4/24/2015. Overcoming Stage 2 Meaningful Use Stumbling Blocks. Objectives

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1 Overcoming Stage 2 Meaningful Use Stumbling Blocks 1 Objectives Review and identify the most difficult Stage 2 Meaningful Use measures to achieve Core Measures 7 and 17 Patient Engagement Core Measure 9 Protect Electronic Health Information Core Measure 15- Summary of Care Core Measure 16, Menu Measures 1, 5, and 6 Public Health Learn tips and tricks to overcome the challenges of the difficult measures by utilizing best practices and lessons learned from M-CEITA s experience with over 5000 providers Define next steps for overcoming Meaningful Use Stage 2 challenges and be able to integrate those into their organization s meaningful use workplan 2 3 1

2 Modifications to Meaningful Use in 2015 Through NPRM Published 04/15/15 The aim of the new rule is "to align Stage 1 and Stage 2 objectives and measures with the long-term proposals for Stage 3, to build progress toward program milestones, to reduce complexity, and to simplify providers' reporting According to CMS, the proposed rule would simplify reporting requirements in several different ways: Allow a 90-day reporting period in 2015 to accommodate the implementation of these proposed changes in 2015 Realign the reporting period beginning in 2015, so hospitals would participate on the calendar year instead of the fiscal year Reduce the overall number of objectives to focus on advanced use of EHRs Remove measures that have become redundant, duplicative, or have reached widespread adoption 4 THE NPRM TURNED THE MEANINGFUL USE 5 Meaningful Use Roadmap Original Status for 2015 New Status for Status 2017 Status 2018 Status AIU AIU Modified Stage 2 Modified Stage 2 or Stage 3 Stage 3 Stage 1: Year 1 or Year 2 Modified Stage 2 with exclusions Modified Stage 2 Modified Stage 2 or Stage 3 Stage 3 Stage 2: Year 1 or Year 2 Modified Stage 2 Modified Stage 2 Modified Stage 2 or Stage 3 Stage 3 6 2

3 EP Current Stage 2 Structure 17 core objectives including public health objectives 3 of 6 menu objectives Proposed Structure 9 core objectives 1 public health objective Measures Deleted Record Demographics Record Vital Signs Record Smoking Status Clinical Summaries Structured Lab Results Patient List Patient Reminders Summary of Care Measure 1 Any Method Measure 3 Test Electronic Notes Imaging Results Family Health History 7 Proposed Objectives for Modified Stage 2 Proposed Objectives for 2015, 2016 and 2017 CPOE Proposed Measures for Providers in 2015, 2016 and 2017 Measure 1: More than 60 percent of medication orders created by the EP during the EHR reporting period are recorded using computerized provider order entry.. Measure 2: More than 30 percent of laboratory orders created by the EP during the EHR reporting period are recorded using computerized provider order entry. Electronic Prescribing Clinical Decision Support Measure 3: More than 30 percent of radiology orders created by the EP during the EHR reporting period are recorded using computerized provider order entry. EP Measure: More than 50 percent of all permissible prescriptions, or all prescriptions, written by the EP are queried for a drug formulary and transmitted electronically using Certified EHR Technology Measure 1: Implement five clinical decision support interventions related to four or more clinical quality measures Measure 2: The EP has enabled and implemented the functionality for drug-drug and drug allergy interaction checks for the entire EHR reporting period. Exclusion: For the second measure, any EP who writes fewer than 100 medication orders during the EHR reporting period. 8 Patient Electronic Access (VDT) 1. EP Measure 1: More than 50 percent of all unique patients seen by the EP during the EHR reporting period are provided timely (within 4 business days after the information is available to the EP) online access to their health information subject to the EP's discretion to withhold certain information. 1. EP Measure 2: At least one patient seen by the EP during the EHR reporting period (or their authorized representatives) views, downloads, or transmits his or her health information to a third party. Protect Electronic Health Information Patient Specific Education Measure: Conduct or review a security risk analysis in accordance with the requirements in 45 CFR (a)(1), including addressing the security (to include encryption) of ephi data stored in Certified EHR Technology in accordance with requirements in 45 CFR (a)(2)(iv) and 45 CFR (d)(3), and implement security updates as necessary and correct identified security deficiencies as part of the EP s risk management process. EP Measure: Patient-specific education resources identified by Certified EHR Technology are provided to patients for more than 10 percent of all unique patients with office visits seen by the EP during the EHR reporting period. Medication Reconciliation Measure: The EP performs medication reconciliation for more than 50 percent of transitions of care in which the patient is transitioned into the care of the EP Summary of Care Measure: The EP that transitions or refers their patient to another setting of care or provider of care (1) uses CEHRT to create a summary of care record; and (2) electronically transmits such summary to a receiving provider for more than 10 percent of transitions of care and referrals. 9 3

4 Secure Messaging Public Health All providers to select 2 of the five measures to report on Measure: During the EHR reporting period, the capability for patients to send and receive a secure electronic message with the provider was fully enabled. Measure Option 1 Immunization Registry Reporting: The EP is in active engagement with a public health agency to submit immunization data and receive immunization forecasts and histories from the public health immunization registry/immunization information system (IIS). Measure Option 2 Syndromic Surveillance Reporting: The EP is in active engagement with a public health agency to submit syndromic surveillance data from a non-urgent care ambulatory setting for EPs Measure Option 3 Case Reporting: The EP is in active engagement with a public health agency to submit case reporting of reportable conditions. Measure Option 4 Public Health Registry Reporting: The EP is in active engagement with a public health agency to submit data to public health registries. Measure Option 5 Clinical Data Registry Reporting: The EP is in active engagement to submit data to a clinical data registry. 10 Patient Engagement- Meaningful Use Stage 2 Core Measure 7- Patient Electronic Access Core Measure 17- Secure Electronic Messaging Remain Core Objectives in Modified Stage 2 Patient Electronic Access- Measure 1 More than 50 percent of all unique patients seen by the EP during the EHR reporting period are provided timely online access to their health information, with the ability to view, download, and transmit to a third party. Timely access is defined as: available to the patient within 4 business days after the information is available to the EP 4

5 Patient Electronic Access- Measure 2 More than 5 percent of all unique patients One patient seen by the EP during the EHR reporting period (or their authorized representatives) must view, download, or transmit to a third party their health information. Patient name, provider's name and office contact information, current and past problem list, procedures, laboratory test results, current medication list and medication history, current medication allergy list and medication allergy history, vital signs smoking status, demographic information, care plan field(s), including goals and instructions. Core Measure 17: Secure Electronic Messaging 5% of unique patients must send an electronic message on relevant health information to the EP. During the EHR reporting period, capability for patients to send and receive a secure electronic message with the provider was fully enabled.. Stumbling Block: Broadband Availability How do I find out if my county meets the 50% exclusion threshold for 3 MPBS broadband for the patient engagement measures? 5

6 But Wait. You re not off the hook yet. 16 Stage 3 The proposed Stage 3 Measures Include: 80% of unique patients must have electronic record availability 35% of educational resources are made available electronically 25% of patients view, download, or transmit their medical record 35% of unique patients are sent a secure message by the provider (can include responses to patient-initiated messages). 17 Why Patient Engagement and Why Now? 18 6

7 Patient Engagement Myths My patients are too old, too poor, too uneducated, too fill in the blank If we build it, they will come Sharing medical information with patients will add to provider workload 19 Don t make Assumptions The 2013 Accenture Consumer Survey on Patient Engagement showed that at least three-fourths of Medicare recipients access the Internet at least once a day for (91%) or to conduct online searches (73%) and a third access social media sites at least once a week. 60% of lower income patients in the study reported using regularly, 54% said they obtained general research information from the Internet, and 78% expressed interest in electronic communications with health care services. It also reported that 67% of Americans 65 and older say that accessing their medical information online is very or somewhat important, and 83% of U.S. seniors think that they should have full access to their electronic health records but only 28% actually do. 20 Actual Practice Example: A 500 provider group assumed their patients would not be interested. Almost 70% Medicaid Low health literacy Marketed only to commercial patients initially What they found: Medicaid patients were actually more receptive Geriatric patients signed up at high rates They now have over 1,000 messages per physician, per year through the EHR Their patients report more satisfaction with their care Family Practice Management 2013 Jan-Feb;20(1):

8 Create Awareness of Portal Benefits Create signage that changes on monthly basis that describes a benefit of the patient portal. Signage is not only in waiting room, but every exam room Every staff member who has a touch point with a patient should be providing the message of benefits of the patient portal Target Caregivers of Elderly or Chronically Ill Patients 22 Actual Practice Example: Organization temporarily assigned staff to engage patients after patient had registered, but before patient was seated in exam room. The practice set up a small office space where staff would not only verify insurance, but engaged patients by: Assisting them with setting up an address, if they did not have one Provided patient with patient portal brochure Had a demo of the portal to demonstrate to patients 23 Secure Messaging Saves Time and Money As electronic messages increase, phone calls decrease It eliminates steps since only the provider or a designee has to handle a message instead of several people Eliminates phone tag The message is automatically connected to the correct chart, decreasing errors Lab results that are delivered electronically save postage, paper, and staff time. 24 8

9 Actual Practice Example: 90% of outgoing messages are lab notifications. One office sends about 75% of these electronically after implementing the patient portal Secure messaging has helped avoid lawsuits, since the patients' actual words are recorded in the chart Provider is not limited to what can be said on a message if the patient can t answer. Creates a record of exactly what the provider said as well. Provider can see that the patient opened lab results and other communications that are sent so the patient cannot claim they were not received. Messages like: Thank you, you're the best, most caring doctor ever become part of the chart. Family Practice Management 2013 Jan-Feb;20(1): Summary of Care Core Measure 15 Remains Core Objective in Modified Stage 2 26 Summary of Care 9

10 Common Theme: Research/Ask 1. Ask your vendor 2. Research and ask your HIE 3. Ask your physician organization 4. Ask other local providers 5. Ask your vendor 28 Summary of Care Three Measures, but 29 Two measures gone in Stage 2! 30 10

11 Measure 2: Provide electronic transitions for 10% 31 Measure 2: Provide electronic transitions for 10% XDR/XDM MU SMTP Measure 2: Provide electronic transitions for 10% What does this mean in plain language? How are Providers meeting this measure in Michigan? Ask Your Vendor 11

12 Using EHR Vendor Community Exchanges Vendor may be HISP or may have contracted with HIPS EHR Vendor Provider B Uses same EHR Vendor 34 Using EHR Vendor Community Exchanges EPIC: Community Connect eclinicalworks: P2P Network Allscripts: Allscripts Community Direct Messaging 35 Using Health Information Exchanges Provider B Health Information Exchange Provider C 36 12

13 Using Health Information Exchanges ANTS Great Lakes Health Connect Ingenium Jackson Community Medical Record MHIN (Michiana Health Information Network) Northern Physicians Organization PatientPing Southeastern Michigan Health Association Southeast Michigan Health Information Exchange Upper Peninsula Health Information Exchange National ehealth Exchange (Healtheway) Using a HISP 1.EHR generates CCDA 2.EHR (certified to include optional SOAP + XDR/XDM transport) sends message to Provider B (via HISP) using SOAP + XD 3.HISP repackages content as Direct message and sends to Provider B In this scenario, the EHR must be certified to support both Direct (required) and SOAP + XDR/XDM (optional) as transport standards. The HISP does not need to be certified. This meets the MU requirement for using CEHRT. 38 Using a HISP Example: Updox More than 45 EHR vendors use Updox as their HISP Network includes Greenway, EPIC, e-mds, Amazing Charts Many providers choosing to use a HISP like Updox, as it is less expensive than other solutions

14 Using Direct Address: Provider-to-Provider 40 Using Direct Address: Provider-to-Provider Direct address looks very similar to an address If you don t know your direct address- ask your vendor Like addresses, Direct addresses can be issued to individuals or to organizations, departments, or specific devices. An example of a Direct address is Measure 2: Stumbling Blocks I am having trouble meeting the 10%. What can I count toward my numerator, and how can I configure my EHR Reference CMS FAQ #10660 regarding third-party organizations delivering Summary of Care Reference FAQ #9690 regarding including transitions between different NPIs 14

15 Measure 2: Stumbling Blocks Configuration and Workflow: Create a report identifying common referred to providers and locations Work with vendor to determine method of choice utilize either SOAP-based transport or ehealth Exchange FAQ #7697 Manually add direct addresses, and/or utilize your HISP s directory Create workflow process, addressing: Who When How 43 Applicable Exclusions Any EP who transfers a patient to another setting or refers a patient to another provider less than 100 times during the EHR reporting period is excluded from all three measures. Note: *measure not based on unique patient encounters I.e. if 2 referrals ordered in a visit, counts toward denominator twice! Don t get comfortable Stage 3 Summary of Care Transitions and Referrals: Measure 1: For more than 50 percent of transitions of care and referrals, the EP: (1) creates a summary of care record using CEHRT (2) electronically exchanges the summary of care record

16 PROTECTED HEALTH INFORMATION THROUGH CONTINUED RISK ASSESSMENT 46 WHAT IS RISK ASSESSMENT? The Health Insurance Portability and Accountability Act (HIPAA) Security Rule requires that covered entities conduct a risk assessment of their healthcare organization. A risk assessment helps your organization ensure it is compliant with HIPAA s administrative, physical, and technical safeguards. A risk assessment also helps reveal areas where your organization s protected health information (PHI) could be at risk. 9 COMMON ELEMENTS OF A RISK ASSESSMENT Elements 1-3 Scope of the Analysis Includes the potential risks and vulnerabilities to the confidentiality, availability and integrity of all e-phi that an organization creates, receives, maintains, or transmits. Data Collection Must identify where the e-phi is stored, received, maintained or transmitted. Identify and Document Potential Threats and Vulnerabilities Identify and document reasonably anticipated threats to e-phi. 16

17 9 COMMON ELEMENTS OF A RISK ASSESSMENT Elements 4-5 Assess Current Security Measures document the security measures an entity uses to safeguard e-phi, whether security measures required by the Security Rule are already in place, and if current security measures are configured and used properly. Determine the Likelihood of Threat Occurrence Documentation of all threat and vulnerability combinations with associated likelihood estimates that may impact the confidentiality, availability and integrity of e-phi of an organization. 9 COMMON ELEMENTS OF A RISK ASSESSMENT Elements 6-7 Determine the Potential Impact of Threat Occurrence Using either a qualitative or quantitative method or a combination of the two methods, an organization must create rules that document the criticality, or impact, of potential risks to confidentiality, integrity, and availability of e-phi. Determine the Level of Risk Organizations should assign risk levels for all threat and vulnerability combinations identified during the risk analysis and include a list of corrective actions that mitigate each risk level. 9 COMMON ELEMENTS OF A RISK ASSESSMENT Elements 8-9 Finalize Documentation No specific format required, but the documentation is a direct input to the risk management process. Periodic Review and Updates to the Risk Assessment Continued due diligence of the Meaningful Use Security Rule requires entities to perform reoccurring reviews and analysis of their risk assessments. The frequency of such processes may vary by entity, but should always be considered an ongoing initiative to reduce the associated risks to reasonable and appropriate levels. 17

18 THE MEANINGFUL USE CORE 15 OBJECTIVE Stage 1 - Eligible Professionals (EP), Eligible Hospitals or Critical Access Hospitals (CAH) must conduct or review a Security Risk Assessment in accordance with the requirements under 45 CFR and implement security updates as necessary and correct identified security deficiencies as part of the provider's risk management process. Stage 2 - Meet the same security risk analysis requirements as Stage 1, EPs and Hospitals will also need to address the encryption and security of data stored in the certified EHR technology (CEHRT). These steps may be completed outside or the EHR reporting period timeframe but must take place no earlier than the start of the EHR reporting year and no later than the provider attestation date. FAQ #10754 EVERY YEAR OF MEANINGFUL USE PARTICIPATION REQUIRES DUE DILLIGENCE AND RE-ASSESSMENT OF SECURITY RISKS Stumbling Blocks Is it true that all of the deficiencies have to be corrected before the attestation date? Not necessarily, as the timing of security updates and deficiency corrections is driven by the provider s risk management process. See FAQ #

19 SECURITY RISK ASSESSMENT MYTHS All of the following are common false myths related to meaningful use risk assessments. The security risk analysis is optional for small providers. Simply installing a certified EHR fulfills the security risk analysis MU requirement. My EHR vendor took care of everything I need to do about privacy and security. I have to outsource the security risk analysis. A checklist will suffice for the risk analysis requirement. There is a specific risk analysis method that I must follow. My security risk analysis only needs to look at my EHR. I only need to do a risk analysis once. Before I attest for an EHR incentive program, I must fully mitigate all risks. Each year, I ll have to completely redo my security risk analysis. SUMMARY Conduct or review a security risk assessment, remediate identified risks, as appropriate, and continually improve controls Items to consider * Access Control * Emergency Access * Automatic Log-off * Audit Log * Integrity * Authentication * Encryption * Accounting of Disclosures * Physical Security of Site(s) and Assets Meaningful Use and Public Health Core Measure 16, Menu Measures 1, 5, and 6 19

20 Under the NPRM: Consolidation of all public health measures into one objective with measure options (in addition to the 9 required objectives) EPs must select to report on any combination of 2 of the 5 available options Measure Maximum Times Measure Can Count Towards Objective for EP Measure 1 Immunization Registry Reporting 1 1 Measure 2 Syndromic SurveillanceReporting 1 1 Measure 3 Case Reporting 1 1 Measure 4 Public Health RegistryReporting* 3 4 Measure 5 Clinical Data RegistryReporting** 3 4 Measure 6 Electronic Reportable Laboratory Results N/A 1 MaximumTimes Measure Can Count Towards Objective for Eligible Hospital or CAH 58 Stumbling Block An exclusion for a measure does not count toward the total of two measures. 59 What Are the Steps for Reporting Public Health Measures? Meet any one of the three options under the umbrella of active engagement: 1. Completed Registration to Submit data 2. Testing and Validation: The EP is in the process of testing and validation of the electronic submission data. Providers must respond to requests from the PHA or CDR within 30 days Failure to respond twice would result in EP not meeting measure 3. Production: The EP has completed testing and validation of the electronic submission and is electronically submitting production data to the PHA or CDR 20

21 Michigan is Ready System Name Michigan Care Improvement Registry (MCIR) Meaningful Use Option 1- Immunization Registry Modified Stage 2 EP EH Ongoing submission Ongoing submission Michigan Syndromic Surveillance System (MSSS) Option 2 - Syndromic Surveillance Ongoing submission* Ongoing submission Case Reporting to be defined Option 3 Not yet available in Michigan Not yet available in Michigan Michigan Cancer Surveillance Program (MCSP) Option 4 -PHA Registry Ongoing submission N/A Michigan Birth Defects Registry (MBDR) Clinical Data Registries Michigan Disease Surveillance System (MDSS) Option 4 - PHA Registry Option 5- Patient safety and QI Organizations Option 6- Electronic Lab Reporting (ELR) Ongoing submission N/A Not Public Health Not Public Health N/A Ongoing submission Core Measure 16: Capability to submit electronic data to immunization registries To pass the Stage 1 and 2 requirements for Follow Up Submission, sites must submit a Registration of Intent notification stating they are actively engaged in the MCIR HL7 Data Quality Assurance (DQA) testing process. This notification must be made by to: Impact of NPRM to be determined Public Health Option 1- Immunization Registry Reporting Adding a New Eligible Professional (EP) The Health System (HS) must send an to with the following information: EP name NPI number Group NPI if applicable MCIR Site ID (associated with the EP) Name, title, and phone number of the current contact person Upon receipt of the above: The new EP s credentials are added to the original HS documentation for auditing purposes. An updated confirmation letter, from the State of Michigan, detailing the inclusion of the new EP is sent via to the contact person on file. 21

22 Public Health Option 2- Syndromic Surveillance Reporting MSSS The Michigan Syndromic Surveillance System (MSSS) is a real-time surveillance system that tracks the chief presenting complaints from healthcare providers, allowing public health officials and providers to monitor trends and investigate unusual increases in symptoms. MSSS is not accepting data from the following provider types: Dentists Dental Surgeons Optometrists/Ophthalmologists Chiropractors Certified Nurse-midwives. Public Health Option 3- Case Reporting This is a new reporting option that was not part of Stage 2. Collection of reportable conditions as defined by the state, territorial, and local PHAs to monitor disease trends and support the management of outbreaks. Examples: hypertension, diabetes, body mass index, devices, and/or other diagnoses/conditions Public Health Option 4- Public Health Registry Reporting May include reporting to national public health agency as fulfillment of this option Environmental Health Registry Evaluation for Veterans 22

23 Public Health Option 5- Clinical Data Registry Reporting Clinical data registries" are administered by, or on behalf of, other non-public health agency entities. Could include submitting PQRS data to health plans, reporting to MiPCT, etc. How Do I Submit? All the information you need is available at MichiganHealthIT.org How Soon Do I Need to Start? WARNING: You have 60 days from the start of your EHR Reporting Period to register in the Health System Testing Repository to be able to successfully attest. 23

24 M-CEITA Assistance 70 M-CEITA Assistance Subsidized assistance is still available for any Medicaid eligible provider Our assistance includes: Dedicated specialist to assist with meaningful use objectives and attestation A Security Risk Assessment to ensure federal compliance Identification of any red flags before attestation Communication liaison to assist between your vendor, the State of Michigan, CMS, and Michigan Information Exchange Pre-audit checklist to run through all of the core measures for successful completion 71 Questions Contact Information: Cindy Buege Michelle Maitland Randy Padgett

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