Lately, healthcare news has been focused on 5010, ICD-10, and HIPAA; no doubt they are all important issues for everyone in the lab, and we need to pay attention.  However, even though we aren’t hearing about ARRA/HITECH and Meaningful Use, it is still very much with us, and many providers have benefited from the stimulus payments. As of December 2011, after a full year of payment eligibility, CMS has paid over $2.5 billion to eligible providers (EP) and hospitals (EH).

The first payments began in May 2011, and started slowly over the first part of the year. After the slow start, activity really ramped up from October through December due to providers being ready for Medicare attestation and Medicaid programs becoming increasingly operational.  The amount paid for 2011 may increase, as EPs have until February 29, 2012, to submit claims for consideration in meeting the 2011 claims threshold of $24,000 and obtaining the maximum payment of $18,000 for the year. One should note that of the EPs in the Medicare program, 99% of EPs have had a successful attestation period.

In terms of the number of EPs and EHs registered in the Medicare and Medicaid programs, year-to-date December 2011 found 124,089 providers registered in the Medicare EHR Incentive Program; 49,126 in the Medicaid program; and 2,834 hospitals registered in both.

Of those registered, Medicare paid $274.6 million to 15,255 EPs and $1.1 billion to 604 EHs. Medicaid paid $296 million to 14,089 EPs and $853.6 million to 1,043 hospitals, while 277 hospitals received both Medicare and Medicaid monies, twelve of which were critical access hospitals.

Under current regulations, eligible providers and eligible hospitals that attest to Stage 1 of the Medicare EHR incentive program this year would need to meet Stage 2 requirements in 2013. However, on November 30, 2011, HHS Secretary Kathleen Sebelius announced that all of Stage 2 will be moved to 2014. CMS has sent the final Stage 2 rule to the Office of Management and Budget for Review, which is one of the last steps before publication in the Federal Register. CMS expects this rule to be published in February of 2012.

Even though Stage 2 has been delayed, there is still a carrot hanging at the end of the stick for EPs and EHs attesting earlier than later. Those who have attested in 2011 can get three years of payment under Stage 1, and those attesting in 2012 can get two years of payments under Stage 1.  With this new information, we can only expect more EPs and EHs to attest during 2012.

Other key dates:

• July 1, 2012 – Last day for EHs to begin their 90-day reporting period to attest in 2012.
• Oct 1, 2012 – Last day for EPs to begin their 90-day reporting period to attest in 2012.
• 2015 – Payment adjustments will begin for those who have not met Meaningful Use.
• 2016 – The incentive program ends.

One final note regarding HITECH and Meaningful Use: while the focus is the EHR, the electronic exchange of lab results from the lab to the EHR is a piece of the ultimate goal, and it will most likely become a Meaningful Use criterion for attestation, so this impacts the lab. If you aren’t already integrated to your EHR, a plan for integration should be in the works.

As always, when new news appears, we’ll blog about it, pointing out the criteria that most impacts the lab. Stay tuned. More to come over the next few years.

Ginger Wooster, MBA, MT (ASCP)
Director of Regulatory Affairs & Applications Specialist
Orchard Software Corporation

Comments (0) Jan 27 2012

In our Orchard Software online forums, we have been getting a lot of questions regarding what the differences are among all of the acronyms affecting healthcare information technology. In this post, we deliver a break-down of all these acronyms in one location. Please comment below if you have any more questions.

American Recovery and Reinvestment Act (ARRA) is the stimulus act from 2009 that started it all. The stimulus act included measures for upgrading the health IT (HIT) infrastructure to increase interoperability (making it easier for entities to share health information). The section of ARRA covering health IT is known as HITECH.

HITECH has two main arms:

• ONC (Office of the National Coordinator) is charged with defining the standards that must be met for a system to become certified and overseeing the certified systems.
• CMS (Centers for Medicare and Medicaid Services) is charged with defining the criteria needed to meet Meaningful Use and overseeing the users of the certified systems. Meaningful Use is the incentive for providers and hospitals to implement electronic systems. Basically, if they meet the Meaningful Use requirements, they will receive payment from CMS. Meaningful Use is a graduated process, defined in three stages. Each stage will build upon the others and increase the ability to share health information. Currently, only Stage 1 has been defined and is what is driving Meaningful Use today.

HIEs are Health Information Exchanges among many providers, hospitals, insurance companies, etc. HIEs can be local, regional, or statewide. HITECH established grant monies for states to develop HIEs. Many HIEs are now forming and are focusing on how data will be shared among the members of the HIE, since the members most likely will have a variety of EMR systems and each state can format their own program under the current Stage 1 rule.

RECs are Regional Extension Centers. The ONC has funded RECs to offer technical assistance, guidance, and information on best practices to support and accelerate healthcare providers’ efforts to become Meaningful Users of EHRs. They are educational in nature, and not required for Meaningful Use.

So where does LOINC (Logical Observation Identifiers Names and Codes) fit in all this? One of the optional menu items to attain Stage 1 Meaningful Use is that an EMR must incorporate lab results as structured data. For Stage 1, ONC did not mandate a particular standard for how structured data should be incorporated. LOINC is one of the possibilities. We look to the final rule for Stage 2 to further define the standards. LOINC are result codes based on test methodology, so if your HIE contains six different labs that all have unique methods for a particular test, there will be six different LOINC. LOINC will be included in the HL7 result transmission from the LIS to the EMR.

Part of the confusion is that LOINC are also being developed for order choices. Thus far, LOINC order codes are not universally accepted. When CPOE (Computerized Provider Order Entry) becomes mandated for labs, we may hear more about them. Understand that while CPOE is a core item (required) for Stage 1, it is for medication orders only and not labs. We expect lab orders to be required in Stage 2; although, the proposed rule states the orders do not need to be transmitted.

The final rule for Stage 2 is expected to be published in July of 2012 and will go into effect on January 1, 2013. So if LOINC becomes the mandated standard, there is still some time. The proposed Stage 3 rule is expected by year end 2013, with the final version published mid-2014 to go into effect January 1, 2015.  Providers and hospitals have until 2015 to meet Meaningful Use. If not, CMS will reduce payments to those who have not.

Those are the only mandated deadlines mentioned in HITECH. However, as vendors, labs, and providers all work towards interoperability, they may want this data in advance to conduct the appropriate testing and validation. Meaningful Use will have a huge impact on your facility, but the lab actually has a limited role.

I hope this puts everything into perspective.  Orchard Software has convenient pages on our website to explain ARRA, HITECH, LOINC, and the rest of the HIT acronyms with helpful diagrams and related information. They can easily be found on the left side of our website. Again, if you have a question regarding this post, please leave a comment or visit www.orchardsoft.com. Remember to visit our blog frequently to receive the latest HIT information!

Ginger Wooster, MBA, MT (ASCP)
Director of Regulatory Affairs & Applications Specialist
Orchard Software Corporation

Comments (0) Nov 18 2011

October 2013 will be here before we know it. Remember, making the transition to ICD-10 is not optional. All “covered entities”—as defined by the Health Insurance Portability and Accountability Act of 1996 (HIPAA)—are required to adopt ICD-10 codes for use in all HIPAA transactions with dates of service on or after the October 1, 2013, compliance date. For HIPAA inpatient claims, ICD-10 diagnosis and procedure codes are required for all inpatient stays with discharge dates on or after October 1, 2013. For providers, ICD-10 diagnosis codes are required for dates of service on or after October 1, 2013.

To process ICD-10 claims or other transactions, providers, payers, and vendors must first implement the “Version 5010” electronic healthcare transaction standards mandated by HIPAA. The existing HIPAA “Version 4010/4010A1” transaction standards do not support the use of the ICD-10 codes.  Hopefully, your facility has already tested the new standards by now. If not, you are getting into crisis mode, since the 5010 standards go into effect in less than two months on January 1, 2012.

The Centers for Medicare & Medicaid Services (CMS) website contains a lot of information and helpful tools to assist you with your transition to ICD-10. I recommend you check out the recently posted CMS implementation handbooks. These handbooks contain all the information you need to prepare for and conduct your implementation of ICD-10. The step-by-step guides are specifically tailored for small and medium provider practices, large provider practices, and small hospitals. I noticed that they did not publish a guide for large hospital systems. My assumption regarding this is that CMS figures that the large hospitals have already taken appropriate measures to make this transition. To date, many integrated delivery systems are well into their project plan. If your facility has not already established a project plan for ICD-10 implementation, you will find the information in these guides helpful to get started.

The guides will help you assess your needs and then design a plan for all your business processes, suggest communication pipelines, break down the training into meaningful and helpful steps, and show you where you might expect and plan for hiccups in your reimbursements.

The appendix of each handbook references relevant templates, which are available for download from the CMS website in both Excel and PDF files. The templates are customizable and have been created to help entities clarify staff roles, set internal deadlines/responsibilities, and assess vendor readiness.

http://www.cms.gov/ICD10/Downloads/ICD10SmallandMediumPractices508.pdf

http://www.cms.gov/ICD10/Downloads/ICD10LargePractices508.pdf

http://www.cms.gov/ICD10/Downloads/ICD10SMallHospitals508.pdf

Speaking of vendor readiness, in anticipation of the October 1, 2013, transition from ICD-9 to ICD-10, Orchard Software is developing product versions that will support the functionality required for ICD-10 coding. The software releases will be available within the next six to nine months. Orchard is involved in the industry and is keeping up with the latest news to ensure that our software will meet the requirements of the regulations and needs of our clients as details emerge and are set regarding the final requirements for ICD-10.

Once the software updates are available for general release, each products’ release notes will contain information regarding how they accommodate the requirements, so clients may begin their testing and implementations well in advance of the transition deadline.

You should be thinking about ICD-10. A successful transition requires a plan, and it only takes one step to get started. It is better to start now and make your transition a leisurely stroll instead of procrastinating and having to start your marathon in September of 2013.

After writing this post, Orchard would like to know what steps your facility has taken to prepare for ICD-10. Please reply in our comments section.

Ginger Wooster, MBA, MT (ASCP)
Director of Regulatory Affairs & Applications Specialist
Orchard Software Corporation

Comments (0) Nov 09 2011