THE MEANING OF MEANINGFUL USE CHANGES IN THE STAGE 2 MU FINAL RULE Angel L. Moore, MAEd, RHIA Eastern AHEC REC
WE WILL BRIEFLY DISCUSS Meaningful Use (MU) Incentive Programs, Eligibility & Timelines
WE WILL BRIEFLY DISCUSS CMS Stage 2 Final Rule Stage 2 Criteria Stage 1 Changes Additional Changes/Revisions (2013 and 2014) Medicaid Volume Calculation Changes Payment Adjustments & Hardship Exemptions The meaning behind all of it
Meaningful Use
MEANINGFUL USE Health Information Technology for Economic and Clinical Health Act (HITECH Act) CEHRT Meaningful Use Requirements Core and Menu HIT Objectives Core and Menu Clinical Quality Measures Incentive Penalty
MEANINGFUL USE Using certified technology in EHR implementation to: Improve quality, safety, efficiency, and reduce health disparities Engage patients and family Improve care coordination, and population and public health Maintain privacy and security of patient health information
Incentive Programs, Eligibility & Timelines
WHEN DO I MEET STAGE 2 MEANINGFUL USE?
Brief Synopsis of Stage 2 Changes (Core and Menu)
STAGE 1 VS. STAGE 2 STAGE 1 15 CORE OBJECTIVES 5 OF 10 MENU OBJECTIVES STAGE 2 17 CORE OBJECTIVES 3 OF 6 MENU OBJECTIVES
STAGE 1 OBJECTIVES STAGE 2 OBJECTIVES Implement drug-drug & drug-allergy interaction checks Maintain up to date problem list Maintain active medication list Maintain active med allergy list
STAGE 1 OBJECTIVES STAGE 2 OBJECTIVES Report CQMs to CMS or the States Conduct test to demonstrate capability to exchange key clinical health information among providers Enable and have access to at least one drug formulary Provide patients with timely electronic access to their health information within 4 days
STAGE 1 MENU OBJECTIVES = STAGE 2 CORE OBJECTIVES Clinical lab test results Generate a list of patients by diagnosis Use EHR to identify and provide patient education Patient Reminders Summary of Care Medication Reconciliation Submit data to NCIR
NEW MEASURES TO STAGE 2 CORE OBJECTIVES SECURE ELECTRONIC MESSAGING PATIENT ENGAGEMENT Ability to view online, download and transmit health information *5% of patients must message provider *5% of patients must access their health information online
A Comparative Analysis of Stages 1 and 2
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure Summary of Changes Use CPOE for medication orders directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local and professional guidelines More than 30% of unique patients with at least one medication in their medication list seen by the EP have at least one medication order entered using CPOE 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 More than 60% of medication, 30% of laboratory, and 30% of radiology orders created by the EP during the EHR reporting period are recorded using CPOE *Increased thresholds/percentages *Additional order types *FINAL RULE PRESENTS ADDITIONAL CHANGESsee additional slides for details Implement drug-drug and drug-allergy interaction checks The EP has enabled this functionality for the entire EHR reporting period No longer a separate objective for Stage 2 This measure is incorporated into the Stage 2 Clinical Decision Support measure *Removed Generate and transmit permissible prescriptions electronically (erx) More than 40% of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technology Generate and transmit permissible prescriptions electronically (erx) More than 50% of all permissible prescriptions written by the EP are compared to at least one drug formulary and transmitted electronically using Certified EHR Technology *Increased from 40% to 50% *Stage 1 Menu item incorporated into the Stage 2 Core Item *FINAL RULE PRESENTS ADDITIONAL CHANGESsee additional slides for details
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure Summary of Changes Record demographics Preferred language Gender Race Ethnicity Date of birth More than 50% of all unique patients seen by the EP have demographics recorded as structured data Record the following demographics Preferred language Gender Race Ethnicity Date of birth More than 80% of all unique patients seen by the EP have demographics recorded as structured data *Increased threshold from 50% to 80% Maintain an up-to-date problem list of current and active diagnoses More than 80% of all unique patients seen by the EP have at least one entry or an indication that no problems are known for the patient recorded as structured data No longer a separate objective for Stage 2 This measure is incorporated into the Stage 2 measure of Summary of Care Document at Transitions of Care and Referrals *Removed Maintain active medication list More than 80% of all unique patients seen by the EP have at least one entry (or an indication that the patient is not currently prescribed any medication) recorded as structured data No longer a separate objective for Stage 2 This measure is incorporated into the Stage 2 measure of Summary of Care Document at Transitions of Care and Referrals *Removed
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure Summary of Changes Maintain active medication allergy list More than 80% of all unique patients seen by the EP have at least one entry (or an indication that the patient has no known medication allergies) recorded as structured data No longer a separate objective for Stage 2 This measure is incorporated into the Stage 2 measure of Summary of Care Document at Transitions of Care and Referrals *Removed Record and chart changes in vital signs: Height Weight Blood pressure Calculate and display BMI Plot and display growth charts for children 2-20 years, including BMI For more than 50% of all unique patients age 2 and over seen by the EP, blood pressure, height and weight are recorded as structured data Record and chart changes in vital signs: Height Weight Blood pressure (age 3 and over) Calculate and display BMI Plot and display growth charts for patients 0-20 years, including BMI More than 80% of all unique patients seen by the EP have blood pressure (for patients age 3 and over only) and height and weight (for all ages) recorded as structured data *Measure changes **FINAL RULE PRESENTS ADDITIONAL CHANGESsee additional slides for details Record smoking status for patients 13 years old or older More than 50% of all unique patients 13 years old or older seen by the EP have smoking status recorded as structured data Record smoking status for patients 13 years old or older More than 80% of all unique patients 13 years old or older seen by the EP have smoking status recorded as structured data *Increased threshold from 50% to 80%
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure Summary of Changes Implement one clinical decision support rule relevant to specialty or high clinical priority along with the ability to track compliance that rule Implement one clinical decision support rule Use clinical decision support to improve performance on highpriority health conditions 1. Implement 5 clinical decision support interventions related to 4 or more clinical quality measures, if applicable, at a relevant point in patient care for the entire EHR reporting period. 2. The EP has enabled the functionality for drugdrug and drug-allergy interaction checks for the entire EHR reporting period *Increased number of CDSRs must be enabled *Previous stage 1 core item (drug interaction checks) incorporated into this stage 2 measure Report clinical quality measures (CQMs) to CMS or the States Provide aggregate numerator, denominator, and exclusions through attestation or through the PQRS Electronic Reporting Pilot No longer a separate objective for Stage 2, but providers must still submit CQMs to CMS or the States in order to achieve meaningful use Starting in 2014, all CQMs will be submitted electronically to CMS *Removed *Deemed as a part of the definition of meaningful use *FINAL RULE PRESENTS ADDITIONAL CHANGES-see additional slides for details
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure Summary of Changes Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, medication allergies), upon request More than 50% of all patients of the EP who request an electronic copy of their health information are provided it within 3 business days Provide patients the ability to view online, download and transmit their health information within four business days of the information being available to the EP i. More than 50% of all unique patients seen by the EP during the EHR reporting period are provided timely (available to the patient within 4 business days after the information is available to the EP) online access to their health information ii. More than 5% of all unique patients seen by the EP during the EHR reporting period (or their authorized representatives) view, download, or transmit to a third party their health information *New *Changed from upon request to a requirement *Additional requirement that patient must access their health information *PATIENT ENGAGEMENT *FINAL RULE PRESENTS ADDITIONAL CHANGES-see additional slides for details
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure Summary of Changes Provide clinical summaries for patients for each office visit Clinical summaries provided to patients for more than 50% of all office visits within 3 business days Provide clinical summaries for patients for each office visit Clinical summaries provided to patients within one business day for more than 50% of office visits *Decreased time to provide clinical summaries Capability to exchange key clinical information (for example, problem list, medication list, medication allergies, diagnostic test results), among providers of care and patient authorized entities electronically Performed at least one test of certified EHR technology's capacity to electronically exchange key clinical information This objective is eliminated from Stage 1 in 2013 and is no longer an objective for Stage 2 This measure is eliminated from Stage 1 in 2013 and is no longer a measure for Stage 2 *Removed *FINAL RULE PRESENTS ADDITIONAL CHANGESsee additional slides for details Protect electronic health information created or maintained by the certified EHR technology through the implementation of appropriate technical capabilities Conduct or review a security risk analysis per 45 CFR 164.308 (a)(1) and implement security updates as necessary and correct identified security deficiencies as part of its risk management process Protect electronic health information created or maintained by the Certified EHR Technology through the implementation of appropriate technical capabilities. Conduct or review a security risk analysis in accordance with the requirements under 45 CFR 164.308 (a)(1), including addressing the encryption/security of data at rest and implement security updates as necessary and correct identified security deficiencies as part of its risk management process *None *Please review new HIPAA Omnibus Final Rule
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure Summary of Changes Implement drugformulary checks (MENU) The EP has enabled this functionality and has access to at least one internal or external drug formulary for the entire EHR reporting period No longer a separate objective for Stage 2 This measure is incorporated into the e- Prescribing measure for Stage 2 *Removed Incorporate clinical labtest results into certified EHR technology as structured data (MENU) More than 40% of all clinical lab tests results ordered by the EP during the EHR reporting period whose results are either in a positive/negative or numerical format are incorporated in certified EHR technology as structured data Incorporate clinical labtest results into Certified EHR Technology as structured data (CORE) More than 55% of all clinical lab tests results ordered by the EP during the EHR reporting period whose results are either in a positive/negative or numerical format are incorporated in Certified EHR Technology as structured data *Moved from menu to core *Increased threshold from 40% to 55% Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research or outreach Generate at least one report listing patients of the EP with a specific condition Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research, or outreach Generate at least one report listing patients of the EP with a specific condition *Moved from menu to core (MENU) (CORE)
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure Summary of changes Send reminders to patients per patient preference for preventive/ follow up care (MENU) More than 20% of all unique patients 65 years or older or 5 years old or younger were sent an appropriate reminder during the EHR reporting period Use clinically relevant information to identify patients who should receive reminders for preventive/follow-up care (CORE) Use EHR to identify and provide reminders for preventive/follow-up care for more than 10% of patients with two or more office visits in the last 2 years *Measure change Provide patients with timely electronic access to their health information (including lab results, problem list, medication lists, medication allergies) within four business days of the information being available to the EP (MENU) More than 10% of all unique patients seen by the EP are provided timely (available to the patient within four business days of being updated in the certified EHR technology) electronic access to their health information subject to the EP s discretion to withhold certain information This objective is eliminated from Stage 1 in 2014 and is no longer an objective for Stage 2 This measure is eliminated from Stage 1 in 2014 and is no longer a measure for Stage 2 *Removed *FINAL RULE PRESENTS ADDITIONAL CHANGESsee additional slides for details
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure Summary of Changes Use certified EHR technology to identify patient-specific education resources and provide those resources to the patient if appropriate (MENU) More than 10% of all unique patients seen by the EP are provided patientspecific education resources Use certified EHR technology to identify patient-specific education resources and provide those resources to the patient if appropriate (CORE) Patient-specific education resources identified by CEHRT are provided to patients for more than 10% of all unique patients with office visits seen by the EP during the EHR reporting period *Moved from menu to core 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 The EP performs medication reconciliation for more than 50% of transitions of care in which the patient is transitioned into the care of the EP 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 The EP performs medication reconciliation for more than 50% of transitions of care in which the patient is transitioned into the care of the EP *Moved from menu to core (MENU) (CORE)
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure Any additional changes? The EP who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care should provide summary of care record for each transition of care or referral The EP who transitions or refers their patient to another setting of care or provider of care provides a summary of care record for more than 50% of transitions of care and referrals The EP who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care should provide summary of care record for each transition of care or referral Provide summary of care document for more than 50% of transitions of care and referrals with 10% sent electronically and at least one sent to a recipient with a different EHR vendor or a CMS test system *Moved from menu to core *Health information exchange required (MENU) (CORE) Capability to submit electronic data to immunization registries or Immunization Information Systems and actual submission except where prohibited and in accordance with applicable law and practice (MENU) Performed at least one test of certified EHR technology's capacity to submit electronic data to immunization registries and follow up submission if the test is successful (unless none of the immunization registries to which the EP submits such information have the capacity to receive the information electronically) Capability to submit electronic data to immunization registries or Immunization Information Systems and actual submission except where prohibited and in accordance with applicable law and practice (CORE) Successful ongoing submission of electronic immunization data from Certified EHR Technology to an immunization registry or immunization information system for the entire EHR reporting period *Moved from menu to core
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure Any additional changes? New Stage 2 Measure (Not a Stage 1 Measure) New Stage 2 Measure (Not a Stage 1 Measure) Use secure electronic messaging to communicate with patients on relevant health information A secure message was sent using the electronic messaging function of Certified EHR Technology by more than 5% of unique patients seen during the EHR reporting period NO
Stage 2 MENU Objective Imaging Results Stage 2 MENU Measure More than 10% of imaging results are accessible through Certified EHR Technology Family History Record family health history for more than 20% Syndromic Surveillance Cancer Specialized Registry Successful ongoing transmission of syndromic surveillance data Successful ongoing transmission of cancer case information Successful ongoing transmission of data to a specialized registry Progress Notes Enter an electronic progress note for more than 30% of unique patients
CMS Stage 2 Final Rule: Stage 1 Changes
2013 STAGE 1 CHANGES Exchange of key clinical information no longer required in 2013 Clinical Quality Measures no longer separate core objective in 2013, but still required to report CQMs
2013 STAGE 1 CHANGES CPOE optional alternate measure in 2013 that becomes required in 2014 for stage 2 attesters You will always have 2 options for stage 1 e-prescribing new exclusion added effective 2013 Providers not within a 10 mile radius of a pharmacy that accepts electronic prescriptions Vital Signs optional new measure and exclusions in 2013 that becomes required in 2014
2014 STAGE 1 CHANGES Electronic Copy of and Electronic Access to Health Information (core and menu) Replaced with the requirement that you must provide patients ability to view online, download, and transmit their health information within 4 days (to more than 50% of unique patients seen by EP) Menu Exclusions can t claim exclusion if there are other objectives you can meet *Vital Signs optional new stage 1 measure in 2013 becomes required stage 1 measure This impacts both stages in 2014
CMS STAGE 2 FINAL RULE: ADDITIONAL CHANGES In 2014, providers will have to upgrade to or adopt certified systems that meet the 2014 certification criteria 2014 3 month reporting period NO MATTER THE STAGE YOU ARE REPORTING 2014 Batch Reporting for Core and Menu Items
PAYMENT ADJUSTMENTS & HARDSHIP EXEMPTIONS
PAYMENT ADJUSTMENTS & HARDSHIP EXEMPTIONS Infrastructure (in an area without internet access) Unforeseen circumstances (example: natural disaster) New EP s (newly practicing providers who haven t had time to meet MU can apply for 2 year extension) By specialist/provider type (certain provider types may meet 3 required areas to be exempt) Follow link for more information http://www.cms.gov/regulations-and-guidance/legislation/ehrincentiveprograms/downloads/paymentadj_hardshipexceptipsheetforep.pdf
MEDICAID VOLUME CALCULATION CHANGES Now includes zero pay claims Under Stage 2 rule (applicable to all stages), States also have option to allow providers to calculate Medicaid patient volume across 90-day period in last 12 months preceding provider s attestation
THE MEANING BEHIND IT ALL Stage 1: Meaningful use criteria focus on: Stage 2: Meaningful use criteria focus on: Stage 3: Meaningful use criteria focus on: Electronically capturing health information in a standardized format More rigorous health information exchange (HIE) Improving quality, safety, and efficiency, leading to improved health outcomes Using that information to track key clinical conditions Increased requirements for e-prescribing and incorporating lab results Decision support for national high-priority conditions Communicating that information for care coordination processes Electronic transmission of patient care summaries across multiple settings Patient access to self-management tools Initiating the reporting of clinical quality measures and public health information More patient-controlled data Access to comprehensive patient data through patient-centered HIE Using information to engage patients and their families in their care Improving population health
THE MEANING BEHIND IT ALL http://www.youtube.com/watch?v=hikmck-zibi&feature=share&list=uuqynwrkixfpyucxqkaz001w
FOR COMPLETE STAGE 2 INFORMATION Stage 1 Changes Tip Sheet http://www.cms.gov/regulations-and- Guidance/Legislation/EHRIncentivePrograms/Downloads/Stage1ChangesTipsheet. pdf CMS Webpage with several stage 2 links http://www.cms.gov/regulations-and- Guidance/Legislation/EHRIncentivePrograms/Stage_2.html MU Stage 2 Final Rule http://www.ofr.gov/(x(1)s(uzclbwrx5fwqm2w2mipkysrh))/ofrupload/ofrdata/ 2012-21050_PI.pdf 42
RESOURCES/REFERENCES Healthit.gov US Department of Health and Human Services ONC Website CMS Stage 2 MU Final Rule CCME (ccmeconsulting.org) CMS Website Stage 1 Changes Tipsheet Stage 1 vs. Stage 2 Comparison