Welcome to Modified Stage 2: The Final Rule for MU in 2015 Brett M. Paepke, OD Advisor, RevolutionEHR
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Registration Each provider needs to register for Incentive program Not required to declare Start or End dates EHR Certification Number needs to be generated Registration guidance document on Insight
What is Modified Stage 2? Notice of Proposed Rulemaking for MU 2015-2017 and Stage 3 released in Q1 2014 1.reduce reporting requirements 2.align reporting periods with calendar year 3.modify patient engagement measures Final Rule released October 6 Ideas discussed tonight are official!
What is Modified Stage 2? Stage 1 and Stage 2 blended into one unified concept 10 total objectives + Clinical Quality Measure reporting All objectives are required. No Core/Menu differentiation Eliminates topped out objectives i.e., Patient Demographics 25th percentile: 97% 50th percentile: 99% 75th percentile: 99.8%
Stages of MU First Year of Meaningful Use Stage of Meaningful Use 2015 2016 2017 2018 2011 Modified Stage 2 Modified Stage 2 Modified Stage 2 or Stage 3 Stage 3 2012 Modified Stage 2 Modified Stage 2 Modified Stage 2 or Stage 3 Stage 3 2013 Modified Stage 2 Modified Stage 2 Modified Stage 2 or Stage 3 Stage 3 2014 Modified Stage 2 Modified Stage 2 Modified Stage 2 or Stage 3 Stage 3 2015 Modified Stage 2 Modified Stage 2 Modified Stage 2 or Stage 3 Stage 3 2016 n/a Modified Stage 2 Modified Stage 2 or Stage 3 Stage 3
Reporting Periods 2015 any 90 consecutive days for all EPs (1/1/15-12/31/15) 2016 any 90 consecutive days for new EPs full calendar year for all others 2017 full calendar year for all Medicare EPs (including new EPs) in modified Stage 2 any 90 consecutive days for providers moving to Stage 3 early * EPs in the Medicaid arm of the incentive program will always have an any 90 consecutive day 1st year
Modified Stage 2 Reorganization Core 1 - CPOE Core 2 - erx Core 3 - Demographics Core 4 - Vital Signs Core 5 - Smoking Status Core 6 - Clinical Decision Support Core 7 - Incorporate Clinical Lab-Test Results Core 8 - Patient Lists Core 9 - Preventative Care Core 10 - Patient Electronic Access Core 11 - Clinical Summaries Core 12 - Patient Specific Educational Resources Core 13 - Medication Reconciliation Core 14 - Summary of Care Core 15 - Immunization Registries Data Submission Core 16 - Protect Electronic Health Information Core 17 - Secure Electronic Messaging Menu 1 - Syndromic Surveillance Menu 2 - Electronic Notes Menu 3 - Imaging Results Menu 4 - Family Health History Menu 5 - Report Cancer Cases Menu 6 - Report Specific Cases
Modified Stage 2 Reorganization Protect Patient Health Information Clinical Decision Support Computerized Provider Order Entry Electronic Prescribing Health Information Exchange Patient Specific Education Medication Reconciliation Patient Electronic Access Secure Electronic Messaging Public Health Reporting
Modified Stage 2 Objectives Protect Patient Health Information Objective Measure Exclusions Alternate Specifications for EPs due for Stage 1 in 2015 Protect electronic health information created or maintained by the CEHRT through the implementation of appropriate technical capabilities. Conduct or review a security risk analysis in accordance with the requirements in 45 CFR 164.308(a)(1), including addressing the security (to include encryption) of data stored in Certified EHR Technology in accordance with requirements in 45 CFR 164.312(a)(2)(iv) and 45 CFR 164.306(d)(3), and implement security updates as necessary and correct identified security deficiencies as part of the EP s risk management process None None
Modified Stage 2 Objectives SRA can be performed anytime during the calendar year as long as it is completed by the day of attestation. 3rd party assistance not required, but a very good idea considering the evolution of audits OIG HIPAA CMS Essentials of the Security Risk Analysis webinar with Marni Anderson
Modified Stage 2 Objectives Clinical Decision Support Objective Measures Exclusions Alternate Specifications for EPs due for Stage 1 in 2015 Use clinical decision support to improve performance on high-priority health conditions 1. Implement five clinical decision support interventions related to four or more clinical quality measures at a relevant point in patient care for the entire EHR reporting period 2. The EP has enabled and implemented the functionality for drug-drug and drug allergy interaction checks for the entire EHR reporting period Any EP who writes fewer than 100 medication orders during the EHR reporting period can exclude from measure 2 Proposed Objective: Implement one clinical decision support rule relevant to specialty along with the ability to track compliance with that rule Proposed Measure: Implement one clinical decision support rule. It is also proposed that drug-drug and drug-allergy interaction checks in measure 2 above must be met since it s the same as a Stage 1 objective
Modified Stage 2 Objectives Clinical Decision Support
Modified Stage 2 Objectives Computerized Provider Order Entry Objective Use computerized provider order entry (CPOE) for medication, laboratory, and radiology orders directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local, and professional guidelines 1. More than 60 percent of medication orders created by the EP during the EHR reporting period are recorded using computerized provider order entry Measures 2. More than 30 percent of laboratory orders created by the EP during the EHR reporting period are recorded using computerized provider order entry 3. More than 30 percent of radiology orders created by the EP during the EHR reporting period are recorded using computerized provider order entry Exclusions Alternate Specifications for EPs due for Stage 1 in 2015 Any EP who writes fewer than 100 medication, laboratory, or radiology orders during the EHR reporting period can exclude from that measure Proposed Measure: More than 30 percent of medication orders created by the EP during the EHR reporting period are recorded using computerized provider order entry Providers due for Stage 1 in 2015 (or 2016) can exclude from measures 2 and 3 as they do not exist in Stage 1
Modified Stage 2 Objectives Computerized Provider Order Entry Medication Orders Lab and Radiology Orders
Modified Stage 2 Objectives Electronic Prescribing Objective Generate and transmit permissible prescriptions electronically (erx) Measure More than 50 percent of all permissible prescriptions, or all prescriptions, written by the EP are queried for a drug formulary and transmitted electronically using Certified EHR Technology 1. Any EP who writes fewer than 100 permissible prescriptions during the EHR reporting period Exclusions Alternate Specifications for EPs due for Stage 1 in 2015 2. An EP who does not have a pharmacy within his or her organization and does not have a pharmacy that accepts electronic prescriptions within 10 miles of the EP's practice location at the start of his or her EHR reporting period Proposed Measure: More than 40 percent of all permissible prescriptions written by the EP are transmitted electronically using Certified EHR Technology
Modified Stage 2 Objectives Health Information Exchange Objective The EP who transitions their patient to another setting of care or refers their patient to another provider of care provides a summary care record for each transition of care or referral The EP that transitions or refers their patient to another setting of care or provider of care: Measure 1. uses CEHRT to create a summary of care record 2. electronically transmits the summary to a receiving provider for more than 10 percent of transitions of care and referrals Exclusions Alternate Specifications for EPs due for Stage 1 in 2015 Any EP who refers a patient to another provider less than 100 times during the EHR reporting period EP may claim an exclusion for this objective since Stage 1 does not have an equivalent
Modified Stage 2 Objectives Summary of Care
Modified Stage 2 Objectives Patient-Specific Education Objective Use clinically relevant information from Certified EHR Technology to identify patient-specific education resources and provide those resources to the patient Measure Patient-specific education resources identified by Certified EHR Technology are provided to more than 10 percent of all unique patients seen by the EP during the EHR reporting period Exclusions Alternate Specifications for EPs due for Stage 1 in 2015 Any EP who has no office visits during the EHR reporting period EP may claim an exclusion for the measure if they did not intend to select the Stage 1 Patient Specific Education menu objective
Modified Stage 2 Objectives Patient-Specific Education 1 2
Modified Stage 2 Objectives Medication Reconciliation Objective The EP who receives a patient from another setting of care or provider of care or believes an encounter is relevant should perform medication reconciliation Measure Exclusions Alternate Specifications for EPs due for Stage 1 in 2015 The EP performs medication reconciliation for more than 50 percent of encounters with new patients and inbound transitions of care. Any EP who saw no new patients and was not the recipient of any transitions of care during the EHR reporting period EP may claim an exclusion for the measure if they did not intend to select the Stage 1 Medication Reconciliation menu objective
Modified Stage 2 Objectives Medication Reconciliation and Health Information Exchange are complimentary objectives Inbound electronic Transition of Care document can be used for Medication Reconciliation Medication Reconciliation
Modified Stage 2 Objectives Medication Reconciliation Get new patients involved in process of obtaining official medication list
Modified Stage 2 Objectives Medication Reconciliation Denominator all new patients automatically included inbound referrals need TOC Document Received box checked Numerator number of patients in denominator who have Medication reconciliation performed box checked
Modified Stage 2 Objectives Patient Electronic Access Objective Provide patients the ability to view online, download, and transmit their health information within 4 business days of the information being available to the EP An EP must meet both measures: Measures 1. More than 50 percent of all unique patients seen by the EP during the EHR reporting period are provided timely (within 4 business days after the information is available to the EP) online access to their health information 2. At least one patient seen by the EP during the EHR reporting period (or their authorized representatives) views, downloads, or transmits his or her health information to a third party Any EP who: Exclusions 1. Neither orders nor creates any of the information listed for inclusion as part of the measures; or 2. Conducts 50 percent or more of his or her patient encounters in a county that does not have 50 percent or more of its housing units with 4Mbps broadband availability according to the latest information available from the FCC on the first day of the EHR reporting period Alternate Specifications for EPs due for Stage 1 in 2015 EP may claim an exclusion for measure 2 since Stage 1 does not have an equivalent
Modified Stage 2 Objectives Patient Electronic Access Measure 1 establish PHR credentials sign encounter within 4 business days Measure 2 promote use of the PHR to have patients View, Download, or Transmit their information V/D/T links available in About Me or Appointments area of PHR
Modified Stage 2 Objectives Patient Electronic Access Measure 1 establish PHR credentials sign encounter within 4 business days Measure 2 promote use of the PHR to have patients View, Download, or Transmit their information V/D/T links available in About Me or Appointments area of PHR
Modified Stage 2 Objectives Secure Electronic Messaging Objective Use secure electronic messaging to communicate with patients on relevant health information Measure During the EHR reporting period, the capability for patients to send and receive a secure electronic message with the provider was fully enabled Any EP who: 1. has no office visits during the EHR reporting period, or Exclusions Alternate Specifications for EPs due for Stage 1 in 2015 2. conducts 50 percent or more of his or her patient encounters in a county that does not have 50 percent or more of its housing units with 4Mbps broadband availability according to the latest information available from the FCC on the first day of the EHR reporting period EP may claim an exclusion since Stage 1 does not have an equivalent
Modified Stage 2 Objectives Secure Electronic Messaging Objective Use secure electronic messaging to communicate with patients on relevant health information Measure During the EHR reporting period, the capability for patients to send and receive a secure electronic message with the provider was fully enabled Any EP who: 1. has no office visits during the EHR reporting period, or Exclusions Alternate Specifications for EPs due for Stage 1 in 2015 2. conducts 50 percent or more of his or her patient encounters in a county that does not have 50 percent or more of its housing units with 4Mbps broadband availability according to the latest information available from the FCC on the first day of the EHR reporting period EP may claim an exclusion since Stage 1 does not have an equivalent
Modified Stage 2 Objectives Public Health Reporting Proposed Objective Proposed Measures Exclusions Alternate Specifications for EPs due for Stage 1 in 2015 The EP is in active engagement with a PHA or CDR to submit electronic public health data in a meaningful way using certified EHR technology, except where prohibited, and in accordance with applicable law and practice There are a total of four possible measures for this objective. EPs would be required to choose from measures 1 through 3, and would be required to successfully attest to any combination of two measures 3 available for each measure EP must report at least one measure unless they can exclude from all available measures
Modified Stage 2 Objectives Public Health Reporting Proposed Objective Proposed Measures Exclusions Alternate Specifications for EPs due for Stage 1 in 2015 The EP is in active engagement with a PHA or CDR to submit electronic public health data in a meaningful way using certified EHR technology, except where prohibited, and in accordance with applicable law and practice There are a total of four possible measures for this objective. EPs would be required to choose from measures 1 through 3, and would be required to successfully attest to any combination of two measures 3 available for each measure EP must report at least one measure unless they can exclude from all available measures
Public Health Reporting What is Active Engagement? The EP is moving toward the submission of real patient data. This can be demonstrated 1 of 3 ways: 1. Completed registration with a registry within 60 days after the start of reporting period 2. Testing of data submission process initiated 3. Actively submitting patient data
Public Health Reporting Exclusions: Do not count as satisfying a measure i.e. EP cannot exclude from Immunization Registry Reporting on grounds that they didn t perform any immunizations during reporting period and have that count as 1 of the 2 measures they need to meet. In the event that 2 measures don t apply, EP can report on whatever is applicable and claim an exclusion for the non-relevant measures If nothing applies or the EP wasn t planning on registry reporting in 2015, a full exclusion is possible. Engagement with the AOA s registry, MORE, is not required to demonstrate MU in 2015
MU Scorecards
Providers originally due for Stage 1 in 2015 MU Scorecards
Providers originally due for Stage 2 in 2015 MU Scorecards
Clinical Quality Measures Required part of being a Meaningful User Report on 9 measures that span 3 or more domains over 90 day period in 2015 Scores not important for Meaningful Use, but can be for other quality reporting programs Two methods to report CQM scores manually during attestation electronically through QualityNet portal
Clinical Quality Measures
Attestation The process by which you tell CMS how you did Attestation for 2015 reporting periods cannot take place until January 4, 2016 and must be completed by February 29, 2016. Preparation Print / capture MU and CQM scorecards on the day of attestation Save scorecards as they ll serve as proof in the event of an audit
Summary Reporting periods 2015: any 90 consecutive days (1/1/15-12/31/15) 2016: any 90 consecutive days for new EPs, full year for all others 2017: full year for all Medicare EPs (including new EPs) in Modified Stage 2 any 90 consecutive days for those who attempt Stage 3 early MU in 2015 involves 10 objectives based mainly on Stage 2 measures + Clinical Quality Measures Key Changes V/D/T Actual Use changes from >5% to equal to or greater than 1 Secure Messaging changes from >5% to Yes/No for having functionality enabled All public health reporting objectives consolidated into one objective with multiple measures Providers due for Stage 1 in 2015 have special exclusions and thresholds All EPs held to same standards in 2016 (except for CPOE) No attestation for 2015 reporting periods until 1/4/16-2/29/16
Questions? Brett M. Paepke, OD Advisor, RevolutionEHR bpaepke@revolutionehr.com