Game Plan. Meaningful Use Where are We? So is Anyone Registering? So, are EPs getting any money? 5/1/2015 $29,584,224,916

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1 Meaningful Use and Quality Reporting: What s here now, what s changing, and what s coming next? Where to go for Help, Handouts, and Future Updates Disclosures: Dr. Henry is affiliated with and has lectured for numerous companies including Topcon, First Insight, RevolutionEHR, FoxFire, VisionWeb, SolutionReach, and the AOA. Jay W. Henry, O.D., M.S. Game Plan Meaningful Use Summary and Statistics Meaningful Use Proposed Modifications for Meaningful Use Proposed Stage 3 for 2018 Clinical Quality Measures EHR Incentive Program Audits Questions Meaningful Use Where are We? So is Anyone Registering? Over 528,829 eligible professionals (EPs), eligible hospitals, and critical access hospitals (CAHs) have registered for the Medicare and/or Medicaid EHR Incentive Programs as of February, ,300 Optometrists have registered as of February, 2015 So, are EPs getting any money? More than $ 20 Billion in Medicare EHR Incentive Program payments have been made as of February, 2015 More than $ 9.2 Billion in Medicaid EHR Incentive Program payments have been made as of February, 2015 Total amount paid under Medicare and Medicaid as of February, 2015 $29,584,224,916 1

2 EHR Incentive Payments to OD s As of February, 2015 for Medicare EHR Incentive Payments 24,134 Optometrists have attested and been paid Which totals $286,082,221 14,128 Ophthalmologists have attested Which totals $199,075,580 Incentive Payments by Specialty Incentive Payments by Specialty under Medicare As of February, Family Practice 75, Internal Medicine 69, Cardiology 26, Optometry 24, Orthopedic Surgery 20, OB/GYN 18, Podiatry 18, Chiropractors 17, Gastroenterology 15, General Surgery 14, Ophthalmology 14, Neurology 12,143 More than 94% of eligible hospitals have registered to participate More than 82% of all EPs have registered to participate More than 75% of all EPs have received an EHR incentive payment 2014 Meaningful Use Attestations (thru March 1, 2015) 209,369 EPs successfully attested for ,435 = New participants 153,002 Attested to Stage 1 56,367 = Attested to Stage 2 2

3 Highlights of Attestations On average all thresholds were greatly exceeded, but every threshold had some providers on the borderline Little difference among specialties in performance, but differences in exclusions Most popular menu items for EPs Drug Formulary Immunization registries Patient list Least popular menu items for EPs Transition of care summary Patient reminders EP Stage 2 Performance EP Stage 2 Performance EP Stage 2 Performance EP Stage 2 Performance The Meaningful Use Monster Changing Once Again Proposed Rule to Modify MU in ! 3

4 Proposed Changes for Why change now? Goal is to align Stage 1 and Stage 2 objectives and measures with the proposed Stage 3 rules More specifically the want to: Build progress toward milestones Reduce complexity Simplify providers reporting Focus on the more advanced use of certified EHR technology Support the health information exchange and quality improvement Proposed Changes for The goal is to simplify and streamline MU while making ongoing changes easier to implement This will be accomplished by: Reducing overall number of objectives Removing measures that have become redundant, duplicative, or have reached wide-spread adoption Meaningful Use Proposed Changes Proposed Changes Stage 1 and Stage 2 for The information is from the Notice of Proposed Rulemaking: EHR Incentive Program Modifications to MU in as published in the Federal Register on 04/15/2015 and is NOT FINAL The information is may change and is currently in a 60 day comment period ending in June Rule should be finalized in Aug / Sept 2015 Proposed Stage 3 rule for 2017 / 2018 and beyond The information is from the Notice of Proposed Rulemaking: EHR Incentive Program Stage 3 as published in the Federal Register on 3/30/2015 and is NOT FINAL The information is may change and is currently in a 60 day comment period ending in June Rule should be finalized in Aug / Sept 2015 From past experience we know that most of the concepts and details will remain the same or very similar but you must understand that some things may be adjusted in the official published final rule Proposed Changes That Impact 2015 Can attest for any 90 day period from January 1, 2015 December 31 st, 2015 No 2015 attestations for Medicare will be accepted until January 1, 2016 Ohio Medicaid will announce attestation timeline once the rule is finalized Proposed Changes for Reporting Period For 2015: EPs would be allowed to attest to an EHR reporting period of any continuous 90-day period within the calendar year For 2016: All returning participants would use an EHR reporting period of the full 2016 calendar year EPs demonstrating MU for the first time in 2016 can use an EHR reporting period of any continuous 90 days during 2016 For 2017: All providers, both new and existing participants, would use an EHR reporting period of 1 full calendar year Proposed Changes for EHR Technology For : Providers will continue to use EHR technology certified to the 2014 standards As long as your vendor has updated you recently, this should be the version you are currently using For 2018: Providers must update / upgrade software to the 2015 EHR standards 4

5 Proposed Changes for 2015 Providers will attest to a single set of blended Stage 1 and Stage 2 objectives and measures beginning in 2015 No core or menu measures All reporting will be for 90 days This set of objectives is being called modified Stage 2 This will be done by leveraging existing objectives and measures of MU Accommodations by multiple exclusions and alternative measures within individual objectives will be made for providers who would have been in different stages of MU If your first year of MU was in 2014 or is in 2015 you will have accommodations / additional exclusions in the proposed new objectives since you would have been in stage 1 during 2015 CQMs will be reported electronically or attested to; CQM 90 day period doesn t need to coincide with the 90 day MU attestation period Because of delayed attestation in 2015, 1 st time attesters that attest after Oct. 1 st will have the CMS penalties reversed after the attestation is complete Proposed Changes for 2016 Providers will attest to a single set of blended Stage 2 objectives and measures beginning in 2016 No alternate measures, some exclusions removed 1 st time attestations will be any 90 days; all other returning Meaningful Users will report on 365 days / calendar year CQMs will be reported electronically or attested to 2014 Stage 2 Flex Rule 2015 Modified Stage Modified Stage 2 MU Changes Over the Years Allowed providers to look back and use Stage 1 Objectives Modified Stage 2 measures Allowed reporting period to be calendar quarter Proposed unified set of reporting objectives with exclusions / alternate measures to account for those that would have been in stage 1 Proposed reporting period of any continuous 90 days Proposed unified set of reporting objectives for everyone Proposed reporting period of 1 year First Year as a Meaningful EHR User 2011 Stage 1 Future of Meaningful Use Stage of Meaningful Use Stage Stage 1 Stage 1 Stage Stage Stage 2 Stage 2 Stage 1 Stage 1 Modified Stage 2 Modified Stage 2 Modified Stage 2 Modified Stage 2* 2015 Modified Stage 2* 2016 * Modified stage 2 includes alternate exclusions for certain objectives for providers that were scheduled to demonstrate stage 1 in 2015 Modified Stage 2 Modified Stage 2 Modified Stage 2 Modified Stage 2 Modified Stage 2 Modified Stage 2 Modified 2 or Stage 3 Modified 2 or Stage 3 Modified 2 or Stage 3 Modified 2 or Stage 3 Modified 2 or Stage 3 Modified 2 or Stage 3 Stage 3 Stage 3 Stage 3 Stage 3 Stage 3 Stage 3 Proposed Changes for Objective / Measure Changes CMS proposes to eliminate the distinction between core and menu objectives, and all retained objectives would be required CMS has identified the following objectives as either redundant, duplicative, or topped out and will no longer require attestation on them Record Demographics Record Vital Signs Record Smoking Status Clinical Summaries Structured Lab Results Patient List Patient Reminders Electronic Notes Imaging Results Family Health History Summary of Care Measure 1 Any Method Measure 3 - Test Proposed Changes for Objective / Measure Changes CMS states that many of these redundant, duplicative, or topped out objectives and measures may be valuable to providers and patients They encourage providers to continue to conduct these activities if it suits their practice and patient population 5

6 Stage 3 Modified Stage 2 5/1/2015 Proposed Changes for Objective / Measure Changes Finally help with the patient engagement objectives Currently there are 2 objectives for EPs that require patient action both have a 5% threshold: View, Download, or Transmit (VDT) Health information Secure Messaging For VDT new requirement would be: 1 patient seen by the provider during the reporting period views, downloads, or transmits their information to a third party For Secure messaging new requirement would be: Yes / No attestation to the statement: The capability for patients to send and receive secure electronic message was enabled during the EHR reporting period Proposed Changes for Objective / Measure Changes Original Stage 1 criteria 2014 Stage 1 criteria 15 core objectives 13 core objectives 5 of 10 menu objectives 5 of 9 menu objectives 20 total objectives 18 total objectives Stage 2 criteria criteria 17 core objectives 9 Objectives 3 of 6 menu objectives + Public Health Objectives / 20 total objectives Registry Reporting Measures 2018 Stage 3 criteria 7 Reporting areas / objectives + Public Health Objectives / Registry Reporting Measures Proposed Objectives (Modified Stage 2) Proposed Objective Changes Modified Stage 2: Stage 3: 2018 Protect Patient Health Information Summary Of Care Electronic Prescribing Patient Electronic Access to Health Information Clinical Decision Support Patient Specific Education Computerized Provider Order Entry Medication Reconciliation Secure Messaging Public Health & Clinical Data Registry Reporting Proposed 2018 Stage 3 Objectives Protect Patient Health Information Computerized Provider Order Entry Health Information Exchange (HIE) Electronic Prescribing Patient Electronic Access to Health Information Public Health & Clinical Data Registry Reporting Clinical Decision Support Coordination of Care through Patient Engagement Protect Electronic Health Information Conduct or review a security risk analysis including addressing the encryption/security of data stored in CEHRT and implement security updates as needed and correct identified security deficiencies as part of the risk management process No exclusion Conduct or review a security risk analysis including addressing the security (including encryption) of data stored in CEHRT and implement security updates as necessary, and correct identified security deficiencies as part of the provider s risk management process No exclusion 6

7 Stage 3 Modified Stage 2 5/1/2015 Protect electronic health information A major goal of the Security Rule is to protect the privacy of individuals health information while allowing covered entities to adopt new technologies to improve the quality and efficiency of patient care This is similar to the current HIPAA security rules You must document and conduct or review a security risk analysis and implement updates as necessary Should be done once prior to end of reporting period Your software vendor should be able to provide you with tools to complete the risk analysis Protect electronic health information HIPAA protects the privacy of individually identifiable health information, called protected health information (PHI) Security Rule protects a subset of information covered by the Privacy Rule, which is all individually identifiable health information a covered entity creates, receives, maintains or transmits in electronic form. The Security Rule calls this information electronic protected health information (e-phi) Annual Security Risk Assessment Cycle Conduct a security risk assessment Protect electronic health information Where to get more help: Monitor results Identify risks, threats, and vulnerabilities Mitigate risks threats and vulnerabilities Develop remediation plan Electronic Prescribing More than 50% of all permissible prescriptions written by the EP are queried for a drug formulary and transmitted electronically using CEHRT You can be excluded from meeting this objective if you write fewer than 100 prescriptions during the reporting period or Do not have a pharmacy within your organization and there are no pharmacies that accept electronic prescriptions within 10 miles of the EP's practice location at the start of your EHR reporting period More than 80% of all permissible prescriptions written by the EP are queried for a drug formulary and transmitted electronically using CEHRT You can be excluded from meeting this objective if you write fewer than 100 prescriptions during the reporting period or Do not have a pharmacy within your organization and there are no pharmacies that accept electronic prescriptions within 10 miles of the EP's practice location at the start of your EHR reporting period 7

8 Modified Stage 2 for 2015 Stage 1 EPs Stage 3 Modified Stage 2 Modified Stage 2 for 2015 Stage 1 EPs 5/1/2015 Electronic Prescribing Alternate for 2015 Stage 1 EPs For 2015 Reporting period only if you were scheduled to be in Stage 1 for 2015 More than 40% of all permissible prescriptions written by the EP are transmitted electronically using Certified EHR Technology E-Prescribing (erx) Clinical Significance? Improves medication safety Better management of medication costs Improved prescribing accuracy and efficiency Increase practice efficiency Reducing health care costs Reduction of adverse drug events Clinical Decision Support (CDS) Measure 1: Implement five clinical decision support interventions related to four or more clinical quality measures at a relevant point in patient care for the entire EHR reporting period Measure 2: The EP has enabled and implemented the functionality for drug-drug and drug-allergy interaction checks for the entire EHR reporting period For Measure 2, you can be excluded if you write fewer than 100 medication orders during the reporting period Measure 1: Implement five clinical decision support interventions related to four or more clinical quality measures at a relevant point in patient care for the entire EHR reporting period Measure 2: The EP has enabled and implemented the functionality for drug-drug and drug-allergy interaction checks for the entire EHR reporting period For Measure 2, you can be excluded if you write fewer than 100 medication orders during the reporting period Clinical Decision Support Alternate for 2015 Stage 1 EPs For 2015 Reporting period only if you were scheduled to be in Stage 1 for 2015 Implement one clinical decision support rule relevant to specialty or high clinical priority, along with the ability to track compliance with that rule 8

9 Modified Stage 2 for 2015 Stage 1 EPs Stage 3 Modified Stage 2 5/1/2015 Clinical Decision Support Details Implement clinical decision support Clinical Decision Support: Functionality that builds upon the foundation of an EHR to provide persons involved in care processes with general and person-specific information, intelligently filtered and organized, at appropriate times, to enhance health and health care Clinical Significance? These are rules designed to help us meet the standard of care in terms of testing and follow up care Examples: If a patient has an active medication of Plaquenil listed, has a macular visual field, color vision testing, and a SD OCT been ordered? When an IOP is above a specific level, a warning of possible glaucoma is triggered If a diagnosis of glaucoma is entered, is the patient scheduled or have they had a VF or a scanning laser within the last 6-12months Computerized Provider Order Entry You must create using CPOE the following: Measure 1: More than 60% of medication orders Measure 2: More than 30% of laboratory orders Measure 3: More than 30% of radiology orders You can be excluded individually from meeting each of the above measures for the ones that you have fewer than 100 orders during the reporting period Use CPOE for medication, lab, & diagnostic imaging orders directly entered by any licensed healthcare professional, credentialed medical assistant, or medical staff member credentialed to and performing the duties of a credentialed medical assistant; who can enter orders into the medical record per state, local and professional guidelines Measure 1: More than 80% of medication orders Measure 2: More than 60% of laboratory orders Measure 3: More than 60% of diagnostic imaging orders Includes radiology, ultrasound, MRI, computed tomography, and other diagnostic imaging You can be excluded individually from meeting each of the above measures for the ones that you have fewer than 100 orders during the reporting period Computerized Provider Order Entry Alternate for 2015 Stage 1 EPs CPOE Details for Modified Stage 2 For 2015 Reporting period only if you were scheduled to be in Stage 1 for 2015 Measure 1: More than 30% of medication orders, created by the EP, during the EHR reporting period are recorded using CPOE Measure 2: Provider may claim an exclusion for measure 2 (lab orders) for an EHR reporting period in 2015 only Measure 3: Provider may claim an exclusion for measure 3 (radiology orders) for an EHR reporting period of 2015 only Computerized Provider Order Entry (CPOE): A provider's use of computer assistance to directly enter medical orders from a computer or mobile device Laboratory Order: Order for any service provided by a laboratory that could not be provided by a nonlaboratory Radiology Order: Order for any imaging services that uses electronic product radiation. The EP can include orders for other types of imaging services that do not rely on electronic product radiation in this definition as long the policy is consistent across all patient and for the entire EHR reporting period 9

10 Stage 3 Modified Stage 2 5/1/2015 CPOE Details for Stage 3 Computerized Provider Order Entry (CPOE): A provider's use of computer assistance to directly enter medical orders from a computer or mobile device Laboratory Order: Order for any service provided by a laboratory that could not be provided by a non-laboratory Diagnostic Imaging Order: Order for any imaging services that uses ultrasound, magnetic resonance, computed tomography, radiologic, and other imaging Computerized Provider Order Entry Clinical Significance? Directly entering orders into a computer has the benefit of reducing errors by minimizing the ambiguity of hand-written orders, but a much greater benefit is seen with the combination of CPOE and clinical decision support tools Implementation of CPOE is being increasingly encouraged as an important solution to the challenge of reducing medical errors, and improving health care quality and efficiency CPOE Lab Test Order Entry CPOE Diagnostic Imaging Order Summary of Care Record The EP that transitions or refers their patient to another setting of care or provider of care must: Measure 1: Use CEHRT to create a summary of care record Measure 2: Electronically transmit such summary to a receiving provider more than 10% of transitions of care and referrals You can be excluded if you transfer a patient to another setting or refer a patient to another provider less than 100 times during the EHR reporting period Covered under the new Stage 3 Objective: Health Information Exchange 10

11 Modified Stage 2 for 2015 Stage 1 EPs Stage 3 Modified Stage 2 Modified Stage 2 for 2015 Stage 1 EPs 5/1/2015 Summary of Care Record Alternate for 2015 Stage 1 EPs For 2015 Reporting period only if you were scheduled to be in Stage 1 for 2015 The EP that transitions or refers their patient to another setting of care or provider of care must: Measure 1: Use CEHRT to create a summary of care record Measure 2: You are excluded from the electronic transmission of a summary of care document if for an EHR reporting period in 2015 you were scheduled to demonstrate Stage 1 Summary of Care Record for Transitions of Care Clinical Significance? You must provide a summary of care record to the provider you are referring the patient to This is important because it allows the next provider of care to understand your clinical findings which may impact the patients care You could use the clinical summary or your electronic copy You must have 10% of the summaries transmitted electronically This is why secure (direct) messaging is so important! Eventually you will be able to look up a doctors direct address on the NPPES website Patient Specific Education Patient specific education resources identified by CEHRT are provided to patients for more than 10% of all unique patients with office visits during the reporting period. To count for this objective educational material given must be identified by the CEHRT You can be excluded if you have no office visits during the reporting period Covered under the Stage 3 Objective: Patient Electronic Access to Health Information Patient Specific Education Alternate for 2015 Stage 1 EPs For 2015 reporting period only Provider may claim an exclusion for Patient specific education 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 item 11

12 Modified Stage 2 for 2015 Stage 1 EPs Stage 3 Modified Stage 2 5/1/2015 Patient specific education resources Clinical Significance? It is our job as a doctor to properly educate our patients on all of their clinical findings and diagnosis as well as risks and benefits of each treatment option Certified EHRs have the ability to identify patient specific educational resources based on the problem list, medication list, or lab test results The EHR technology must identify the patient educational material or resources The resources do not have to be stored within or generated by the EHR Medication Reconciliation The EP performs medication reconciliation (including name, dosage, frequency, and route) for more than 50% of transitions of care in which the patient is transitioned into your care You can be excluded if you are not the recipient of any transitions of care during the EHR reporting period Covered under the new Stage 3 Objective: Health Information Exchange Medication Reconciliation Alternate for 2015 Stage 1 EPs For 2015 reporting period only Provider may claim an exclusion for the measure of 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 Medication Reconciliation Clinical Significance? This is very important to our patient care Unintended inconsistencies in medication regimens may occur at any point of transition in care The goal is to review all medications a patient it taking with them and provide them with a current updated list after each encounter This helps avoid negative drug interactions as well as drug duplication Medication reconciliation is the process of identifying the most accurate list of all medications the patient is taking by comparing the medical record to an external list of medications obtained from a patient, hospital or other provider 12

13 Stage 3 Modified Stage 2 Modified Stage 2 for 2015 Stage 1 EPs 5/1/2015 Patient Electronic Access to Health Information Measure 1: More than 50% of all unique patients are provided timely (within 4 business days after the info is available to the EP) online access to their health information Measure 2: At least one patient seen by the EP during the reporting period (or their authorized representatives) views, downloads, or transmits their health information to a third party You can be excluded if you neither order nor create any of the info listed for inclusion You can be excluded if you conduct 50% or more of encounters in a county that does not have 50% or more housing units with 3Mbps broadband availability Measure 1: For more than 80% of all unique patients seen by the EP (1) The patient (or patient-authorized rep) is provided access to view online, download, and transmit their health information within 24 hours of its availability to the provider (2) The patient (or auth rep) is provided access to an ONC-certified API that can be used by third-party apps or devices to provide patients access to their health information, within 24 hours of its availability to the provider Measure 2: EP must use clinically relevant information from CEHRT to identify patient-specific educational resources and provide electronic access to those materials to more than 35% of unique patients seen by the EP during the reporting period You can be excluded from both measures if you have no office visits during the reporting period You can be excluded from Measure 1 if you conduct 50% or more of encounters in a county that does not have 50% or more housing units with 4Mbps broadband availability Patient Electronic Access Alternate for 2015 Stage 1 EPs For 2015 reporting period only Measure 1: More than 50% of all unique patients are provided timely (within 4 business days after the info is available to the EP) online access to their health information Measure 2: Providers may claim an exclusion for this part (at least one patient seen by the EP during the reporting period (or their authorized representatives) views, downloads, or transmits their health information to a third party) if for an EHR reporting period in 2015 they were scheduled to demonstrate Stage 1 13

14 Stage 3 Modified Stage 2 5/1/2015 Patient Electronic Copy and Electronic Access Clinical Significance? Patient access will allow patients to understand what clinical testing was completed during an encounter as well as the results of those tests Online electronic access through either a patient portal or personal health record (PHR) will satisfy this objective The minimal information to be included is: Lab test results, problem list, medication list, and medication allergy list You may withhold information from the electronic copy in accordance with HIPAA Patient Electronic Copy and Electronic Access: API Application Programming Interface (API) API is a set of programming protocols Enables access to data via third-party applications More flexible than a patient portal If API provides view, download, transmit than a patient portal is not needed separately Secure Electronic Messaging During the entire reporting period, the capability for patients to send and receive a secure electronic message with the provider was fully enabled You can be excluded if you have no office visits You can be excluded if you conduct 50% or more of encounters in a county that does not have 50% or more housing units with 3Mbps broadband availability Covered under the new Stage 3 Objective: Coordination of Care Through Patient Engagement 14

15 Modified Stage 2 for 2015 Stage 1 EPs Stage 3 Modified Stage 2 5/1/2015 Secure Electronic Messaging Alternate for 2015 Stage 1 EPs For 2015 reporting period only An EP may claim an exclusion for this measure if for an EHR reporting period in 2015 you were scheduled to demonstrate Stage 1 Secure Electronic Messaging Secure Message: Any electronic communication between a provider and patient that ensures only those parties can access the communication This electronic message could be secure or the electronic messaging function of a PHR, an online patient portal, or any other electronic means that is authenticated (both patient and EHR user) and encrypted Public Health and Clinical Data Registry (CDR) Reporting EPs required to choose from measures 1-5, and required to successfully attest to any combination of two measures. Some measures may be used more than once Measure 1: Immunization registry reporting can count 1 time toward objective Measure 2: Syndromic Surveillance reporting can count 1 time toward objective Measure 3: Case Reporting can count 1 time toward objective Measure 4: Public Health Registry reporting can count 3 times toward objective Measure 5: Clinical Data Registry reporting can count 3 times toward objective You may be excluded from the measures that don t apply but you can only claim an exclusion once you can exclude from all remaining measures EPs required to choose from measures 1-5, and required to successfully attest to any combination of three measures. Some measures may be used more than once Measure 1: Immunization registry reporting can count 1 time toward obj. Measure 2: Syndromic Surveillance reporting can count 1 time toward obj. Measure 3: Case Reporting can count 1 time toward objective Measure 4: Public Health Registry reporting can count 3 times toward obj. Measure 5: Clinical Data Registry reporting can count 3 times toward obj. You may be excluded from the measures that don t apply but you can only claim an exclusion once you can exclude from all remaining measures 15

16 Modified Stage 2 for 2015 Stage 1 EPs 5/1/2015 Public Health and Clinical Data Registry (CDR) Reporting Alternate for 2015 Stage 1 EPs For 2015 reporting period only EPs scheduled to be in Stage 1 in 2015 must report on at least one measure below unless they can exclude from all available measures Measure 1: Immunization registry reporting can count 1 time Measure 2: Syndromic Surveillance reporting can count 1 time Measure 3: Case Reporting can count 1 time Measure 4: Public Health Registry reporting can count 3 times Measure 5: Clinical Data Registry reporting can count 3 times Public Health and Clinical Data Registry (CDR) Reporting To meet this objective you must be in active engagement with a Public Health Agency or clinical data registry to submit electronic data in a meaningful way using CEHRT, except where prohibited and in accordance with applicable law and practice You may be excluded from the measures that don t apply but you can only claim an exclusion once you can exclude from all remaining measures Public Health and Clinical Data Registry (CDR) Reporting: Active Engagement Active engagement is defined as: Option 1: Completed registration to submit data: Registration was completed within 60 days after the start of the EHR reporting period and the EP is awaiting an invitation from the PHA or CDR to begin testing Option 2: Testing and Validation: EP is in the process of testing and validation of the electronic submission of data. EPs must respond to requests from the PHA within 30 days; failure to respond twice within a reporting period would result in failure to meet this objective Option 3: Production: EP has completed testing and validation and is electronically submitting produciton data to PHA or CDR 1. Public Health and Clinical Data Registry (CDR) Reporting: Immunization Registry EP is in active engagement with a PHA to submit immunization data and receive immunization forecasts and histories You may excluded from this measure: If you do not administer any immunizations to any of the populations for which data is collected Operate in a jurisdiction for which no immunization registry is capable of accepting the specific standards required Operate in a jurisdiction where no immunization registry has declared readiness to receive data at the start of the reporting period 2. Public Health and Clinical Data Registry (CDR) Reporting: Syndromic Surveillance EP is in active engagement with a PHA to submit syndromic surveillance data Any EP meeting one or more of the following criteria may be excluded from this measure: Does not treat or diagnose or directly treat any disease or condition associated with a syndromic surveillance system in their jurisdiction Operates in a jurisdiction for which no PHA is capable of receiving electronic syndromic data in the specific standards required Operates in a jurisdiction where no PHA has declared readiness to receive syndromic surveillance data from Eps at the start of the EHR reporting period 16

17 3. Public Health and Clinical Data Registry (CDR) Reporting: Case Reporting EP is in active engagement with a PHA to submit case reporting of reportable conditions PHA collects reportable conditions as defined by the state, territorial, or local PHA to monitor disease trends and support management of outbreaks Any EP may be excluded from the case reporting if the EP: Does not teat or diagnose any reportable diseases Operates in a jurisdiction for which no PHA is capable of receiving electronic case reporting in the specific standards required Operates in a jurisdiction where no PHA has declared readiness to receive electronic case reporting data at the start of the EHR reporting period 4. Public Health and Clinical Data Registry (CDR) Reporting: Public Health Registry EP is in active engagement with a PHA to submit data to public health registries Public Health Registry is a registry that is administered by, or on behalf of, a local, state, territorial, or national PHA and which collects data for public health purposes Any EP may be excluded from public health registry reporting if the EP: Does not diagnose or directly teat any disease or condition associated with a public health registry in their jurisdiction during the reporting period Operates in a jurisdiction for which no public health registry is capable of accepting electronic transactions in the specific standards required Operates in a jurisdiction where no public health registry for which the EP is eligible has declared readiness to receive electronic registry transactions at the start of the EHR reporting period 5. Public Health and Clinical Data Registry (CDR) Reporting: Clinical Data Registry EP is in active engagement with a PHA to submit data to a clinical data registry Clinical data registries are administered by, or on behalf of, other non-public health agencies Clinical data registries can be used to monitor health care quality and resource use Any EP may be excluded from clinical data registry reporting if the EP: Does not diagnose or directly teat any disease or condition associated with a clinical data registry Operates in a jurisdiction for which no clinical data registry is capable of accepting electronic registry transactions in the specific standards required Operates in a jurisdiction where no clinical data registry for which the EP is eligible has declared readiness to receive electronic registry transactions at the start of the EHR reporting period AOA Registry More - Measures and Outcomes Registry for Eyecare AOA Registry Benefits PQRS Reporting Meaningful Use Clinical Data Registry Benchmark and Outcomes Advocacy Evidence-Base Physician Payment Modifier 17

18 Stage 3 5/1/2015 AOA Registry Roll Out Registry will be launched in June 2015 at Optometry s Meeting Integrate with EMRs Health Innovation Technologies RevolutionEHR Compulink Advantage/EHR First Insight MaximEyes SQL Coordination of Care Through Patient Engagement You must attest to the numerator and denominator for all 3 measures, but would only be required to successfully meet the threshold for two of the three measures listed to meet the objective Measure 1: (1) More than 25% of all unique patients seen by the EP during the reporting period view, download, or transmit to a third party their health information or (2) More than 25% of all unique patients seen by the EP during the reporting period access their health information through the use of an ONC-certified API that can be used by third-party apps or devices Measure 2: For more than 35% of all unique patients seen by the EP during the reporting period, a secure message was sent using CEHRT to the patient (or auth rep), or in response to a secure message sent by the patient Measure 3: Patient-generated health data or data from a non-clinical setting is incorporated into the CEHRT for more than 15% of all unique patients seen by the EP during the reporting period You may exclude from both parts of measure 1, measure 2, and measure 3 : If you have no office visits If you conduct 50% or more of encounters in a county that does not have 50% or more housing units with 4Mbps broadband availability Information From Patient or Non- Clinical Setting Information from patient Patient generates the data on their own Recording own vital signs, activity and exercise, medication intake, nutrition Information from non-clinical setting Non-EP or non-hospital provider who doesn t have access to the EPs EHR Nutritionists, physical therapists, occupational therapists, psychologists, home health providers Could include: Social service data, advanced directives, medical device data, fitness monitoring, etc. 18

19 Stage 3 5/1/2015 Health Information Exchange You must attest to the numerator and denominator for all 3 measures, but would only be required to successfully meet the threshold for two of the three measures listed to meet the objective Measure 1: For more than 50% of transition of care and referrals the EP that transitions or refers their patient to another setting of care or provider of care (1) creates a summary of care record using CERHT and (2) electronically exchanges the summary of care record Measure 2: For more than 40% of transitions or referrals received and patient encounters in which the provider has never before encountered the patient, the EP incorporates into the patient s EHR an electronic summary of care document from a source other than the provider s EHR system Measure 3: For more than 80% of transitions or referrals received and patient encounters in which the provider has never before encountered the patient, the EP performs a clinical information reconciliation. Reconciliation must be done for: Meds, Med Allergies, and Current problem list You may be excluded from Measure 1 if: You neither transfer a patient nor refer a patient to another provider or You conduct 50% or more of encounters in a county that does not have 50% or more housing units with 4Mbps broadband availability You may be excluded from Measure 2 and 3 if: The total of transitions or referrals received and encounters in which you have never before encountered the patient is few than 100 during the reporting period or You conduct 50% or more of encounters in a county that does not have 50% or more housing units with 4Mbps broadband availability 19

20 How to Survive Don t forget about the deleted measures Continue to monitor them and utilize them because they impact other measures and CQMs Run Stage 2 reports for all providers (even those in Stage 1 for 2015) This will identify gaps and workflow issues to meet the modified Stage 2 Objectives Start planning now Be prepared but understand the changes discussed today are proposed and won t be final until August Thresholds and exclusions may change in the Final Rule Talk to your vendors Have them adjust MU reports as needed Clinical Quality Measures Clinical Quality Measures (CQMs) Still Required to be a Meaningful User CQMs are tools that help measure and track the quality of health care services provided by eligible professional These measures use data associated with providers ability to deliver high-quality care or relate to long term goals for quality health care Clinical Quality Measures Measuring and reporting CQMs helps to ensure our health care system is delivering effective, safe, efficient, patient centered and timely care Clinical Quality Measures CQMs measure many aspects of care including: Health outcomes Clinical processes Patient safety Efficient use of health care resources Care coordination Patient engagements Population and public health Adherence to clinical guidelines 20

21 Clinical Quality Measures To participate in the Medicare and Medicaid EHR incentive programs and receive a payment providers are required to submit CQM data from certified EHR technology CQMs may be reported electronically or via attestation Clinical Quality Measures For EPs will need to report 9 (of 64 possible) measures These 9 measures must cover at least 3 of the 6 National Quality Strategy domains Patient and Family Engagement Patient Safety Care Coordination Population/Public Health Efficient Use of Healthcare Resources Clinical Process/Effectiveness CMS encourages eligible professionals to report from the recommended set to the extent those CQMs are applicable to your scope of practice and patient population Clinical Quality Measures Samples of 2015 CQMs Controlling High Blood Pressure Use of High-Risk Medications in the Elderly Preventive Care and Screening: Tobacco Use Documentation of Current Medications in the Medical Record Preventive Care and Screening: Body Mass Index Screening and Follow-Up Closing the Referral Loop Receipt of Specialist Report Need Help Understanding CQMs for 2015? CQM webpage Guidance/Legislation/EHRIncentivePrograms/Cli nicalqualitymeasures.html CMS EHR Incentive Audits 21

22 Audit Selection Providers who receive an EHR incentive payment for either the Medicare or Medicaid EHR Incentive Program are subject to an audit 5 10% who have attested will be audited CMS will oversee Medicare Incentive Audits Individual States will oversee Medicaid Incentive Audits Audit Selection First, random audits are being done In addition, risk profile of suspicious / anomalous data will also trigger audits CMS is not going to make the risk profile public You may be subject to successive audits Pre- and Post- Payment Audits Post-Payment Audits are those which occur after you have received an EHR Incentive Payment. They began in July, Pre-Payment Audits are those which occur before you have received an EHR Incentive Payment. They began in January, If you have a post-payment audit for your first year of participation, you will typically get a prepayment audit for the following year Audit Statistics In 2014, a Freedom of Information Act request was filed to obtain information on those audited since the program started For unknown reasons, the data is not automatically published by CMS The initial look at this data is scary! Pre Payment Audits as of Sept, ,825 Pre Payment Audits have been undertaken for EPs. 3,820 of 5,825 Pre Payment audits have been completed which is 66% Over 2000 Pre Payment audits still in process! So, how did these entities make out? 22

23 Pre Payment Audits as of Sept, of 3,820 (21%) pre-payment audits completed did not meet meaningful use and failed! CMS is citing two main reasons for failing Failure to use a certified EHR (7.1%) Failure to meet the appropriate objectives and associated measures (92.9%) Take away Know the measures! Post Payment Audits as of Sept, ,780 Post Payment Audits have been undertaken for EPs. 4,601 of 4,780 Post Payment Audits have been completed which is 96% Only about 179 Post Payment audits are still in process but CMS says these are getting ready to gear back up as they catch up on the Pre Payment Audits So, how did these entities make out? Post Payment Audits as of Sept, 2014 Audits as of Sept, ,106 of the 4,601 (post payment audits completed did not meet meaningful use and failed! 1 in 4 failed (24%) CMS is citing two main reasons for failing Failure to use a certified EHR (1.1%) Failure to meet the appropriate objectives and associated measures (98.9%) You really have to know the measures! CMS is stating that of those EPs who failed audits they are returning between $41.92 and $19,800 per provider Average returned incentive was $16,862 per provider A large problem for many EPs who are audited is no longer employing the person who was responsible for attesting! Please have a game plan in place to create and protect your MU and audit information! Medicare Audit Process Figliozzi and Co will send initial request letter Letter will be sent electronically from CMS to in provider s EHR registration Follow-up by phone and mail, as needed Providers selected for audits will be required to submit, as soon as possible, supporting documentation to validate their submitted attestation data Initial review is a desk review What you will receive that contains a number of items DR - 1 EP Audit Engagement Letter in PDF format DR 2 Document Request Letter Eligible Professionals in Microsoft Excel 97 format DR 3 Attachment 1 Accessing Web Portal in PDF format DR 3.1 Attachment 2 Web Portal FAQ 23

24 Audit Engagement Letter Preparing Documentation Requested It is the provider s responsibility to maintain documentation that fully supports the meaningful use and clinical quality measure data submitted during attestation Documentation should be retained for six years post-attestation Save all electronic or paper documentation that would help support your attestation and support the values you entered in the Attestation Module including the clinical quality measures Documentation Suggested Please have a signed contract / statement from your EHR Vendor showing Proof of Possession of your Certified EHR (CEHRT) Statement should include doctor name, certified EHR version number you are using, and date you started using the certified version and that you were using it during the entire reporting period 24

25 Primary Documentation The source reports / document(s) from the providers CEHRT which were used during attestation are one of the most important report(s) This should provide a summary of the data that supports the information used for attestation It should show all numerators and denominators used for attestation Needs to show specific doctor and time period on report Additional documentation can be used if a report is not available or the information entered differs from the report and must demonstrate how the data was accumulated and calculated Providers should retain a report from CEHRT to validate all clinical quality measure data Documentation for EXCLUSION(S) Documentation to support each exclusion to a measure claimed by the provider Report from the certified EHR system that shows a zero denominator for the measure or otherwise documents that the provider qualifies for the exclusion 25

26 Immunization Exclusion Examples of Information Needed for Successful Audit Outcomes Electronic Prescribing More than 40% of all permissible prescriptions written are transmitted electronically using certified CEHRT You can be excluded from meeting this objective if you write fewer than 100 prescriptions during the reporting period or (New Starting 2013) Do not have a pharmacy within your organization and there are no pharmacies that accept electronic prescriptions within 10 miles of the EP's practice location at the start of your EHR reporting period More than 50% of prescriptions are compared to a drug formulary and transmitted electronically You can be excluded from meeting this objective if you write fewer than 100 prescriptions during the reporting period or Do not have a pharmacy within your organization and there are no pharmacies that accept electronic prescriptions within 10 miles of the EP's practice location at the start of your EHR reporting period Information needed during an Audit of Percentage Based Objectives Primary document is always the report from the EHR system showing numerator, denominator, and percentage for these measures Be sure to always keep a copy of the report you used during your attestation Extra documentation: You should have a screen shot showing you completing the measure in question. For example for erx a screen shot for a patient with you as the provider in the date range you are attesting Any exclusion(s) should show denominator supports the exclusion or a letter of explanation is needed For example for erx a denominator on the report of less than 100 would meet the exclusion criteria How to get Screen Shots Window s free Snipping Tool Start, Accessories, and find Snipping Tool PrtScn on keyboard which copies to clipboard, holding area, and then past in to Word Techsmith s advanced tool called Snagit 26

27 Information needed during an Audit of Non-Percentage Based Objectives These are the objectives that require a Yes attestation in order for a provider to meet the objective for meaningful use To validate provider attestation for these objectives, additional documentation is needed The following are examples of how you may support meeting these objectives Information needed during an Audit of Non-Percentage Based Objectives Primary Documentation is typically: one or more screenshots from the certified EHR system that are dated during the EHR reporting period selected for attestation Secondary Documentation if screenshot not available: a signed letter from your EHR vendor may also be helpful stating this is available, enabled and active, during the entire reporting period and audit logs show it has not been disabled Drug-Drug and Drug-Allergy Checks EP has enabled the functionality to automatically check for drug-drug and drugallergy interactions for the entire EHR reporting period There is no exclusion for this objective. No longer a separate objective for Stage 2 It has been incorporated into the Stage 2 Clinical Decision Support measure 27

28 Medicare Audit Determination One or more screenshots from the certified EHR system that are dated during the EHR reporting period selected for attestation Provider will receive an Audit Determination Letter back from the audit contractor (Figliozzi & Co) This will inform the provider whether they are successful in meeting meaningful use If the provider is found not to be eligible for an EHR incentive payment then the payment will be recouped Providers must use the appeals process if they believe they received an incorrect adverse audit finding CMS and ONC personnel cannot intervene in the audit determination process Medicare Fraud & Abuse CMS may pursue additional measures against providers who attest fraudulently to receive an EHR incentive payment It is a crime to defraud the Federal Government and its programs Punishment may involve imprisonment, significant fines, or both Providers can lose Medicare participation or their licenses to practice Jay W. Henry, O.D., M.S. Questions? 28