The Journey to Meaningful Use: Where we were, where we are, and where we may be going

Transcription

1 The Journey to Meaningful Use: Where we were, where we are, and where we may be going June 27, 2013 Matthew Stanford, WHA Louis Wenzlow, RWHC 1 Where have we been? When HIT Adop on Meaningful Use Adoption 1

2 Wisconsin hospitals have a very high EHR adoption rate The Health Information and Management Systems Society (HIMSS) tracks the sophistication of EHR technologies adopted by hospitals. HIMSS ranks hospital EHR sophistication on a scale of 1 to 7. As of the 3rd quarter of 2012, Wisconsin had the 12 th highest average score in the nation on its EHR sophistication scale. Ranks: Wisconsin 12 Illinois 11 Indiana 22 Iowa 10 Michigan - 13 Minnesota 9 Missouri 14 North Dakota 47 Ohio 28 South Dakota -30 * Sources: HIMSS EMR Adoption Model, Q WI hospitals are rapidly implementing new HIT technologies 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% Percentage of WI Hospitals That Have Fully Implemented or Partially Implemented HIT Technologies vs Master person index database Lab information system Pharmacy system Enterprise medication admin record Medication dispensing Radiology information system Computerized radiography Picture Archiving and Communication System Order Entry/Resulting Inpatient charting Bedside medication verification Computerized physician order entry Electronic health record portal Surgery mgmt system Interface engine * Source: WHA Information Center, LLC, Annual Survey of Hospitals,

3 WI hospitals are rapidly implementing new HIT technologies 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% Percentage of WI Hospitals That Have Fully Implemented HIT Technologies vs Master person index database Lab information system Pharmacy system Enterprise medication admin record Medication dispensing Radiology information system Computerized radiography Picture Archiving and Communication System Order Entry/Resulting Inpatient charting Bedside medication verification Computerized physician order entry Electronic health record portal Surgery mgmt system Interface engine * Source: WHA Information Center, LLC, Annual Survey of Hospitals, WI hospitals are rapidly implementing new HIT technologies 300% 250% Percentage Increase in Number of WI Hospitals That Have Fully Implemented HIT Technologies vs % 150% 100% 50% 0% Master person index database Lab information system Pharmacy system Enterprise medication admin record Medication dispensing Radiology information system 606% Computerized radiography Picture Archiving and Communication System Order Entry/Resulting Inpatient charting Bedside medication verification Computerized physician order entry Electronic health record portal Surgery mgmt system Interface engine * Source: WHA Information Center, LLC, Annual Survey of Hospitals,

4 Wisconsin hospitals have a very high EHR adoption rate 100 out of 124 community hospitals in Wisconsin have attested to CMS that they have adopted, implemented, or upgraded to federally certified EHR technology. As of May 2013, Wisconsin ranks 7 th in the nation in the rate of adoption of certified EHR technology by community hospitals % 90.0% 80.0% 70.0% 60.0% 50.0% Percent of Community Hospitals that have attested to CMS that they have adopted, implemented, or upgraded to ONC certified EHR technology. Wisconsin 40.0% 30.0% 20.0% 10.0% 0.0% DC HI ME KS SD ND ID RI UT MN NH NY NE CO SC MA PA MD NC NV AR CT VT GA MI MT TN NJ CA IL FL TX OR MO WV WY IN IA LA OK MS VA OH WA WI AK AL KY NM AZ DE * Sources: (1) Numerator -CMS: Medicare and Medicaid Incentive Provider Payments By State, Program Type and Provider Type January 2011 to May 2013 & (2) Denominator - AHA: State Hospital Data 2012 Where have we been and where are we now? The Changing Regulatory Framework for Meaningful Use 4

5 HITECH Act HITECH Act created the Medicare and Medicaid EHR Incentive Programs HITECH Act was a section of the 2009 Federal Stimulus Bill the American Reinvestment and Recovery Act (ARRA). Both CMS and the Office of the National Coordinator for Health Information Technology (ONC) promulgate regulations implementing the EHR Incentive Programs. Meaningful use and EHR certification rules Health care providers must be meaningful users of certified electronic health records in order to receive Medicare HIT incentive payments/not receive penalties. Creation of the EHR Program Framework 2 EHR Programs: Medicare Incentives/Penalties & Medicaid incentives Hospitals eligible for both; Physicians must choose one CAHs have different payment methodology for Medicare EHR Program but not Medicaid Medicare penalties begin in 2015*, no penalties for Medicaid program (more on that later) State runs the Medicaid EHR Program, but incentives are 100% Fed $ s. 5

6 Creation of the EHR Program Framework Two key differences between the Medicare and Medicaid EHR Programs Hospitals don t need to achieve meaningful use to receive the 1 st Medicaid incentive payment; only need to attest to the Adoption, Implementation, or Upgrade (AIU) to an ONC Certified EHR. A hospital must participate in the Medicare program in consecutive years. Participation in the Medicaid program may be in non-consecutive years. Creation of the EHR Program Framework PPS vs. CAH payment methodology for the Medicare Incentive PPS: Payment based on Medicare share of the hospital s discharges CAH: Payment based on Medicare share + 20% of the cost of the EHR technology. CAH can take up to 4 years of Medicare incentives But no incentives paid after

7 Incentive Payment Transition Factor for PPS Hospitals Year hospital first qualifies Year hospital meets MU and receives incentive payment % % 100% % 75% 100% % 50% 75% 75% % 50% 50% 50% % 25% 25% Only 90 days of compliance must be shown in first payment year. begins October Some Key Elements of Original Framework Have Changed Stage timelines Meaningful Use and Clinical Quality Measures now have two different timelines EHR Certification and Meaningful Use now have separate timelines Penalties moved up 7

8 Original MU Timeline in First Final Rule First Qualifying Year Stage criteria EHsand EPs must meet in each payment year: and Beyond 2011 Stage 1 Stage 1 Stage 2 Stage 2 TBD 2012 Stage 1 Stage 1 Stage 2 TBD 2013 Stage 1 Stage 1 TBD 2014 Stage 1 TBD 2015 TBD New Timeline in Current Final Rule First Qualifying Year Stage criteria EHsand EPs must meet in each payment year: Stage 1 Stage 1 Stage 1 Stage 2 Stage Stage 1 Stage 1 Stage 2 Stage Stage 1 Stage 1 Stage Stage 1 Stage Stage 1 8

9 New Timeline in Current Final Rule However, the timeline under the First Qualifying Stage criteria EHsand EPs must meet in each payment year: Year Current Final Rule isn t this simple Stage 1 Stage 1 Stage 1 Stage 2 Stage Stage 1 Stage 1 Stage 2 Stage Stage 1 Stage 1 Stage Stage 1 Stage Stage 1 Real New Timeline in Current Final Rule Progression if you start MU in 2012 MU Req EHR Certification standard (CEHRT) Quality Req 2012 Stage 1 v v * Stage 1 v v * Stage 2 v v * Stage 2 v v * Stage 3 v. 2014? v * Stage 3 v. 2014? v Progression if you start MU in 2013 MU Req EHR Certification standard (CEHRT) Quality Req 2013* Stage 1 v v * Stage 1 v v * Stage 2 v v * Stage 2 v. 2014? v. 2014? 2017* Stage 3 v. 2014?? v. 2014?? 2018* Stage 3 v. 2014?? v. 2014?? 18 9

10 Real New Timeline in Current Final Rule Progression if you start MU in 2014 MU Req EHR Certification standard (CEHRT) Quality Req 2014* Stage 1 v v * Stage 1 v v * Stage 2 v. 2014? v. 2014? 2017* Stage 2 v. 2014? v. 2014? 2018* Stage 3 v. 2014?? v. 2014?? 2019* Stage 3 v. 2014?? v. 2014?? 19 Real New Timeline in Current Final Rule Special case for In 2014, all hospitals, regardless of whether they are at Stage 1 or Stage 2 of MU, will only need to attest to 3 months (1 Quarter) of meeting the applicable MU, CEHRT, and Quality Measure standards. (Keep in mind for penalty discussion) 20 10

11 Real New Timeline in Current Final Rule Paced EHR meaningful use remains in theory But, paced EHR technology implementation has been abandoned. The current final rule de-links Certification requirements from the Meaningful Use Stages. Beginning in 2014, for a hospital to receive an incentive, the hospital must use the v certified technology regardless of what MU Stage the hospital is at. 21 Original Penalty Scheme Penalties begin in FY PPS Hospitals -Three-quarters of the applicable market basket update is reduced by: CAHs Allowable Medicare cost reimbursement percentage reduced to: 33.33% 66.66% 100% % % % 11

12 New Penalty Timeline Practically speaking, the penalty year has been accelerated for PPS hospitals. Penalties for PPS hospitals in 2015 will be incurred based on actions in 2013 or Penalties for CAHs in 2015 will be incurred based on actions in Year penalty will be paid Year a PPS hospital must attest to meeting MU,CEHRT, CQMto avoid the penalty Year a CAH hospital must attest to meeting MU,CEHRT, CQMto avoid the penalty 2013 n/a n/a 2014 n/a n/a or before July 1, 2014 if attesting for the first time or before July 1, 2015 if attesting for the first time or before July 1, 2016 if attesting for the first time New Penalty Timeline Paced EHR meaningful use remains in theory But, paced EHR technology implementation has been abandoned. Can t just focus on MU; also have to factor in the separate timelines for the EHR certification rules (CEHRT) and Quality Measures. Regardless of MU stage, if a PPS hospital does not implement the new v CEHRT and new v Quality Measures by July 2014 (or April 2014 if attesting to MU for the first time), your hospital will receive a penalty in either 2015 or Result -All participating PPS hospitals will need to upgrade their EHR in 2014 in order to avoid penalties 12

13 Quality Measures Timelines Paced EHR meaningful use remains in theory But, paced EHR technology implementation has been abandoned. The first final rule included quality measures as a meaningful use standard, and the quality measure requirement would vary with the Stage of meaningful use. The current final rule de-links the Quality Measures from the Meaningful Use Stages. Beginning in 2014, for a hospital to receive an incentive/avoid a penalty, the hospital must meet the v Quality Measures regardless of what MU Stage the hospital is at. 25 Where are we now? Stage 2 and New Stage 1 13

14 Current Final Rule Modifies Original Stage 1 Final Rule The Stage 2 MU Final Rule also made some changes to Stage 1 MU that take effect in 2014: Dropping HIE test requirement in 2013 Optional CPOE denominator change Combining public health reporting requirements Changes to vital signs measures. New patient portal requirement Quality measures no longer vary based on meaningful use stage

15 Overview of Stage 2 MU 22 hospital objectives for Stage 2; including 7 new objectives Must meet (or qualify for an exception to) 16 core objectives and 3 of 6 menu set objectives. 29 Overview of Stage 2 MU The 7 new objectives are: emar-tracking meds from order to administration in conjunction with an emar (core) Patient portal -Providing a patient portal and tying performance to patient use of the portal (core) Imaging- Making imaging results accessible through the EHR (core) Family history - Recording family history as structured data (menu) erx-electronically generating and transmitting discharge prescriptions (menu) Notes- Recording electronic notes in patient records (menu) Lab-Providing structured electronic lab results from reference labs to physician offices (menu) 30 15

16 Key Items in Stage 2 MU Patient Portal Hospital must ensure that at least 50% of patients have secure online access to information about a discharge within 36 hours of discharge Hospital must show that 5% of patients discharged have actually accessed the portal. 31 Key Items in Stage 2 MU Summary of Care Record Hospital must provide a summary of care record (defined by ONC) for more than 50%of transitions of care and referrals. Hospital must electronicallytransmit a summary of care record using certified EHR technology or via an exchange facilitated by or consistent with the Nationwide Health Information Network Exchange for more than 10% of transitions of care and referrals. Hospital must conduct at least one successful electronic exchange of a summary of care document with a recipient who has certified EHR technology from a different EHR developer

17 Key Items in Stage 2 MU Electronic Medication Administration Record (emar) More than 10% of medication orders created by authorized providers of the hospital s inpatient or emergency department are tracked using emar emar is defined as technology that automatically documents the administration of medication into certified EHR technology using electronic tracking sensors (RFID) or electronically readable tagging (barcoding). 33 CPOE Key Items in Stage 2 MU Measure: More than 60% of medication, 30% of laboratory, and 30% of radiology orders created by authorized providers of the eligible hospital s inpatient or emergency department are recorded using CPOE. Objective: Use CPOE for medication, laboratory and radiology orders entered directly by any licensed health care professional who can enter orders into the medical record per state, local and professional guidelines

18 Key Items in Stage 2 MU Rule Clinical Quality Measures CQMs are now de-linked from MU. Now v.2011 CQMs and v.2014 CQMs. All CQMs to be electronically reported by v.2014 CQMs: Must report 16 out of 29 CQMs; must cover 3 of 6 domains. There were 15 Stage 1 CQMs; all are included in v CQMs. Vendors are not required to be capable of generating all of the relevant CQMs. This will likely result in vendors, rather than hospitals, choosing which of the 16 CQMs that will be measured. 35 Key Items in Stage 2 MU Rule Clinical Quality Measures Some overlap with quality measure requirements in other programs: 22 overlap with the Medicare Inpatient Quality Reporting (IQR) Program. 5 overlap with the Hosptial Value-Based Purchasing (HVBP) Program 2 overlap with the Medicare Outpatient Quality Reporting (OQR) Program. 1 is used by the Joint Commission

19 Where are we going? Stage 3 and beyond 38 19

20 Timeline Stage 3 MU Development August 2012 Stage 2 MU Final Rule published. November Health Information Technology Policy Committee (HITPC) develops draft definition of Stage 3 MU requirements and requests comments. January 2013 Providers express significant concern to HITPC that it is premature to consider Stage 3 before evaluating the experiences of Stage 1 and Timeline Stage 3 MU Development March 2013 Acting CMS Administrator Marilyn Tavenner announces that rulemaking for Stage 3 will not take place in 2013 as previously anticipated. Instead, CMS intends to pause to assess the program and review input. We are going to spend 2013 on education and learning what is working in Stage 2 and what isn t working. 2014?? ONC and CMS will issue proposed rules for Stage 3 and a comment period will follow 2014?? ONC and CMS will issue final rules for Stage Currently first year that Stage 3 could apply

21 Stage 3 MU Development Reading the tea leaves what we might see in a proposed rule Focus on outcomes rather than process More measures dependent on patient use Focus on interoperability, assuming the infrastructure is in place More alignment with goals of ACA and existing quality initiatives? Migration toward measures tenuously related to EHR use (alternative to COPs) 41 21