Where Are We? Patient Centered Medical Home Hector Delgado, D.O. Medical Director of Primary Care

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1 Baptist Health Quality Network Clinically Integrated Network Community Care Where Are We? Patient Centered Medical Home Hector Delgado, D.O. Medical Director of Primary Care Board Payer Strategy & Contracting Committee Performance Improvement & Quality Committee Professional Standards Primary Care Collaborative Transition of Care (TOC) Institutional Care Tertiary Hospital Long Term Acute Care H Hospital Skilled Nursing Facility Hospice Primary Care ED Urgent Care Governance Specialist Clinical Program Development Contracting Infrastructure Payer Pharmacy Integrated Practice Units Home Health Telemedicine Title Title 1

2 Title Title Physician Helpline (toll free) 1 (8) BHQN-DOC 1 (8) Physician Helpline (toll free) 1 (8) BHQN-DOC 1 (8) Providers Physician Practice Staff Care Coordinators Patients Transfer Center Specialist Care Model Hospital Physician Helpline (toll free) 1 (8) BHQN-DOC 1 (8) Outpatients Inpatients BHQN Patients Non-BHQN Patients PCP Case Managers Pharmacist Nursing Behavioral Health Psychologist Dieticians Chronic Disease The Patient Centered Medical Home is a health care setting that facilitates partnerships between individual patients, their personal physicians and when appropriate, the patient s family. Care is facilitated by registries, information technology, health information exchange and other means to assure that patients get the indicated care when and where they need and want it in a culturally and linguistically appropriate manner. We will strive for NCQA certification and Joint Commission certification Physician Referral Line Episodic Patients 2

3 Evolution to Date Delivery of Primary Care The patient centered medical home is an approach to the delivery of primary care that is: Patient-centered: A partnership among practitioners, patients, and their families ensures that decisions respect patients wants, needs, and preferences, and that patients have the education and support they need to make decisions and participate in their own care. Comprehensive: A team of care providers is wholly accountable for a patient s physical and mental health care needs, including prevention and wellness, acute care, and chronic care. Coordinated: Care is organized across all elements of the broader health care system, including specialty care, hospitals, home health care, community services and supports. Accessible: Patients are able to access services with shorter waiting times, "after hours" care, 2/7 electronic or telephone access and strong communication through health IT innovations. NCQA-The Future of PCMH Foundation for a Better Health Care System Committed to quality and safety:clinicians and staff enhance quality improvementthrough the use of health IT and other tools to ensure that patients and families make informed decisions about their health. Start-to-Finish Recognition - Before Learn It 1 2 Do you Is your practice Attend free Get the free PCMH want to proceed eligible for PCMH on-board Standards & Guidelines toward PCMH recognition? training recognition? YES Start-to-Finish Recognition - During Earn It STOP! Transform practice Order free online Do you have Attend free Obtain using Standards & application or more practice Standards & multi-site Guidelines sites? Guidelines training approval (-12 months) Is Is your practice eligible for PCMH recognition?your practice eligible for NCQA PCMH Recognition? Before proceeding, consult our full eligibility criteria to make sure you take the right path. You can also watch a video on the important qualities of a medical home. Do you work in a specialty other than primary care? If so, your practice may be eligible for NCQA s new Patient-Centered Specialty Practice Recognition program. As the textbook for PCMH 2011 recognition, the standards and guidelines explain the requirements that every practice must meet to earn NCQA Recognition. This important resource is available free of charge Critical training: Every practice considering transforming into an NCQA-Recognized PCMH should have its engaged staff attend our free Getting on Board training. This important 90- minute session covers the PCMH recognition process from start to finish. Don t start without it! Think you have what it takes to deliver high-quality, patientcentered primary care? Move on to the next step of the Start-to- Finish Medical Home path to earn PCMH recognition. Order the free Online Program Specific Application account. This application will collect your information; it s also where you sign program agreements. Create an account for one or more practice sites and for future Add-On and Renewal Surveys. NO Does your practice provide care Questions? Review the Multiat three or more sites? If so, Site FAQs and the Multi-Site you might be a Multi-Site process, Multi-site process Practice and could be eligible guide and additional Multi-Site for a streamlined recognition Resources. process. Training sessions The NCQA PCMH Standards and Guidelines discuss the requirements for earning NCQA Recognition. NCQA conducts free, live training sessions to help you achieve the best possible survey results. You can also download and listen to a recorded training session or attend one of NCQA s frequent seminars across the country. You may attend as often as you need to. Transforming your practice into a medical home takes time. Depending on your practice s current capabilities, you may need 12 months to complete the process and produce the required PMCH 2011 documentation. Although NCQA evaluates your efforts, we cannot provide consulting. For a list of NCQA-Certified PCMH 2011 Content Experts, refer to our directory. For other questions, refer to our FAQ's. NCQA.org -Patient-Centered Medical Home Recognition NCQA.org -Patient-Centered Medical Home Recognition

4 Start-to-Finish Recognition - During Earn It Start-to-Finish Recognition - After Keep It Attend a free software Prepare and NCQA reviews training (at least 0 Purchase ISS Submit online Submit ISS ISS Survey Tool days before submitting Survey Tool application Survey Tool (0-60 days) ISS Survey Tool) to NCQA 15 Receive decision (results in ISS) PROMOTE UPGRADE your NCQA your NCQA Recognition Recognition status status MAINTAIN your NCQA Recognition status Free training sessions: Now that you have transformed your practice, you are ready to report your efforts for recognition. Use NCQA s Interactive Survey System (ISS) software to document how you meet PCMH 2011 requirements. We conduct live ISS training sessions that include ample time for questions, or download and listen to our recorded training sessions at your convenience. Purchase your license for the electronic ISS Survey Tool ($80), and document each practice s medical home features. NCQA also reviews and scores your practice in the ISS. Download and read the current Clarifications on PCMH Policies and Standards. Submit your Online Application now, before you submit your ISS Survey Tool. NCQA reviews your application and notifies you in 1 5 business days that your application is linked to your ISS Survey Tool. After you receive notification, you may submit the Survey Tool when it is complete. Pay for your NCQA Recognition review using this pricing schedule. To pay by credit card, use this credit card form; to pay by check, use this check cover sheet. NCQA s review begins when we receive full payment. Review, scoring and You will receive making the recognition notification from NCQA decision for each that your results are practice site occurs available at your ISS within 60 days of when login screen. NCQA receives your fully paid ISS Survey submission. NCQA.org -Patient-Centered Medical Home Recognition Your practice is welcome to download, personalize and distribute the release to your local media. Please send the release to for review and approval before you send it out. If you would like NCQA to distribute a press release, please fill out the local media contacts form and it to NCQA has created PCMH seals and graphics to help you champion your achievements. Follow the Guidelines for Advertising and Marketing Recognition Programs in all NCQA-related marketing activities. Was your final recognition level Don t let your recognition lapse! lower than you would have Recognition lasts years, but liked? You may ask NCQA to you should start the renewal reconsider its PCMH decision. process at least 6 months before You might also upgrade your expiration. Check requirements recognition level say, from for renewals if you are a Level 1 to Level by coming recognized Level 2 or Level through for an Add-On Survey. practice and are interested in streamlined renewal. Multi-sites, see your requirements for PCMH 2011 renewal or PCMH 201 renewal. NCQA.org -Patient-Centered Medical Home Recognition PCMH Recognition Scorecard Key Components of PCMH* Personal Clinician: first contact, continuous, comprehensive, care team Whole Person Orientation: all patient health care needs; all stages of life; acute; chronic; preventive; end of life Coordinated Care: when and where needed/wanted; culturally and linguistically appropriate; use information technology *Based on The Joint Principles

5 Growing Evidence on PCMH PCMH Improves Low-Income Access, Reduces Inequities Berenson, Commonwealth Fund, May 2012 PCMH Improves Quality/Patient Satisfaction, Lowers Costs PCPCC, September 2012 Colorado PCMHMulti-Payer Pilot Reduced Inpatient Admissions, ER Visits & Demonstrated Plan ROI Harbrecht September 2012 The Group Health Medical Home At Year Two: Cost Savings, Higher Patient Satisfaction And Less Burnout For Providers Soman Health Affairs, May 2010 PCMHs Save Money Reduction in hospital and emergency room use Harbrecht et al 2012, PCPCC 2012, Patel 2012, Fields et al 2010 Lower overall per member per month costs Fields et al 2010, PCPCC 2012, Takach 2011, Patel 2012 Health plans can have strong return on investment Raskas et al, 2012 / Harbrecht 2012 Also see the Patient-Centered Primary Care Collaborative ssummary of Patient-Centered Medical Home Cost and Quality Results, PCPCC 201 The Patient-Centered Medical Home s Impact on Cost and Quality: An Annual Update of the Evidence, Nielsen, M. Olayiwola, J.N., Grundy, P., Grumbach, K. (ed.) Shaljian, M Evolving PCMH and More Reduction : in Physician hospital and Practice emergency Connections room use Harbrecht (PPC) - developed et al 2012, with PCPCC Bridges 2012, to Excellence) Patel 2012, Fields et al 2010 Lower 2006: PPC overall standards per member updated per month costs Fields et al 2010, PCPCC 2012, Takach 2011, Patel : PPC PCMH Health plans can have strong return on investment Raskas et al, 2012 / Harbrecht : PCMH2011 Also see the Patient-Centered Primary Care Collaborative ssummary of Patient-Centered Medical 2011: ACO Home Accreditation Cost and Quality Results, PCPCC : Patient-Centered Specialty Practice 201: PCMH201 PCMH 201: Key Changes 1. Additional emphasis on team-based care New element = Team-Based Care Highlights patient as part of team, including QI 2. Care management focused on high-risk patients Use evidence-based decision support Identify patients who may benefit from care management and self-care support: Social determinants of health Behavioral health High cost/utilization Poorly controlled or complex conditions. More focused, sustained Quality Improvement (QI) on patient experience, utilization, clinical quality Annual QI activities; reports must show the practice remeasures at least annually Renewing practices will benefit from streamlined requirements, but must demonstrate re-measurement from at least two prior years. Alignment with Meaningful Use Stage 2 (MU2) MU2 is not a requirement for recognition. 5. Further Integration of Behavioral Health. Show capability to treat unhealthy behaviors, mental health or substance abuse Communicate services related to behavioral health Refer to behavioral health providers 5

6 201 Content and Scoring 6 standards / 27 elements 1: Enhance Access and Continuity A. *Patient-Centered Appointment Access.. B. 2/7 Access to Clinical Advice C. Electronic Access 2: Team-Based Care A. Continuity B. Medical Home Responsibilities C. Culturally and Linguistically Appropriate Services (CLAS) D. *The Practice Team Pts Pts : Plan and Manage Care A. Identify Patients for Care Management B. *Care Planning and Self-Care Support... C. Medication Management D. Use Electronic Prescribing E. Support Self-Care and Shared Decision-Making 5: Track and Coordinate Care A. Test Tracking and Follow-Up B. *Referral Tracking and Follow-Up. C. Coordinate Care Transitions Pts 5 20 Pts PCMH201 & Meaningful Use : Population Health Management A. Patient Information B. Clinical Data C. Comprehensive Health Assessment D. *Use Data for Population Management. E. Implement Evidence-Based Decision-Support Pts : Measure and Improve Performance A. Measure Clinical Quality Performance B. Measure Resource Use and Care Coordination C. Measure Patient/Family Experience D. *Implement Continuous Quality Improvement... E. Demonstrate Continuous Quality Improvement F. Report Performance G. Use Certified EHR Technology Pts 0 20 Score Level 1 Score Level 2 Score Level *Must Pass Elements 5-59 points 60-8 points points Meaningful Use of Health Information Technology PCMH-Related Programs NCQAemphasizes Health Information Technology (HIT) because highly effective primary care is information-intensive ACO Patient-centered medical homes are the central foundation of an ACO. PCMH 201 reinforces incentives to use HIT to improve quality Meaningful Use language is embedded in PCMH 201 standards Synergy:PCMH201 Recognized medical practices are well-positioned to qualify for meaningful use, and vice versa PCSP Improving care coordination with primary care and other specialties, with a focus on strategies that effectively manage the referral process to enhance patient-centered care. CEC Allows those certified to highlight their comprehensive knowledge of the requirements, the application process and documentation of the PCMH program. 6

7 What are ACOs? Eligible Applicants ACO Patient-centered medical homes are the central foundation of an ACO. Provider-based organizations that are accountable for both quality and costs of carefor a defined population - Arrange for the total continuum of care Align incentives and reward providers based on performance (quality and financial) - Incentivized through payment mechanisms such as shared savings or partial/full-risk contracts Goal is to meet the triple aim - Improve people s experience of care - Improve population health - Reduce overall cost of care Outpatient primary care practices Practice defined: a clinician or clinicians practicing together at a single geographic location - Includes nurse-led practices in states where state licensing designates Advanced Practice Registered Nurses (APRNs) as independent practitioners -Does not include urgent care clinics or clinics open on a seasonal basis PCMHis central to ACO PCMH Eligibility Basics Systems Needed by Practice for Survey Process Recognitions are conferred at geographic site level -one Recognition per address, one address per survey MDs, DOs, PAs, and APRNspracticing at site with their own or shared panel of patients are listed with Recognition Cliniciansshould be listed at eachsite where they routinely see a panel of their patients - Clinicians can be listed at any number of sites - Site clinician count determines program fee - Non-primary care clinicians should not be included 1. Computer system and staff skill with: - - Internet access - Microsoft Word - Microsoft Excel - Adobe Acrobat Reader (available free online) - Document scanning and screen shots 2. Access to the electronic systems used by the practice, e.g. billing system, registry, practice management system, electronic prescriptionsystem, EHR, Web portal, etc. 7

8 Transformation and Prep Work Components of a Standard Transformation may take -12 months Your roadmap: PCMH 201 Standards and Guidelines everything covered Implement changes: - Practice-wide commitment - New policies and procedures for staff - Staff training and reassignments - Medical record systems - Reporting capabilities improvement Develop and organize documentation Procedures and electronic systems must be fully implemented at least months before survey submission Statement of the Standard Elements Factors Scoring Explanation Documentation Reading a Standard Must Pass Elements Rationale for Must Pass Elements Identifies key concepts of PCMH Helps focus Level 1 practices on most important aspects of PCMH Guides practices in PCMH evolution and continuous quality improvement Standardizes Recognition Must Pass Elements 1A : Patient Centered Appointment Access 2D : The Practice Team D : Use of Data for Population Management B : Care Planning and Self-Care Support 5B : Referral Tracking and Follow-Up 6D : Implement Continuous Quality Improvement 8

9 What is a Critical Factor? Documentation Types Required to receive more than minimal or, for some factors, any points Identified in the scoring section of the element PCMH 1A Example: Critical Factor impact on scoring 100% 75% 50% 25% 0% meets 5-6 factors meets - factors meets 2 factors There are 9 Critical Factors Three Critical Factors in Must Pass Elements meets 1 factor meets 0 factors PCMH 1 PCMH 2 PCMH PCMH PCMH 5 1A, F1 1B, F2 2D, F E, F1 A, F6 C, F1 5A, F1 5A, F2 5B, F8 1. Documented process Written procedures, protocols, processes for staff, workflow forms (not explanations); must include practice name and date of implementation. 2. Reports Aggregated data showing evidence. Records or files Patient files or registry entries documenting action taken; data from medical records for care management.. MaterialsInformation for patients or clinicians, e.g. clinical guidelines, self-management and educational resources NOTE: Screen shots or electronic copy may be used as examples (EHRcapability), materials (Web site resources), reports (logs) or records (advice documentation) Documentation Time Periods Also Called Look-Back Period Report Data, Files, Examples and Materials Should display information that is current within the last 12 months Documented Process Policies, procedures and processes should be in place for at least months prior to survey submission Reporting Period (Meaningful Use) A recent month period Reporting Period (Log or Report) Refer to documentation guidelines for other references to minimum data for logs and reports (one week, one month, etc.) PCMH1 Patient-Centered Access NOTE: ALL DOCUMENTS MUST SHOW DATES 9

10 PCMH 1: Patient-Centered Access Intent of Standard provides access to team-based care for both routine and urgent needs of patients / families / caregivers at all times Patient-centered appointment access 2/7 Access to clinical advice Electronic access 10 Points Elements Meaningful Use Alignment Patients receive electronic: On-line access to their health information Clinical summaries of office visits Secure messages from the practice PCMH 1A: Patient-Centered Appointment Access MUST PASS PCMH 1B: 2/7 Access to Clinical Advice PCMH 1C: Electronic Access PCMH 1A: Patient-Centered Access has a written process and defined standards for providing access to appointments, and regularly assesses its performance on: 1. Providing routine and urgent same-day appointments - CRITICAL FACTOR 2. Providing routine and urgent-care appointments outside regular business hours. Providing alternative types of clinical encounters. Availability of appointments 5. Monitoring no-show rates 6. Acting on identified opportunities to improve access NOTE: Critical Factors in a Must Pass element are essential for Recognition PCMH 1A: Scoring and Documentation PCMH 1A, Factor 1: Example Same-Day Scheduling Policy MUST PASS.5 Points - Must meet 2 factors to pass this Must-Pass Element 100% 75% 50% 25% 0% meets 5-6 factors meets - factors meets 2 factors meets 1 factor meets 0 factors Documentation F1-6: Documented process, definition of appointment types and F1:Report(s) with at least 5 days of data showing availability/use of same-day appointments for both routine and urgent care F2: Materials communicating extended hours or report showing after-hours availability, process to arrange afterhours access not required if practice has regular extended hours. F: Report with frequency of scheduled alternative encounter types in recent 0-calendar-day period. F:Report showing appointment wait times compared to practice defined standards including policy for how practice monitors appointment availability with at least 5 days of data. F5: Report showing rate of no shows from a recent-0-calendar day period. (Patients seen/scheduled visits). F6:Documented process indicating the method a practices uses to select, analyze and update its approach to creating greater access to appointments and a report showing practice has evaluated access data and implemented QIPlan to create greater access. 10

11 PCMH 1A, Factor 1: Example Scheduling Policy PCMH 1A, Factor 1: Example Third Next Available Appointment ABCD Medical Center Explanation: reserves time for same-day appointments. This report shows the number of days to the third next available appointment for each day from 10/1/201 through 10/18/201 as measured first thing each morning as the clinic day began. Provider Monitoring Date Days Jones, MD 10/1/201 1 Jones, MD 10/15/201 0 Jones, MD 10/16/201 0 Jones, MD 10/17/201 1 Jones, MD 10/18/201 2 Average # of days 0.8 PCMH 1A, Factor 2: Routine & Urgent Care Outside Regular Hours PCMH 1A, Factor : Alternative Clinical Encounters From Practice Brochure: Accessible Services: We have regular extended hours beyond normal 9-5 We have a physician on call for emergency after hours We strive to achieve excellent communication Shared medical appointments/group visits: Multiple patients are seen as a group for follow-up care or management of chronic conditions Voluntary Allows patient interaction with other patients and members of health team Practice should document in the medical record This factor requires a documented process and a 0 calendar day report 11

12 PCMH 1A, Factor 1, & 5: Appointments Audit PCMH 1B: 2/7 Access to Clinical Advice Dr. #1 Dr. #2 Dr. # Dr.# has a written process and defined standards for providing access to clinical advice and continuity of medical record information at all times, andregularly assesses its performance on: 1. Continuity of medical record information for care and advice when the office is closed 2. Providing timely clinical advice by telephone - CRITICAL FACTOR. Providing timely clinical advice using a secure, interactive electronic system*. Documenting clinical advice in patient records *NA if the practice cannot communicate electronically with patients. NA responses require an explanation PCMH 1B: Scoring and Documentation PCMH 1B, Factors 1, 2, & Example.5 Points 100% 75% 50% 25% 0% meets factors meets 2 factors meets 1 factor meets factors meets 0 factors (including factor 2) (including factor 2) (or does t meet factor 2) Documentation F1-: Documented process and F2&: Report(s) showing response times during and after hours (7 calendar day report(s) minimum) F:Three examples of clinical advice documented in record. One example when office open AND one example when office closed. PROCEDURE: General Internal Medicine Effective Date: 2/17/2012 Patients will be seen routinely between the hours of 8:00 a.m. and 6:00 p.m., depending on the individual practice. Doctors will make special accommodations when necessary. This means that we may stay later, add additional hours, or meet patients at the office or hospital after hours as needed to provide care. Factor 2. Doctors are on call 2 hours per day and are available through the usual office telephone number. Patient phone calls are answered by a live person during office hours and through the answering service after hours. Clinical response time is to be within one hour. After-hour calls are put on hold by the answering service and then immediately put through to the physician on call. If a physician is unable to immediately take an after-hours call, it will be answered within one hour. Doctors have access to patient s medical records from their homes/mobile devices. Factor 1. Doctors may direct patients to an affiliated urgent care center or to the local emergency room, depending on acuity of symptoms. Doctors will use their own discretion regarding where to refer a patient, based on their clinical judgment. If a patient is referred to an urgent care center or an emergency room, our physician will communicate directly to the attending physician on duty, relaying any pertinent clinical information. Doctors can answer outside regular office hours. (no timeframe to fully meet factor ) Doctors will document after-hours advice in patient s medical record. This documentation will include the time of patient call and the time call was returned by clinician. Factor. 12

13 PCMH 1B, Factors 1, 2 & : Documented Process Timely Clinical Advice by Telephone PCMH 1B, Factors 2 & ABCD Family Medicine Clinical Advice Policy Effective 6/0/201 ABCDPediatrics Clinical Advice By Telephone Policy *Policy reviewed: December 1, 201 Patients have 2/7 telephonic access to a clinician (MD, RN, NP or PA) to provide clinical advice. Calls during office hours are to be responded to within one hour and are to be recorded as a noted patient interaction in the EMRat the time of the call. The on-call provider has computer access by logging onto the EMRremotely while on-call, which enables that care provider access to patient records, to view and search patient records, and also record after hours activity for a patient,. After hours calls from patients are to be responded to by the on-call provider within one hour and are to be recorded as a noted patient interaction in the EMRin within 2 hours of communication with the patient. ABCDPediatrics, P.A. provides clinical advice by telephone for all established patients. During office hours our telephone staff forwards calls from patients regarding a new symptom, illness or concern to clinical staff for triage via telephone. If a clinical staff member is unavailable, a message will be taken or call may be routed to voic which is reviewed by a clinical staff member. Non-urgent calls are returned within 2 business hours. Urgent calls are returned within hours. Emergency calls are routed directly to a provider for an immediate response or the caller is directed to seek emergency care at the nearest emergency department. Clinical staff members are responsible for documenting clinical advice in the patient s medical record. All clinical advice, delivered by telephone is documented within 2 hours. Policy effective date: December 0, 201 PCMH 1B, Factor 2: Example Response Times to Calls PCMH 1B, Factor 2: Patient Access Audit Shows: Call date/time Response date/time If time meets policy person Who Time response Time to Date Call Time Calling Responded entered in OXBOW Respond 9/2/201 Patient 9:10am Mary 9:15am 05 minutes 9/2/201 Patient 11:5am Barbara 12:00pm 15 minutes 9/2/201 Patient 8:20pm Dr. Smith 8:0pm 10 minutes 9/2/201 Patient 8:2am Kathie 8:0am 08 minutes 9/2/201 Patient 11:25am Lucy 11:0am 05 minutes 9/2/201 Patient 6:25am Dr. Smith 6:0am 05 minutes 9/25/201 Patient 5:22pm Mary 5:0pm 08 minutes Need documented process and report Minimum 7 days of data 1

14 PCMH 1B, Factor : Example Timely Advice Electronic Message PCMH 1B, Factor : Example Timely Clinical Advice by Secure E-Message Advice Electronic Message Clinical Call Response Time: 1/6/201 2/6/20 Note: Minimum 7 Calendar Day Report Required Does NOT show if practice meets its standard Message Responders Total Number of Messages Average Response in Hours Physicians Residents Mid-Levels Nurses Clinical Assistants Total (standard is 2 hours) PCMH 1B, Factor : Example Timely Clinical Advice by Secure E-Message PCMH 1C: Electronic Access Practice provides through a secure electronic system: 1. > 50% of patients have online access to their health information w/in business days of information being available to the practice * 2. >5% of patients view, and are provided the capability to download, their health information or transmit their health information to a third party *. Clinical summaries provided for > 50% of office visits within 1 business day *. Secure message sent by > 5% of patients * 5. Patients have two-way communication with the practice 6. Patients may request appointments, prescription refills, referrals and test results * * Stage 2 Meaningful Use Requirements 1

15 PCMH 1C: Scoring and Documentation PCMH 1C, Factor 1 Online Access: MU 2 Points 100% 75% 50% 25% 0% meets 5-6 factors meets - factors meets 2 factors meets 1 factor meets 0 factors Date Range 1/12/201 - /11/201 Documentation F1-: Reportsbased on numerator and denominator with at least months of recent data F5 & 6: Screen shots showing the capability of the practice s web site or portal including URL. 15

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