Recent and Proposed Rule Changes for Meaningful Use

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1 Recent and Proposed Rule Changes for Meaningful Use Ohio Health Information Management Association Annual Meeting & Trade Show, Wednesday, March 25, 2015 Scott Mash, MSLIT, CPHIMS Cathy Costello, JD Overview Ohio and National Totals for 2014 Meaningful Use 2015 Penalties Priorities for 2015 Stage 3 Proposed Meaningful Use for 2017 Ohio s Progress to Meaningful Use As of January 31, 2015 (as of ) Medicaid Adoption and Use Success 5,797 Providers $362.7 Million Medicare Meaningful Use Success 12,041 Providers $884.0 Million Total Incentives to Ohio from CMS 17,838 Unique Providers $1.2 Billion 1

2 Physicians and Meaningful Use in 2014 as of February 1, 2015 Nationally, out of a potential of 433,950 providers who could have attested for 2014 Meaningful Use, only 209,369 or 48% actually attested Of the 125,262 EPs eligible for Stage 2 MU in 2014, only 56,367 or 45% had attested Replace text box with chapter logo Hospitals and Meaningful Use in ,379 hospitals actually attested Of the 2,389 hospitals eligiblefor Stage 2 in 2014, only 1,818 actually attested to Stage 2 or 76% This is as of March 1, 2015 Replace text box with chapter logo Ohio s Top 10 EHRs for MU in 2014 EHR System # EPs Attesting Epic 5,455 eclinical Works 885 Allscripts Enterprise 603 Athena 555 NextGen 516 Allscripts PRO 433 Medent 311 GE Centricity 244 InteGreat 228 Greenway 176 2

3 Physician Payment Adjustments 2015 Amount of Adjustment EPs Affected % of Total EPs $1 - $250 87,000 34% $250 - $1,000 55,000 21% $1,000 - $2,000 36,000 14% $2, ,000 31% Total 256, % 2015 Meaningful Use 2015 and 2016 Meaningful Use 2015 and 2016 Meaningful Use not addressed in proposed regulations released last Friday CMS has stated publicly that 2015 reporting will be cut back to 1 quarter (Medicare) or 90 days (Medicaid) 3

4 MU Reporting for 2015 Must have 2014 Edition CEHRT in place at beginning of 2015 reporting period. If beyond the first year of reporting, will be required to attest for a 90 day (Medicaid) or quarter (Medicare) period in 2015*: EHs: October 1, 2014 December 30, 2015 EPs: January 1, 2015 December 31, 2015 *As announced by CMS but not finalized by rule yet Things to Do Up Front for 2015 Stage 2 Enable 5 Clinical Decision Support (CDS) rules related to 4 clinical quality measures (CQMs)/3 domains; pick CQMs (9) Schedule your privacy and security review (P&S); must be completed prior to attestation; encrypt system Register for Stage 2 public health reporting with Ohio Department of Health (by 60 th day of reporting period): Contact CliniSync HIE for assistance with referrals for transitions of care, Direct Link to Stage 2 Worksheet CMS provides worksheet for Stage 2: Guidance/Legislation/EHRIncentivePrograms/Downloads/ EP_Attestation_Stage2Worksheet.pdf 4

5 CMS s Focus & Changes in Stage 2 Transitions of Care Patient Engagement Public Health Reporting Requires providers to share structured summary of care records electronically Requires providers to share information with patients electronically Requires providers to report information for public health reporting Clinical Quality Measures Report 9 CQMs of 64 CQMS across 3 of the 6 national quality strategy domains. Elderly patient presents with multiple, chronic conditions Physician and clinicians order tests or procedures Continuing communication with patient, long-term care or home health Data and patient health information comes directly to physician through CliniSync The medical neighborhood is connected, so provider shares with other treating clinicians Provider immediately shares results with patient and patient s family, offering a care plan Transition/Summary of Care Objective Objective: Measure: The EP/EH who transitions or refers patient to another setting/provider of care provides summary care record. EP/EH must satisfy all following to meet the objective: 1. Provides a summary of care record for >50% of transitions of care/referrals. 2. >10% of such transitions/referrals are electronically transmitted. 3. Conducts successful electronic exchanges with different EHR or NIST Randomizer. Exclusion: Any EP whotransfers/refers patient to another provider < 100 times during reporting periodis excluded from all 3 measures. 5

6 Patient Portal Objectives Objective: Measure: Exclusion: Providepatient ability to view, download, transmit health information. EP/EH must satisfy all following to meet the objective: 1. > 50% ofunique patients seen during reporting period have online access to information within: A. EH: 36 hours of discharge B. EP: 4 business days of info available to provider 2. > 5% of unique patients seen during reporting period actually view, download or transmit 3. EP Only: > 5% ofunique patients seen during reporting period send secure message to provider Located in county with > 50% of 3Mbps broadband available. Exclusions for Menu Measures Exclusions will no longer count as reporting a meaningful use objective from the menu set. Can exclude 1 public health measure if Stage 1 Must meet 5 menu measures in Stage 1 (or 4+1), 3 menu measures in Stage 2, or report on all of the menu objectives through a combination of exclusions and meeting measures. Stage 2 Menu Measures 3 menu objectives to be reported in Stage 2: o Patient family history recorded o Electronic notes o Imaging results link in medical record o 3 public health reporting measures 6

7 Looking Ahead to Stage 3 Stages of Meaningful Use Stage 1 Stage 2 Stage 3 Proposed last Friday; will be finalized Summer, 2015 Data Capture & Patient Engagement Capture health info as structured data Track key clinical conditions Report CQMs & public health information Patient and family engagement Advanced Clinical Processes & Data Sharing Utilization of health information exchange (HIE) Improved Patient Care through care coordination & patient engagement Electronic transmission of care summaries Improved Outcomes & Pubic Health Improve quality, safety, and efficiency Decision support for national high-priority conditions Access to comprehensive patient data Improving population health Meaningful Use Stage 2 to Stage 3 Stage 2: Core and Menu Measures CQMs attested to manually; chart abstractions Transition Period: 2017 Can attest to Stage 2 or Stage 3, depending on vendor upgrades and measure readiness Stage 3: 2018 and Beyond All attest to full year Stage 3 No core and menu CQMs are submitted electronically 7

8 Proposed Stage 3 Meaningful Use Hospitals Move from fiscal year reporting (October 1 September 30) to calendar year reporting (January 1 December 31) effective 2017 reporting period. Last quarter of 2016 for hospitals is a non-reporting quarter except for CQMs. Physicians/EPs Stay on same calendar year reporting cycle. As of 2017, new EPs will have to report for a full year in their 1 st year of reporting unless they are Medicaid EPs (90 days). All functionality will need to be electronic. How Meaningful Use Changes in Stage 3 Proposed rule for Stage 3 looks different than Stage 2: There will be no core and menu measures, just options for many of the 8 reporting areas ( flexible measures) All reporting will be one year (except for 1 st year Medicaid) CQMs will be reported electronically; no chart abstraction or paper based measures 23 How Meaningful Use Changes in Stage 3 Must have 2015 Edition EHR in place no later than beginning of 2018 reporting period. If EP/EH completed MU incentive program participation, then still required to report to avoid penalties. Updates to MU will be published every year in Physician Fee Schedule (PFS) rule published the last quarter of the year. Hospital measures may be updated as part of the IPPS rule. 24 8

9 Technical Changes for Stage Edition will include Unique Device Identifier (UDI) for implantable devices as part of the summary of care for tracking and notification purposes. The summary of care document can be customized by EP or EH to include information that is current and considered historically relevant to the patient s care. Behavioral health, psychological data and socio-economic data (e.g., employment status) will be protected by separate segmentation within the CCD-A (sequestered) with separate access points. 25 CMS s Focus Areas in Stage 3 Protect Patient Health Information More intensive review related to administrative and physical safeguards; must correct identified security deficiencies from security risk analysis Electronic Prescribing Clinical Decision Support Physicians may count controlled substance prescriptions as part of e-prescribing; Hospitals only count new or changed erx Remains at 5 CDS related to 4 CQMs Includes expanded definition of CDS to allow use of order sets, templates, etc. CMS s Focus Areas in Stage 3 (cont d) CPOE Patient Electronic Access to Health Information (VDT) Patient Electronic Access to Patient Information Expanded to include diagnostic imaging Includes individuals with like credentials to medical assistant: credentialed to and performing equivalent duties Access to info within 24 hours using portal Access within 24 hours using API (Application Program Interface) Patient education information must be provided electronically to 35% of patients 9

10 CMS s Focus Areas in Stage 3 (cont d) Coordination of Care Health Information Exchange Public HaHealth/Data Registry Reporting CQM Reporting Can include information that is generated by the patient or outside an EP/EH location Summary of care documents are customizable by the EP/EH Includes both public and private reporting; must include 3 reporting measures for EPs; 4 reporting measures for EHs Electronic reporting by 2018 No specified #; will update annually Proposed Stage 3 Measures for MU MEASURE Security Risk Assessment E-prescribing (erx) PERFORMANCE THRESHHOLD Technical, administrative, physical; encryption; updates and deficiencies addressed EP: >80% queried for formulary; transmitted electronically EH: >25% discharge meds for new or changed Rx queried for formulary; transmitted as erx Clinical Decision Support (CDS) EPs/EHs: 5 CDS related to 4 CQMs; implement drugdrug/drug-allergy; expanded CDS Proposed Stage 3 Measures for MU CPOE MEASURE PatientElectronic Access to Health Information (2 measures with options) PERFORMANCE THRESHHOLD EP/EH: >80% med orders >60% lab orders >60% diagnostic imaging EP/EH: 1) >80% of unique patients, either o Provided access to VDT within 24 hours, OR o Provided access to API to retrieve information within 24 hours AND 2) >35% of unique patients provided electronic access to patient education resources 10

11 Proposed Stage 3 Measures for MU MEASURE( Coordination of Care through Patient Engagement (2 out of 3 measures required) PERFORMANCE THRESHOLD EP/EH: Must meet 2 out of 3: 1) >25% actively engage with EHR by either: o >25% view, download or transmit (VDT) information (portal) OR o >25% use API to access health information 2) >35% secure message is either sent by EP to patient 3) >15% patient generated health data from non-clinical setting (can include support areas) incorporated into EHR Proposed Stage 3 Measures for MU MEASURE( Health Information Exchange (2 out of 3 measures required) PERFORMANCE THRESHOLD EP/EH: Must meet 2 out of 3: 1) >50% of transitions of care/referrals creates a summary of care record and transmits it electronically. 2) >40% of transitions of care/referrals where patient has never been seen, provider incorporates an electronic summary of care document into patient record from source outside of own EHR system. 3) >80% % of transitions of care/referrals where patient has never been seen, provider performs clinical information reconciliation including meds, medication allergy, current problem list Proposed Stage 3 Measures for MU MEASURE Public Health Reporting (public)/ Clinical Data Reporting (private) (EP: 3 measures required EH: 4 measures required) EP/EH must be actively engaged in reporting PERFORMANCE THRESHOLD EPmust choose 3: 1) Immunization registry 2) Syndromic surveillance 3) Case reporting (public) 4) Public health registry reporting (EP: can report to 3 max; EH: can report to 4 max) 5) Clinical data registry reporting (EP: can report 3 max; EH: can report 4 max) EH must choose 4: Any or the above registry reporting, as well as: 6) Electronic reportable labs 11

12 Comments on Proposed Stage 3 Regs Meaningful Use Stage 3 rules CMS-3310-P are at the proposed level. Results will not be finalized until Summer, If you would like to comment, send comments to: Via send comments electronically to Via regular mail: send written comments to: Centers for Medicare & Medicaid Services Department of Health and Human Services Attn: CMS-3310-P P.O. Box 8013 Baltimore, MD Comments must be received by 5:00 PM May 29, 2015 Watch for new federal grant coming out in April or May, 2015!!! Grant is called the Practice Transformation Network grant If Ohio is named as a grantee, we will receive approximately $30 Million to support over 6,000 practitioners in moving to new Medicare, Medicaid and private payer payment programs and quality reporting initiatives All support would be free of charge to the practices Check at in April 35 Meaningful Use support, education and guidance Support for both Stage 1 and Stage 2 Monthly face-to-face visits or conference calls with MU team to review MU reports and progress Meaningful Use Mock Audits and Audit Response Support Assistance with MU Registration and Attestation process 36 12

13 Questions? Cathy Costello Website: While visiting our website don t forget to sign up for our newsletter! Scott Mash smash@ohiponline.org