Advancing Care Information (ACI) and Meaningful Use (MU) in 2017

Click to edit Master title style Advancing Care Information (ACI) and Meaningful Use (MU) in 2017 Bruce Maki, MA M-CEITA / Altarum Institute Regulatory & Incentive Program Analyst April 13, 2017 4/13/2017 1 1

Disclaimer This presentation was current at the time it was performed, broadcast, published or uploaded to the web. Medicare and Medicaid policy changes frequently, so links to source documents and resources have been provided for your reference. This presentation was prepared as a service to the public and is not intended to grant rights or impose obligations. This presentation may contain references or links to statutes, regulations, or other policy materials. The information provided is only intended to be a general summary. It is not intended to take the place of either the written law or regulations. We encourage participants to review the specific statutes, regulations, and other interpretive materials for a full and accurate statement of their contents. 2

Agenda Overview of M-CEITA Participating in MU and ACI in 2017 Eligibility Reporting Periods Attestation Options Program Structure 2017 Objectives and Measures Resources Questions & Answers 3

Who is M-CEITA? Michigan Center for Effective Information Technology Adoption (M-CEITA) One of 62 ONC Regional Extension Centers (REC) providing education & technical assistance to primary care providers across the country Funded by ARRA of 2009 (Stimulus Plan) Founded as part of the HITECH Act to accelerate the adoption, implementation, and effective use of electronic health records (EHR), e.g. 90-days of Meaningful Use Purpose: support the Triple Aim by achieving 5 overall performance goals THE TRIPLE AIM Improve patient experience Improve population health 3Reduce costs Improve Engage Quality, Patients Safety & & Efficiency Families Performance Measurement Improve Care Coordination Improve Population And Public Health Meaningful Use Ensure Privacy And Security Protections Certified Technology Infrastructure 4

M-CEITA Services Meaningful Use Support Security Risk Assessment Audit Preparation Targeted Process Optimization (Lean) GLPTN - Great Lakes Practice Transformation Network Chronic Care Management (CCM) Quality Payment Program Resource Center www.mceita.org 1-888-MICH-EHR www.qppresourcecenter.com 5

ACI and MU in 2017: Dual Participation 6

Glossary of Acronyms Acronym Definition Acronym Definition ACI Advancing Care Information HIE Health Information Exchange APM Alternative Payment Model HIT/HEALTH IT Health Information Technology ARRA American Recovery and Reinvestment Act of 2009 HITECH ACT Health Information Technology for Economic and Clinical Health Act CDS Clinical Decision Support MACRA Medicare Access and CHIP Reauthorization Act CEHRT Certified Electronic Health Record Technology M-CEITA Michigan Center for Effective IT Adoption CHIP Children's Health Insurance Program MCIR Michigan Care Improvement Registry CMS Center for Medicare & Medicaid Services MIPS Merit-based Incentive Payment System CNS Certified Nurse Specialist MU Meaningful Use CPI/CPIA Clinical Practice Improvement Activities NP Nurse Practitioner CPOE Computerized Provider Order Entry ONC Office of the National Coordinator for Health IT CPS Composite Performance Score PA Physicians Assistant CRNA Certified Registered Nurse Anesthetist PQRS Physician Quality Reporting System EC Eligible Clinician QCDR Qualified Clinical Data Registry EHR Electronic Health Record QPP Quality Payment Program EP Eligible Professional SGR Sustainable Growth Rate ephi Electronic Protected Health Information SRA Security Risk Assessment erx Electronic Prescribing TIN Tax Identification Number GLPTN Great Lakes Practice Transformation Network VM/VBM Value Modifier/Value Based Modifier 7

Eligibility for MU and ACI Eligible Providers Medicaid MU EPs Doctors of Medicine (MD) Doctors of Osteopathy (DO) Doctors of Dental Surgery/Dental Medicine (DMD/DDS) Doctors of Optometry Nurse Practitioners (NP) Physician Assistants (PA) practicing in a PA-led Federally Qualified Health Center (FQHC) or a PA-led Rural Health Clinic (RHC) Certified Nurse Midwife (CNM) ACI ECs Doctors of Medicine (MD) Doctors of Osteopathy (DO) Doctors of Dental Surgery/Dental Medicine (DMD/DDS) Doctors of Optometry Nurse Practitioners (NP) Physician Assistants (PA) Chiropractors Clinical Nurse Specialists (CNS) Certified Registered Nurse Anesthetists (CRNA) Doctors of Podiatry 8

Eligibility for MU and ACI Additional Requirements MU A minimum 30% patient volume attributable to Michigan Medicaid patient encounters (90 day period) For pediatricians (not NPs in peds clinic), a minimum 20% patient volume attributable to Michigan Medicaid patient encounters (pays 2/3 of incentive) ACI Medicare PFS (Part B) allowable billing charges greater than $30,000 AND provides care to more than 100 Medicare patients in one year Dates used to determine 2017 eligibility: 9/1/15 to 8/31/16 In April, CMS will mail letters to ECs who meet the low volume threshold for MIPS exemption 9

2017 Reporting Period Meaningful Use New and Returning Participants: MU measures - Any continuous 90-365 days within the Calendar Year Providers electing optional Stage 3: Any continuous 90 days within the CY (requires 2015 CEHRT) For Returning Participants (MU Only), CQMs must be reported for a full year ACI (MIPS) Test Pace: Report the 4 or 5 ACI Base Measures (based upon CEHRT Edition) Partial Year: Submit 90 days of data Full Year: Submit 365 days of data 10

Attestation Options MU Attestation (CHAMPS/ehrMIPP) ACI QCDR (Qualified Clinical Data Registry) Qualified Registry EHR Attestation (new CMS portal coming) Attestation Window MU: 1 st time MUers can attest as of 4/1/17; All others 1/1/18-3/1/18 ACI: 1/1/18-3/31/18 If participating in MU and MIPS, you must attest separately for each program 11

Program Structure Modified Stage 2 MU Structure 12

Program Structure Advancing Care Information Structure Base Score Performance Score Bonus Points Composite Score Makes up to 50 POINTS of the total Advancing Care Information Performance Category Score Makes up to 90 POINTS of the total Advancing Care Information Performance Category Score Earn up to an add l 15 POINTS in the total Advancing Care Information Performance Category Score Earn 100 or more points and receive the full 25 POINTS in the Advancing Care Information Category of the MIPS Composite Performance Score 13

Advancing Care Information Structure Base Score Makes up to 50 POINTS of the total Advancing Care Information Performance Category Score 14

Advancing Care Information Structure Performance Score Makes up to 90 POINTS of the total Advancing Care Information Performance Category Score 15

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Example ACI Scoring Base Score Performance Score Bonus Points Composite Score Earn 50 Points Attest for all 5 measures (all or nothing) (4 measures if still on 2014 CEHRT) Up to 90 Points Measure points accumulated by decile 1-10% = 1 point 11-20% = 2 points Etc. Up to 15 Points 5% Additional Public Health Registry 10% CPIA Alignment Earn 100-155 points and receive full 25 POINTS in the Advancing Care Information category of MIPS Composite Performance Score (CPS) 17

Main Differences Between MU and ACI MU still measures EPs on CDS (Clinical Decision Support) and CPOE (Computerized Provider Order Entry) while ACI does not include these measures There are no measure thresholds that must be met in ACI (with exception of base score). Each numerator/denominator or Yes/No converts to points Except for the erx measure, there are no exclusions for ACI measures; must meet Base requirements then ECs can elect on reporting for Performance and Bonus Measures The scoring is different between programs MU is pass/fail Except for the Base Score which is pass/fail, ACI uses decile scoring 18

Converting MU Scores to ACI Base Score Example BASE MEASURES Numerator Denominator Performance Score Threshold Score erx 2718 2827 96% Numerator YES VDT - Access 429 432 99% >/= YES HIE/SoC 21 83 25% 1 Patient YES SRA N/A N/A YES Yes/No YES TOTAL BASE SCORE 50% 19

Converting MU Scores to ACI Performance Score Example PERFORMANCE MEASURES Numerator Performance Denominator Score Decile Score Performance Weighting Score HIE/SoC 21 83 25% 3 Up to 20% 6% VDT - Access 429 432 99% 10 Up to 20% 20% VDT - Use 186 432 43% 5 Up to 10% 5% Patient Education 418 432 97% 10 Up to 10% 10% Medication Reconciliation 307 332 92% 10 Up to 10% 10% Secure Messaging 31 432 7% 1 Up to 10% 1% MCIR N/A N/A YES N/A 0 or 10% 10% TOTAL PERFORMANCE SCORE 62% 20

Converting MU Scores to ACI Bonus Score Example BONUS MEASURES MSSS or Specialized Registry Report Specific CPIA using CEHRT (See Fact Sheet for List) Numerator Denominator Performance Rate Performance Rating Score N/A N/A YES 5% 5% N/A N/A NO 10% Scoring Example Totals: Base 50% Performance 62% Bonus 5% Total ACI Score: 117%, topped at 100% TOTAL BONUS SCORE 5% EC would earn the maximum 25 ACI points towards total MIPS score 21

Meaningful Use (MU) and Advancing Care Information (ACI) 2017 Objectives and Measures 22

The ACI and MU Objectives: 1. Protect Patient Health Information (SRA) 2. Clinical Decision Support Interventions (CDS) (MU ONLY) 3. Computerized Provider Order Entry (CPOE) (MU ONLY) 4. Electronic Prescribing (erx) 5. Health Information Exchange (formerly Summary of Care) 6. Patient Specific Education 7. Medication Reconciliation 8. Patient Electronic Access (VDT/Pt Portal) 9. Secure Electronic Messaging 10. Public Health Reporting 23

MU Measure Objective 1: Protect Patient Health Information (SRA Security Risk Analysis) Measure Threshold Exclusion 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 ephi created or maintained in CEHRT in accordance with requirements under 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 Y/N N/A 24

ACI Measure Objective: Measure: Protect Patient Health Information Security Risk Analysis Conduct or review a security risk analysis (SRA) in accordance with the requirements in 45 CFR 164.308(a)(1), including addressing the security (to include encryption) of ephi data created or maintained by CEHRT in accordance with requirements in 45 CFR164.312(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 MIPS eligible clinician s risk management process. Reporting Requirements YES/NO To meet this measure, eligible clinicians must attest YES to conducting or reviewing a security risk analysis and implementing security updates as necessary and correcting identified security deficiencies. Scoring Information Required for Base Score: Yes Percentage of Performance Score: 0% Eligible for Bonus Score: No 25

MU Measure Objective 2: Clinical Decision Support (CDS)* Measure Threshold Exclusion Measure 1: Implement 5 CDS interventions related to 4 or more CQMs at a relevant point in patient care for the entire reporting period (RP). Absent 4 CQMs related to an EPs scope of practice or patient population, the CDS interventions must be related to Y/N N/A high-priority health conditions Measure 2: The EP has enabled and implemented the functionality for drug/drug and drug/allergy interaction checks for the entire RP Y/N EP who writes < 100 medication orders during the RP *No equivalent ACI measure 26

Objective 3: Computerized Provider Order Entry (CPOE)* Measure Threshold Exclusion Measure 1: > 60% of medication orders created by the EP during the RP are recorded using CPOE Measure 2: > 30% of laboratory orders created by the EP during the RP are recorded using CPOE Measure 3: > 30% of radiology orders created by the EP during the RP are recorded using CPOE > 60% > 30% > 30% MU Measure EP who writes < 100 medication orders during the RP EP who writes < 100 laboratory orders during the RP EP who writes < 100 radiology orders during the RP *No equivalent ACI measure 27

MU Measure Objective 4: Electronic Prescribing (erx) Measure Threshold Exclusion > 50% of all permissible prescriptions written by the EP are queried for a drug formulary* & transmitted electronically using CEHRT > 50% EP who writes < than 100 medication orders during the RP or does not have a pharmacy within his or her organization and there are no pharmacies that accept electronic prescriptions within 10 miles of the EP's practice location at the start of the RP * Note they must be queried against a drug formulary to count! 28

ACI Measure Objective: Measure: Exclusion: Reporting Requirements NUMERATOR: The number of prescriptions in the denominator generated, queried for a drug formulary, and transmitted electronically using CEHRT. DENOMINATOR: Number of prescriptions written for drugs requiring a prescription in order to be dispensed other than controlled substances during the performance period; or number of prescriptions written for drugs requiring a prescription in order to be dispensed during the performance period. Scoring Information Electronic Prescribing Electronic Prescribing The MIPS eligible clinician is in active engagement with a public health agency to submit syndromic surveillance data from a non-urgent care ambulatory setting where the jurisdiction accepts syndromic data from such settings and the standards are clearly defined. Any MIPS eligible clinician who writes fewer than 100 permissible prescriptions during the 2017 performance period. Required for Base Score: Yes Percentage of Performance Score: 0% Eligible for Bonus Score: No 29

MU Measure Objective 5: Health Information Exchange (HIE) Measure Threshold Exclusion EP that transitions or refers their patient to another setting of care or provider of care must (1) use CEHRT to create a summary of care (SOC) record; and (2) electronically transmit such summary to a receiving provider for > 10% of transitions of care (TOC) and referrals > 10% EP who transfers a patient to another setting or refers a patient to another provider < 100 times during the RP 30

ACI Measure Objective: Measure: Health Information Exchange Health Information Exchange (HIE) The MIPS eligible clinician that transitions or refers their patient to another setting of care or health care clinician (1) uses CEHRT to create a summary of care record; and (2) electronically transmits such summary to a receiving health care clinician for at least one transition of care or referral. Reporting Requirements NUMERATOR: The number of transitions of care and referrals in the denominator where a summary of care record was created using CEHRT and exchanged electronically. DENOMINATOR: Number of transitions of care and referrals during the performance period for which the EC was the transferring or referring health care clinician. Scoring Information Required for Base Score: Yes Percentage of Performance Score: Up to 20% Eligible for Bonus Score: No 31

MU Measure Objective 6: Patient Specific Education Measure Threshold Exclusion Patient specific education resources identified by CEHRT are provided to patients for > 10% of all unique patients with office visits seen by the EP during the RP > 10% EP who has no office visits during the RP 32

ACI Measure Objective: Measure: Patient Electronic Access Patient Specific Education The MIPS eligible clinician must use clinically relevant information from CEHRT to identify patient-specific educational resources and provide access to those materials to at least one unique patient seen by the MIPS eligible clinician. Reporting Requirements NUMERATOR: The number of patients in the denominator who were provided access to patient-specific educational resources using clinically relevant information identified from CEHRT during the performance period. DENOMINATOR: The number of unique patients seen by the MIPS eligible clinician during the performance period. Scoring Information Required for the Base Score: No Percentage of Performance Score: Up to 10% Eligible for Bonus Score: No 33

MU Measure Objective 7: Medication Reconciliation Measure Threshold Exclusion The EP performs medication reconciliation for > 50% of TOC in which the patient is transitioned into the care of the EP > 50% EP who was not the recipient of any transitions of care during the RP 34

ACI Measure Objective: Measure: Medication Reconciliation Medication Reconciliation The MIPS eligible clinician performs medication reconciliation for at least one transition of care in which the patient is transitioned into the care of the MIPS eligible clinician. Reporting Requirements NUMERATOR: The number of transitions of care or referrals in the denominator where the following three clinical information reconciliations were performed: medication list, medication allergy list, and current problem list. DENOMINATOR: Number of transitions of care or referrals during the performance period for which the MIPS eligible clinician was the recipient of the transition or referral or has never before encountered the patient. Scoring Information Required for the Base Score: No Percentage of Performance Score: Up to 10% Eligible for Bonus Score: No 35

MU Measure Objective 8: Patient Electronic Access (VDT) Measure Threshold Exclusion Measure 1: > 50% of all unique patients seen by the EP during the RP are provided timely access to view online, download, and transmit (VDT) to a third party their health information subject to the EP's discretion to withhold certain information Measure 2: > 5% of unique patients (or PARs) seen by the EP during the reporting period VDTs their health information during the reporting period > 50% > 5% EP who neither orders nor creates any of the information listed for inclusion as part of the measures except for patient name and provider s name and office contact information EP who neither orders nor creates any of the information listed for inclusion as part of the measures except for patient name and provider s name and office contact information; OR conducts 50% or more of their patient encounters in a county that does not have 50% 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 RP 36

ACI Measure Objective: Measure: Patient Electronic Access Provide Patient Access At least one patient seen by the MIPS eligible clinician during the performance period is provided timely access to view online, download, and transmit to a third party their health information subject to the MIPS eligible clinician s discretion to withhold certain information. Reporting Requirements NUMERATOR: The number of patients in the denominator (or patient authorized representative) who are provided timely access to health information to view online, download, and transmit to a third party. DENOMINATOR: The number of unique patients seen by the MIPS eligible clinician during the performance period. Scoring Information Required for the Base Score: Yes Percentage of Performance Score: Up to 20% Eligible for Bonus Score: No 37

ACI Measure Objective: Measure: Patient Electronic Access View, Download or Transmit At least one patient seen by the MIPS eligible clinician during the performance period (or patient-authorized representative) views, downloads or transmits their health information to a third party during the performance period. Reporting Requirements NUMERATOR: The number of unique patients (or their authorized representatives) in the denominator who have viewed online, downloaded, or transmitted to a third party the patient s health information during the performance period. DENOMINATOR: Number of unique patients seen by the MIPS eligible clinician during the performance period. Scoring Information Required for the Base Score: No Percentage of Performance Score: Up to 10% Eligible for Bonus Score: No 38

MU Measure Objective 9: Secure Electronic Messaging Measure Threshold Exclusion For > 5% of unique patients seen by the EP during the RP, a secure message was sent using the electronic messaging function of CEHRT to the patient (or PAR), or in response to a secure message sent by the patient (or PAR) during the RP > 5% EP who has no office visits during the RP or EP who conducts 50% or more of their patient encounters in a county that does not have 50% 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 RP 39

ACI Measure Objective: Measure: Reporting Requirements NUMERATOR: The number of patients in the denominator for whom a secure electronic message is sent to the patient (or patient-authorized representative), or in response to a secure message sent by the patient (or patient-authorized representative), during the performance period. DENOMINATOR: Number of unique patients seen by the MIPS eligible clinician during the performance period. Scoring Information Required for Base Score: No Percentage of Performance Score: Up to 10% Eligible for Bonus Score: No Secure Electronic Messaging Secure Electronic Messaging For at least one patient seen by the MIPS eligible clinician during the performance period, a secure message was sent using the electronic messaging function of CEHRT to the patient (or the patient-authorized representative), or in response to a secure message sent by the patient (or the patient authorized representative), during the performance period. 40

MU Measure Objective 10: Public Health Reporting (EPs must attest YES to 2 out of 3 measures) Measure Measure Option 1: Immunization Registry Reporting The EP is in active engagement with a public health agency to submit immunization data Measure Option 2: Syndromic Surveillance Reporting The EP is in active engagement with a public health agency to submit syndromic surveillance data Measure Option 3: Specialized Registry Reporting The EP is in active engagement to submit data to a qualified specialized registry Exclusion MI EPs: Does not administer any immunizations for which data is collected by the immunization registry MI EPs in Non-Urgent Care Settings: Is not in a category of providers from which ambulatory syndromic data is collected by the PHA EP (a) does not diagnose/treat any disease/condition associated with, or collect relevant data that is collected by, a specialized registry in their jurisdiction during the RP; (b) operates in a jurisdiction for which no specialized registry is capable of accepting electronic registry transactions in the specific standards required to meet the CEHRT definition at the start of the RP; or (c) operates in a jurisdiction where no specialized registry for which the EP is eligible has declared readiness to receive electronic registry transactions at the beginning of the RP 41

ACI Measure Objective: Measure: Public Health Reporting Immunization Registry Reporting The MIPS eligible clinician is in active engagement with a public health agency to submit immunization data. Reporting Requirements YES/NO To meet this measure, MIPS eligible clinicians must attest YES to being in active engagement with a public health agency to submit immunization data. Scoring Information Required for Base Score: No Percentage of Performance Score: 0 or 10% Eligible for Bonus Score: No 42

ACI Measure Objective: Measure: Public Health Reporting Syndromic Surveillance Reporting The MIPS eligible clinician is in active engagement with a public health agency to submit syndromic surveillance data. Reporting Requirements YES/NO To meet this measure, MIPS eligible clinicians must attest YES to being in active engagement with a public health agency to submit syndromic surveillance data. Scoring Information Required for Base Score: No Percentage of Performance Score: 0% Eligible for Bonus Score: Yes, up to 5% total 43

ACI Measure Objective: Measure: Public Health Reporting Specialized Registry Reporting The MIPS eligible clinician is in active engagement to submit data to a specialized registry. Reporting Requirements YES/NO To meet this measure, MIPS eligible clinicians must attest YES to being in active engagement to submit data to a specialized registry. Scoring Information Required for the Base Score: No Percentage of Performance Score: 0% Eligible for Bonus Score: Yes, up to 5% total 44

Concluding Thoughts MU and ACI (MIPS) are separate programs; participating in one does not give credit in the other Although separate, ACI and MU are still quite similar The objectives are nearly identical although with different measure scoring Meeting MU likely means a decent, if not max, ACI score (25pts) Goal should no longer be just meeting the MU threshold; with ACI every numerator/point counts and could mean an increase in Medicare reimbursements 45

Resources Quality Payment Program Website: https://qpp.cms.gov/ 2017 MU Program Requirements: https://www.cms.gov/regulations-and- Guidance/Legislation/EHRIncentivePrograms/2017ProgramRequirements.html QPP Final Rule: https://www.federalregister.gov/documents/2016/11/04/2016-25240/medicare-program-merit-based-incentive-payment-system-mips-andalternative-payment-model-apm MU Final Rule: http://federalregister.gov/a/2015-25595 2017 MU Measure Specification Sheets: https://www.cms.gov/regulations-and- Guidance/Legislation/EHRIncentivePrograms/Downloads/TableofContents_EP_Med icaid_modifiedstage2.pdf ACI Performance Category Fact Sheet: https://qpp.cms.gov/docs/qpp_aci_fact_sheet.pdf ACI Measure Specification Sheets: https://qpp.cms.gov/docs/qpp_advancing_care_information_measure_specificatio ns.zip 46

Questions? www.mceita.org Bruce Maki bruce.maki@altarum.org 734-302-4744 47