Achieving Meaningful Use in Failure to understand the requirements can be costly. By Jeffrey Lehrman, DPM

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1 Achieving Meaningful Use in 2016 Failure to understand the requirements can be costly. 93 By Jeffrey Lehrman, DPM This article is written exclusively for PM and appears courtesy of the American Academy of Podiatric Practice Management. The AAPPM has a forty-plus year history of providing its member DPM s with practice management education and resources. Use program. If 2012, 2013, or 2014 was your first year participating in the Meaningful Use program, you are eligible for incentive payments based on 2016 compliance (Figure 2). If your first year reporting was any slotted for the assigned value for If your first year reporting was 2012, you are scheduled to receive $1,960 for successful attestation in If your first year reporting was Richard Thomas Dreamstime.com Failure to successfully attest to Meaningful Use in 2016 will result in a 4% reduction of your Medicare Part B Physician Fee Schedule in The Meaningful Use program is completely separate from the Physician Quality Reporting System (PQRS), and their penalties are additive if you are subject to both. These penalties can start to add up if you are not compliant with these programs (Figure 1)! Some providers are still eligible for incentive payments based on compliance with the Meaningful The Meaningful Use program is completely separate from the Physician Quality Reporting System (PQRS), and their penalties are additive if you are subject to both. other than these three years, you are not eligible for incentive payments based on 2016 participation. If your first year attesting was any of these three years, but you have skipped one or more years between then and 2016, your incentive payment is still 2013 or 2014, you are scheduled to receive $3,920 for successful attestation in Notice these payments are reduced from those that were advertised at the onset of the Meaningful Use program. This is because Continued on page 94

2 Figure 1: Penalties for Not Qualifying for Meaningful Use Year of Meaningful Use Noncompliance Year of Medicare Fee Schedule Adjustment Medicare Fee Schedule 1% 2% 3% 4% 5% 5% Adjustment % 94 Figure 2: Incentive Payments for Starting Meaningful Use First Year Attesting to Meaningful Use Incentive for Successful $0 $1,960 $3,920 $3,920 $0 $ Participation Meaningful Use (from page 93) these payments are now subject to the 2% sequestration on federal spending. The length of the 2016 Meaningful Use reporting period for all providers, other than those for which 2016 is their first year reporting, is one full calendar year. The reporting period for providers in which 2016 is their first year reporting Meaningful Use is any consecutive 90-day period. All reporters are in Modified Stage 2 for Stage 2, as it was originally described, no longer exists. The Modified Stage 2 objectives are easier to achieve than were the objectives in Stage 2 as it was originally described. No one is still in Stage 1. No one is in Stage 3 in All providers, regardless of how many years they have or have not participated in the past, will report using Modified Stage 2 in Modified Stage 2 has a single set of 10 objectives. Measures are no longer broken down into core and menu set. There are no elective measures. Let s take a look at all 10 Objectives needed to achieve Meaningful Use in 2016: Objective 1: Protect Electronic Health Information This is a HIPAA requirement and something you should be doing anyway for HIPAA compliance. This requires a security risk analysis. Whoever performs the risk analysis needs to ensure that it meets the stringent requirements of this measure s description and should provide documentation of what exactly was done, what risks were identified, and then the provider should document steps that were taken to address identified risks. Objective 2: Clinical Decision Support There are really two measures to this objective. The first is to implement five clinical decision support interventions related to four or more clinical quality measures at a relevant Measures are no longer broken down into core and menu set. There are no elective measures. point in patient care. There are many clinical quality measures relevant to podiatric care from which you can choose. If you are unsure how to develop these clinical decision support rules, this is something your EHR vendor should assist you with. The second requirement of Objective 2 is to enable and implement the functionality for drug-drug and drug-allergy interaction checks. This is Continued on page 96

3 96 Meaningful Use (from page 94) Objective 5: Summary of Care Record This objective also has two measures. The first mandate is that when a provider transitions or refers a patient to another setting or provider of care, she must utilize the EHR to create a summary of care record. The record should contain the items listed in Figure 3. The second measure of this objective is that the provider must elec- Continued on page 98 something that your EHR should be capable of, and it should be turned on during the entire reporting period. Again, this is something you can check with your EHR vendor on if you have questions about how this works within your system. Objective 3: Computerized Physician Order Entry (CPOE) There are really three measures to this third objective. The first is that more than 60 percent of medication orders created by the provider must be recorded using CPOE. E-prescribing a medication is an example of CPOE. Another example would be creating the medication order within the EHR and having the prescription printed out onto paper directly from the EHR. The second measure of this third objective is that more than 30 percent of laboratory orders created by the provider must be recorded using CPOE. Examples of this would be entering an order for an HgA1c lab test through the EHR and then having that order electronically transmitted to the lab where the blood will be drawn or having the EHR print out the order onto a paper prescription. The final measure of this objective is that more than 30 percent of radiology orders created by the provider must be recorded using CPOE. Examples of this are similar to those described above for the laboratory orders, with the radiology order either being transmitted directly to the imaging facility from the EHR or printed out onto a paper prescription. X-rays done in the office are not subject to this CPOE requirement, which means they do not go in the denominator when determining your percentage compliance with this measure. Ordering a CT scan or an MRI that is done outside of your office are examples of orders that do fall into the denominator for this measure. There are potential exclusions to each of these measures and each is considered separately. A provider may be excluded from one, two, or three of these. A provider who prescribes fewer than 100 medication orders during the reporting period is exempt from the first measure of objective 3. A provider who writes Figure 3: Summary of Care Record Patient name Provider s name and office contact info Current problem list PMH Procedures Laboratory test results Current medication list and medication history Current medication allergy list and medication allergy history Vital signs (height, weight, blood pressure, BMI, growth charts) Smoking status Demographic information (preferred language, sex, race, ethnicity, date of birth) Care plan field(s), including goals and instructions; and any known care team members including the primary care provider of record. for fewer than 100 laboratory orders during the reporting period is exempt from measure 2 of objective 3. A provider who orders fewer than 100 radiology exams during the reporting period is exempt from the third measure of this objective. Your EHR should give you the ability to easily track how many of each of these orders are performed and how many are performed using CPOE. If, at the end of the reporting period, you find that you were exempt from any of these measures, you will be given the opportunity to indicate that when it is time to attest. Those that are in a 90-day reporting period may find that they qualify for these exemptions more frequently than those that are in a full year reporting period. Objective 4: Electronic Prescribing This objective requires that more than 50 percent of all permissible prescriptions written by the provider are queried for a drug formulary and transmitted electronically using Certified EHR Technology to the patient s pharmacy. Your EHR should give you the ability to do both of these. You qualify for an exclusion to this requirement if you write for fewer than 100 permissible prescriptions during the EHR reporting period, or you do not have a pharmacy within your organization and there are no pharmacies that accept electronic prescriptions within 10 miles of your practice location at the start of the EHR reporting period. Similar to Objective 3, those that are in a 90-day reporting period may find that they qualify for this exemption more frequently than those that are in a full year reporting period.

4 98 Meaningful Use (from page 96) tronically transmit this summary of care record to the receiving provider for more than 10 percent of all transitions of care and referrals that occur. In order to perform this objective and track it, your EHR must give you the ability to keep track of all transitions of care, create this summary of care document for them, keep track of how many summary of care documents were created, transmit the document to the referring provider, and keep track of what percentage of summary of care records were transmitted to the referring provider. Providers who transfer a patient to another setting or to another provider less than 100 times during the EHR reporting period will be able to claim an exclusion from this objective. This is another situation where you are more likely to qualify for this exception if your reporting period is 90 days versus an entire year. Your EHR should be set up to keep track of how many transitions of care take place during the reporting period, allowing you to know if you qualify for the exception or not. Objective 6: Patient-Specific Education In order to meet this objective, the provider must provide patient-specific education resources that have been identified by Certified EHR Technology to more than 10 percent of all unique patients. Ideally, this is set up for the EHR to know when the educational resource should be provided. This can be done if a certain key word is used within the body of a note, if a certain template is used, or perhaps if a certain ICD code is used. An example would be having a system that somehow notifies the EHR when you are seeing a diabetic patient, and the EHR is programmed to print out a handout on diabetic foot care whenever you see a diabetic patient, and you get a pop-up window reminding you to give it to the patient which you can click to indicate that the information was provided. Objective 7: Medication Reconciliation To meet this objective, the provider must perform a medication reconciliation for more than 50 percent of patients who are transitioned into the care of the provider. Your EHR should give you the ability to track how many patients are transitioned into the practice, when a medication reconciliation is performed, and keep track of what percentage of transitions of care have had medication reconciliations performed. Objective 8: Patient Electronic Access This objective contains one of the big changes from Stage 2. The first component of this measure is that at least 50 percent of all unique patients seen by the provider during the EHR reporting period are provided online access to their health information within four business days after the information is available to the provider, which usually means within four business days of the visit. Health information refers to the same list that was needed for the above-described Summary of Care Record in Objective #5. It is noted that the provider may choose to withhold certain information if s(he) feels that it is not safe or appropriate to share with the patient. The provider merely needs to make the information available to access it online. The provider does not need to send it directly to the patient. Having the patient s address is not necessary to fulfill this measure. The second component of this measure is at least one patient seen by the provider during the EHR reporting period must view, download, or transmit his or her health information to a third party. Having just one patient access and view their health information that was made available online as part of the first component of this objective will satisfy this requirement. Objective 9: Secure Electronic Messaging This is another big change from Stage 2 to Modified Stage 2. The requirement for 2016 under Modified Stage 2 guidelines is to have the capability for patients to exchange secure electronic messages with the provider fully enabled throughout the EHR reporting period. No message 50 percent of all unique patients seen by the provider during the EHR reporting period are provided online access to their health information within four business days after the information is available to the provider. actually needs to be exchanged. The EHR must have the ability to do it and it must be turned on. Objective 10: Public Health Reporting This objective has three measures. Podiatrists are exempt from the first two measures because they deal with situations podiatrists do not encounter. Measure 3 requires the provider to be in active engagement to submit data to a specialized registry. Podiatrists are not exempt from this measure as there are multiple registries for conditions we treat. There are several things a provider needs to do to meet this requirement. The first is that the provider must register to submit data to a clinical data registry (CDR) within 60 days after the start of the EHR reporting period. The reporting period for 2016 is the full calendar year, so the start of the reporting period was January 1, A provider who did not register with a CDR by February 29, 2016 will have no chance to meet the requirements of this measure and therefore will not be able to attest to having achieved Meaningful Use in If the provider is registered with a CDR that has limited resources to initiate the testing and validation process, then just registering and waiting for an invitation from the CDR to begin testing and validation will Continued on page 100

5 100 Meaningful Use (from page 98) satisfy this requirement, but this type of CDR is rare or nonexistent. Providers who are registered with an active registry must be in the process of testing and validation of the electronic submission of data in order to meet the requirements of this measure. In order to do this, providers must respond to requests from the CDR within 30 days, and this must take place at least twice during the EHR reporting period. There are multiple registries to which you may choose to submit data. Submitting a PQRS measure group through a registry does not satisfy the requirements of Meaningful Use Objective 10, Measure 3. Submitting data to a CDR to satisfy the requirements of Objective 10, Measure 3 usually involves uploading and sharing a large volume of Summary of Care documents and/or Continuity of Care Documents from your EHR to the CDR. The APMA has formed a collaboration with the US Wound Registry and MedXpress Specialty Registry such that both offer a discounted price to APMA members. MedXpress also offers the same discount to AAPPM members. Submitting data to a registry that collaborates with the APMA may help to provide the APMA with information that can be helpful for public policy efforts. The final step to achieving Meaningful Use in 2016 is to report Clinical Quality Measures (CQMs). You must report nine CQMs covering at least three National Quality Strategy (NQS) domains. This is something that your EHR should be tracking for you. Differing from all of the above-mentioned requirements, there are no thresholds for these, meaning there is no percentage cut off you have to meet. There is no plan to change Meaningful Use in any way for 2016 from what was described in this article. As for the future, at the time of the writing of this article, we are scheduled to still be required to meet Meaningful Use criteria in We are currently scheduled to have the option to attest in 2017 using Modified Stage 2 for a You must report nine CQMs covering at least three National Quality Strategy (NQS) domains. full year reporting period or using Stage 3 for a 90-day reporting period. Current guidelines dictate that failure to achieve Meaningful Use by either of these options in 2017 will result in a 5% reduction of your Medicare Part B Physician Fee Schedule in Changes to the Meaningful Use program are ahead for us. In 2015, Congress passed the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). MARCA seeks to consider quality, cost, and clinical practice improvement activities in calculating how Medicare physician payments are determined. Another MARCA goal is to combine Meaningful Use, PQRS, and the Value Based Payment Modifier programs into one new system. This new system has already been named the Merit-Based Incentive Payment System (MIPS). CMS has made known its goal of basing payment on value and better quality of care. They have published a goal of making 50 percent of Medicare payments in 2018 linked to getting better results for patients, providing better care, and spending healthcare dollars more wisely. Stay tuned for changes to these programs, as our reimbursement will become more closely tied to them over the next couple of years. PM References EHR Incentive Programs: What s Next? APMA News and Publications cfm?itemnumber=19610 EHR Incentive Programs: Where We Go Next The CMS Blog Dr. Lehrman is a Fellow of the American Academy of Podiatric Practice Management (AAPPM), serves as an expert panelist on Codingline.com, and is on the APMA Coding Committee. Follow him on Dr. Lehrman has no conflict of interest or financial relationship with the US Wound Registry or MedXpress Specialty Registry.

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