Trisha Harkness, CISSP. Midwest HCCN Collaborative December 14, Learning Objectives

Transcription

1 Preparing for MU Stage 3 Trisha Harkness, CISSP Midwest HCCN Collaborative December 14, 2017 Learning Objectives Understand the Relationship Between Medicaid MU and MIPS Realize the Role of Certified EHR Technology Recognize the Timeline for Participation in MU Stage 3 Comprehend the Objectives and Measures for MU Stage 3 2 1

2 Acronyms ACI: Advancing Care Information API: Application Programming Interface C-CDA: Consolidated Clinical Document Architecture CCDS: Common Clinical Data Set CDS: Clinical Decision Support CEHRT: Certified EHR Technology CPOE: Computerized Provider Order Entry EC: Eligible Clinician (MIPS) EHR: Electronic Health Record EP: Eligible Professionals (MU 3 Acronyms ephi: Electronic Protected Health Information MIPS: Merit-based Incentive Payment System MU: Meaningful Use ONC: Office of the National Coordinator PHI: Protected Health Information UDI: Unique Device Identifier VDT: View, Download and Transmit 4 2

3 Medicaid EHR Incentive Program (a/k/a MU) is available until 2021 for EPs who submitted a Medicaid attestation in 2016 or prior EPs include MDs/DOs, Dentists, Nurse Practitioners, Certified Nurse Midwives and Physician Assistants (if a PA-led clinic) Participation is all or nothing MU, MIPS or APMs 5 MIPS started in 2017 MU, MIPS or APMs Participation in an Advanced APM is an alternative to MIPS ECs include Physicians, Physician Assistants, Nurse Practitioners, Clinical Nurse Specialists and Certified Registered Nurse Anesthetists Categories include: Quality (Previously Physician Quality Reporting System) Improvement Activities (New) Advancing Care Information (Previously MU) Core measures are required Bonus measures are also available Cost (Previously Value-Based Modifier) 6 3

4 Certified EHR Technology 2014 CEHRT is associated with MU Stage 2 requirements 2015 CERHT is associated with MU Stage 3 requirements In 2018, MU EPs and MIPS ECs can use 2014 CHERT, 2015 CEHRT or a combination of both 7 Timeline for Participation 2017: Medicaid Meaningful Use Modified Stage 2 (and/or MIPS Transition Year) 90 day MU and CQM reporting period 2018: Medicaid Meaningful Use Modified Stage 2 or Stage 3 (and/or MIPS Transition Year) 90 day MU reporting period Full calendar year CQM reporting period 2019: Medicaid Meaningful Use Stage 3 (and/or MIPS) Full calendar year MU and CQM reporting period 8 4

5 Objective 1: Protect Patient Health Information Objective: Protect ephi created or maintained by the CEHRT through the implementation of appropriate technical, administrative and physical safeguards Measure: Conduct or review a security risk analysis in accordance with the HIPAA Security Rule Include addressing the security (including encryption) of data created or maintained by CEHRT Implement security updates as necessary Correct identified security deficiencies as part of the risk management process MIPS Required measure 9 Objective 2: Electronic Prescribing Objective: Generate and transmit permissible prescriptions electronically Measure: More than 60% of all permissible prescriptions written by the EP are: Queried for a drug formulary and Transmitted electronically using CEHRT MIPS Required measure 10 5

6 Objective 3: Clinical Decision Support Objective: Implement CDS interventions focused on improving performance on high-priority health conditions Measures: EP must satisfy both measures Implement five CDS interventions related to 4 or more relevant CQMs at a relevant point in patient care EP has enabled and implemented the functionality for drugdrug/drug-allergy interaction checks Not submitted for MIPS 11 Objective 4: Computerized Provider Order Entry Objective: Use CPOE for medication, laboratory and diagnostic imaging orders directly ordered by a provider Measures: EP, through a combination of meeting the thresholds and exclusions (or both), must satisfy all 3 measures >60% of medication orders are recorded using CPOE >60% of laboratory orders are recorded using CPOE >60% of radiology orders are recorded using CPOE Not submitted for MIPS 12 6

7 Objective 5: Patient Electronic Access to Health Information Objective: EP provides patients with timely electronic access to their health information and patient specific education Measures: EPs must satisfy both measures >80% of unique patients are provided with timely access to view online, download and transmit health information and provider ensures patient s health information is available to access using the patient s application of choice EP must use clinically relevant information from CEHRT to identify patient-specific educational resources and provide electronic access to those materials to >35% of unique patients 13 Objective 5: Patient Electronic Access to Health Information Patient access to their electronic health record is a MIPS Required measure Other measures are bonus points 14 7

8 Objective 6: Coordination of Care Objective: Use CEHRT to engage with patients about the patient s care Measures: Provider must attest to all 3 measures and must meet the threshold for at least 2 measures >5% of unique patients engage in the electronic health record may accessible by the EP by: Viewing, downloading or transmitting their information to a third party, Accessing their health information via an API, or A combination of VDT and API 15 Objective 6: Coordination of Care Measures (cont.): >25% of unique patients are sent a secure message using CEHRT or a response to a patient s message >5% of unique patients have patient generated health data or data from a nonclinical setting incorporated in the CEHRT MIPS Bonus measures 16 8

9 Objective 7: Health Information Exchange Objective: EP provides a summary of care record when transitioning or referring a patient to another setting of care, receives or retrieves a summary of care record upon the receipt of a transition, referral or first encounter with a new patient, and incorporates summary of care information from other providers into their EHR Measures: Provider must attest to all 3 measures and must meet the threshold for at least 2 measures >50% of outgoing transitions of care or referrals include a summary of care record generated by the certified EHR and are electronically exchanged 17 Objective 7: Health Information Exchange Measures (cont.): EP incorporates a summary of care into CEHRT for >40% of incoming transitions of care Clinical reconciliation is performed for >80% of incoming transitions of care, referrals or patients never before encountered Generating outgoing electronic transitions and referrals and incorporating incoming referrals or transition of care or new patients are MIPS Required measures 18 9

10 Objective 8: Public Health and Clinical Data Registry Reporting Objective: EP is in active engagement with a public health agency or clinical data registry to submit electronic public health data in a meaningful way using certified EHR technology Measures: EPs must be actively engaged with at least 2 registries Immunization Registry Syndromic Surveillance Reporting (Urgent Care only) Electronic Case Reporting Public Health Registry Reporting Clinical Data Registry Reporting 19 Objective 8: Public Health and Clinical Data Registry Reporting Bonus points are available in MIPS Highlight: Michigan Dental Registry 20 10

11 Clinical Quality Measures CQM reporting periods Returning providers: Full year Provider s first MU attestation: 90 days Available CQMs reduced from 64 to 53 To align with MIPS, removed 11 measures that had not been updated and were no longer clinically relevant Report on 6 CQMs No longer required to cross 3 domains 21 Documentation Is Crucial! Hard copies of MU reports Hard copies of CQM reports Logs, screenshots, etc. of at least 5 enabled clinical decision support rules Logs, screenshots, etc. of enabled drug-drug/drug-allergy interactions Supporting documentation for patient encounter volume ONC certification and update log, screenshot, etc. of EHR used to meet MU objectives 22 11

12 Key Takeaways CMS is allowing flexibility in the Medicaid EHR Incentive Program in CEHRT combined with new measures or measures with increased thresholds will likely require changes in workflows. Engaging staff from all affect departments is very important. Understanding the functionality of your EHR and how data is gathered for MU reporting is crucial! Maintain supporting documentation for everything submitted for at least 6 years. 23 Any Questions Health Center Connections is a health center controlled network organized and supported by KAMU. This project is supported by the Health Resources and Services Administration (HRSA) of the U.S. Department of Health and Human Services (HHS) under grant number HRSA , Health Center Controlled Networks for $625,000 from 8/1/16 through 7/31/17 with no financing from nongovernmental sources. This information or content and conclusions are those of the author and should not be construed as the official position or policy of, nor should any endorsements be inferred by HRSA, HHS or the U.S. Government

13 Resources Electronic Health Record Incentive Program-Stage 3 and Modified Stage 2 Final Rule Federal Register Vol. 80, No. 200 Hospital Inpatient Prospective Payment Systems Final Rule Federal Register Vol. 82, No. 155 Eligible Professional Medicaid EHR Incentive Program Stage 3 Objectives and Measures: Table of Contents HHS Guidance on Risk Analysis CMS Quality Payment Program Quality Measures For MU ecqm measures, filter to Data Submission Method to EHR 25 Overwhelmed If you participate in the Kansas HCCN and need assistance with the privacy and security of your health information, meaningful use or MIPS, resources are available. tkennedy@kspca.org (785)

14 Trish Harkness, CISSP, CHPS Health IT and Systems Specialist Alone we can do so little; together we can do so much. Helen Keller