data to immunization registries. Since ClinicTracker is focused on behavioral healthcare, not general medicine, we opted to forgo certifying this criterion. As long as the providers in your agency do not administer immunizations, you can attest with ClinicTracker Connect.

Question: Does the delay in implementation of Stage 2 I heard about mean I don’t need to upgrade to certified software?
Answer: No, you will still have to upgrade. However, there is a proposal under consideration that CMS will grant some extra time to providers who are experiencing difficulties fully implementing the Stage 2 edition. The details of that plan have not been finalized and, regardless, you will have to have the 2014 version no later than 2015. Therefore, if you’re going to adopt new software with the intent of attesting for Stage 2, you might as well be ready now. We have seen similar delays with other initiatives such as ICD-10, and continue to ensure that ClinicTracker is ready for you to make the transition well ahead of the government timelines.

Question: Where can I get more information about the Meaningful Use Program?
Answer: Here are some resources to get you started:

Now that ClinicTracker is certified for Stage 2 of the ONC-ACB Meaningful Use program, it will let you take advantage of substantial funding opportunities.

CMS-Required Certification Information

This EHR Module is 2014 Edition compliant and has been certified by an ONC-ACB in accordance with the applicable certification criteria adopted by the Secretary of the U.S. Department of Health and Human Services. This certification does not represent an endorsement by the U.S. Department of Health and Human Services or guarantee the receipt of incentive payments.

Vendor Name: JAG Products, LLC
Date Certified: 5/16/2014
Product Version: ClinicTracker Connect 8.0
Certification ID Number: 05162014-2558-8
Modules Tested: 170.314(a)(1-15); 170.314(b)(1-5, 7); 170.314(c)(1-3); 170.314(d)(1-9); 170.314(e)(1-3); 170.314(f)(1, 3); 170.314(g)(2-4) CMS138v2; CMS155v2; CMS156v2; CMS163v2; CMS165v2; CMS177v2
Clinical Quality Measures Tested: CMS068v3; CMS117v2; CMS122v2; CMS138v2; CMS155v2; CMS156v2; CMS163v2; CMS165v2; CMS177v2
Additional Software Used: EMR Direct phiMail, DrFirst Rcopia

Click here for the required “Costs and Limitations” disclosure.

What’s Next?

Stage 3, of course! One of the biggest challenges with the Meaningful Use program is a constantly changing landscape and set of rules. Given the many delays and rule changes that have unfolded with Stage 2, it is likely that Stage 3 will roll out with similar challenges. We are monitoring the changes closely.

Greater Stimulus Funding for Behavioral Healthcare

The Behavioral Health Information Technology Act of 2012 (H.R. 6043) was introduced with bi-partisan support and with the goal of amending who exactly qualified as an “eligible professional” in the Meaningful Use program. It, like its predecessor, (S. 539), aimed to extend the reach of the healthcare initiative to behavioral and mental health professionals, substance abuse professionals, clinical psychologists, licensed social workers, psychiatric hospitals, community mental health centers, residential mental health treatment facilities, outpatient mental health treatment facilities, and substance abuse facilities. This extension, according to AHIMA, also intended to extend eligibility for assistance from the health IT regional extension centers to specified behavioral health providers.

As things stand now, behavioral health providers looking to qualify for Meaningful Use must work through currently covered physicians and nurse practitioners with whom they are affiliated.

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Find out how Meaningful Use can benefit your facility. Contact us today and we’ll explain how ClinicTracker works, and how you can take full advantage of the incentives available.

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