Updates to the EHR Incentive Programs - 2014 Jason Felts, MS, CSCS HIT Practice Advisor
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Jason Felts, MS Jason Felts has more than six years of experience in healthcare and currently works as a Health Information Technology (HIT) Practice Advisor for the Oklahoma Foundation for Medical Quality. He currently works with multiple physician practices and hospitals throughout the state of Oklahoma and serves as a consultant for meaningful use, workflow redesign, privacy and security of health information systems, and many other Health IT related issues. Jason serves as the meaningful use coordinator for the Regional Extension Center. He is a member of the Meaningful Use Burning Issues Group. This elite group of individuals fields questions nationally about meaningful use from healthcare providers and other Regional Extension Centers.
Background August 29, 2014 CMS released a new rule allowing flexibility in the use of Certified EHR Technology (CEHRT) for 2014. This rule allows providers (EPs) and hospitals (EHs) to attest to Stage 1 or Stage 2 based on the ability to fully implement 2014 CEHRT. This revised rule went into effect October 1, 2014
Changes & Revisions No changes to stage 2 objectives and measures or revisions to reporting periods other than 2014 Fall outside the scope of this proposed rule No changes to existing measures or exclusions There were 3 CEHRT options created will not extend past 2014 No changes to 2015 or subsequent years would put the forward progress of the program at risk and cause further delay in implementing effective health IT infrastructure.
CEHRT Editions A. Using 2011 Edition CEHRT Only B. Using a Combination of 2011 and 2014 Edition CEHRT C. Using 2014 Edition CEHRT
ONC CHPL Website
Stage 1 2013 Objectives Core CPOE Drug-drug/drug-allergy interactions Problem list erx Medication list Allergy list Demographics Core (cont.) Vital signs Smoking status CDSS 1 rule Electronic copy of health info Clinical visit summaries Security risk analysis
Stage 1-2013 Menu Implement drug formulary Structured lab results List of patients by condition Patient reminders Timely electronic access Patient education Medication reconciliation Summary of care Menu (Public Health) Immunization registry Syndromic surveillance data Not available in OK
Stage 1-2014 CPOE all medication orders instead of by unique patients Patient portal objective required View, download, transmit Core objective Must meet 50% threshold patients registered Not responsible for 2 nd measure 5% patient usage Merged timely access and electronic copy objectives
Stage 1-2014 Vital Signs Age range changed to all patients 3+ (instead of 2+) Exclusions added Can exclude BP or height & weight instead of excluding all 3 Exclusions Do not count toward your total number of menu objectives
WHO GETS TO DO STAGE 1 AGAIN??? 16
Basis for using one of the CEHRT options Stems from a problem with installing software due to vendor delays and fully implementing 2014 CEHRT in time for a full reporting period in 2014 Fully implemented includes training, workflows and related activities ONC could not state a hard or exact date for being fully implemented Case-by case basis
Flex Options *Providers who choose one of these options must attest that they are unable to fully implement 2014 Edition CEHRT because of issues related to 2014 Edition CEHRT availability delays when they attest to MU objectives and measures. Reason must be attributable to the issues related to software development, certification, implementation, testing or release of the product by the EHR vendor
Permissible reasons for using CEHRT options Could not create an exhaustive list of all permissible reasons Instead, they gave examples of what DOES NOT count as a permissible reason for using CEHRT options
Does NOT Include Financial issues or costs associated with implementing, upgrading or installing Cost concerns related to things like insufficient internet access and barriers to obtaining infrastructure (i.e. broadband access) file an application for a hardship exception Staff turnover and changes
Does NOT include Issues related to the Meaningful Use objectives and measures Failure to meet one of the stage 2 measure thresholds Failure to conduct the activities required to meet a measure (i.e. registering with OSDH for immunizations/lab, or conducting a security risk analysis)
Security Risk Analysis Does my risk analysis have to be done during my EHR reporting period? No, you must conduct or review an SRA at least once prior to the end of the reporting period. This could occur prior to the beginning of your reporting period. Should be completed within the same program year of attestation.
Does NOT include Lastly, does not include Situations stemming from a provider s inaction or delay in implementing 2014 Edition CEHRT These situations include providers waiting too long to engage a vendor or a provider s inability or refusal to purchase the requisite software update All of these circumstances would not be permissible reasons to use the CEHRT options
Summary of Care Measure 1: Provide a SOC for 50% of transitions of care or referrals Measure 2: 10% of SOC records must be transmitted electronically
Summary of Care EPs and EHs that cannot meet the 2 nd measure of the SOC objective (i.e. 10% sent electronically) due to the intermediary or recipient of the transition or referral experiencing delays in ability to fully implement CEHRT have the ability to choose on the CEHRT options. Referring provider must retain documentation clearly demonstrating that they were unable to meet the 10% threshold
Summary of Care What does this mean? An EP or EH can chose a CEHRT option if there are not enough other facilities that they refer to frequently that have 2014 Edition CEHRT in place This can include long-term care, home health, hospitals, specialists, etc. Must retain documentation
Adopt, Implement, Upgrade AIU now applies to 2014 CEHRT only Cannot receive an AIU payment if you adopt 2011 CEHRT or a combination of 2011 and 2014 CEHRT
Practicing in multiple locations If a provider practices in multiple locations, but not all locations have 2014 Edition CEHRT, can the choose one of the CEHRT options? The CEHRT options do apply, unless over 50% of encounters occur at a location with 2014 CEHRT in place, then the options do not apply.
Attestation When attesting EPs and EHs will chose to what measures they are attesting: 2013 stage 1, 2014 stage 1, or stage 2 If you choose 2013 or 2014 stage 1, you will have to attest to an additional statement saying that you were unable to fully implement 2014 CEHRT No additional documentation is needed at the time you attest, but will need additional documentation for an audit
Attestation and Audits Documentation to retain to support the not fully implemented requirement: Ticket numbers Emails with vendor Project plans Must retain documentation for CEHRT options for 6 years post-attestation
CQMs 2011 CEHRT 3 core/3 alt core and 3 of list of 44 Combo 2011 & 2014 Stage 1 2013 option use 2011 CQMs Stage 1 2014 option use 2014 CQMs In 2014 you can choose to submit through attestation or submit electronically If using 2011 CEHRT, you must submit CQMs through attestation
Stage 3 No additional changes made to Stage 3, must wait for stage 3 proposed rule Stage 3 will begin in 2017 at the earliest for all EPs and EHs
Payment Adjustments No changes were made to timelines for payment adjustments 1 st time attesters still must attest by end of 3 rd quarter 2014 to avoid 2015 payment reduction*** They can attest to any 90 days (i.e. after 3 rd quarter) and avoid 2016 payment reductions
Hardship Applications CMS has re-opened the submission period for hardship exception applications Who should file for a hardship? Providers that did not achieve MU in 2013 First time attesters that did not achieve MU in the first 3 quarters of 2014 This applications is to avoid the 2015 payment reduction
Hardship Exceptions Hardship Extension Application Online form Due 11/30/2014 New Exception Category: Unforeseen and/or Uncontrollable Circumstances: EHR Certification/Vendor Issues You will need your CMS EHR Certification ID http://onc-chpl.force.com/ehrcert
Hardship Exceptions Hardship exceptions for the 2016 payment reduction will be available next year and should be completed by April 1, 2015 for EHs and July 1, 2015 for EPs
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