CMS Modifications to Meaningful Use in Final Rule. Slide materials and recording will be available after the webinar

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1 CMS Modifications to Meaningful Use in Final Rule Denise Satterfield Practice Solutions Advisor December 2015 Welcome Slide materials and recording will be available after the webinar Submit questions in Question Area on GoTo Webinar Control Panel Polling questions are enabled In case of technical issues, check Chat Area All Attendees are in Listen Only Mode 1

2 Stage 1 Data capturing and sharing Stage 2 Advanced clinical processes Stage 3 Improved outcomes Goals of Updated Provisions 1 Align with Stage 3 proposed rule to achieve overall goals of programs 2 Synchronize reporting period objectives and measures to reduce burden 3 Continue to support advanced use of health IT to improve outcomes for patients 2

3 Modifications to Meaningful Use in 2015 through 2017 NPRM Final Rule for Medicare and Medicaid EHR Incentive Programs Streamlines program by removing redundant, duplicative and topped out measures Modifies patient action measures in Stage 2 objectives related to patient engagement Aligned reporting period with full calendar year Changes EHR reporting period in 2015 to 90-day period to accommodate modifications Changes to Participation Timeline Attest to modified version of Stage 2 with accommodations for Stage 1 providers Attest to modified version of Stage 2 Attest to either modified version of Stage 2 or full version of Stage Attest to full version of Stage 3 6 3

4 Alignment of Meaningful Use NPRMs The Stage 1 and 2 Modification NPRM reconciles measures to align criteria for 2015 to 2017 with Stage 3 to: Prepare providers to report Stage 3 criteria in 2018 (Single set of 8 objectives optional for 2017, mandatory for 2018 full calendar year of reporting) Reduce provider burden and create a single set of sustainable objectives that promote best practices for patients Alignment of Meaningful Use NPRMs (cont.) Enable providers to focus on objectives which support advanced use of health IT, such as: health information exchange consumer engagement public health reporting 4

5 Reporting Period: 2015 In 2015 only, the EHR reporting period for all providers will be any continuous 90-day period within calendar year Medicare participants no longer need to use the quarter but may choose any 90-day period in the calendar year. Reporting Periods: 2016 In 2016, first-time participants may use EHR reporting period of any continuous 90-day period between Jan. 1, 2016 and Dec. 31, 2016 All returning participants must use EHR reporting period of full calendar year (Jan. 1, 2015 through Dec. 31, 2016) 5

6 Reporting Period: 2017 In 2017, all providers, both new or existing, must use EHR reporting period of one full calendar year as defined in Stage 3 rule (except Medicaid EPs demonstrating MU for the first time and those who choose to implement Stage 3=90 days). EHR Certification No changes to individual certification requirements for objectives and measures of meaningful use for EHR reporting period in 2015 through 2017 Providers should continue to use 2014 Edition certification criteria for EHR reporting period in 2015 and subsequent years until transition to 2015 Edition certification criteria is required for EHR reporting period in 2018 Note: Providers may upgrade early to technology certified to the 2015 Edition for EHR reporting period prior to 2018 as outlined in Stage 3 proposed rule 6

7 Reporting in 2015 and only- providers scheduled to be Stage 1 in 2015 may use alternate exclusions and specifications In 2016, all EPs will report on 10 objectives including one consolidated public health measure All EHs will report on nine objectives including one consolidated public health measure Modifications to patient action and public health objectives Removal of Objectives Objectives and measures that are deemed redundant, duplicative, or topped-out have been removed The Final Rule emphasizes that even though you will not be accountable to a specific threshold on removed measures, it doesn t mean you can skip the work. CMS reasoned that most healthcare providers have fully integrated these basic chart keeping tasks into their workflows, so there is no need to monitor ongoing specific performance. 7

8 Objectives and Measures Removed Problem List (previously only Stage 1) Medication Allergy List (previously only Stage 1) Medication List (previously only Stage 1) Demographics Vital Signs Smoking Status Clinical Summaries Structured Lab Results Patient List Patient Reminders Summary of Care (Part 1 and Part 3) Electronic Notes Imaging Results Family Health History 15 Retained Objectives and Measures Modified Stage 2 CPOE E-prescribing Clinical Decision Support Patient Access keeping Part 1 (portal sign up 50 percent). Part 2 is modified to drop VDT threshold from 5 percent to at least 1 patient. Protect Electronic Health Information Patient Specific Education Medication Reconciliation (inbound referrals) 16 8

9 Retained Objectives and Measures Modified Stage 2 (cont.) Summary of Care-now called Health Information Exchange (outbound referrals, Part 2) electronic transmission can be Direct or HIE Secure Messaging changed to attest only (yes/no) to confirm functionality is fully enabled ; no minimum patient threshold. Public Health 17 Retained Objectives and Measures Because so many measures have been dropped from attestation, there is now no distinction between Core and Menu, all retained Menu Objectives will now be required. Now known as modified Stage

10 Retained Objectives and Measures (cont.) For 2015 only there is a special exception for EPs who would have been Stage 1 this year. Where thresholds or objectives conflict for the same fundamental objective, these EPs only need to meet the lesser of the requirements between what was 2014 Stage 1 and 2014 Stage 2. All EPs are encouraged to strive for the modified Stage 2 objectives, but you can fall back to the Stage 1 alternatives without penalty. Only for 2015! Everyone moves to the modified Stage 2 in Retained Objectives and Measures (cont.) Stage Stage CPOE 30% medication 60% med/30% lab/30% radiology eprescribe 40% 50% plus check drug formulary Clinical Decision Support Patient Access Part 1-50%, Protected Electronic Health Info 1 rule 5 rules, including drug-drug/drugallergy checks Part 1-50%, Part 2- exclusion for Part 2 at least 1 patient No change No change 20 10

11 Retained Objectives and Measures (cont.) Patient Specific Education Medication Reconciliation Summary of Care = Health Info Exchange Secure Messaging Stage Stage Can claim exclusion Can claim exclusion Can claim exclusion Can claim exclusion 10% 50% Part 2 electronic 10% Yes/No confirm fully enabled Public Health Report on 1 Report on 2 21 Public Health Measure This is the trickiest change. All public health measures have been consolidated into 1 single objective. EPs must report active engagement (rather than ongoing submission ). Active engagement means the provider is in the process of moving towards sending production data through the following options: Option 1: Complete Registration to submit data (within 60 days of start of reporting period) Option 2: Testing and Validation Option 3: Production 11

12 Public Health Measure EPs must choose 2 of the following 5 public health measures: Immunization Registry (bidirectional) Syndromic Surveillance (in Tennessee, only open to EH with an ER) Case Reporting Public Health Registry Reporting (up to 3 of this type)-other than IIS Clinical Data Registry Reporting (up to 3 of this type)- includes ACOs and other non-governmental groups It is recommended to contact your vendor for more direction on your options for the public health measure Clinical Quality Measures No changes to CQM selection or reporting scheme from CQM requirements in Stage 2 rule (9 CQMs covering 3 public health domains) For EHR reporting period in 2015 (and for providers participating for first time in 2016), providers attest to any continuous 90-day period of CQM data during calendar year through Medicare EHR Incentive Program 12

13 Clinical Quality Measures (cont.) Registration and Attestation site Providers also have option to electronically report CQM data using established methods for electronic reporting For 2016 and subsequent years, providers beyond first year of meaningful use may attest to one full calendar year of CQM data or electronically report CQM data using established methods for electronic reporting outlined Attestation Attestations will not be accepted until Jan. 4, 2016 for a 2015 reporting period to allow the states and CMS to update their systems to reflect the modifications rule. Attestation portals for both TennCare (PIPP) and Medicare are shut down to new attestations as of the approval date of the final rule AIU attestation are still accepted through TennCare PIPP

14 NPRM Approval The Notice of Proposed Rule Making was approved on Oct. 6, 2015 with an official filing date of Oct. 16, CMS Help Desks EHR Information Center Help Desk Phone: TTY: Hours of operation: Monday-Friday 8:30 a.m. 4:30 p.m. in all time zones (except on Federal holidays) NPPES Help Desk Phone: 800) TTY:

15 CMS Help Desks PECOS Help Desk Phone: TTY: Identification & Access Management System (I&A) Help Desk PECOS External User Services (EUS) Help Desk Phone: TTY Contact Can assist with short term contracts and/or Help Desk Membership Denise Satterfield, Practice Solutions Advisor Middle TN Jennifer Ride, Director

16 Denise Satterfield, Practice Solutions Advisor Middle TN QHIT