Meaningful Use Stage 2 MU Audits

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1 Meaningful Use Stage 2 MU Audits Presented by: Deb Anderson, CPHIMS HTS Consultant HTS, a division of Mountain Pacific Quality Health Foundation 1

2 CEHRT Certified Electronic Health Record Technology (EHR) EH Eligible Hospital CAH Critical Access Hospital EP Eligible Provider MU Meaningful Use CPOE Computerized Provider Order Entry SRA Security Risk Assessment (or Analysis) The Acronym Rule! 2

3 Introductions What is Meaningful Use Goals and Stages of MU Stage 2 for EP and EH Stage 1 to Stage 2 overlap Stage 2 Menu measure details 2014 Clinical Quality Measures Payment adjustments and Hardships MU Audit documentation 3

4 HTS is a division of Mountain Pacific Quality Health Foundation. We are the Regional Extension Center (REC) for MT/WY. We assist healthcare facilities with utilizing Health Information Technology (HIT) to improve health care, quality, efficiency and outcomes. 4

5 Catherine Darnell HIT Outreach Coordinator v Linda Cramer HIT Manager Wyoming Dept. of Health Medicaid (o) (c)

6 6

7 The American Recovery and Reinvestment Act of 2009 authorizes the Centers for Medicare & Medicaid Services (CMS) to provide incentive payments to eligible professionals (EPs) and hospitals who adopt, implement, upgrade, or demonstrate meaningful use of certified electronic health record (EHR) technology. Audit Documentation Guidance If it isn t documented, it didn t happen 7

8 MU is NOT a little IT Project MU is NOT something that magically happens MU does NOT work without PROVIDERS MU is NOT just Pumpkin Pie in the sky! 8

9 To receive an EHR incentive payment, providers have to show that they are meaningfully using their EHRs by meeting thresholds for a number of objectives. The EHR Incentive Programs are phased in three stages with increasing requirements. Eligible professionals participate in the program on the calendar year, while eligible hospitals and CAHs participate according to the federal fiscal year. Providers must attest to demonstrating meaningful use every year to receive an incentive and avoid a Medicare payment adjustment. 9

10 That requires the input of data from the CEHRT into the CMS or State Medicaid site as attestation 10

11 Meaningful use is using certified electronic health record (EHR) technology 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 Ultimately, it is hoped that the meaningful use compliance will result in: Better clinical outcomes Improved population health outcomes Increased transparency and efficiency Empowered individuals More robust research data on health systems 11

12 12

13 * The CMS 2014 Flexibility Rule extends Stage 2 through 2016 and start Stage 3 in

14 For attestation, all must attest with new 2014 version of E.H.R, regardless of stage of Meaningful Use The 2014 Flexibility Rule allows Hospitals and providers to use 2011 CEHRT or 2011/2014 Combined CEHRT to attest for a 90 day reporting period in

15 15

16 Stage 2 CMS home page Guidance/Legislation/EHRIncentivePrograms/Stage_2.html Stage 2 Hospital TOC link - Guidance/Legislation/EHRIncentivePrograms/Downloads/S tage2_meaningfulusespecsheet_tablecontents_eligiblehos pitals_cahs.pdf Stage 2 Provider TOC link - Guidance/Legislation/EHRIncentivePrograms/Downloads/S tage2_meaningfulusespecsheet_tablecontents_eps.pdf 16

17 Most of the Stage 1 Menu Measures are now Core Measures Some Measures are combined and some eliminated Thresholds have been Raised Some New Objectives, but most are in the Menu selection A Menu Exclusion can not be used if you can meet any of the menu objectives 17

18 Stage 2 uses a core and menu structure for objectives that providers must achieve in order to demonstrate meaningful use. Core objectives are objectives that all providers must meet. There are also a predetermined number of menu objectives that providers must select from a list and meet in order to demonstrate meaningful use. To demonstrate meaningful use under Stage 2 criteria Eligible professionals must meet: 17 core objectives 3 menu objectives that they select from a total list of 6 Total of 20 objectives Eligible hospitals and CAHs must meet: 16 core objectives 3 menu objectives that they select from a total list of 6 Total of 19 objectives 18

19 1. Use computerized provider order entry (CPOE) for medication, laboratory and radiology orders 2. Generate and transmit permissible prescriptions electronically (erx) 3. Record demographic information 4. Record and chart changes in vital signs 5. Record smoking status for patients 13 years old or older 6. Use clinical decision support to improve performance on high-priority health conditions 7. Provide patients the ability to view online, download and transmit their health information 8. Provide clinical summaries for patients for each office visit 9. Protect electronic health information created or maintained by the Certified EHR Technology 10. Incorporate clinical lab-test results into Certified EHR Technology 11. Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research, or outreach 12. Use clinically relevant information to identify patients who should receive reminders for preventive/follow-up care 13. Use certified EHR technology to identify patient-specific education resources 14. Perform medication reconciliation 15. Provide summary of care record for each transition of care or referral 16. Submit electronic data to immunization registries 17. Use secure electronic messaging to communicate with patients on relevant health information 19

20 1. Submit electronic syndromic surveillance data to public health agencies 2. Record electronic notes in patient records 3. Imaging results accessible through CEHRT 4. Record patient family health history 5. Identify and report cancer cases to a State cancer registry 6. Identify and report specific cases to a specialized registry (other than a cancer registry) 20

21 Objective Stage 1 Stage 2 Measure Stage 1 Measure Stage 2 Demographics Core Core >50% >80% Vital Signs Core Core >50% >80% Smoking Status Core Core >50% >80% Lab Results into EHR Menu Core >40% >55% Patient Specific Education Menu Core >10% >10% Medication Reconciliation Menu Core >50% >50% Patient List by Condition Menu Core 1 List At least 1 Eligible Professionals Only Clinical Summaries after Visit Menu Core >50% >50% Patient Reminders Menu Core >20% >20% 21

22 Stage 1 CPOE Use EHR for more than 30% of the MEDICATION orders. Stage 2 CPOE 3 Measures based on orders created. 60% MEDICATION orders 30% LAB orders 30% RADIOLOGY orders Scope Expanded Exclusion for EP: Any EP who writes fewer than 100 medication, radiology, or laboratory orders during the EHR reporting period. 22

23 Stage 1 Objective EP EH Measure Timely Electronic Access to Health Information Electronic Copy of Health Information Electronic Copy of Discharge Instructions Stage 1 Measures combined into One Stage 2 Core Measure View, Download and Transmit to Third Party within 4 days. (EP) View, Download and Transmit to Third Party within 36 hours. (EH) NEW Core Measure n/a Menu >10% Core >50% n/a Core >50% Stage 2 2 Measures, >50% of unique patients have information available online >5% unique patients download or transmit their information. 24

24 The following information must be available to satisfy the objective and measure: Patient Name Admit and discharge date and location. Reason for hospitalization. Care team including the attending of record as well as other providers of care. Procedures performed during admission. Current and past problem list. Current medication list and medication history. Current medication allergy list and medication allergy history. Vital signs at discharge. Laboratory test results (available at time of discharge). Summary of care record for transitions of care or referrals to another provider. Care plan field(s), including goals and instructions. Discharge instructions for patient. Demographics maintained by hospital (sex, race, ethnicity, date of birth, preferred language). Smoking status. 25

25 Stage 1 EP EH Measure Stage 2 Summary of Care record for each Transition of Care Promote use of HIE for patient care. New Requirements. Core 3 Measures >50% patients referred to another setting of care are provided a Summary of Care record >10% referrals are Electronic >At least one successful test to a different EHR developer than sender or with a CMS-designated test EHR. 26

26 Measure 1: Summary of Care can be Electronic or Paper directly to provider or the patient Not counted if Provider has access to the Record in EHR System The fields MUST be present with: Current problem list, Current medication list, and Current medication allergy list Exclusion: Provider of care that transfers a patient to another setting or refers a patient to another provider <100 times during the EHR reporting period. 27

27 Measure 2: A summary of care record for more than 10% of such transitions and referrals must be sent either (a) electronically transmitted using CEHRT to a recipient or (b) where the recipient receives the summary of care record via exchange consistent with governance mechanism ONC establishes for Health Information exchange. Measure 3: Yes/No Conducts one or more successful electronic exchanges of summary of care document, as part of which is counted in "measure 2" or Conducts one or more successful tests with the CMS designated test EHR during the EHR reporting period. 28

28 Through 2013 Objective EP EH Measure Calculate and Transmit CMS Quality Measures CHANGE IN REPORTING Core 2014 Hospitals or CAH 15 EP - 6 Clinical Quality Measures are now incorporated into the definition of a meaningful user rather than part of Core Set Measures. To meet Stage 2 Meaningful Use status: 16 of 29 CQMs required for EH/CAH 9 of 64 Measures for EP More details to follow. 29

29 Stage 1 EP EH Stage 2 One Core, one Menu for EP All Core for EH 30

30 Objective NEW! Electronic Medication Administration Record (emar) [EH only] NEW Core! >10% Exclusion: Any hospital or CAH with an average daily inpatient census of fewer than 10 patients Secure Messaging [EP only] NEW Core! >5% Exclusion: 1) Provider has no office visits during the reporting period. 2) Broadband limitations in area of practice. 31

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32 Objective: Record electronic notes in patient records. Measure: Enter at least one electronic progress note for >30% of unique patients. The text must be searchable and may contain drawings and other content. Exclusions: None 33

33 Objective: Imaging results are accessible through Certified EHR Technology Measure: >10% of all tests whose result is one or more images ordered are accessible. Exclusions: EP - Any EP who orders less than 100 tests whose result is an image during the EHR reporting period; or any EP who has no access to electronic imaging results at the start of the EHR reporting period. EH - None Notes: No limitations on the resolution of the image. Native storage is not required by the objective and measure. Images and imaging results scanned into the CEHRT may count. 34

34 Objective: Record patient family health history as structured data. Measure >20% of all unique patients seen by the EP or Hospital during the EHR reporting period have a structured data entry for one or more first-degree relatives. Exclusions: An EP who has no office visits 35

35 Objective: Capability to identify and report cancer cases to a public health central cancer registry, except where prohibited, and in accordance with applicable law and practice. Measure: Successful ongoing submission of cancer case information from CEHRT to a public health central cancer registry for the entire EHR reporting period. Exclusions: The EP does not diagnose or directly treat cancer; PLUS (Same as the Other Public Health Measures) 36

36 Objective: Capability to identify and report specific cases to a specialized registry (other than a cancer registry), except where prohibited, and in accordance with applicable law and practice. Measure: Successful ongoing submission of specific case information from CEHRT to a specialized registry for the entire EHR reporting period. Exclusions: 1) The EP does not diagnose or directly treat any disease associated with a specialized registry sponsored by a national specialty society for which the EP is eligible, or the public health agencies in their jurisdiction. 37

37 Objective: Generate and transmit permissible discharge prescriptions electronically (erx). Measure >10% of hospital discharge medication orders for permissible prescriptions (for new, changed, and refilled prescriptions) are queried for a drug formulary and transmitted electronically using certified EHR technology. Exclusions: 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. 38

38 Objective: Provide structured electronic lab results to ambulatory providers. Measure: Hospital labs send structured electronic clinical lab results to the ordering provider >20% of electronic lab orders received. Exclusions: None 39

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40 EPs must meet all 17 core objectives: Core Objective Measure Stage 2 Change 1. CPOE Use CPOE for more than 60% of medication, 30% of laboratory, and 30% of radiology Up from 30% of just medication orders 2. E-Rx E-Rx for more than 50% Up from 40% 3. Demographics Record demographics for more than 80% Drug/formulary checks folded into this measure from Stage 1 menu item Up from 50% 4. Vital Signs Record vital signs for more than 80% Up from 50% 5. Smoking Status Record smoking status for more than 80% Up from 50% 49

41 EPs must meet all 17 core objectives: Core Objective Measure Stage 2 Change 6. Clinical Decision Support Implement 5 clinical decision support interventions + drug/drug and drug/allergy Up from one CDSI rule Must be linked to at least 4 Clinical Quality Measures (CQMs) 10. Labs Incorporate lab results for more than 55% 11. Patient List Generate patient list by specific condition Drug/drug and drug/allergy folded into this measure Up from 40% and no longer a menu item No longer a menu item 50

42 EPs must meet all 17 core objectives: Core Objective 12. Reminders 7. Patient Online Access also known as View, Download and Transmit Measure 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 Provide online access to health information for more than 50% with more than 5% actually accessing Stage 2 Change No longer a menu item, but down from 20% and does not include the entire patient database No longer a menu item and up from 10% on part #1. Replaces electronic access and electronic copy of medical record. Must give URL, login/password and instruction info to patient Part #2 is new and requires patient action to meet the measure and additional software. Exclusion for providers in areas with limited 51

43 EPs must meet all 17 core objectives: Core Objective Measure Stage 2 Change 8. Clinical Summaries 13. Patient Education 17. Secure Messaging Provide office visit summaries for more than 50% of office visits within 1 business day Use EHR to identify and provide education resources more than 10% More than 5% of patients send secure messages to their EP Down from three business days, percent is the same (50%) No longer a menu item New for Stage 2 Requires patient action to meet the measure 14. Medication Reconciliation Medication reconciliation at more than 50% of transitions of care No longer a menu item 52

44 EPs must meet all 17 core objectives: Core Objective Measure Stage 2 Change 15. Summary of Care 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 successfully testing with CMS Randomizer No longer a menu item 10% sent electronically is a new requirement - at least one sent to a recipient with a different EHR vendor 16. Immunizations Successful ongoing transmission of immunization data No longer a menu item Requires more than just a test to meet this measure 9. Security Risk Analysis Conduct or review security analysis and incorporate in risk management process 53

45 EPs must select 3 out of 6 menu objectives: Menu Objective Measure Stage 2 Change 3. Imaging Results More than 20% of imaging results are accessible through Certified EHR Technology 4. Family History Record family health history for more than 20% 1. Syndromic Surveillance Successful ongoing transmission of syndromic surveillance data New for Stage 2 New for Stage 2 Requires more than just a test to meet this measure 54

46 EPs must select 3 out of 6 menu objectives: Menu Objective Measure Stage 2 Change 5. Cancer Registry Successful ongoing transmission of cancer case information New for Stage 2 6. Specialized Registry Successful ongoing transmission of data to a specialized registry 2. Electronic Notes Enter an electronic progress note for more than 30% of unique patients New for Stage 2 (does not include cancer registry, immunization or syndromic registries) New for Stage 2 any searchable note can be dictated just not scanned 55

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48 April The Centers for Medicare and Medicaid Services awarded Figliozzi and Co., of Garden City, N.Y., a contract to audit payments and compliance with the agency s EHR Incentive Program. The three-year contract will not exceed $3.13 million Any provider or hospital attesting to receive an EHR incentive payment for either the Medicare or Medicaid EHR Incentive Program potentially can be subject to an audit. 72

49 Figliozzi and Company is the designated contractor performing audits on behalf of the Centers for Medicare & Medicaid Services (CMS), and will perform Stage 2 audits on Medicare EPs and eligible hospitals, as well as on hospitals that are dually eligible for both the Medicare and Medicaid EHR Incentive Programs. If you are selected for an audit you will receive a letter from Figliozzi and Company with the CMS and EHR Incentive Program logos on the letterhead. States and their contractors will perform audits on Medicaid providers. Contact your State Medicaid Agency for more information about audits for Medicaid EHR Incentive Program payments. 73

50 Sample Audit Letter for EPs Sample Audit Letter for Eligible Hospitals & CAHs 74

51 Audit Overview Fact Sheet Stage 2 Supporting Documentation for Audits 75

52 Providers who receive an EHR incentive payment for Stage 2 of the Medicare or Medicaid EHR Incentive Program potentially may be subject to an audit. Eligible professionals (EPs), eligible hospitals, and critical access hospitals (CAHs) should retain ALL relevant supporting documentation (in either paper or electronic format) used in the completion of the Attestation Module responses. Documentation to support attestation data for Stage 2 meaningful use objectives and clinical quality measures should be retained for six years post attestation. Documentation to support payment calculations (such as cost report data) should continue to follow the current documentation retention processes. 76

53 There are numerous pre payment edit checks built into the EHR Incentive Programs' systems to detect inaccuracies in eligibility, reporting, and payment. Medicare providers may also be subject to pre payment audits. These pre payment audits will include random audits, as well as audits that target suspicious or anomalous data. For those providers selected for pre payment audits, CMS and its contractor, Figliozzi and Company, will request supporting documentation to validate submitted attestation data before releasing payment. CMS and Figliozzi and Company will also continue to conduct post payment audits during the course of the EHR Incentive Programs. Providers selected for post payment audits will also be required to submit supporting documentation to validate their submitted attestation data. 77

54 The primary documentation that will be requested in all reviews is the source document(s) that the provider used when completing the attestation. This document should provide a summary of the data that supports the information entered during attestation. Ideally, this would be a report from the certified EHR system, but other documentation may be used if a report is not available or the information entered differs from the report. Providers should retain a report from the certified EHR system to validate all clinical quality measure data entered during attestation, since all clinical quality measure data must be reported directly from the certified EHR system. Providers who use a source document other than a report from the certified EHR system to attest to meaningful use data (e.g., non clinical quality measure data) should retain all documentation that demonstrates how the data was accumulated and calculated. 78

55 The numerators and denominators for the measures The time period the report covers Evidence to support that it was generated for that EP, eligible hospital, or CAH (e.g., identified by National Provider Identifier (NPI), CMS Certification Number (CCN), provider name, practice name, etc.) Evidence to support that the report was generated by the certified EHR system (e.g., screenshot of the report before it was printed from the system) 79

56 Because some certified EHR systems are unable to generate reports that limit the calculation of measures to a prior time period, CMS suggests that providers download and/or print a copy of the report used at the time of attestation for their records. Although the summary document is the primary review step, there could be additional and more detailed reviews of any of the measures, including review of medical records and patient records. The provider should be able to provide documentation to support each measure to which he or she attested, including any exclusions claimed by the provider. 80

57 In addition, not all certified EHR systems currently track compliance for non percentage based meaningful use objectives. These objectives typically require a Yes attestation in order for a provider to be successful in meeting meaningful use. To validate provider attestation for these objectives, CMS and its contractor may request additional supporting documentation. A few examples of suggested documentation are listed below. Please note that the suggested documentation does not preclude CMS or its contractor from requesting additional information to validate attestation data. 81

58 Audit Validation Functionality is available, enabled, and active in the system for the duration of the EHR reporting period. Suggested Documentation One or more screenshots from the certified EHR system that are dated during the EHR reporting period selected for attestation. Other options Audit logs Video 82

59 Drug/Drug Interactions Drug/Allergy Interactions Drug Formulary checking 83

60 Audit Validation Security risk analysis of the certified EHR technology was performed prior to the end of the reporting period. Suggested Documentation Report that documents the procedures performed during the analysis and the results. Report should be dated prior to the end of the reporting period and should include evidence to support that it was generated for that provider s system (e.g., identified by National Provider Identifier (NPI), CMS Certification Number (CCN), provider name, practice name, etc.). Notes: The Stage 2 measure for Protect Electronic Health Information also requires providers to address encryption/security of data stored in certified EHR technology Flexibility allows report to be dated before attestation 84

61 Audit Validation More than one report listing patients of the provider with a specific condition. Suggested Documentation Report with a specific condition that is from the certified EHR system and is dated during the EHR reporting period selected for attestation. 85

62 Audit Validation Ongoing submission of electronic data using certified EHR technology for the entire EHR reporting period. 86

63 Suggested Documentation Dated screenshots from the EHR system that document successful submission to the registry or public health agency. Should include evidence to support that it was generated for that provider s system (e.g., identified by National Provider Identifier (NPI), CMS Certification Number (CCN), provider name, practice name, etc.). A dated record of successful electronic transmission (e.g., screenshot from another system, etc.). Should include evidence to support that it was generated for that provider (e.g., identified by National Provider Identifier (NPI), CMS Certification Number (CCN), provider name, practice name, etc.). Letter or from registry or public health agency confirming receipt of submitted data, including the date of the submission and name of sending and receiving parties. For exclusions to public health reporting objectives, a letter, , or screenshot from the registry that demonstrates EP was unable to submit and would therefore qualify under one of the provided exclusions to the objective. 87

64 Audit Validation Documentation to support each exclusion to a measure claimed by the provider. Suggested Documentation Report from the certified EHR system that shows a zero denominator for the measure or otherwise documents that the provider qualifies for the exclusion. 88

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68 Once the audit is concluded, the provider will receive an Audit Determination Letter from the audit contractor. This letter will inform the provider whether they were successful in meeting meaningful use of electronic health records. If, based on the audit, a provider is found not to be eligible for an EHR incentive payment, the payment will be recouped. Questions pertaining to audits should be directed to Peter Figliozzi at (516) x302, or by at Figliozzi and Company s website is 92

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