2015 2017 Modification NPRM EHR Incentive Program and Meaningful Use 2015 Meaningful Use DeeAnne McCallin, MU Program Director 09/09/2015 update
Disclaimer The information included in this presentation is for informational purposes only The CMS proposed rule reviewed in this deck may be viewed at https://s3.amazonaws.com/publicinspection.federalregister.gov/2015-08514.pdf A fact sheet about the NPRM is also available at http://www.cms.gov/newsroom/mediareleasedatabase/factsheets/2015-fact-sheets-items/2015-04-10.html
Show of hands Informal Survey How many scheduled for Stage 2 in 2015? How many scheduled for Stage 1 2015 (first or second year of Stage 1)? How many are scheduled for AIU 2015? NOTE: The last year to begin CA Medicaid EHR Incentive Program is 2016!
Stage 2 (& even S1) in 2015 Complete your upgrade to 2014 CEHRT are you fully implemented and updated? Coordinate with your EHR Vendor & Registries regarding your Public Health reporting Implement patient portal Review monthly Meaningful Use reports, assess for gaps, corrections needed in workflow, identify successes, etc.
The 2015 2017 Proposed Modifications Comments were due to CMS June 14, 2015
Abbreviated Summary of the Mod NPRM for 2015 NPRM = Notice of Proposed Rule Making Proposed 2015 changed to a 90-day period for all EPs Proposed modification of the patient action measures in Stage 2 objectives related to patient engagement (effects EPs scheduled for Stage 1 in 2015 as well) Streamlines the program by removing reporting requirements on measures which have become redundant, duplicative, or topped out
Timeline Known and Anticipated Friday April 10, 2015 NPRM Released Wed April 15, 2015 NPRM published in Federal Register 60 day comment period comments due June 14, 2015 CMS quiet period review of comments Sept. 3, 2015 CMS submitted to Office of Management and Budget (OMB) for review* Final Ruling could be 9/3/15 + 90 + 30 days No sooner than Jan. 2016 for Medicare attestations, CA SLR availability TBD * Combined S3 and 2015 CEHRT NPRMs
The Stages are merging together
The Proposed 2015 2017 Measures Measures Public Health CQMs 1. CPOE 2. erx 3. CDS 4. VDT* (elec axs) 5. SRA (protect) 6. Education 7. Med Recon 8. Sum of Care* 9. Secure Msg* If scheduled for Stage 1 in 2015 then must meet 1 of 5 Otherwise, must meet 2 of 5 CMS proposed that Iz Registry be bidirectional 2014 CQMs Report on 9 from 3 Domains * There are proposed changes to the measures These measures apply no matter whether your EP is Stage 1 or Stage 2 in 2015+!!!
NPRM TABLE 4: CURRENT STAGE STRUCTURE, RETAINED OBJECTIVES, AND PROPOSED STRUCTURE
NPRM TABLE 2: STAGE OF MEANINGFUL USE CRITERIA BY FIRST YEAR NPRM: *The Modifications to Stage 2 proposed in this rule include alternate exclusions and specifications for certain objectives and measures for providers that were scheduled to demonstrate Stage 1 of meaningful use in 2015.
Clear as mud, right?!?! Best Mud Run Ever! May 30, 2015 near Stockton, CA
The Removed Measures due to redundant, duplicative or 1. Drug Formularies* 2. Demographics* 3. Problem List* 4. Medication List* 5. Med Allergy List* 6. Vitals* 7. Smoking Status* 8. Clinical Summary topped out 9. Sum of Care (M1&M2) 10.Lab Results* 11.Patient List 12.Reminders 13.Electronic Notes 14.Imaging Results* 15.Family Health History * Incorporated into another active measure (see slide 27)
NPRM TABLE 3: OBJECTIVES AND MEASURES IDENTIFIED BY PROVIDER TYPE WHICH ARE REDUNDANT, DUPLICATIVE OR TOPPED OUT
NPRM TABLE 3: OBJECTIVES AND MEASURES IDENTIFIED BY PROVIDER TYPE WHICH ARE REDUNDANT, DUPLICATIVE OR TOPPED OUT (continued)
Confused? (You re not alone) In this proposed rule, we (CMS) are seeking to make changes to the requirements for Stage 1 and Stage 2 of meaningful use for 2015 through 2017 to align with the approach for Stage 3 of meaningful use in 2017 and subsequent years.
2011 2012 2013 2014 2015 2016 2017 An EP s Medi-Cal EHR Program Timeline one possible scenario (EP scheduled for 2015 Stage 2 Year 1) Program Year 1 n/a - skipped Program Year 2 Program Year 3 Program Year 4 Program Year 5 Program Year 6 AIU n/a - skipped MUS1Yr1 MUS1Yr2 FLEX* Modification MU** Modification MU Elective Stage 3 * Flexed to 2013 Stage 1 Definition ** 2015 scheduled for Stage 2
2015 Modification Scenario #1 (EP scheduled for Stage 2) Year 4 2015 Scheduled for Stage 2 Modification MU 90 Day reporting period Not eligible for Alternate Exclusions Cannot submit attestation until 2016 o CA SLR availability TBD probably April 2016 o 9 Core Measures o 2 Public Health Measures (out of 5) o 9 2014 CQMs from 3 Domains Year 5 2016 Modification MU, Full Year reporting period (January, 1 2016 December 31, 2016) Year 6 2017 Modification MU - Stage 3 attestation optional
2015 Modification Scenario #1 Details Measures for EPs Scheduled for 2015 Stage 2 1. CPOE Measure 1 Medication Orders > 60% Measure 2 Lab Orders > 30% Measure 3 Radiology > 30% 2. Electronic Prescribing Greater than 50% Incorporates drug formulary check 3. Clinical Decision Support Measure 1 Implement 5 CDS Measure 2 DrugDrug and Drug Allergy interaction checks
2015 Modification Scenario #1 Details Measures for EPs Scheduled for 2015 Stage 2 4. Patient Electronic Access VDT Measure 1 >= 50% online access made available Measure 2 now only at least 1 patient to meet this measure (not 5%!); must view, download or transmits his or her health information to a third party 5. Protect Electronic Health Information (SRA) 6. Patient Specific Education provided for > 10% 7. Medication Reconciliation performed for > 50% of transitions of care in which the patient is transitioned into the care of the EP
2015 Modification Scenario #1 Details Measures for EPs Scheduled for 2015 Stage 2 8. Summary of Care (has list of required elements) Former Measure 1 deleted/removed (50% provided) Former Measure 2 for > 10% of transitioned or referred patients (to another setting) a provider would be required to simply create the summary of care record using CEHRT and transmit the summary of care record electronically (does not require receipt of record) Former Measure 3 deleted/removed ( Test EHR ) 9. Secure Messaging now a Yes/No measure (Yes to pass) Capability for patients to send and receive a secure electronic message with the EP was fully enabled
2015 Modification Scenario #1 Details Measures for EPs Scheduled for 2015 Stage 2 Public Heath Requirement Must meet 2 of 5 Measure Option 1 Immunization Registry Reporting Measure Option 2 Syndromic Surveillance Reporting Measure Option 3 Case Reporting (page 93 of NPRM) Measure Option 4 Public Health Registry Reporting (like previous specialized registry, cancer counts, pg 95 of NPRM) Measure Option 5 Clinical Data Registry Reporting (page 97 of NPRM; reporting to other non-ph entities not LDH) Clinical Quality Measures 2014 CQMs 9 out of 64 (ideally with denominator > 0) Must be from 3 National Domains
2012 2013 2014 2015 2016 2017 2018 An EP s Medi-Cal EHR Program Timeline a 2 nd possible scenario (EP scheduled for 2015 Stage 1 Yr 2) Program Year 1 n/a - skipped Program Year 2 Program Year 3 Program Year 4 Program Year 5 Program Year 6 AIU n/a - skipped MUS1Yr1 FLEX Modification MU * Modification MU Modification MU Stage 3 * Alternate Exclusions available for EPs scheduled for Stage 1 in 2015 * 2015 scheduled for Stage 1
2015 Modification Scenario #2 Alternate Exclusion Options (EP scheduled for 2015 Stage 1) 1. CPOE Measure 1 Medication Orders > 30% (alternate measure) Measure 2 Lab Orders may exclude ( alternate excl.) Measure 3 Radiology may exclude ( alternate excl.) 2. Electronic Prescribing Greater than 40% 3. Clinical Decision Support Implement 1 CDS Alternate Measures and Alternate Exclusions applicable in 2015 only for EPs scheduled for Stage 1; this scenario only flags CPOE alternate information but Alts are applicable thru the measures 4. Patient Electronic Access VDT Measure 1 >= 50% online access made available Measure 2 (1 patient or former 5%) may exclude
2015 Modification Scenario #2 Alternate Exclusion Options (EP scheduled for 2015 Stage 1) 5. Protect Electronic Health Information (SRA) 6. Patient Specific Education may exclude 7. Medication Reconciliation may exclude 8. Summary of Care may exclude 9. Secure Messaging may exclude Public Heath Requirement Must meet 1 of 5 (see slide 15) Clinical Quality Measures 2014 CQMs 9 out of 64 (ideally with denominator > 0) Must be from 3 National Domains
An EP s Medi-Cal EHR Program Timeline a 3 rd possible scenario (EP scheduled for 2015 Stage 2 Yr 2) 2011 2012 2013 2014 2015 2016 Program Year 1 Program Year 2 Program Year 3 Program Year 4 Program Year 5 Program Year 6 AIU MUS1Yr1 MUS1Yr2 MUS2Yr1 (no Flex) Modification MU Modification MU
Stay with me, I know
Patient Electronic Access VDT Measure unless the information is not available in certified EHR technology (CEHRT), is restricted from disclosure due to any federal, state or local law regarding the privacy of a person s health information, including variations due to the age of the patient or the provider believes that substantial harm may arise from disclosing particular health information in this manner. See 5 Page Stage 2 VDT Measure Specification Sheet: http://www.cms.gov/regulations-and- Guidance/Legislation/EHRIncentivePrograms/downloads/Stage2_EPCore_7_PatientEle ctronicaccess.pdf
Transition of Care: Summary of Care Record The Mod NPRM simplifies measure 2 Proposed Measure2: The EP, eligible hospital or CAH that transitions or refers their patient to another setting of care or provider of care that -- (1) uses CEHRT to create a summary of care record; and (2) electronically transmits such summary to a receiving provider for more than 10 percent of transitions of care and referrals. The proposed updates to this measure reflect stakeholder input regarding operational challenges in meeting this measure, and seek to increase flexibility for providers while continuing to drive interoperability across care settings and encouraging further innovation.
Elements Required for VDT and Sum of Care Data Element Patient Electronic Access - VDT (To the patient!) Summary of Care (To another provider!) Patient name X X Referring or transitioning provider's name and office contact information (EP only) X X Current And Past Problem List X Past list at EP's discretion Procedures X X Encounter diagnosis not required X
Elements Required for VDT and Sum of Care Data Element Patient Electronic Access - VDT (To the patient!) Summary of Care (To another provider!) Immunizations not required X Laboratory test results X X Vital signs (height, weight, blood pressure, BMI) X (plus growth charts) X Smoking status X X Functional status, including activities of daily living, cognitive and disability status not required X
Elements Required for VDT and Sum of Care Data Element Patient Electronic Access - VDT (To the patient!) Summary of Care (To another provider!) Demographic information (preferred language, sex, race, ethnicity, date of birth) X X Care plan field, including goals and instructions X X Care team including the primary care provider of record and any addl known care team members beyond the referring or transitioning provider and the receiving provider X X
Elements Required for VDT and Sum of Care Data Element Patient Electronic Access - VDT (To the patient!) Summary of Care (To another provider!) Reason for referral not required X Current medication list X X Medication list history X not required Current medication allergy list X X Medication allergy list history X not required
Mod NPRM Public Health Measures is in active engagement with a public health agency... Measure Option 1 Immunization Registry Reporting: to submit immunization data and receive immunization forecasts and histories from the public health immunization Registry Measure Option 2 Syndromic Surveillance Reporting: to submit syndromic surveillance data from a non-urgent care ambulatory setting Measure Option 3 Case Reporting: to submit case reporting of reportable conditions Measure Option 4 Public Health Registry Reporting: to submit data to public health registries Measure Option 5 Clinical Data Registry Reporting: to submit data to a clinical data registry.
Payment Adjustments if eligible for the Medicare EHR Incentive program (even if you participate in the Medicaid EHRIP), you are subject to Payment Adjustments if not a meaningful user Does your organization submit any claims for Medicare Part B Reimbursements that are billed at the individual NPI level (not facility level billing)? If so, and if an MD, DO, DDS, you are probably subject to payment adjustments Hardship waiver applications are due each year by July 1 st, looking back at previous CY to avoid following CY penalty
2015 Summary The NPRM covers more than what has been included in these 20+ slides (read the rule) How does this NPRM affect your IT, clinical work flow plans and/or MU reporting period for 2015? Does this NPRM affect your EHR Vendor, their reporting, their versions? Expect slow CA SLR adoption of the Modifications programming changes to the attestation system will take a while
Fewer exclusions and think about 2016 More alignment across your EPs Full year reporting be ready on Jan 1 st! Do Gap Analysis throughout the year Last year to begin in CA Medicaid Incentives
QUESTIONS? CalHIPSO REC: deeanne@calhipso.org 510-302-3364 www.calhipso.org