Tuesday, March 2, 2010

Q & A with Frances Dare

Question: What is Federal Financial Participation? "The Recovery Act establishes 100 percent Federal Financial Participation (FFP) for States to provide incentive payments to eligible Medicaid providers to purchase, implement, and operate (including support services and training for staff) certified EHR technology. It also establishes 90 percent FFP for State administrative expenses related to carrying out this provision."
Answer: 100% FFP means that the federal government will pay the States 100% of the costs associated with providing incentive payments to eligible Medicaid providers to purchase, implement, and operate certified EHR technology. The 90% FFP means that the federal government will pay the state’s 90% of the costs associated with EHR administrative expenses and the states will pay the other 10% of costs associated with EHR administrative expenses. Administrative expenses are those expenses related to administering the incentive payments to providers, auditing and monitoring of payments, and participating in statewide efforts to promote interoperability and meaningful use of EHR technology.

Question: Who are eligible professionals (EPs) required to report "meaningful use" to?
Answer: EPs participating in the Medicaid EHR incentive program will report meaningful use to the states. However, in order for EPs to receive incentive payments in the first year, EPs are only required to attest to adopting, implementing or upgrading certified EHR technology. It is not until year two and subsequent years that EPs will be required to prove “meaningful use” in order to receive Medicaid incentive payments.
EPs participating in the Medicare EHR incentive program will report meaningful use to CMS. The Medicare EHR program requires EPs to prove meaningful use in year 1.

Question: Do the standards and qualifications defined by ONC's Interim Final Rule (IFR) need to be obeyed by practitioners or is the IFR's only focus the certification of EHR systems?
Answer: IFR’s focus is solely on certification for EHR systems; however, practitioners must be using a certified EHR system in order to receive the incentive payment.

Question: Regarding EPs that have already implemented an EHR before EHR systems have been deemed “certified”- Will the EHR vendors automatically upgrade their customer’s system to include everything they need in order to prove meaningful use once meaningful use standards and EHR certification standards have been determined? Or will the customers have to contact the vendor in order to receive the upgraded needed to meet certification and meaningful use requirements?
Answer: It depends. Some vendors will automatically upgrade their customer’s system and some vendors will not. It may depend on the contract the medical practice/ hospital signed with the vendor. Also, costs associated with this upgrade will vary by vendor and by contract. All medical practices/hospitals should speak with their potential vendors and find out the answer to this question before purchasing an EHR system.

Question: How does an EP prove that they have met the standards for the incentive? For example, how would they prove that at least 75% of all written prescriptions have been transmitted electronically using a certified EHR system? Does each EHR system automatically generate a report? Or does this have to be done manually? If EHR automatically generates a report, will the EHR system transmit this information to whomever it needs to go to (whether it be the state, CMS, or a registry) or will this have to be done in another program?
Answer: In 2011 and 2012 EPs will have to provide the numerator and denominator of how they reached the 75%. For all objectives that are measured by percentages, the EP will need to provide the numerator and denominator used to reach the percentage. Some objectives are measured by a yes or no and therefore no calculations are required.
As of now, reports will have to be generated manually.
We do not know whether the information will eventually be transmitted through the EHR system or through an additional program.

Question: If a pediatrician has a patient volume threshold of 30% or greater are they eligible to receive the maximum Medicaid incentive amount of $63,750?
Answer: Yes
However, if the pediatrician has a patient volume threshold of 20-29% they will be eligible for a reduced incentive amount totaling $42,500.

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