Behavioral Health Meaningful Use Q&A
by Leigh-Ann Renz, 6.26.14
PIMSY behavioral health EHR recently hosted two Meaningful Use for mental health webinars with MU consultant (and PIMSY Advisory Board expert) Adam Lowell. Here is a list of the questions posed to us during the webinars, our answers, and additional information regarding the CMS Meaningful Use programs for mental & behavioral health care providers:
I thought for year one for Medicaid, the provider simply had to adopt an EHR - not report 90 days?
Stage one of MU is a two year process involving registering with CMS, setup, implementation and training of an electronic health record and 90 day attestation process.
So I have to choose between participating in either Medicare or Medicaid MU, correct?
Correct: you can switch between the programs if needed, but only once. If you qualify for both programs, please note that you can earn higher incentive funds – and have more time to participate – in the Medicaid program.
Can you participate in both Medicaid & Medicare programs if multiple sites are involved?
It is billed under the organization's NPI number. Therefore, you must choose a grant program.
My behavioral health organization is not opening until 10/1/14. We will have 2 psychiatrists employed by the agency. We accept Medicare and Medicaid. Can we still make use of MU?
Yes, as long as you have an MD, DO or NP (on staff or contracted).
If we choose Medicaid, which is our highest population, will we still be penalized by Medicare?
No – if you are eligible for the Medicare program and don’t participate in MU at all, your reimbursements will be subject to penalties. But if you are eligible for both programs and attest / report for Medicaid, that is considered MU participation, and you won’t be penalized.
If there are multiple providers and cumulatively the Medicaid total is over 30%, is that ok? Ie, doctor 1 sees 33% Medicaid, but doctor 2 sees 28% Medicaid patients.
Yes, the 30% is cumulative across the practice. However, with percentages that close, you’ll want to monitor them closely and make sure that the 90 days you’re reporting on qualifies. This monitoring and accuracy reporting is what Adam ensures as your MU consultant.
Is the 30% Medicaid requirement for the individual psychiatrist or for the group practice?
It is by provider. A group average is acceptable for determining which grant program to choose.
We have a psychiatrist & 2 NPs – can the 30% Medicaid incentive be an average across providers?
Yes, for determining which grant program. Providers supply individual numbers for attestation.
Who is responsible for reporting? Does the provider (MD, NP) do this or can it be done by someone in an administrative role?
We’ve never seen it done by a provider – because it’s processing and reporting of practice data, this is usually done by an administrative team.
Can we switch EHRs within the MU program?
There’s actually no limit limitation on changing EHRs (it’s just difficult to keep meeting the measures, unless you make the change in 2014 when you’re only required to report on a quarter.
But it’s more of a challenge if you need to meet MU for a full year in consecutive months. Contact us for more information on switching to PIMSY mental health EHR – we can walk you through the process of data migration, cost estimate, PIMSY training, etc.
What happens to the incentive money if your provider leaves after the first year?
The money the practice has received is theirs to keep. Pick up MU when a new provider joins the practice.
Do you have a list of certified EHR vendors?
Yes, CMS has provided this in the CHPL listing: click here.
Do you have the full list of additional BH measures that are up for comment for stage 2?
Yes, click here.
How can we determine if we have been compliant to meaningful use expectation and not missed our deadline?
Hire an MU consultant (like Adam) to evaluate and ensure compliance.
If a new provider starts when the agency is in year 3 of MU how much would you collect from Medicaid for them?
It depends on whether or not they have participated in MU prior to employment. If they have not participated previously, they should qualify for the full grant reimbursement of $63,750.
What if you switch EHRs and applied under the first one what happens?
Change the next attestation to the new EHR and submit. Not a big deal.
When we have a 90 day attestation, is it permissible to only have had say 120 days of the data for the year?
You need to report on the data recorded during 90 days, not historical data.
We contract with a psychiatrist but only for 3 hours per month. Would the psychiatrist be considered a contract worker?
Yes: it doesn’t matter how much a provider works for you: as long as they have not committed their incentive funds to another organization, they can qualify your practice for MU.
Must CQMs be reported electronically for MU? And we can only use CQMs that are certified by our EHR vendor?
Yes, CQMs must be reported electronically. And you can only report on the CQMs certified by your EHR vendor.
How do the PQRS measures come into play with MU CQMs?
They are the same: There is a large list of CQMs, and both MU and PQRS use the same list. The differentiating factor is the PQRS reporting method: if you report via a certified EHR, you can only report on the CQMs that the EHR used for MU certification. If you use the other reporting methods (claims-based, GPRO, registry, etc), you have a much wider pool of CQMs to choose from.
Is claims based cumbersome if you have a large volume?
That depends on how you process your invoicing: since claims-based is processed through billing, it is contingent on which method you use. For example, a large volume of reporting via 1500 forms would be more cumbersome than electronic billing via PIMSY (or other EHR with PQRS claims-based reporting assistance). PIMSY has built comprehensive templates for claims-based reporting that walk you through the process and make it seamless.
Explain group proxy versus individual threshold
MU reporting and reimbursement is by individual eligible provider, not by the organization.
• Click here for our MU Resource Center, which is full of information
See a video of the presentation here (you have to click the play button in the lower left corner):