Overview of the CMS Modification to Meaningful Use 2015 through 2017

Transcription

1 Overview f the CMS Mdificatin t Meaningful Use 2015 thrugh 2017 On April 10, 2015, the Centers fr Medicare & Medicaid Services (CMS) issued a new prpsed rule fr the Medicare and Medicaid EHR Incentive (meaningful use) Prgrams t, accrding t the agency, align Stage 1 and Stage 2 bjectives and measures with the lng-term prpsals fr Stage 3, build prgress tward prgram milestnes, reduce cmplexity and simplify reprting. Highlights The prpsed rule wuld streamline reprting requirements. T accmplish these gals, the NPRM prpses t Reduce the verall number f bjectives; Remve measures that have becme redundant, duplicative r have reached widespread adptin; Significantly reduce the reprting requirements fr the patient electrnic access requirements (view, dwnlad and transmit/secure messaging); Allw a 90 day reprting perid in 2015 t accmmdate the implementatin f these prpsed changes in 2015; Realign the reprting perid beginning in 2015, s hspitals wuld participate n the calendar year instead f the fiscal year. Summary f Majr Prvisins EHR Reprting Perid in 2015 and 2016 Fr 2015 and 2016, CMS prpses allwing new participants in meaningful use t attest fr an EHR reprting perid f any cntinuus 90-day perid within the calendar year. Fr 2015 nly, CMS prpses allwing all EPs (regardless f prir participatin in the prgram) t attest t an EHR reprting perid f any cntinuus 90-day perid within the calendar year. The agency states that this 90-day EHR reprting perid fr 2015 wuld allw EPs additinal time t address any remaining issues with implementatin f technlgy certified t the 2014 Editin and accmmdate changes t the bjectives and measures f meaningful use prpsed in this rule. In 2016, CMS prpses that EPs demnstrating meaningful use fr the first time may use an EHR reprting perid f any cntinuus 90-day perid between Jan. 1, 2016 and Dec. 31, Hwever, all returning participants wuld use an EHR reprting perid f a full calendar year frm Jan. 1, 2016 thrugh Dec. 31, In 2017 all EPs, including bth new and existing participants, wuld use an EHR reprting perid f ne full calendar year as prpsed in the Stage 3 prpsed rule, with a limited exceptin fr Medicaid EPs demnstrating meaningful use fr the first time. Page 1 f Pennsylvania Ave. NW, #600. Washingtn, DC T F mgma.rg

2 CMS als prpses aligning the definitin f an EHR reprting perid with the calendar year fr all EPs beginning in 2015 and cntinuing thrugh 2016 nward. Specifically, this wuld change the EHR reprting perid fr eligible hspitals and critical access hspitals frm the fiscal year t the calendar year beginning in Meaningful Use Objectives and Measures fr 2015 thrugh 2017 Similar t what CMS prpsed in the Stage 3 rule, the agency has identified bjectives and measures fund t be redundant, duplicative r tpped ut, and wuld n lnger require these fr successful demnstratin f meaningful use. These changes wuld remve the menu and cre structure f Stages 1 and 2 and reduce the verall number f bjectives t which a prvider must attest. The fllwing bjectives are prpsed t be n lnger required t be reprted: Recrd Demgraphics Recrd Vital Signs Recrd Smking Status Clinical Summaries Structured Lab Results Patient List Patient Reminders Summary f Care Measure 1 Any Methd Measure 3 Test Electrnic Ntes Imaging Results Family Health Histry In additin, CMS prpses changes t individual bjectives and measures fr Stage 2 f meaningful use as fllws: Changing the threshld fr the Stage 2 Objective fr Patient Electrnic Access secnd measure frm "5%" t "equal t r greater than ne. Cnverting the threshld fr the Stage 2 Objective Secure Electrnic Messaging frm a percentage-based measure t a yes/n respnse regarding whether functinality is fully enabled. Cnslidating all public health reprting bjectives int ne bjective with measure ptins fllwing the structure f the Stage 3 Public Health Reprting Objective. CMS ntes that these prpsals include prvisins t maintain the existing definitins fr the bjectives and measures, including numeratr and denminatr calculatin, prvisins t maintain measure threshlds fr 2015, and prvisins t allw exclusins fr certain EPs in 2015 in rder t facilitate the transitin fr EPs already engaged in the wrkflws, data capture and measure calculatin fr an EHR reprting perid in Page 2 f Pennsylvania Ave. NW, #600. Washingtn, DC T F mgma.rg

3 Current stage structure, retained bjectives and prpsed structure Current Stage 1 Structure Retained Objectives Prpsed Structure - 13 cre bjectives - 5 f 9 menu bjectives (including 1 public health bjective) - 6 cre bjectives - 3 menu bjectives - 2 public health bjectives - 9 cre bjectives - 1 public health bjective (2 measure ptins) Current Stage 2 Structure Retained Objectives Prpsed Structure - 17 cre bjectives - 3 f 6 menu bjectives (including public health bjectives) - 9 cre bjectives - 0 menu bjectives - 4 public health bjectives - 9 cre bjectives - 1 public health bjective (2 measure ptins) Certificatin Requirements Under this prpsed rule, CMS des nt prpse changes t the individual certificatin requirements fr the bjectives and measures f meaningful use fr an EHR reprting perid in 2015 thrugh Until a transitin t EHR technlgy certified t the 2015 Editin is required (included in the Stage 3 prpsed rule beginning with an EHR reprting perid in 2018), CMS prpses that EPs wuld cntinue t use EHR technlgy certified t the 2014 Editin fr an EHR reprting perid in 2015, 2016 and As utlined in the Stage 3 prpsed rule, EPs may upgrade early t EHR technlgy certified t the 2015 Editin fr an EHR reprting perid prir t Medicaid EHR Incentive Prgram in 2015 thrugh 2017 CMS states that the prpsals included in this rule wuld als apply fr the Medicaid EHR Incentive Prgram, including the prpsed changes t the EHR reprting perid in 2015 and 2016, and the bjectives and measures required t demnstrate meaningful use in 2015 thrugh Cnsistent with the Stage 3 prpsed rule, CMS prpses cntinuing t ffer states flexibility under the Medicaid EHR Incentive Prgram fr the public health reprting bjective. Fr meaningful use in 2015 thrugh 2017, CMS wuld cntinue the plicy stated in the Stage 2 final rule allwing states t specify the means f transmissin f data r therwise change the public health measure (as lng as it des nt require EHR functinality abve and beynd that which is included in the certificatin requirements specified under the 2014 Editin certificatin criteria). Page 3 f Pennsylvania Ave. NW, #600. Washingtn, DC T F mgma.rg

4 Clinical Quality Measurement CMS des nt prpse changes t the Clinical Quality Measures (CQM) selectin r reprting scheme (9 r 16 CQMs acrss at least 3 dmains) frm current CQM requirements fr all EPs seeking t demnstrate meaningful use. Fr an EHR reprting perid in 2015, and fr EPs demnstrating meaningful use fr the first time in 2016, CMS is prpsing that EPs may Attest t any cntinuus 90-day perid f CQM data during the calendar year thrugh the meaningful use registratin and attestatin site; r Electrnically reprt CQM data using the established methds fr electrnic reprting. Fr 2016 and subsequent years, EPs beynd their first year f meaningful use may attest t ne full calendar year f CQM data r electrnically reprt their CQM data using the established methds fr electrnic reprting. Alternate Exclusins and Specificatins fr Meaningful Use Stage 1 EPs in 2015 CMS prpses several alternate exclusins and specificatins fr EPs scheduled t demnstrate Stage 1 f meaningful use in 2015, which wuld allw these EPs t cntinue t demnstrate meaningful use despite prpsals t use nly Stage 2 meaningful use bjectives and measures fr These prvisins fall int the fllwing tw majr categries: Maintaining specificatins fr bjectives and measures which have a lwer threshld r ther measure difference between Stage 1 and Stage 2. Establishing an exclusin fr Stage 2 measures that d nt have an equivalent Stage 1 measure assciated with any Stage 1 bjective, r where the EP did nt plan t attest t the menu bjective that wuld nw be therwise required. Fr the first categry, CMS prpses that EPs scheduled t demnstrate Stage 1 f meaningful use fr an EHR reprting perid in 2015 may attest using specificatins established fr Stage 1 bjectives and measures fr each retained bjective r measure where there is a difference in specificatins between Stages 1 and 2. Fr example, the Stage 1 electrnic prescribing bjective fr EPs requires that "mre than 40% f all permissible prescriptins written by the EP are transmitted electrnically using certified EHR technlgy. Hwever, the Stage 2 electrnic prescribing bjective requires that "mre than 50% f all permissible prescriptins written by the EP are cmpared t at least ne drug frmulary and transmitted electrnically using Certified EHR Technlgy. Therefre, fr an EHR reprting perid in 2015, EPs scheduled t demnstrate Stage 1 f meaningful use may attest using the specificatins assciated with the Stage 1 measure. CMS ntes that fr an EHR reprting perid beginning in 2016, all EPs must attest t Stage 2 specificatins fr the measure, including measure threshlds. Fr an EHR reprting perid in 2016, all EPs, including thse wh wuld therwise be scheduled fr Stage 1 in 2016, wuld be required t meet Stage 2 specificatins with n alternate exclusins. Page 4 f Pennsylvania Ave. NW, #600. Washingtn, DC T F mgma.rg

5 Fr the secnd categry, CMS ntes that sme bjectives, such as the Patient Electrnic Access bjective, have the same requirements fr ne measure (mre than 50% f patients are prvided access t view, dwnlad and transmit their health infrmatin) fr bth Stage 1 and Stage 2. Hwever, there is an additinal measure fr Stage 2 (mre than 5% f patients view, dwnlad r transmit their health infrmatin). Other bjectives, such as the Summary f Care bjective, are designated as a menu bjective fr Stage 1, but are a cre bjective fr Stage 2, and may have additinal measure requirements in Stage 2 that are nt applicable fr Stage 1. Sme Stage 2 bjectives cnsist f requirements frm multiple Stage 1 bjectives, such as drug-drug and drug-allergy decisin supprt interventins. Fr these cnslidated bjectives, all EPs wuld be required t attest t the Stage 2 bjective and measures. Fr bjectives where there is a measure that is nt equivalent between Stage 1 and Stage 2, r where the bjective mves frm menu t cre between Stage 1 and Stage 2, CMS prpses including an exclusin fr prviders wh were scheduled t demnstrate Stage 1 f meaningful use fr the 2015 EHR reprting perid. Fr example, Stage 1 EPs may be excluded frm the requirement t send an electrnic summary f care recrd fr mre than 10% f transitins f care, as required in the Stage 2 Summary f Care bjective measure 2. Alternate exclusins and specificatins fr certain meaningful use bjectives and measures fr the 2015 EHR reprting perid are defined in the descriptin f each bjective and measure in this prpsed rule. Demnstratin f Meaningful Use CMS prpses t cntinue its cmmn methd fr demnstrating meaningful use in bth the Medicare and Medicaid EHR Incentive Prgrams. The demnstratin methds CMS has adpted fr Medicare wuld autmatically be available t states fr use in their Medicaid prgrams. The agency prpses cntinuing t use attestatin as the methd fr demnstrating that an EP has met the bjectives and measures f meaningful use. In lieu f individual Medicare EP attestatin thrugh the CMS registratin and attestatin system, CMS prpses cntinuing t use the existing ptinal batch file prcess fr attestatin. CMS prpses shifting attestatin deadlines t accmmdate the prpsed switch t calendar year-based reprting fr eligible hspitals and critical access hspitals (CAHs) beginning in 2015, as well as the newly-prpsed 90-day EHR reprting perid fr all EPs in The agency additinally prpses changes t attestatin deadlines fr new meaningful EHR users in 2015 and 2016 in rder t avid Medicare payment adjustments in 2016 and Finally, CMS prpses an alternate attestatin ptin fr certain Medicaid EPs t demnstrate meaningful use in 2015 and subsequent years t avid Medicare payment adjustments. Page 5 f Pennsylvania Ave. NW, #600. Washingtn, DC T F mgma.rg

6 Payment Adjustments and Hardship Exceptins CMS prpses changes t the definitin f an EHR reprting perid regarding a payment adjustment, as well as the attestatin deadlines fr certain EPs t demnstrate meaningful use fr an EHR reprting perid in rder t avid the Medicare payment adjustment. Prpsed Objectives, Measures and Alternative Measures CPOE Prpsed Objectives Prpsed Measures fr Prviders Measure 1: Mre than 60% f medicatin rders created by the EP r authrized prviders f the eligible hspital's r CAH's inpatient r ER department (POS 21 r 23) during the EHR reprting perid are recrded using cmputerized prvider rder entry. Measure 2: Mre than 30% f labratry rders created by the EP r authrized prviders f the eligible hspital's r CAH's inpatient r ER department (POS 21 r 23) during the EHR reprting perid are recrded using cmputerized prvider rder entry. Measure 3: Mre than 30% f radilgy rders created by the EP r by authrized prviders f the eligible hspital's r CAH's inpatient r ER department (POS 21 r 23) during the EHR reprting perid are recrded using cmputerized prvider rder entry. Prpsed Alternate Measures, Exclusins and/r Specificatins fr Certain Prviders 2015 ONLY If fr an EHR reprting perid in 2015, the prvider is scheduled t demnstrate Stage 1: Alternate Measure 1: Mre than 30% f all unique patients with at least ne medicatin in their medicatin list seen by the EP r admitted t the eligible hspital's r CAH's inpatient r ER department (POS 21 r 23) during the EHR reprting perid have at least ne medicatin rder entered using CPOE; OR, mre than 30% f medicatin rders created by the EP, r authrized prviders f the eligible hspital r CAH, fr patients admitted t their inpatient r ER departments (POS 21 r 23) during the EHR reprting perid are recrded using cmputerized prvider rder entry. Alternate Exclusin fr Measure 2: Prvider may claim an exclusin fr measure 2 (labratry rders) f the Stage 2 CPOE bjective fr an EHR reprting perid in Alternate Exclusin fr Measure 3: Prvider may claim an exclusin fr measure 3 (radilgy rders) f the Stage 2 CPOE bjective fr an EHR reprting perid in Page 6 f Pennsylvania Ave. NW, #600. Washingtn, DC T F mgma.rg

7 Electrnic Prescribing Clinical Decisin Supprt Patient Electrnic Access (VDT) Measure: Mre than 50% f all permissible prescriptins, r all prescriptins, written by the EP are queried fr a drug frmulary and transmitted electrnically using Certified EHR Technlgy. Measure 1: Implement 5 clinical decisin supprt interventins related t fur r mre CQMs at a relevant pint in patient care fr the entire EHR reprting perid. Absent fur clinical quality measures related t an EP s, eligible hspital s r CAH's scpe f practice r patient ppulatin, the clinical decisin supprt interventins must be related t high-pririty health cnditins. It is suggested that 1 f the 5 clinical decisin supprt interventins be related t imprving healthcare efficiency. Measure 2: The EP, eligible hspital, r CAH has enabled and implemented the functinality fr drug-drug and drug allergy interactin checks fr the entire EHR reprting perid. Exclusin: Fr the secnd measure, any EP wh writes fewer than 100 medicatin rders during the EHR reprting perid. Measure 1: Mre than 50% f all unique patients seen by the EP during the EHR reprting perid are prvided timely (within 4 business days after the infrmatin is available t the EP) nline access t their health infrmatin (subject t the EP's discretin t withhld certain infrmatin). EP Measure 2: At least 1 patient seen by the EP (r their authrized representatives) during the EHR reprting perid views, dwnlads, r transmits his r her health infrmatin t a third party. If fr an EHR reprting perid in 2015, the prvider is scheduled t demnstrate Stage 1: Alternate EP Measure: Mre than 40% f all permissible prescriptins written by the EP are transmitted electrnically using Certified EHR Technlgy. If fr an EHR reprting perid in 2015, the prvider is scheduled t demnstrate Stage 1: Alt. Objective and Measure 1: Objective: Implement 1 clinical decisin supprt rule relevant t specialty r high clinical pririty, r high pririty hspital cnditin, alng with the ability t track cmpliance with that rule. Measure: Implement 1 clinical decisin supprt rule. Alternate Exclusin Measure 2: Prvider may claim an exclusin fr the secnd measure if fr an EHR reprting perid in 2015 they were scheduled t demnstrate Stage 1, which des nt have an equivalent measure. Page 7 f Pennsylvania Ave. NW, #600. Washingtn, DC T F mgma.rg

8 Prtect Electrnic Health Infrmatin Patient Specific Educatin Medicatin Recnciliatin Summary f Care Secure Messaging Measure: Cnduct r review a security risk analysis in accrdance with the requirements in 45 CFR (a)(1), including addressing the security (t include encryptin) f ephi data stred in Certified EHR Technlgy in accrdance with requirements in 45 CFR (a)(2)(iv) and 45 CFR (d)(3), and implement security updates as necessary and crrect identified security deficiencies as part f the EP, eligible hspital r CAHs risk management prcess. Measure: Patient-specific educatin resurces identified by Certified EHR Technlgy are prvided t patients fr mre than 10% f all unique patients with ffice visits seen by the EP during the EHR reprting perid. Measure: The EP, eligible hspital r CAH perfrms medicatin recnciliatin fr mre than 50% f transitins f care in which the patient is transitined int the care f the EP r admitted t the eligible hspital's r CAH's inpatient r ER department (POS 21 r 23). Measure: The EP, eligible hspital r CAH that transitins/refers their patient t anther setting f care r prvider f care (1) uses CEHRT t create a summary f care recrd; and (2) electrnically transmits such summary t a receiving prvider fr mre than 10% f transitins f care and referrals. Measure: During the EHR reprting perid, the capability fr patients t send and receive a secure electrnic message with the prvider was fully enabled. Nne Alternate Exclusin: Prvider may claim an exclusin fr the measure f the Stage 2 Patient Specific Educatin bjective if, fr an EHR reprting perid in 2015, they were scheduled t demnstrate Stage 1, but did nt intend t select the Stage 1 Patient Specific Educatin menu bjective. Alternate Exclusin: EP may claim an exclusin fr the measure f the Stage 2 Medicatin Recnciliatin bjective if, fr an EHR reprting perid in 2015, they were scheduled t demnstrate Stage 1 but did nt intend t select the Stage 1 Medicatin Recnciliatin menu bjective. Alternate Exclusin: Prvider may claim an exclusin fr Measure 2 f the Stage 2 Summary f Care bjective if, fr an EHR reprting perid in 2015, they were scheduled t demnstrate Stage 1, which des nt have an equivalent measure. Alternate Exclusin: An EP may claim an exclusin fr the measure if, fr a 2015 EHR reprting perid, they were scheduled t demnstrate Stage 1, which des nt have an equivalent Public Health measure. Page 8 f Pennsylvania Ave. NW, #600. Washingtn, DC T F mgma.rg

9 Public Health Reprting Measure Optin 1 Immunizatin Registry Reprting: The EP, eligible hspital, r CAH is actively engaged with a public health agency t submit immunizatin data and receive immunizatin frecasts and histries frm the public health immunizatin registry/immunizatin infrmatin system (IIS). Measure Optin 2 Syndrmic Surveillance Reprting: The EP, eligible hspital/, r CAH is actively engaged with a public health agency t submit syndrmic surveillance data frm a nnurgent care ambulatry setting fr EPs, r an ER r urgent care department fr eligible hspitals and CAHs (POS 23). Measure Optin 3 Case Reprting: The EP, eligible hspital, r CAH is actively engaged with a public health agency t submit case reprting f reprtable cnditins. Measure Optin 4 Public Health Registry Reprting: The EP, eligible hspital, r CAH is actively engaged with a public health agency t submit data t public health registries. Measure Optin 5 Clinical Data Registry Reprting: The EP, eligible hspital, r CAH is actively engaged in submitting data t a clinical data registry. Nne Page 9 f Pennsylvania Ave. NW, #600. Washingtn, DC T F mgma.rg