Meaningful Use in 2015 and Beyond Changes for Stage 2

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1 Meaningful Use in 2015 and Beyond Changes for Stage 2 Jennifer Boaz Transformation Support Specialist Proprietary 1

2 Definitions AIU = Adopt, Implement or Upgrade EP = Eligible Professional API = Application Programming Interface IIS = Immunization Information System CAH = Critical Access Hospital MU = Meaningful Use CDR = Clinical Data Registry NPRM = Notice of Proposed Rulemaking CEHRT = Certified Electronic Health ONC = Office of the National Coordinator Record Technology PHA = Public Health Agency CMS = Centers for Medicare & Medicaid Services POS = Place of Service CQM = Clinical Quality Measure R&A = Registration & Attestation System ED = Emergency Department EHR = Electronic Health Record EH = Eligible Hospital Proprietary 2

3 Agenda Changes for 2015 and beyond New timeline for 2015 and beyond Objectives and Measures Overview for Link to Final Rule of Meaningful Use Changes https://s3.amazonaws.com/publicinspection.federalregister.gov/ pdf Proprietary 3

4 Changes to EHR Incentive Programs & Meaningful Use Proprietary 4

5 Changes Beginning in 2015 Modified Stage 2 Modifications to Meaningful Use in 2015 through 2017 In January, CMS announced intent to make changes to the EHR Incentive Program and to Meaningful Use CMS released the NPRM on April 10 th announcing several changes to MU beginning in 2015 Public comments were due June 15 th Final rule was announced on October 6 th Covers Stage 2 and Stage 3 changes Proprietary 5

6 Changes Beginning in 2015 Modified Stage 2 Restructured Stage 1 and Stage 2 objectives and measures to align with Stage 3: 10 objectives for EPs, including one consolidated public health reporting objective with measure options 9 objectives for EHs and CAHs, including one consolidated public health reporting objective with measure options Proprietary 6

7 Changes Beginning in 2015 Modified Stage 2 Starting in 2015, the EHR reporting period aligns with the calendar year for all providers (Jan 1-Dec 31) EHR reporting period in 2015 changed to 90 days to accommodate modifications to Meaningful Use Streamlined the program by removing redundant, duplicative, and topped out measures CQM reporting for EPs, EHs, and CAHs remains as previously finalized Proprietary 7

8 Changes Beginning in 2015 Modified Stage 2 EPs and EHs have the option of attesting to Stage 3 in continuous day reporting period for anyone attesting to Stage 3 in 2017 Requires 2015 edition CEHRT Everyone will be required to attest to Stage 3 in 2018 The opening date for the 2015 program year will be January 4, 2016 and ending February 29, 2016, for the Medicare and Medicaid EHR Incentive Programs. The Colorado Medicaid Attestation site will not be open until approximately April of 2015, so expect this delay in attestation. Participants will not be penalized for this delay. Proprietary 8

9 Changes Beginning in 2015 Alternate Exclusions & Specifications All EPs and EHs will attest to modified Stage 2 in 2015 These will have special thresholds and exclusions those scheduled to attest to Stage 1 for 2015 only Allows providers to exclude modified Stage 2 measures in 2015 for which there is no Stage 1 equivalent Proprietary 9

10 What is not changing? Starting in 2015, all EPs and EHs must reach all MU objectives using a 2014 Edition Certified Health Record Technology (CEHRT) Adopt, Implement or Upgrade (AIU) is still available for the Medicaid EHR Incentive Program Eligibility Requirements remain the same Medicaid is accepting new providers for incentive payment Medicare will no longer accept new providers for payment https://www.cms.gov/regulations-andguidance/legislation/ehrincentiveprograms/eligibility.html#bookmark4 Proprietary 10

11 What is not changing? Clinical Quality Measures No changes to CQM selection or reporting scheme from CQM requirements in Stage 2 (EP: 9 measures, 3 domains; EH: 16 measures, 3 domains) For 2015 only, can report on continuous 90 days For 2016 and subsequent years, must report a full calendar year Electronically reporting CQMs-Continue to use established methods for electronic reporting Multiple programs (MU, PQRS), single electronic submission EPs submit full calendar year of data EHs submit 1 calendar quarter of data for 2015 (Q1, Q2, or Q3), requires use of the April 2014 release of ecqms Proprietary 11

12 Payment Adjustments Who is affected? Medicare EPs, EHs, and CAHs EPs and hospitals that bill Medicare and can participate in either the Medicare or Medicaid Incentive Programs Who is not affected? Medicaid EPs who can only participate in the Medicaid EHR Incentive Program and do not bill Medicare Proprietary 12

13 Payment Adjustments (Pg 571 of Final Rule) How are adjustments applied? Eligible Professionals Medicare physician fee schedule (PFS) amount for covered professional services furnished by EP during the year Eligible Hospitals Inpatient Prospective Payment System (IPPS) payment rate Eligible Critical Access Hospitals MCR reimbursement for inpatient services during the cost reporting period in which they failed to demonstrate MU Adjustment is 1% per year, and cumulative for every consecutive year the EP is not a meaningful user up to 5%. Proprietary 13

14 Payment Adjustments Payment Adjustments EHR Reporting Period Payment Adjustment Year % Adjustment -1% -2% -3% -4% -5% -5% Proprietary 14

15 Payment Adjustments Avoiding Adjustments EPs and EHs Demonstrate MU prior to 2015 calendar/fiscal payment adjustment year (and every year after) CAHs Demonstrate MU during the same FY the payment adjustment takes place to avoid adjustment (starting 2015 and beyond) May apply for hardship exceptions to avoid the payment adjustments Proprietary 15

16 New Proposed Timeline Proprietary 16

17 Requirements for EHR Reporting Periods Reporting period for EPs, EHs, and CAHs will be based on a calendar year. Any continuous 90 days between January 1, 2015 and December 31, 2015 (EPs) Any continuous 90 days between October 1, 2014 and December 31, 2015 (EHs and CAHs only) All providers are required to use technology certified to the 2014 edition. In 2016 and 2017, providers can choose to use a 2014 or 2015 edition. Proprietary 17

18 Requirements for EHR Reporting Periods In 2016, the EHR reporting period must be January 1 and December 31 of the calendar year New participants (EP/EH/CAH) would have an EHR reporting period of any continuous 90 day period between January 1, 2016 and December 31, 2016 In 2017, the EHR reporting period would be one full calendar year for all providers except new participants and/or providers who choose to implement Stage 3, who are allowed a 90-day reporting period Proprietary 18

19 Current Meaningful Use Timing First Program Year Incentive Payment Year * TBD TBD TBD TBD * TBD TBD TBD TBD * TBD TBD TBD * TBD TBD TBD

20 NEW Meaningful Use Timing First Year Attesting to Meaningful Use 2011 Modified Stage Modified Stage Modified Stage Modified Stage 2* 2015 Modified Stage 2* 2016 Stage of Meaningful Use N/A Modified Stage 2 Modified Stage 2 Modified Stage 2 Modified Stage 2 Modified Stage 2 Modified Stage 2 Modified Stage 2 or Stage 3 Modified Stage 2 or Stage 3 Modified Stage 2 or Stage 3 Modified Stage 2 or Stage 3 Modified Stage 2 or Stage 3 Modified Stage 2 or Stage 3 Stage 3 Stage 3 Stage 3 Stage 3 Stage 3 Stage 3 20

21 Objectives and Measures Overview for Proprietary 21

22 Eliminated Topped Out Objectives Provider Type Objective Provider Type Objective EP / EH Record Demographics EP / EH Record Vital Signs EP / EH Record Smoking Status EP Clinical Summaries EP / EH Structured Lab Results EP / EH Patient List EP / EH EH Summary of Care (Measure 1 % threshold; Measure 3 test) Electronic Medication Administration Record (emar) EP EH Patient Reminders Advanced Directives EP / EH Electronic Notes EP / EH Imaging Results EP / EH Family Health History EH Structured Labs to Ambulatory Providers 23

23 Modified Stage 2 Objectives erx was a Menu objective for EHs and will be required starting in 2015 Public Health objectives have been combined into one with multiple measures EPs and EHs scheduled to demonstrate Stage 1 in 2015 will have alternate measures and/or exclusions Eliminates menu measures and changes to all core measures Modified Stage 2 Objectives Protect Electronic Health Information Clinical Decision Support Computerized Provider Order Entry (CPOE) Electronic Prescribing (erx) Health Information Exchange (formerly known as Summary of Care) Patient Specific Education Medication Reconciliation Patient Electronic Access Secure Electronic Messaging (EP only) Public Health and Clinical Data Registry Reporting 24

24 Protect Electronic Health Information (Pg 134 of Final Rule) Objective Protect electronic health information created or maintained by the CEHRT through the implementation of appropriate technical capabilities. 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 data stored in CEHRT 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 or EH s risk management process. Exclusion/Alternate Exclusion None https://www.healthit.gov/providers-professionals/security-risk-assessment-tool 25

25 Clinical Decision Support (Pg 140 of Final Rule) Objective Use clinical decision support to improve performance on high-priority health conditions. Measure 1 Implement five (5) clinical decision support interventions related to four or more (4+) clinical quality measures at a relevant point in patient care for the entire EHR reporting period. Absent four (4) clinical quality measures related to an EP or EH scope of practice or patient population, the clinical decision support interventions must be related to high priority health conditions. Measure 2 The EP or EH has enabled and implemented the functionality for drug-drug and drug-allergy interaction checks for the entire EHR reporting period. 26

26 Clinical Decision Support (Pg 140 of Final Rule) Exclusion Any EP who writes fewer than 100 medication orders during the EHR reporting period. Alternate Exclusion Implement one (1) clinical decision support rule relevant to specialty or high clinical priority, or high-priority hospital condition, along with the ability to track compliance with that rule. Measure 1: Implement one (1) clinical decision support rule. Measure 2: Must report or take exclusion. Proprietary 26

27 Computerized Provider Order Entry (CPOE) (Pg 148 of the Final Rule) Objective Use computerized provider order entry 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. Measure 1 More than 60% of medication orders created by the EP or by authorized providers of the EH inpatient or emergency department (POS 21 or 23) during the EHR reporting period are recorded using CPOE. Measure 2 More than 30% of laboratory orders created by the EP or by authorized providers of the EH inpatient or emergency department (POS 21 or 23) during the EHR reporting period are recorded using CPOE. Measure 3 More than 30% of radiology orders created by the EP or by authorized providers of the EH inpatient or emergency department (POS 21 or 23) during the EHR reporting period are recorded using CPOE. 28

28 Computerized Provider Order Entry (CPOE) (Pg 148 of the Final Rule) Exclusion Measure 1 Exclusion: Any EP who writes fewer than 100 medication orders during the EHR reporting period. Measure 2 Exclusion: Any EP who writes fewer than 100 laboratory orders during the EHR reporting period. Measure 3 Exclusion: Any EP who writes fewer than 100 radiology orders during the EHR reporting period. EHs must meet all three measures. Alternate Exclusion Alternate Measure 1: More than 30% of all unique patients with at least one (1) medication in their medication list seen by the EP or admitted to the EH inpatient or emergency department (POS 21 or 23) during the EHR reporting period have at least one (1) medication order entered using CPOE; or more than 30% of medication orders created by the EP during the EHR reporting period, or created by the authorized providers of the EH for patients admitted to their inpatient or emergency departments (POS 21 or 23) during the EHR reporting period, are recorded using CPOE. Proprietary 28

29 Computerized Provider Order Entry (CPOE) (Pg 148 of the Final Rule) Alternate Exclusion Alternate Exclusion for Measure 2: Providers scheduled to be in stage 1 in 2015 may claim an exclusion for measure 2 (laboratory orders) of the Stage 2 CPOE objective for an EHR reporting period in 2015; and providers scheduled to be in stage 1 in 2016 may claim an exclusion for measure 2 of the Stage 2 CPOE objective for an EHR reporting period in Alternate Exclusion for Measure 3: Providers scheduled to be in Stage 1 in 2015 may claim an exclusion for measure 3 (radiology orders) of the Stage 2 CPOE objective for an EHR reporting period in 2015; and, providers scheduled to be in Stage 1 in 2016 may claim an exclusion for measure 3 of the Stage 2 CPOE objectives for an HER reporting period in Proprietary 29

30 Electronic Prescribing (erx) (Pg 164 of Final Rule) Objective EP: Generate and transmit permissible prescriptions electronically (erx). EH: Generate and transmit permissible discharge prescriptions electronically (erx). Measure EP: More than 50% of all permissible prescriptions, written by the EP are queried for a drug formulary are transmitted electronically using CEHRT. EH: More than 10% of hospital discharge mediation orders for permissible prescriptions (for new and changed prescriptions) are queried for a drug formulary and transmitted electronically using CEHRT. 31

31 Electronic Prescribing (erx) (Pg 164 of Final Rule) Exclusion EP: Writes fewer than 100 permissible prescriptions during the EHR reporting period; or Does not have a pharmacy within his or her organization and there are no pharmacies that accept electronic prescriptions within 10 miles of the EP s practice location at the start of his or her EHR reporting period. EH: Any EH that does not have an internal pharmacy that can accept electronic prescriptions and is not located within 10 miles of any pharmacy that accepts electronic prescriptions at the start of their EHR reporting period. Alternate Exclusion EP: For Stage 1 providers in 2015, more than 40% of all permissible prescriptions written by the EP are transmitted electronically using CEHRT. EH: The EH may claim an exclusion for the erx objective and measure if for an EHR reporting period in 2015 if they were either scheduled to demonstrate Stage 1, which does not have an equivalent measure, or if they are scheduled to demonstrate Stage 2 but do not select the Stage 2 erx objective for an EHR reporting period in Proprietary 31

32 Health Information Exchange (Summary of Care) (Pg 179 of Final Rule) Objective The EP or EH who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care provides a summary care record for each transitions of care or referral. Measure The EP or EH that transitions or refers their patient to another setting of care or provider of care that 1) uses CEHRT to create a summary of care record, and 2) electronically transmits such summary to a receiving providers for more than 10% of transitions of care and referrals. 33

33 Health Information Exchange (Summary of Care) (Pg 179 of Final Rule) Exclusion EP: 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. Alternate Exclusion EP or EH may claim an exclusion for the measure of the Stage 2 measure that requires the electronic transmission of a summary of care document if for an EHR reporting period in 2015, they were scheduled to demonstrate Stage 1, which does not have an equivalent measure. Proprietary 33

34 Patient Specific Education (Pg 193 of Final Rule) Objective EP: Use clinically relevant information from CEHRT to identify patient-specific education resources and provide those resources to the patient. EH: Use clinically relevant information from CEHRT to identify patient-specific education resources and provide those resources to the patient. Measure EP: 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. EH: More than 10% of all unique patients admitted to the EH s inpatient or emergency department (POS 21 or 23) are provided patient specific education resources identified by CEHRT. 35

35 Patient Specific Education (Pg 193 of Final Rule) Exclusion EP: Any EP who has no office visits during the EHR reporting period. EH: None Alternate Exclusion EP or EH may claim an exclusion if for an EHR reporting period in 2015 they were scheduled to demonstrate Stage 1 but did not intend to select the Stage 1 Patient Specific Education menu objective. Proprietary 35

36 Medication Reconciliation (Pg 204 of Final Rule) Objective The EP or EH who receives a patient from another setting of care or provider of care or believes an encounter is relevant should perform medication reconciliation. Measure The EP or EH performs medication reconciliation for more than 50% of transitions of care in which the patient is transitioned into the care of the EP or admitted to the EH s inpatient or emergency department (POS 21 or 23). 37

37 Medication Reconciliation (Pg 204 of Final Rule) Exclusion Any EP who was not the recipient of any transitions of care during the EHR reporting period. There is no EH exclusion for this objective. Alternate Exclusion EP or EH may claim an exclusion for the measure of the Stage 2 Medication Reconciliation objective if for an EHR reporting period in 2015 they were scheduled to demonstrate Stage 1 but did not intend to select the Stage 1 Medication Reconciliation menu objective. Proprietary 37

38 Patient Electronic Access (Pg 214 of Final Rule) Objective EP: Provide patients the ability to view online, download, and transmit their health information within 4 business days of the information being available to the EP. EH: Provide patients the ability to view online, download, and transmit information about a hospital admission. Measure 1 EP: More than 50% of all unique patients seen by the EP during the EHR reporting period are provided timely (within four (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. EH: More than 50% of all patients who are discharged from the inpatient or ED of an EH have their information available online within 36 hours of discharge. 39

39 Patient Electronic Access (Pg 214 of Final Rule) Measure 2 EP: For an EHR reporting period in 2015 and 2016, at least one (1) 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. For an EHR reporting period in 2017, more than 5 percent of unique patients seen by the EP during the HER reporting period (or his or her authorized representatives) view, download or transmit to a third party their health information during the HER reporting period. EH: At least 1 patient discharged from the inpatient or ED of an EH (or their authorized representative) views, downloads, or transmits his or her health information to a third party. Proprietary 39

40 Patient Electronic Access (Pg 214 of Final Rule) Exclusion EP: Any EP who neither orders nor creates any of the information listed for inclusion as part of the measures, or Conducts 50% or more of his or her patient encounters in a county that does not have 50% or more of its housing units with 4Mbps broadband availability according to the latest information available from the FCC on the first day of the EHR reporting period. EH: Any EH or CAH that is located in a county that does not have 50% or more of its housing units with 4Mbps broadband availability according to the latest information available from the FCC on the first day of the EHR reporting period. Alternate Exclusion EP or EH: May claim an exclusion for the second measure if for an EHR reporting period in 2015 they were scheduled to demonstrate Stage 1, which does not have an equivalent measure. Proprietary 40

41 Secure Electronic Messaging (EP only) (Pg 234 of Final Rule) Objective Use secure electronic messaging to communicate with patients on relevant health information. Measure 2015: The capability for patients to send and receive secure electronic message with the EP was fully enabled during the EHR reporting period. 2016: For at least 1 patient seen by the EP during the EHR reporting period, a secure message was sent using the electronic messaging function of CEHRT to the patient (or the patient-authorized representative), or in response to a secure message sent by the patient (or the patient-authorized representative) during the EHR reporting period. 2017: For more than 5 percent of unique patients seen by the EP during the HER reporting period, a secure message was sent using the electronic messaging function of CEHRT to the patient (or the patient-authorized representative), or in response to a secure message sent by the patient (or the patient-authorized representative) during the HER reporting period. 42

42 Secure Electronic Messaging (EP only) (Pg 234 of Final Rule) Exclusion Any EP who: 1) Has no office visits during the EHR reporting period, or 2) Conducts 50% or more of his or her patient encounters in a county that does not have 50% or more of its housing units with 4Mbps broadband availability according to the latest information available from the FCC on the first day of the EHR reporting period. Alternate Exclusion An EP may claim an exclusion for the measure if for an EHR reporting period in 2015 they were scheduled to demonstrate Stage 1, which does not have an equivalent measure. Proprietary 42

43 Public Health and Clinical Data Registry Reporting (Pg 243 of Final Rule) Active Engagement definitions: Completed registration to submit data, Testing and validation, or Production-required for attesting to the measure EPs will need to attest to 2 of the 3 available measures EHs will need to attest to 3 of the 4 available measures Objective The EP or EH is in active engagement with a Public Health Agency (PHA) or clinical data registry (CDR) to submit electronic public health data in a meaningful way using CEHRT, except where prohibited and in accordance with applicable law and practice. 44

44 Public Health Measures M1: Immunization Registry Measure The EP or EH is in active engagement with a PHA to submit immunization data to the immunization information systems (IIS). M3: Specialized Registry Reporting The EP or EH is in active engagement with a PHA to submit data to public health registries. M2: Syndromic Surveillance Measure The EP or EH is in active engagement with a PHA to submit syndromic surveillance data from a non-urgent care ambulatory setting for EPs or an emergency or urgent care department for EHs (POS 23). M4: Electronic Reportable Laboratory Result Measure (EH only) The EH is in active engagement with a PHA to submit ELR results. 45

45 CDPHE Meaningful Use Registration Site Proprietary 45

46 Public Health and Clinical Data Registry Reporting - Definitions Public Health Registry Registry administered by or on behalf of a local, state, territorial or national PHA which collects data for public health purposes Ex: Cancer registry, Case Reporting, Prescription Drug Monitoring Program Immunization and Syndromic Surveillance are part of this definition, but are their own measures 46

47 Public Health Exclusions (Pg 243 of Final Rule) Immunization Registry Measure Exclusions 1) Any EP or EH that does not administer any immunizations to any of the populations for which data is collected by the jurisdiction s immunization registry or IIS during the EHR reporting period, 2) Any EP or EH that operates in a jurisdiction for which no immunization registry or IIS is capable of accepting the specific standards required to meet the CEHRT definition at the start of the EHR reporting period, or 3) Any EP or EH that operates in a jurisdiction where no immunization registry or IIS has declared readiness to receive immunization data from the EP or EH at the start of the EHR reporting period. Alternate Exclusion-for all measures In 2015, EPs scheduled to demonstrate Stage 1 will only be required to successfully attest to 1 measure and EHs will only be required to successfully attest to 2 measures. Proprietary 47

48 Public Health Exclusions (Pg 243 of Final Rule) Syndromic Surveillance Measure Exclusions 1) Any EP that does not treat or diagnose or directly treat any disease or condition associated with a syndromic surveillance system in his or her jurisdiction, 2) Any EH that does not have an emergency or urgent care department, 3) Any EP or EH that operates in a jurisdiction for which no PHA is capable of receiving electronic syndromic surveillance data from EPs and EHs in the specific standards required to meet the CEHRT definition at the start of the EHR reporting period, or 4) Any EP or EH that operates in a jurisdiction where no PHA has declared readiness to receive syndromic surveillance data from EPs and EHs at the start of the EHR reporting period. Proprietary 48

49 Public Health Exclusions (Pg 243 of Final Rule) Specialized Registry Reporting Exclusions 1) Any EP or EH that does not treat or diagnose any disease or condition associated with, or collect relevant data that is collected by, a specialized registry in their jurisdiction during the HER reporting period. 2) Any EP or EH that operates in a jurisdiction for which no PHA is capable of receiving electronic case reporting data from EPs and EHs in the specific standards required to meet the CEHRT definition at the start of the EHR reporting period, or 3) Any EP or EH that operates in a jurisdiction where no PHA has declared readiness to receive electronic registry transactions at the beginning of the EHR reporting period. Proprietary 49

50 Public Health Exclusions (Pg 243 of Final Rule) Electronic Reportable Laboratory Measure (EH only) Exclusions 1) Any EH that does not perform or order laboratory tests that are reportable in their jurisdiction during the EHR reporting period. 2) Any EH that operates in a jurisdiction for which no PHA is capable of accepting the specific ELR standards required to meet the CEHRT definition at the start of the EHR reporting period. 3) Any EH that operates in a jurisdiction where no PHA has declared readiness to receive ELR results from EHs at the start of the EHR reporting period. Proprietary Not For Redistribution 50

51 Public Health Exclusions (Pg 243 of Final Rule) If the EP qualifies for multiple exclusions and the remaining number of measures available to the EP is less than 2, the EP can meet the objective by meeting the 1 remaining measure available to them and claims applicable exclusions. If no measures remain available, the EP can meet the objective by claiming exclusions for all measures. Proprietary 51

52 Questions? Jennifer Boaz Transformation Support Specialist Proprietary 52

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