4Medapproved Learning Lunch Webinar Series How to Keep up with Stage 2 MU (Meaningful Use) Questions and Answers

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1 4Medapproved Learning Lunch Webinar Series How to Keep up with Stage 2 MU (Meaningful Use) Questions and Answers Q: Does transfer of care happen within a health system - say for example primary care to a specialist - will that be counted in Med Reconciliation - same EMR A: --For medication reconciliations, CMS defines transitions of care to mean the movement of a patient from one clinical setting (inpatient, outpatient, physician office, home health, rehab, long-term care facility, etc.) to another or from one EP to another. At a minimum transitions of care include first encounters with a new patient and encounters with existing patients where a summary of care records (of any type) is provided to the receiving provider. The summary of care records can be provided either by the patient or by the referring/transiting provider or institution. Q: FYI some states allow POB, Prescribe on Behalf, so non-licensed others than the actual MD can order under a valid license and probably will carry over to other orders within the EMR. Is this true? A: --Per CMS, "any licensed healthcare professional who can enter orders into the medical record per state, local and professional guidelines" may enter orders for medication, labs, or radiology. Q: Who can I reach out to regarding state registries to see if I need to even be concerned about reporting? If the registry is not up can I exempt myself? A: --A list of the statewide immunization registries can be found on the CDC website, The syndromic surveillance information needs to be submitted to state public health agencies. A complete list of US state health agencies is available at If your state's public health agency does not have the capacity to receive the information electronically, the EP can be excluded. However, keep in mind that you cannot claim an exclusion to both public health measures. Q: if an MD moves and the new location is unable to obtain the same menu items or QM items, what should we do? And if it means we can't attest for 365 days but can pick back up in 2014 for 90 days- would it be 90 days with stage 1 year2 or would we jump to stage 2? A: --If you have a doctor transferred in from another practice, make sure you get a copy of their individual meaningful use dashboard report from their previous place of employment, with their MU numbers. This will help you to compile accurate numbers when it's time to attest.

2 Q: If S2 requires that CQM's be reported electronically, how will that happen? Many states do not have an HIE running, so how will the CQM's transmit? A: --First things first. Remember that the CQM reporting requirements for 2013 remain the same as in previous years. CMS is introducing electronic reporting of the measures by aligning the PQRS and CQM reporting. Eligible Professionals who choose to report the same PQRS & CQM measures may participate in the PQRS-Medicare EHR Incentive Pilot where they can either use a PQRS EHR Data Submission Vendor ( Assessment-Instruments/PQRS/Downloads/2013ParticipatingDataSubmissionVendors_ pdf) to submit the measures on their behalf or if they are using one of the qualified EHRs from this list ( Instruments/PQRS/Downloads/2013QualifiedEHRDirectVendors.pdf), they can report CQMs directly from their EHR. In order to allow participants to successfully report CQMs electronically for 2014 and beyond, CMS has detailed the electronic specifications required for each CQM. If your EHR is not on the qualified list above, make sure they have a copy of this list, ( so they can qualify to report electronically in the future. Q: Does Medication rec include medication dosages? As a specialist we aren't concerned with the dosage, but rather the drug. A: --CMS defines medication reconciliation as the process of identifying the most accurate list of all medications that the patient is taking, including name, dosage, frequency, and route, by comparing the medical record to an external list of medications obtained from a patient, hospital, or other provider. Q: We have read that a nurse or CMA may place the order for the physician. Is that true? A: --CMS revised their description of who can enter orders into the EHR and have it count as CPOE for the purposes of the CPOE measure. Any licensed healthcare professional can enter orders into the medical record for purposes of including the order in the numerator for the measure of the CPOW objective if they can enter the order per state, local, and professional guidelines. The order must be entered by someone who could exercise clinical judgment in the case that the entry generates any alerts about possible interactions or other clinical decision support aides. This necessitates that CPOE occurs when the order first becomes part of the patient's medical record and before any action can be taken on the order. Each provider will have to evaluate on a case-by-case basis whether a given situation is entered according to state, local, and professional guidelines, allows for clinical judgment before the medication is given, and is the first time the order becomes part of the patient's medical record. Q: when you answer the nurse/cma question, if acceptable, will that include lab and radiology also? A: --"Any licensed healthcare professional who can enter orders into the medical record per state, local and professional guidelines" may enter medication, labs, or radiology orders.

3 Q: if a Provider using a lab interface provided by a lab company does that lab interface have to be a CEHRT certified product in addition to the EMR being certified? A: --To date, clinical laboratories are not required to be ONC-ATCB certified. The mandate is for certified EHR technology to be able to pull in structured lab results, but there is no direct mandate for the labs to deliver the results in such a manner. Providers expect end-to-end fully functional bi-directional lab CPOE connectivity, so labs should be prepared for an onslaught of connectivity requests from ambulatory providers. Q: You mentioned batch reporting. I was aware we can batch report for quality, but hadn't heard about batch reporting for the functional measures. Were you referring to quality measures? Thanks for clarifying. A: --Medicare EPs within a single group practice may report core and menu objective meaningful use data through a "batch" file process in lieu of individual Medicare EP attestation through the CMS Attestation website. The batch process includes defining the stage of meaningful use the individual EP is in, numerator, denominator, exclusion, and yes/no information for each core and menu objective. CMS indicates that the batch reporting process will be established no later than January 1, CMS defines a Medicare EHR Incentive Group as two or more EPs, each identified with a unique National Provider Identifier (NPI) associated with a group practice identified under one tax identification number (TIN) through the Provider Enrollment, Chain, and Ownership System (PECOS). Q: Some providers in the organization are going into Stage 1, while others are going to Stage 2. How do we align the technology to allow for both stages? For example, for Stage 1, we called it gender; for Stage 2, it s called sex. How do we allow for attestation for some providers for Stage 1, while allowing others in the organization to attest for Stage 2 when the terms don t align? A: --Your EHR vendor should be working on backward mapping that connects those dots. Get in touch with your EHR vendor to ensure this is something they are ready for when it comes time to attest. Q: Is it true that CQMs can be reported in 2014 via attestation if the EP is in year #1 of MU? A: --No. The new requirements for electronic reporting of CQMs go into effect in 2014, regardless of the stage or year an EP is attesting. CMS took great care when naming them. They intentionally left out any reference to the stage an EPs is in; instead, they named them the 2014 ecqm rules. Q: We have some providers that have a lot of pts that do not go on the internet and will not set up the portal. Will CMS reconsider this in the future? If the point is to have pts engaged in their care and records it doesn't make sense to just get them on the portal in our office to achieve numbers. That doesn't seem to be the goal of the measure. A: -- I highly doubt that the patient engagement aspect of meaningful use is going anywhere. If your patients do not have access to the internet and your providers refuse to set up a portal, you are going to have to get creative to meet the requirements for meaningful use and to avoid penalties on your Medicare reimbursements in the coming years. Setting up a kiosk in your waiting room may be a solution, where patients can view their records on site, allowing the providers to satisfy the stage 2 requirements.

4 Q: Many physicians are distressed about creating opportunities to get to the 5% threshold for patient portal engagement (made even worse in low income areas where patients have limited access). Any recommendations on how physicians can promote the portal (encourage children to get vaccination records via the portal, etc.). A: --I read recently that asking medical records to engage patients is like asking a dictionary to tell a story. Getting patients engaged in their health takes creativity and long-term thinking. To start, it may be worth investing in a kiosk for your patient waiting room. Especially in low income areas where patients may not have access to the internet at home, patients could still have a chance to look at their health record either before or after their visit. A good kiosk will give patients a chance to update any of their demographic, medication, or family history information, as well as see if they are due for any vaccinations or schedule future appointments. Their engagement could result in bettering their health, but it could also help providers meet their targets for meaningful use. As for promoting the portal, studies show that patients are more likely to enroll in a portal at check-out rather than at check-in. Posting signs about the portal where patients will seem them is a great way to communicate. Q: Comment: CQMs e-reporting can (sometimes, at least) also be fulfilled by use of PQRS e-reporting program. A: --True! It's called the PQRS-Medicare EHR Incentive Pilot. You can read more about it here: Incentive-Pilot-Quick-Ref-Guide.pdf-- Q: We started participating in 2011 for MU. On our MU reports, it says Report Ambulatory CQMs to CMS with a green check mark. Green check mark means good and the info is being sent to CMS. Does this mean we are participating in the EHR Pilot? A: --It sounds your EHR has captured sufficient data for your chosen CQMs and it's ready to report them to CMS. However, be careful. That green check mark does not necessarily mean that the info has been transmitted to CMS. For 2013, you have two options to submit CQMs: 1. Submit CQMs with your attestation, through the CMS Medicare EHR Registration & Attestation website. 2. If you are tracking the same measures for CQMs and PQRS, then you can submit them through the PQRS-Medicare EHR Incentive Pilot. However, in 2014 and beyond, you will need to submit CQMs electronically, using the specifications defined by CMS. Make sure your EHR vendor is upgrading their ability to report CQMs using this spec sheet: --

5 Q: And when patients realize that they have to visit a different portal for every provider the engage with and that each of these portals only contains information from that provider and that each of these portals looks and feels different will they just give up on portals altogether? A: --Great point. But you may be surprised by how excited patients get when they have access to their health information or find that they are building a relationship with their doctor. But you're right. There is still room to grow in ways that allow patients to view information from multiple doctors in the same portal. Q: Is there a specific percentage of patients that have to recall for preventative care and reported? A: --Yes, 10%. The details of this measure are: Denominator: the number of unique patients who have had two or more office visits with the EP in the 24 months prior to the beginning of the EHR reporting period. Numerator: the number of patients in the denominator who were sent a reminder per patient preference when available during the EHR reporting period. Threshold: The resulting percentage must be more than 10 percent in order for an EP to meet this measure. Seems like the way to succeed with this measure is to run a report at the beginning of your EHR reporting period, singling out patients who have been in for a visit twice in the past two years. For every 100 patients on that report, send out at least 10 reminders. Reminders sent before the reporting period will not count toward meaningful use. Q: In Jan 2014, we will be enrolled and just starting to bill Medicare, do we need to worry about the stage 1 policies at all? A: --If your first year of attesting meaningful use will be 2014, the Stage 1 core and menu objectives would apply to your practice, taking into account the changes that the Stage 2 final rule made to Stage 1. You would be reporting a 90-day period that aligns with a calendar year quarter. And your 9 chosen CQMs would need to be reported electronically either through your EHR or if your PQRS and CQMs are aligned through the PQRS Medicare EHR Incentive Pilot. EHR-Incentive-Pilot-Quick-Ref-Guide.pdf Make sure your EHR has the specification sheet to be able to report your CQMs. Guidance/Legislation/EHRIncentivePrograms/Electronic_Reporting_Spec.html -- Q: Will you provide that resource to all attendees? A: --yes

6 Q: For medication reconciliation, what defines "transferred to your care"? We are a specialist and have patients referred to us... is this "transferred to our care"? A: --For medication reconciliations, CMS defines transitions of care to mean the movement of a patient from one clinical setting (inpatient, outpatient, physician office, home health, rehab, long-term care facility, etc.) to another or from one EP to another. At a minimum transitions of care include first encounters with a new patient and encounters with existing patients where a summary of care records (of any type) is provided to the receiving provider. The summary of care records can be provided either by the patient or by the referring/transiting provider or institution. Q: Stage 2 requires providers to allow patients to view their health records online. Every EHR product will require sophisticated system requirements (hardware and stuffs). Does it mean that Stage 2 wants all the patients to upgrade their personalized computer to the expected EHR system requirement? A: --No. Patients should not need to upgrade their personal computers in order to have access to the patient portal. All they should need is access to the internet. In low-income areas where patients may not have access to the internet at home or work, providers are challenged with finding creative ways for patients to engage. They may consider implementing a kiosk in the waiting room to give their patients access to their health records. --

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