Meaningful Use: Past, Present and Future

Transcription

1 Click to edit Master title style Meaningful Use: Past, Present and Future Bruce Maki, MA M-CEITA / Altarum Institute Regulatory Analyst and Project Manager 5/5/

2 Agenda 1. Overview of M-CEITA 2. Meaningful Use: Past, Present & Future 3. Questions 2

3 Who is M-CEITA? Michigan Center for Effective Information Technology Adoption (M-CEITA) One of 62 ONC Regional Extension Centers (REC) originally funded to provide education & technical assistance to primary care providers across the country Founded as part of the HITECH Act to accelerate the adoption, implementation, and effective use of electronic health records (EHR), e.g. 90-days of MU Originally Funded by ARRA of 2009 (Stimulus Plan) Purpose: support the Triple Aim by achieving 5 overall performance goals THE TRIPLE AIM 3 Improve Quality, Safety & Efficiency Improve patient experience Improve population health Reduce costs Engage Patients & Families Performance Measurement Improve Care Coordination Improve Population And Public Health Meaningful Use Ensure Privacy And Security Protections Certified Technology Infrastructure 3

4 M-CEITA Services Meaningful Use Support Technical assistance, including workflow redesign, security risk assessment and MU compliance. (e.g. patient portal and clinical quality measures) Security Risk Assessment Support meeting the requirements of MU Measure: Protect Electronic Health Information, including an assessment using our exclusive tool. Audit Preparation A review of Meaningful Use attestation documentation using our exclusive Audit File Checklist to correct any issues before completing the process. Targeted Process Optimization (Lean) A workflow analysis and redesign of core processes using Lean principles to increase efficiency and reduce duplication. (e.g. chart prep, doc. Management) PQRS Support Technical Assistance for the Physician Quality Reporting System including measure selection as well as reporting method selection and assistance. GLPTN - Great Lakes Practice Transformation Network No cost Technical Assistance to eligible providers in support of quality improvement initiatives, PQRS support, and preparing for upcoming advanced payment model changes under MACRA/MIPS 4

5 The Past A Brief History of Meaningful Use 5

6 Meaningful Use as defined by CMS Meaningful Use is using certified electronic health record (EHR) technology to: Improve quality, safety, efficiency, and reduce health disparities Engage patients and families Improve care coordination and population and public health Maintain privacy and security of patient health information Ultimately, it is hoped that 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 6

7 Meaningful use: Path to better outcomes and quality Stage 2 Advanced clinical processes Stage 3 Improved outcomes Stage 1 Data capture and sharing Better clinical outcomes Improved population health outcomes Increased transparency and efficiency Empowered individuals More robust research data on health systems For more information on meaningful use of EHRs, visit: 7

8 Original Meaningful Use Timeline First Year of MU Stage of Meaningful Use TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD

9 Medicare EHR Incentive Program Incentive amount varies based on Fee-for-Service allowable charges Maximum of $44,000 over 5 years Payments after 4/1/13 reduced by 2% due to mandatory federal sequestration Requires 5 consecutive years: may not skip a year Administered by CMS Payment reductions starting in 2015 if eligible provider is not participating by 2013 (1% in 2015, increasing 1%/yr to 5%) 9

10 Medicaid EHR Incentive Program Requires at least 30% Medicaid patient visit volume (20% for pediatricians) to be eligible to participate Program allows some mid-level providers (e.g. nurse practitioners) as well as physicians to participate Maximum of $63,750 over 6 years of participation May skip years Administered by state Medicaid agencies No Medicaid payment reductions if not participating First year: Adopt / Implement / Upgrade (AIU) Adopt: purchase access to certified EHR Implement: begin using certified EHR Upgrade: upgrade existing EHR to certified version 10

11 Medicare Payment Schedule for EPs (with 2% Sequestration reduction) 11

12 Medicaid Incentive Payments (not affected by Sequestration) Annual Incentive Payment by Year of Meaningful Use Medicaid payments are made over 6 years The last year Medicaid eligible professionals can join is 2016 Participation does not need to be during consecutive years If joining in 2016, however, EP cannot skip a year without missing an incentive payment as no payments will be made after

13 Eligible Professionals (EP s) Who is an Eligible Professional under the Medicare Program? Eligible professionals under the Medicare EHR Incentive Program include: Doctor of medicine or osteopathy Doctor of dental surgery or dental medicine Doctor of podiatry Doctor of optometry Chiropractor Who is an Eligible Professional under the Medicaid Program? Eligible professionals under the Medicaid EHR Incentive Program include: Physicians (primarily doctors of medicine and doctors of osteopathy) Nurse practitioner Certified nurse-midwife Dentist Physician assistant who furnishes services in a Federally Qualified Health Center or Rural Health Clinic that is led by a physician assistant. 13

14 The Present Modified Stage 2 14

15 Medicare and Medicaid Programs; Electronic Health Record Incentive Program Stage 3 and Modifications to Meaningful Use in 2015 Through 2017 Final Rule with Comment Period (aka Modified Stage 2 / Stage 3 Final Rule) Released: October 6, 2015 Published: October 16, 2015 Effective: December 15, 2015 Medicare EPs can attest to a 2015 reporting period in the Federal RAS between 1/4/16 3/11/16 Medicaid EPs can attest to a 2015 reporting period in CHAMPS/eMIPP between 2/14/16 4/30/16 Medicaid EPs can begin attesting to a 2016 reporting period on 6/1/16 15

16 Key changes in the Modified Stage 2 Rule Stage 1 and Stage 2 objectives and measures restructured to align with Stage 3 Streamlined the program by removing redundant, duplicative, and topped out (RDT) measures One set of objectives and measures for all participants Patient engagement objectives that require patient action were modified Limited accommodations for Scheduled Stage 1 EPs in 2016 (CPOE) Significant changes to the Public Health objective Optional Alternate Exclusions added to Public Health ( ) No proof of intent/documentation required to claim Alt Exclusions 16

17 Meaningful Use Progression for EPs Stage 1 15 Core 5 Menu 6 CQMs Stage 1 13 Core 5 Menu 9 CQMs Stage 2 17 Core 3 Menu 9 CQMs Modified Stage 2 10 Objectives 9 CQMs Stage 3 Optional: Objectives, some with lowered thresholds Stage 3 8 Objectives CQM reporting is required by regulations; Medicare PFS rulemaking to address reporting requirements 17

18 Meaningful Use Reporting Periods 2016 New Participants: Any continuous 90 days within the Calendar Year (CY) Returning Participants: Full Calendar Year (366 days) Pending congressional legislation my reduce this to 90 days 2017 New Participants: Any continuous 90 days within the CY Providers electing Stage 3: Any continuous 90 days within the CY (requires 2015 CEHRT) Returning Participants: Full Calendar Year (365 days) 18

19 Measures removed under Modified Stage 2 ( but Still Meaningful ) 19

20 Gone but Still Meaningful (cont d) Many of these objectives and measures include actions that may be valuable to providers and patients, such as providing a clinical summary to a patient Conduct these activities as best suits the practice and the preferences of the patient population The removal is not intended as a withdrawal of an endorsement for these best practices or to discourage providers from conducting and tracking these activities for their own quality improvement goals No longer required to separately calculate and attest to the results of these measures for MU Some of the removed measures contain data elements that are still needed within other measures such as Patient Electronic Access (patient portal) and Health Information Exchange (Summary of Care) or are needed to calculate various Clinical Quality Measures 20

21 2016 Requirements In addition to meeting the measures or exclusions for the remaining 10 objectives, as in previous years, all EPs have to report on Clinical Quality Measures 21

22 Modified Stage 2 Meaningful Use Objectives: 1. Protect Patient Health Information (SRA) Not Episodic, should cover entire program year Conduct within same CY as reporting period, acceptable to be conducted outside of reporting period if reporting period is < CY but must be conducted prior to attestation 2. Clinical Decision Support (CDS) (2 measures) Implement CDS Interventions Implement Interaction Checks 3. Computerized Provider Order Entry (CPOE) (3 measures) Medication Orders Laboratory Orders** Radiology Orders** ** EPs scheduled to be in Stage 1 in 2016 are not required to report on Lab and Radiology orders, only Medication orders 22

23 Modified Stage 2 MU Objectives (cont d): 4. Electronic Prescribing (erx) 5. Health Information Exchange (formerly Summary of Care) 6. Patient Specific Education 7. Medication Reconciliation 8. Patient Electronic Access (VDT/Pt Portal) (2 measures) Timely Access Usage 9. Secure Electronic Messaging 10. Public Health Reporting (3 measures) Immunization Registry Syndromic Surveillance Registry Specialized Registry 23

24 Objective 5: Health Information Exchange (HIE) Measure Threshold Exclusion EP that transitions or refers their patient to another setting of care or provider of care must (1) use CEHRT to create a summary of care (SOC) record; and (2) electronically transmit such summary to a receiving provider for > 10% of transitions of care (TOC) and referrals > 10% EP who transfers a patient to another setting or refers a patient to another provider < 100 times during the RP 24

25 Objective 5: HIE (cont d) Options for counting a transition in the numerator: EP must generate the Summary of Care (SoC) document from CEHRT and must electronically transmit it to the receiving EP via Direct OR EP can now electronically transmit to a Health Information Exchange (HIE) who can then USE ANY MEANS available to route the SoC document to the receiving provider HIE does not need to use CEHRT to deliver to receiving provider HIE can use ANY available means to deliver the SoC document Proof of receipt ( reasonable certainty ) is still required by the sending provider but this too can use non-tech methods. Onus is on HIE to provide this. The issue here is that transmitting the SoC document to an HIE will likely NOT trigger the EHR MU measure report; thus this change may necessitate manually tracking 25

26 Objective 10: Public Health Reporting Measure Measure Option 1: Immunization Registry Reporting The EP is in active engagement with a public health agency to submit immunization data Measure Option 2: Syndromic Surveillance Reporting The EP is in active engagement with a public health agency to submit syndromic surveillance data Measure Option 3: Specialized Registry Reporting The EP is in active engagement to submit data to a qualified specialized registry Exclusion MI EPs: Does not administer any immunizations for which data is collected by the immunization registry MI EPs in Non-Urgent Care Settings: Is not in a category of providers from which ambulatory syndromic data is collected by the PHA EP (a) does not diagnose/treat any disease/condition associated with, or collect relevant data that is collected by, a specialized registry in their jurisdiction during the RP; (b) operates in a jurisdiction for which no specialized registry is capable of accepting electronic registry transactions in the specific standards required to meet the CEHRT definition at the start of the RP; or (c) operates in a jurisdiction where no specialized registry for which the EP is eligible has declared readiness to receive electronic registry transactions at the beginning of the RP 26

27 Public Health (cont d) Active Engagement = Option 1 Completed Registration to Submit Data The EP, eligible hospital or CAH registered to submit data with the PHA or, where applicable, the organization to which the information is being submitted; registration was completed within 60 days after the start of the EHR reporting period; and the EP, eligible hospital, or CAH is awaiting an invitation to begin testing and validation. Option 2 Testing and Validation The EP, eligible hospital, or CAH is in the process of testing and validation of the electronic submission of data. Option 3 Production The EP, eligible hospital, or CAH has completed testing and validation of the electronic submission and is electronically submitting production data. 27

28 Public Health Reporting (cont d) Alternate Exclusions for 2016: EPs previously scheduled to be in Stage 1 or Stage 2 May claim an Alternate Exclusion for Measure 2 (Syndromic Surveillance) and Measure 3 (Specialized Registry) An Alternate Exclusion may only be claimed for up to two measures, then the provider must either attest to or meet the exclusion requirements for the remaining measure described in (e)(10)(i)(c) Another Option for Syndromic Surveillance in 2016: To accommodate EPs struggling to find and register with an alternate registry, MSSS has agreed to allow EPs who were Actively Engaged on 12/31/15 to maintain that status through 12/31/16 with no additional work/submissions/onboarding needed from the EP 28

29 Objective 10: Public Health Measure 3 Specialized Registry Reporting: To qualify as a MU valid specialized registry, the registry must do the following: 1. Publically declare readiness to accept electronic data (by 1 st day of RP) Failure to declare by 1 st day of EP reporting period does not mean EP cannot use registry to achieve MU in that program year. Instead, it creates an option. 2. Be able to accept electronic submissions manual data entry into a website does not count, but an electronic file upload would 3. Be able to support the registration/onboarding and production processes 4. Be able to provide documentation to EP as evidence of Active Engagement 29

30 What obligations do EPs have for finding a Specialized Registry for 2016? Determine if the specialized registries offered by a Public Health Agency (PHA) in MI are relevant to the provider s scope of practice Birth Defects Registry Cancer Registry (must have EHR certified to Cancer reporting standards) MiDR: Michigan s Dental Registry (did not declare readiness by 1/1/16, thus consideration is optional until 2017) Determine if a Medical Society with which the provider is affiliated endorses or sponsors a MU valid specialized registry If no to both, EP can claim the exclusion in

31 Clinical Quality Measures (CQMs) 2016 and 2017 New Participants Any continuous 90 days w/in CY Does not need to be same as MU 90 days Attest through Medicare RAS or Medicaid emipp Or attest using established methods for electronic reporting Returning Participants Full Calendar Year Attest through Medicare RAS or Medicaid emipp Or attest using established methods for electronic reporting 31

32 Stage 3 The Future of Meaningful Use 32

33 MIPS: Merit-Based Incentive Payment System Beginning in 2017, providers will be annually measured in 4 performance categories: Meaningful Use (proposed rename: Advancing Care Information ) Value Based Modifier for Cost PQRS & Value Base Modifier for Quality Clinical Practice Improvement These programs make up 85% of the MIPS score. The best thing an organization can do to prepare is improve on these programs NOW. Meaningful Use is not dead! Meaningful Use IS expected to change again under MACRA/MIPS, but it is not going away. Also, the pending changes will affect the Medicare MU program but not necessarily the Medicaid MU program currently scheduled to end in

34 Newly Proposed Changes to Medicare MU Changes from the Medicare EHR Incentive Program to Advancing Care Information Meaningful Use Must report on all objective and measure requirements New Proposal New proposal streamlines measures and emphasizes interoperability, information exchange, and security measures. Clinical Decision Support and Computerized Provider Order Entry are no longer required. One-size-fits-all every measure reported and weighed equally All-or-nothing EHR measurement and quality reporting Misaligned with other Medicare reporting programs Customizable Physicians or clinicians can choose which best measures fit their practice Flexible multiple paths to success Aligned with other Medicare reporting programs. No need to report quality measures as part of this category 34

35 Advancing Care Information MIPS Advancing Care Information Objectives and Measures Objective Protect Patient Health Information Electronic Prescribing Patient Electronic Access Coordination of Care Through Patient Engagement Measure Security Risk Analysis eprescribing Patient Access Patient-Specific Education View, Download and Transmit (VDT) Secure Messaging Patient-Generated Health Data Health Information Exchange Exchange Information with Other Physicians or Clinicians Exchange Information with Patients Clinical Information Reconciliation Immunization Registry Reporting Public Health and Clinical Data Registry Reporting (Optional) Syndromic Surveillance Reporting (Optional) Electronic Case Reporting (Optional) Public Health Registry Reporting (Optional) Clinical Data Registry Reporting 35

36 Meaningful Use Stage Modified Stage 2 Crosswalk to Stage 3 Objectives Modified Stage 2 Stage 3 (2018)* SRA Conduct or Review during CY and prior to attestation including addressing encryption/security of data created or maintained in CEHRT Medications > 60% > 60% CPOE Labs > 30% > 60% Radiology > 30% > 60% erx > 50% of all permissible prescriptions are queried for a drug formulary AND transmitted electronically > 60% of all permissible prescriptions are queried for a drug formulary AND transmitted electronically Clinical Decision Support Rules Interactions 5 Enabled for Entire Reporting Period (RP) Enabled for Entire Reporting Period (RP) 36

37 Meaningful Use Stage 3 (cont d) Objectives Modified Stage 2 Stage 3 (2018)* Patient Education > 10% Incorporated into Patient Electronic Access View, Download and Transmit (VDT) Access > 50% w/in 4 days Incorporated into Patient Electronic Access Usage > 5% Incorporated into Coordination of Care through Patient Engagement Patient Electronic Access Access Patient Education N/A Secure Messaging > 5% > 80% of all unique patients are provided timely access to VDT their health information AND ensure health information is available for the patient to access using any application of their choice that is configured to meet the technical specifications of the API in the EPs CEHRT For > 35% of unique patients, CEHRT is used to identify educational resources to which electronic access is provided Incorporated into Coordination of Care through Patient Engagement 37

38 Meaningful Use Stage 3 (cont d) Coordination of Care through Patient Engagement Objectives Modified Stage 2 Stage 3 (2018)* VDT Secure Messaging Patient Generated Health Data N/A > 10% of unique patients engage with EHR by either 1) VDT health information or 2) access health information via an API or 3) a combination of both > 25% of unique patients, or in response to a secure message sent by patient > 5% of unique patients incorporate non-clinical setting data into the CEHRT Medication Reconciliation > 50% Incorporated into Health Information Exchange 38

39 Meaningful Use Stage 3 (cont d) Objectives Modified Stage 2 Stage 3 (2018)* Provide SoC Electronically Use CEHRT to create a SoC AND transmit electronically for > 10% of ToCs Use CEHRT to create a SoC AND transmit electronically for > 50% of ToCs Health Information Exchange Receive or Retrieve SoC N/A EP receives or retrieves a SoC for > 40% of ToCs in which the EP has never encountered the patient AND incorporates it into the patient s CEHRT record Reconciliation of Clinical Information N/A Perform a reconciliation of clinical information for > 80% of transitions/referrals or for patient encounters in which the EP has never encountered the patient 39

40 Meaningful Use Stage 3 (cont d) Objectives Modified Stage 2 Stage 3 (2018)* Imms Registry Syndromic Surveillance Actively Engaged w/2 of 3 Specialized Registry Public Health Electronic Case Reporting N/A Actively Engaged w/3 of 5 PH Registry Reporting Clinical Data Registry Reporting Included as Specialized Registry * As Stage 3 is optional in 2017, some measure thresholds have been reduced to allow early adopters ease in transitioning to the 2018 Stage 3 required thresholds 40

41 CMS HITECH funds to support connection with non-eps Letter to State Medicaid Directors issued on 2/29/2016 Funds to promote HIE and encourage the adoption of certified EHR technology by other Medicaid providers Behavioral health providers, substance abuse treatment providers, long-term care providers, home health providers, pharmacies, laboratories, correctional health providers, emergency medical service providers, and public health providers. Funds can be spent on HIE interoperability & infrastructure but cannot be spent on purchasing EHR technology. Activities must directly support achievement of MU by EPs. 41

42 Expanded M-CEITA Support for non-eps In partnership with the State of Michigan, M-CEITA is proposing to expand services in 2017 to include: Support of Medicaid BH providers adoption and implementation of Electronic Consent Management (econsent) for the electronic exchange of patient information Support for EHR Adoption, Optimization and HIE by Long Term and Post Acute Care organizations in support of Medicaid EP Meaningful Use 42

43 Resources Modified Stage 2 Final Rule: MIPS/APM Proposed Rule: Tipsheet: Guidance/Legislation/EHRIncentivePrograms/Downloads/2016_EPWhatYou NeedtoKnowfor2016.pdf Modified Stage 2 Tipsheet: Guidance/Legislation/EHRIncentivePrograms/Downloads/Stage3Overview2 015_2017.pdf 2016 Program Requirements and Tools and- Guidance/Legislation/EHRIncentivePrograms/2016ProgramRequirements.ht ml Hardship Exception Application: Guidance/Legislation/EHRIncentivePrograms/PaymentAdj_Hardship.html 43

44 Questions? Bruce Maki