Meaningful Use. UERMMMC Medical Alumni Association Meeting July 17, David Nilasena, M.D., Chief Medical Officer CMS Region VI
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1 Meaningful Use UERMMMC Medical Alumni Association Meeting July 17, 2015 David Nilasena, M.D., Chief Medical Officer CMS Region VI
2 2 Topics Proposed Rule: Modifications to Meaningful Use in 2015 through 2017 Proposed Rule for Stage 3 of Meaningful Use Road to ICD-10 Resources
3 Proposed MU Stage Timeline
4 Proposed Rule: Modifications to Meaningful Use in 2015 through Issued by CMS on April 10, 2015, comment period closed June 9, 2015 Aligns Stage 1 and Stage 2 objectives and measures with long-term proposals for stage 3 (2018) Reduces complexity, eliminates some objectives/measures, simplifies reporting for 2015, 2016 and 2017 Focuses on advanced use of certified EHR technology to support health information exchange
5 Proposed Rule: Modifications to Meaningful Use in 2015 through Proposing to move all providers (EPs, EHs, and CAHs) to a reporting period based on the calendar year in 2015 Reporting periods for all providers in 2015 reduced; and reporting periods for new participants in 2015 and 2016 also addressed Providers no longer to attest to objectives that have been identified to have reduced utility because they are redundant, duplicative or have topped out
6 Proposed Rule: Modifications to Meaningful Use in 2015 through Objectives and Measures Which Are Redundant, Duplicative or Topped Out Objectives/Measures EPs EHs/CAHs Record Demographics Record Vital Signs Record Smoking Status Clinical Summaries Structured Lab Results Patient List Patient Reminders Summary of Care: Measure 1- Any Method; Measure 3- Test Electronic Notes Imaging Results Family Health History emar Advanced Directives Structure Labs to Ambulatory Providers
7 Proposed Rule: Modifications to Meaningful Use in 2015 through For all providers in 2015 only, reporting period is any continuous 90-day period in calendar year 2015 For EPs: January 1- December 31, 2015 For EHs/CAHs: October 1, December 31, 2015 Starting in 2016, EPs, EHs, and CAHs that have not successfully demonstrated MU previously and are first-time participants: any continuous 90-day period in calendar year 2016 All returning participants in 2016 report for the full calendar year in reporting requirements addressed in Stage 3 proposed rule
8 Proposed Rule: Modifications to Meaningful Use in 2015 through Proposing to require all providers to meet a single set of objectives/measures for 2015 reporting period Proposing accommodations within individual objectives for providers in different stages of MU Includes: Retaining different specifications between Stage 1 and Stage 2 Allowing special exclusions for certain objectives or measures for EPs previously scheduled for Stage 1 in 2015
9 Proposed Rule: Modifications to Meaningful Use in 2015 through Proposing changes to Patient Engagement Requirements for Patient Action to View, Download or Transmit (VDT)Health Information: Remove the 5 percent threshold for Measure 2 from the EP and EH/CAH Patient Electronic Access (VDT) objective; instead require at least 1 patient seen by EP or discharged from hospital during reporting period views, downloads or transmits health info to a third party 2. Secure Messaging Using CEHRT: Convert measure for Stage 2 EP secure messaging objective from the 5 percent threshold to a yes/no attestation to the statement: The capability for patients to send and receive a secure electronic message was enabled during the EHR reporting period.
10 Proposed Rule: Modifications to Meaningful Use in 2015 through Proposed Objectives for 2015, 2016, and 2017 Objectives/Measures EPs EHs/CAHs CPOE Electronic Prescribing Clinical Decision Support Patient Electronic Access (VDT) Protect Electronic Health Information Patient Specific Education Medication Reconciliation Summary of Care Secure Messaging Public Health
11 Proposed Rule: Modifications to Meaningful Use in 2015 through Proposed changes to attestation deadlines for EHs/CAHs due to alignment to calendar year reporting For the 2015 EHR reporting period, EH/CAH must attest by February 29, 2016 For the 2016 EHR reporting period, EH/CAH must attest by February 28, 2017 For the 2015 reporting period, providers would not be able to attest until January 1, 2016, regardless of the 90-day reporting period that is chosen by the provider
12 12 Proposed Rule for Stage 3 of Meaningful Use Proposed rule was published in the Federal Register on March 30, 2015 Comment period closed May 29, 2015 Stage 3 is expected to be the final stage Following a proposed optional year in 2017, beginning in 2018 all providers would report on the same definition of MU at the Stage 3 level regardless of prior participation All participants in the EHR Incentive Program will use a single stage of meaningful use in 2018
13 13 Proposed Rule for Stage 3 of Meaningful Use Encourages electronic submission of clinical quality measures (CQM) in 2017 Requires the electronic submission of clinical quality measures (CQM) in 2018 All providers in their first year of demonstrating meaningful use would report on a calendar year EHR reporting period beginning in calendar year 2017 Exception: Medicaid providers in their first year of demonstrating meaningful use
14 14 Proposed Rule for Stage 3 of Meaningful Use Proposing a set of 8 objectives with associated measures Proposing that clinical quality measures in Stage 1 and Stage 2 final rules that included paper-based workflows, chart abstraction, or other manual actions will be removed or transitioned to an electronic format utilizing EHR functionality for Stage 3 Optional electronic CQM data submission for 2017; required beginning in 2018 Proposing that alignment between the Medicare and Medicaid EHR Incentive Programs and other CMS quality reporting programs such as PQRS and Hospital IQR be addressed in future rulemaking
15 15 Proposed Rule for Stage 3 of Meaningful Use Objectives/Measures EPs EHs/CAHs Protect Patient Health Information 1 measure 1 measure Electronic Prescribing 1 measure 1 measure Clinical Decision Support 2 measures 2 measures CPOE 3 measures 3 measures Patient Electronic Access to Health Information 2 measures 2 measures Coordination of Care through Patient Engagement Health Information Exchange Proposed Objectives for Stage 3 3 measures (2 options for measure #1) Attest to 3 measures, meet thresholds for 2 of those measures Public Health and Clinical Data Registry Reporting Choose 3 of 5 measures and successfully attest 3 measures (2 options for measure #1) Attest to 3 measures, meet thresholds for 2 of those measures Choose 4 of 6 measures and successfully attest
16 16 Proposed Rule for Stage 3 of Meaningful Use Stage 3 ecqm measure sets and reporting requirements will be published annually in the IPPS rulemaking process for EHs; and in the PFS rulemaking process for EPs Attestation will be an ecqm reporting option for Medicare Meaningful Use in 2017, but EPs, EHs, and CAHs must ereport ecqms starting in 2018 unless they demonstrate circumstances that don t allow them to ereport CMS will publish ecqm reporting requirements for Meaningful Use in the Physician Fee Schedule rulemaking for 2017 and subsequent years Medicaid ecqm reporting requirements would continue to be determined by the states, subject to CMS approval
17 2015 Incentive Payments and 2017 Payment Adjustments 17 MD & DO DDM Oral Sur Pod. Opt. PQRS Value Modifier EHR Incentive Program Pay Adj (2017) -2.0% of MPFS 2-9 EPs & solo 10+ EPs PQRS- Reporting (2017) +2.0 (x), +1.0(x), or neutral Non-PQRS Reporting (2017) -2.0% of MPFS PQRS- Reporting (Up or Neutral Adj) (2017) +4.0 (x), +2.0(x), or neutral PQRS- Reporting (Down Adj) (2017) -2.0% or -4.0% of MPFS Non- PQRS Reporting (2017) -4.0% of MPFS Medicare Inc. (2015) $4,000- $12,000 (based on when EP 1 st demo MU) Medicaid Inc. (2015) $8,500 or $21,250 (based on when EP did A/I/U) $8,500 or $21,250 (based on when EP did A/I/U) N/A Medicare Pay Adj (2017) -3.0% of MPFS Total Medicare Payment Adjustment s at Risk for Non- Participatio n in PQRS and Meaningful Use in 2017 Physicians in groups of 2-9 EPs & Solo physicians : -7.0% Physicians in groups of 10+ EPs: -9.0% Chiro.
18 2015 Incentive Payments and 2017 Payment Adjustments Practitioners Physician Assistant Nurse Practitioner Clinical Nurse Specialist Certified Registered Nurse Anesthetist Certified Nurse Midwife Clinical Social Worker Clinical Psychologist Registered Dietician Nutrition Professional Audiologits Therapists Physical Therapist Occupational Therapist Qualified Speech-Language Therapist PQRS Value Modifier Pay Adj. (2017) Groups of 2+ EPs -2.0% of MPFS -2.0% of MPFS EPs included in the definition of group to determine group size for application of the value modifier in 2017 (2 or more EPs). In 2017, VM only applies to payments made to physicians under the MPFS; beginning in 2018, VM will also apply to non-physician EPs See above EHR Incentive Program Medicare Inc. N/A Medicaid Inc. (2015) $8,500 or $21,250 (based on when EP did A/I/U) N/A $8,500 or $21,250 (based on when EP did A/I/U) N/A Medicare Pay Adj. (2017) N/A Total Medicare Payment Adjustments at Risk for Non-Participation in PQRS and Meaningful Use in % of MPFS N/A N/A N/A -2.0% of MPFS 18
19 19 ICD-10: Now Is the Time To Get Ready 5 Steps to Transition to ICD Make a Plan 2. Train Your Staff 3. Update Your Processes 4. Talk to Your Vendors and Payers 5. Test Your Systems and Processes
20 Road to 10 CMS Website 20
21 21 10 Facts about ICD Transition date is October 1, You don t have to use 68,000 codes 3. You will use a similar process to look up ICD-10 codes that you use with ICD-9 4. Outpatient and office procedure codes aren t changing 5. All Medicare FFS providers can test with CMS before the transition
22 22 10 Facts about ICD If you cannot submit ICD-10 claims electronically, Medicare offers several options: Free billing software MAC provider Internet portals Paper claims, if waiver provisions are met
23 23 10 Facts about ICD Practices that do not prepare for ICD-10 will not be able to submit claims for services performed on or after October 1, Reimbursement for outpatient and physician office procedures will not be determined by ICD-10 codes 9. Costs could be substantially lower than projected earlier
24 24 Where to Call for Help QualityNet Help Desk: (TTY ) 7:00 a.m. 7:00 p.m. CST M-F or You will be asked to provide basic information such as name, practice, address, phone, and e- mail Provider Contact Center: Questions on status of 2013 PQRS/eRx Incentive Program incentive payment (during distribution timeframe) See Contact Center Directory at Medicare EHR Incentive Program Information Center: (TTY ) ACO Help Desk via the CMS Information Center: Option 2 or cmsaco@cms.hhs.gov Comprehensive Primary Care (CPC) Initiative Help Desk: or cpcisupport@telligen.org Physician Value Help Desk (for VM questions) Monday Friday: 8:00 am 8:00 pm EST Phone: , press option 3 Physician Compare Help Desk PhysicianCompare@westat.com
25 25 Online Resources 2015 MPFS Final Rule CMS PQRS Website Medicare and Medicaid EHR Incentive Programs Medicare Shared Savings Program CMS Value-based Payment Modifier (VM) Website Program/ValueBasedPaymentModifier.html Physician Compare MLN Connects Provider enews PQRS Listserv ICD-10: Road to 10
26 Contact Info 26 David Nilasena Centers for Medicare & Medicaid Services Dallas Regional Office Phone: (214) RO
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HIMSS applauds the Department of Health and Human Services for its diligence in writing this rule, particularly in light of the comments and recommendations made by our organization and other stakeholders.