Meaningful Use Update: Stage 3 and Beyond Carla McCorkle, Midas+ Solutions CQM Product Lead
Objectives Discuss major changes to Meaningful Use program for Stage 3 and impact on hospitals Identify steps to prepare for Stage 3 Summarize strategies to increase and maintain stakeholder engagement with Meaningful Use goals
2015 ONC HIT Certification Proposed Rule
Major Provisions Improve interoperability Facilitate accessibility and data exchange Provide ONC HIT Certification Program accessiblity to more types of health IT Support Medicare and Medicaid EHR Incentive Programs Address health disparities by expanding certification
Major Provisions (continued) Ensure all HIT possesses relevant privacy and security capabilities Improve patient safety Increase reliability and transparency of certified HIT Provide HIT developers with more flexibility and opportunities for certification
2015 EHR Certification EHR technology certified to either 2014 or 2015 edition will support attestation for Stage 1 or Stage 2 in 2017 All providers will be required to use 2015 Edition CEHRT for Stage 3 reporting Optional reporting in 2017 Required in 2018
Timeline Rule published: March 30, 2015 Where to review: http://www.regulations.gov/#!documentdetail ;D=HHS_FRDOC_0001-0572 NOTE: This link allows you to view comments received to date. Comment period ends: 11:59 p.m. EDT on May 29, 2015
Stage 3 Meaningful Use Proposed Rule
History and Background 2009 ARRA signed into law 2011 Stage 1 reporting begins 2014 Stage 2 reporting begins 2017 Optional Stage 3 reporting begins 2010 2012 2015 2018 Stage 1 FR Stage 2 FR Stage 3 proposed Required Stage 3 reporting begins
Purpose of MU Aligns with National Quality Strategy aim to provide better care Improve quality, safety, efficiency, and reduce health disparities Engage patients and families Improve care coordination Ensure adequate privacy and security protections for personal health info Improve population and public health
Meaningful Use Stages Stage 1 Clinical data capture Sharing of data with patient and other providers Stage 2 Incorporated advanced clinical practices, such as CDS and Care Coordination Finalized CQMs Stage 3 Build on groundwork of 1 & 2 Increase interoperability Focus on advanced use of EHR and improved outcomes Simplify reporting requirements and reduce program complexity
Stage 3 Proposed Rule Major Provisions Streamlined approach for Stage 3 Further alignment with other CMS quality reporting programs Stage 3 intended to be last stage of Meaningful Use Reduced complexity
Final MU Stage Annual changes affecting EHR Incentive Program would be made in future rulemaking Reporting for Stage 3 is optional for all providers in 2017; required for all in 2018
Streamlined Approach All provider in first year of demonstrating MU would report on CY beginning in January 2017 Exception: Medicaid providers in 1 st year All providers would be required to attest based on a full year of data for a SINGLE set of MU objectives and measures Optional in 2017 Required in 2018
Streamlined Approach (continued) Proposing a set of 8 objectives with associated measures: Protect Patient Health Information Electronic Prescribing Clinical Decision Support Computerized Order Entry Patient Electronic Access to Health Information Coordination of Care through Patient Engagement Health Information Exchange Public Health and Clinical Data Registry Reporting
Stage 3 Objectives & Measures 1) Protecting PHI protect electronic PHI created or maintained by CEHRT through implementation of appropriate technical, administrative, and physical safeguards Measure: Conduct or review a security risk analysis in accordance with requirements under 45 CFR 164.308(a)(1) Including addressing the security (including encryption) of data stored in CEHRT Implement security updates as necessary Correct identified security deficiencies NPRM, pages 63-66
Stage 3 Objectives & Measures (continued) 2) eprescribing maintain Stage 2 objective with increased threshold (generate and transmit permissible discharge prescriptions) Measure: >25% of hospital discharge med orders for permissible prescriptions (new and changed) are queried for a drug formulary and transmitted electronically using CEHRT NPRM, pages 67-74
Stage 3 Objectives & Measures (continued) 3) Clinical Decision Support - Implement clinical decision support (CDS) interventions focused on improving performance on high-priority health conditions. Measure 1: Implement 5 CDS interventions related to 4 or more CQMs at a relevant point in patient care for entire EHR reporting period. Absent 4 CQMs related to patient population, CDS interventions must be related to high-priority health conditions. Measure 2: The EH/CAH has enabled and implemented functionality for drug-drug and drug-allergy interaction checks for entire EHR reporting period. NPRM, pages 75-81
Stage 3 Objectives & Measures (continued) 4) CPOE - Use CPOE for medication, lab, and diagnostic imaging orders directly entered by any licensed healthcare professional or credentialed MA (or equivalent), who can enter orders into EHR per state, local, and professional guidelines. Measure 1: During EHR reporting period, >80% of med orders created during ED or IP stay are recorded using CPOE Measure 2: During EHR reporting period, >80% of lab orders created during ED or IP stay are recorded using CPOE Measure 3: During EHR reporting period, >80% of diagnostic imaging orders created during ED or IP stay are recorded using CPOE NPRM, pages 81-89
Stage 3 Objectives & Measures (continued) 5) Patient Access to ephi - EH/CAH provides access for patients to view online, download, and transmit PHI or retrieve PHI through an API, within 24 hours of its availability. Measure 1: For >80% of all unique patients discharged from EH/CAH IP or ED: Patient or representative is provided access to view online, download, and transmit PHI within 24 hrs of its availability; OR Patient or representative is provided access to ONC-certified API that can be used by third-party applications/devices to provide patients/representatives access to their PHI, within 24 hours of its availability. Measure 2: EH/CAH must use clinically relevant information from CEHRT to identify patient-specific educational resources and provide electronic access to those materials to >35% of unique patients discharged from EH/CAH IP or ED during EHR reporting period
Stage 3 Objectives & Measures (continued) 6) Care Coordination - Use communications functions of CEHRT to engage with patients or representatives about patient's care. Measure 1: During EHR reporting period, >25% of all unique patients discharged from EH/CAH IP or ED actively engage with EHR made accessible by provider. Measure 2: For >35% of all unique patients discharged from EH/CAH IP or ED during EHR reporting period, a secure message was sent using electronic messaging function of CEHRT to the patient or representative, or in response to a secure message sent by patient or representative. Measure 3: Patient-generated health data or data from a non-clinical setting is incorporated into CEHRT for >15% of all unique patients discharged by EH/CAH IP or ED during EHR reporting period.
Stage 3 Objectives & Measures (continued) 7) Health Information Exchange EH/CAH provides a summary of care record (SOCR) when transitioning or referring patient to another setting of care, retrieves a SOCR upon first patient encounter with a new patient, and incorporates SOCR from other providers into their EHR using functions of CEHRT. Measure 1: For >50% of transitions of care (TOC)/referrals, EH/CAH that transitions/refers patient to another setting/provider of care (1) creates SOCR using CEHRT; and (2) electronically exchanges SOCR. Measure 2: For >40% of TOC/referrals received and patient encounters in which provider has never before encountered patient, EH/CAH incorporates into patient's EHR an electronic SOCR from a source other than provider's EHR system. Measure 3: For >80% of TOC/referrals received and patient encounters in which provider has never before encountered patient, EH/CAH performs a clinical information reconciliation. Medication Medication allergy Current Problem List
Stage 3 Objectives & Measures (continued) 8) Public Health and Clinical Data Registry EH/CAH is in active engagement with PHA or CDR to submit electronic public health data in a meaningful way using CEHRT, except where prohibited, and in accordance with applicable law and practice. MEASURES FOR OBJECTIVE 8: PUBLIC HEALTH AND CLINICAL DATA REGISTRY REPORTING OBJECTIVE Measure Max. # of times measure can count Measure 1 Immunization Registry Reporting 1 Measure 2 Syndromic Surveillance Reporting 1 Measure 3 Case Reporting 1 Measure 4 Public Health Registry Reporting 4 Measure 5 Clinical Data Registry Reporting 4 Measure 6 Electronic Reportable Lab Results 1
Alignment EHR reporting period Eliminate current 90-day reporting period for those demonstrating MU for first time Create single CY reporting period Better alignment with CMS quality reporting programs Allows for single attestation reporting period
Alignment (continued) EHR reporting for adjustment year Stage 3 Rule eliminates the exception for a 90 day EHR reporting period for new meaningful EHR users beginning with the EHR reporting period in 2017 Reporting period for a payment adjustment year will be the full calendar year that is 2 years before the payment adjustment year (for EPs and EHs) EHR reporting period for 2017 incentive payments would be full 2017 calendar year
Alignment (continued) Proposing removal of measures that are topped out In both MU measures and CQMs Further alignment to be addressed in future rulemaking
General Changes Changes to Payment Adjustments Statute requires Medicare payment adjustment beginning in 2015 Propose to maintain all payment adjustment provisions finalized in the Stage 2 rule Exception; change to the relationship between the EHR reporting period year and the payment adjustment year for CAHs
General Changes (continued) Changes to Payment Adjustments Propose to maintain four categories of exceptions Lack of internet availability A time-limited exception for newly practicing EPs or new hospitals Unforeseen circumstances such as natural disasters (EP only) exception EP at multiple locations with lack of control over the availability of CEHRT at practice locations constituting 50 percent or more of their encounters
CQM Updates CQM reporting Electronic submission encouraged in 2017 Required electronic submission in 2018 Alignment to CY will create 3-month gap in reporting(october 1 December 31, 2016) CQMs may still be required
CQM Updates (continued) CQM reporting Stage 3 ecqm measure sets & reporting requirements will be published in annual IPPS ruling Will include reporting requirements, methods, and submission periods
Timeline Rule published: March 30, 2015 Where to review: http://www.regulations.gov/#!documentdetail ;D=CMS-2015-0033-0002 NOTE: This link allows you to view comments received to date. Comment period ends: 11:59 p.m., EDT on May 29, 2015
2016 IPPS Proposed Rule
CQM Reporting Continue to report 16 of 28 IP measures Topped out measures will be retained for ecqm reporting Minimal burden Monitor effectiveness of ecqm reporting Appropriate to understand differences in chart-abstracted and electronic quality measures Impacted measures STK-6 STK-8 VTE-1 VTE-2 VTE-3
CQM Reporting (continued) CMS recognizes that measure rates between chart-abstracted and electronically captured measures may not be the same Electronic submission Helps evaluate variations Determines needed adjustments
CQM Reporting (continued) Reporting required for HIQR beginning with Q3 CY 2016 Six measures may be reported via chart-abstracted submission or electronic CQM submission ED-1 ED-2 STK-4 VTE-5 VTE-6 PC-01 Hospitals may choose to submit by either method If reporting via chart abstraction - must be reported for full year If electronic reporting, may report on Q3 and Q4 and measures will count as 6 of the 16 required for ecqm reporting
CQM Reporting (continued) Public reporting will be delayed Measure reported electronically will be footnoted (1) the hospital submitted data via EHR (2) data are being processed and analyzed (3) CMS will eventually publicly report this data once CMS determines the data to be reliable and accurate Timeline for public reporting will be addressed in future rulemaking
Future Considerations Use of core clinical data elements derived from EHRs for use in future quality measures For example, risk adjustment of outcome measures Collection of additional administrative linkage variables to link a patient s episode of care from EHR data with his administrative claim data Use of content exchange standards
Timeline Rule published: March 30, 2015 Where to review: http://www.regulations.gov/#!documentdetail ;D=CMS-2015-0049-0004 NOTE: Comments are not displayed Comment period ends: 11:59 p.m., EDT on June 16, 2015
Preparing for Stage 3
Preparing for Stage 3 and Beyond Review Rules and COMMENT Validation of CQMs PARTICIPATE! Do not minimize importance of security measures Encrypted data storage Audit logs Timely installation of software security updates Regular SRAs
Preparing for Stage 3 and Beyond (continued) Be aware of challenges eprescribing increases from 50 to 80% Diagnostic imaging added to CPOE Patient access to health information Stage 3 no longer requires that a certain % of patients actually take action, but must be able to access within 24 hours
Stakeholder Engagement Involve in all aspects of MU Decision makers or Followers? Champions Educate, Educate, Educate
CMS published 2016 CQM logic in early May Significant changes aimed at improving accurate representation of patient care Currently performing impact analysis OVERVIEW: Wednesday, June 3, 2015 at 11:30 a.m., CDT
Thanks for attending. Are there any questions? Carla McCorkle, Midas+ Solutions CQM Product Lead carla.mccorkle@xerox.com