How Do You Get Paid? And how do you pay for it?

1
How Do You Get Paid?And how do you pay for it?

• Rick Snyder, FHFMA
• Vice President, Finance and Information Services
• Oklahoma Hospital Association

2
Medicare and Medicaid Programs Electronic Health
Record (EHR) Incentive Program

• Notice of Proposed Rule Making, Jan. 13, 2010
• Comments accepted through March 15
• Final rule expected by summer
• Significant changes expected in Final Rule

3
Medicare Incentive - PPS
4
Medicare Days

• Worksheet S-3 Lines 1, 2, 6-9, 10, 14 cols 4
  and 6
• Line 2 Medicare Advantage (Part C) Days
• Acute subprovider days (Psych, Rehab units)
• NOT Skilled Nursing, Swing Bed, or nursery

5
Medicare Incentive PPScontd
6
Medicare Incentive PPScontd
7
Medicaid Incentive PPS
8
Medicaid Incentive PPScontd
9
Medicaid Incentive PPS(contd)
10
Medicare Incentive CAH
11
Medicare Incentive CAH(contd)
12
Medicare Incentive CAH(contd)
13
Medicare Incentive CAH(contd)

• Reasonable acquisition costs of depreciable
  assets
• computers and associated software and hardware
  necessary to administer certified EHR
  technology
• Does this include capitalized installation costs?
• CAHs must submit the necessary documentation (as
  specified by CMS or its contractors) on health
  IT acquisition costs
• No administrative of judicial review for CAHs of
  the
• Methodologies, specifications, fiscal reporting
  periods used, or identification of reasonable
  costs

14
Medicaid Incentives - CAH

• No Medicaid Incentives for Critical Access
  Hospitals in Proposed Rule
• ARRA Section 4201 acute-care hospital
• Proposed Rule CMS Certification Numbers xx0001
  xx0879
• AHA plans legislative fix if not in final rule

15
How Soon can we be paid?

• Medicare Incentives available as early as Oct
  2010 (theoretically)
• PPS Interim payment mentioned, but not described
• Interim payments based on days/discharges in cost
  report for year ended prior to payment FFY
• Final payment is based on days/discharges in cost
  report for year ended during payment FFY
• CAH Prompt interim payment mentioned, but not
  described
• After CMS or MAC reviews documentation and
  determines payment amount

16
Other requirements for Medicare payment

• EHR must be certified!
• Demonstration of Meaningful Use - 2011
• Attest, in a manner specified by CMS, that the
  hospital used certified EHR and specify the
  technology used.
• Attest the hospital or CAH satisfied each of
  the applicable objectives and associated
  measuresand provide the result for each
  applicable measure for all patients
  admittedduring the EHR reporting period for
  which a selected measure is applicable
• Attestation must be auditable
• 2012 and subsequent years
• Same, except clinical quality measures are
  reported directly to CMS.

17
Requirements for Medicaid payment

• Generally match Medicare requirements
• Attestations and data submitted to State
• FIRST PAYMENT YEAR required to have adopted,
  implemented, or upgraded certified EHR
  technology.
• Adoption means actual installation
• Meaningful Use is required in second subsequent
  years

18
Medicaid Meaningful Use

• Proposed Rule examples of States additions to
  Federal meaningful use requirements
• participation in a health information exchange
• link to immunization, lead screening, or newborn
  screening registries
• must be readily available to providers and not
  represent a financial burden to them
• OHCA planning activities

19
State Medicaid HIT Plan

• Meaningful Use to be identified in the State
  Medicaid HIT Plan (SMHP)
• OHCA to submit SMHP before June 30
• CMS has 60 days to review SMHP
• SMHP approval required before OHCA can get
  Medicaid Incentive funding
• Must coordinate with State Health Information
  Exchange Cooperative Agreement Plan (8.9 million)

20
Meaningful Use AHA approach

• Flexible, incremental not all or nothing
• Additional meaningful use objectives
• 12 suggested measures/objectives
• eMAR, bedside barcode med admin, nursing
  assessments, plans of care
• Evidence-based order sets etc
• 25 qualifies as M.U. initially increased in
  future years

21
(No Transcript)
22
(No Transcript)
23
(No Transcript)
24
H.R. 4851

• Extension for unemployment, COBRA, Medicare
  physician payment rates, etc.
• Clarified physician incentives in hospital
  outpatient clinics
• Bill limits outpatient exclusion to ER physicians
• Cloture invoked April 13

25
Paying for EHRs

• ARRA Section 3014 EHR Loan program
• Requires 15 match from State
• OHCA budget request 4.16 million
• 20.8 million with match, to repeat in 2012
• HHS could start Jan.1, 2010, but didnt
• Also available to tribes

26
Bank financing

• Programs designed for incentive payments
  example
• Lafayette Ambassador Bank's Health IT Financing
  Package can help
• 100 of 25,000 implementation cost per
  physician.
• Competitive fixed or floating rates available.
• 48-month term.
• Interest only for 12 months, then 36 equal
  monthly payments.
• Secured with business assets, such as inventory
  and accounts receivable.

27
Vendor financing

• Modern Healthcare, March 1, 2010

• Modern Healthcare, March 1, 2010

28
Free EHR?
29
Other financing possibilities

• Alliance with regional hospitals
• Philanthropy
• Community foundations
• Capital fund drive

30

• Rick Snyder
• VP, Finance Information Services
• Oklahoma Hospital Association
• [phone]
• rsnyder_at_okoha.com