Proposed Rule for Meaningful Use Stage 2

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1 Proposed Rule for Meaningful Use Stage 2 The Old The Changes The New Continuing Medical Education Disclaimer hi i if h i i S d Ch i This is to certify that Marnivia Spencer and Chris Hudson have disclosed no relevant financial relationships to this presentation. 1

2 Objectives At the end of this webinar you will be able to: Identify changes to the program s timeline Know MU Stage 1 criteria i changes Evaluate the MU Stage 2 requirements Identify Clinical Quality Measure changes and reporting requirements Understand the Medicare Payment Adjustments and Exceptions Evaluate proposed Medicaid Specific changes Submit comments to CMS HIT Measures 2

3 What is Meaningful Use? An Eligible Professional using certified EHR technology to: Improve health care quality, safety, efficiency and reduce health disparities Engage patients and families in their health care Improve care coordination Improve population and public health While maintaining privacy and security Eligible Professionals Medicare or Medicaid? Medicare Medicare Medicaid and Medicaid Only only MD DO DDS/DMD * In South Carolina OD DPM DC NPs PAs (in FQHCs and RHCs) CertifiedC dnurse Midwives Optometrists * 3

4 Medicaid EP Requirements The Medicaid EPs must : Have >= 30 % Medicaid volume ( >=20% for pediatricians only) OR Practice predominantly in an FQHC or RHC with >= 30% needy individual patient volume Licensed Credentialed No OIG exclusions Living and not hospital based Meaningful Use Stages You Are Here MU Stage 2 Proposed Rule Public Comment Period (March 7- May 7, 5 pm) Stage 3 Stage 2 Stage 1 Source: ONC, CMS Presentation 7/22/2010 4

5 Meaningful Use Stage 2 Key Dates June 2011 Feb 2012 March 7, 2012 March 7, 2012 May 7, 2012 (5pm) Summer 2012 Jan 1, 2014 July 3, 2014 HITPC (Health IT Policy Committee) Recommendations on Stage 2 Stage 2 Proposed Rule Released Meaningful Use Stage 2 publication in the Federal Register Public Submission Comment Period (Likes and Dislikes) Stage 2 Final Rule Released Eligible Professionals Proposed MU Stage 2 Start Date Must begin 90 day Reporting Period to avoid 2015 Payment Adjustment Stages of Meaningful Use New Timeline 1 st Stage of Meaningful Use year TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD TBD Source: 5

6 Medicare/Medicaid Penalties Medicare Providers who do not demonstrate Meaningful Use by : Beyond 1% decrease 2% decrease 3% decrease Up to 5% maximum Medicaid No penalties Medicare Incentives Payout Table Amount You May Receive Each Year Year EHR Use is first demonstrated Yr 1 Yr 2 Yr 3 Yr 4 Yr 5 TOTAL 2011 $18,000 $12,000 $8,000 $4,000 $2,000 $44, $18,000 $12,000 $8,000 $4,000 $2,000 $44, $15,000 $12,000 $8,000 $4,000 $0 $39, $12,000 $8,000 $4,000 $0 $24, /Later $0 $0 $0 $0 6

7 Medicaid Incentives Payout Table Amount You May Receive Each Year Year EHR MU is first Shown Yr 1 Yr 2 Yr 3 Yr 4 Yr 5 Yr 6 TOTAL 2011 $ 21,250 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $63, $ 21,250 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $63, $ 21,250 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $63, $ 21,250 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $63, $ 21, $ 8,500 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $63, $ 21,250 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $63, /Later $0 $0 $0 $0 $0 $0 $0 CPOE Vital Signs Vital Signs Changes to Stage 1 Old Proposed Optional Required Denominator: Number of unique patients with at least one medication in their med list Exclusion: All three elements (BP, HT, WT) not relevant to scope of practice Age Limits: >=Age 2 for Blood Pressure and Height/Weight Denominator: Number of medication orders during the EHR Reporting Period Exclusion: Allows BP to be separated from height/weight Age Limits: >=Age 3 for Blood Pressure, No age limit for Height/Weight

8 HIE Testing E Copy & Online Access Public Health Objectives Changes to Stage 1 One test of electronic transmission of key clinical information Old Proposed Optional Required Provide patients with an electronic copy of their health information and timely electronic access Immunizations Reportable Labs Syndromic Surveillance No longer required Online: view, download and transmit >50% patients seen by EP online access 4 business days Addition of except where prohibited Removed 2013 onward onward Meaningful Use Stage 2 EP Objectives Stage Core Objectives Menu Objectives of of 5 8

9 MU Stage 2 EP Objectives Reporting Requirements Measure Denominator Patient encounters Stage 1 Stage 2 Denominator patients maintained in the EHR OR all patients >50% at location(s) with a Certified EHR Denominator All patients >=50% at location(s) with a Certified EHR Meeting Objectives Exclusions Meet the measure = meet the objective Apply towards meeting an objective Meet the measure = meet the objective Do not apply towards meeting an objective Stage 2 Stage 2 Core Objectives EP Core Objectives/Measures 1 Use CPOE > 60% of medication, lb laboratory and radiology orders Proposed Change >30% to >60% Added d laboratory and radiology orders Exclusion (during reporting period) An EP who writes <100 medication, lb lab or radiology orders 2 E Rx > 65% >40% to >65% Writes <100 Rx No pharmacy onsite No e Rx pharmacy <= 25 miles 3 Record demographics > 80% >50% to >80% NONE 9

10 Stage 2 Core Objectives Stage 2 EP Core Objective Proposed Change Exclusion (during reporting period) 4 Recordvital signs > 80% >50% to >80% Split exclusion No patients >=3 years old BP & Ht/Wt Ht/Wt everyone Belief that Ht, Wt, BP are not relevant to scope of work BP > 3yrs 5 >13yrs, record smoking status for >80% >50% to >80% Does not see patients >=13 years old 6 Implement 5 clinical 1 to 5 clinical NONE decision support interventions and drug/drug and drug/allergy decisions Combined 2 measures Stage 2 Core Objectives Stage 2 EP Core Objective 7 Incorporate lab results for > 55% 8 Generate at least one patient list by specific condition 9 Use EHR to identify and provide >10% of all unique patients with office visit in 24 months prior to reporting period with reminders for preventive/follow up Proposed Change >40% to >55% Moved from Menu to Core Moved from Menu to Core >20% Between 5 yrs and 65 yrs Moved from Menu to Core Exclusion (during reporting period) No lab test orders with +/ or numeric results format NONE No office visits within 24 months prior to reporting period 10

11 Stage 2 Core Objectives Stage 2 EP Core Objective Proposed Change Exclusion (during reporting period) 10 Provide online Replaced p the Neither orders nor access to health information for > 50% of all unique patients with >10% actually accessing E copy of Health info Within 4 business days after info avail to EP creates information listed for inclusion may exclude both measures >50% patients without adequate internet infrastructure according to the FCC 11 Provide office visit summaries in 24 hours Now contains the medications, problems & allergy listing 3 days to 24 Hours No office visits Stage 2 Core Objectives Stage 2 EP Core Objective Proposed Change Exclusion (during reporting period) 12 Use theehrto to identify Movedfrom Noofficevisits office and provide education resources >10% of all office visits Menu to Core Office visits, not unique patients seen 13 >10% of patients send secure messages to their EP New for S Stage 2 No office visits 14 Medication reconciliation at > 65% of transitions of care >50% to >65% Moved from Menu to Core EP did not receive any transitions of care 11

12 Stage 2 Core Objectives Stage 2 EP Core Objective Change Exclusion (during reporting period) 15 Provide summary of >50% to >65% Does not transfer or care document > 65% of transitions of care and referrals with >10% sent electronically from provide in any manner to electronically refer a patient 16 Successful ongoing transmission of immunization data * * Except where prohibited, and in accordance with applicable law and practice 17 Conduct or review security analysis and incorporate in risk management process Test Move forward if state ready Exclusions still apply Same as Stage 1 with increased focus on security encryption Does not administer immunizations applicable populations Data unable to be received or accepted NONE Stage 2 Stage 2 Menu Objectives (Select 3 of 5) EP Menu Objectives/Measures Exclusion (during reporting period) 1 More than 40% of all EP does not perform diagnostic i scans and test order are accessible in the interpretation of scans or tests that result in an image Certified EHR 2 Record family health history for more than 20% of patients No office visits 3 Successful ongoing transmission of syndromic surveillance data to public health agencies* * Except where prohibited, and in accordance with applicable law and practice Does not collect ambulatory syndromic surveillance information on their patients No Public Health Agency in jurisdiction capable of receiving electronic syndromic surveillance data within ONC standards 12

13 Stage 2 Stage 2 Menu Objectives (Select 3 of 5) EP Menu Objective/Measures 4 Identify and report cancer cases to a State cancer registry* Exclusion (during reporting period) Doesn t diagnose or directly treat cancer patients There isn t an agency in jurisdiction capable of receiving electronic cancer information 5 Successful ongoing submission i of specific case data (not cancer) to a specialized registry* Doesn t treat a disease associated with iha registry Operates in jurisdiction where there isn t a registry capable of receiving the specified data * Except where prohibited, and in accordance with applicable law and practice Clinical Quality Clinical Quality Measures and Payment Penalties 13

14 Proposed Clinical Quality Measures Stage Clinical Quality Measures 1 (Prior to 2014) 6 from 44 1 &2 (2014) 12 from 125 Proposed Reporting on Clinical Quality Measures for 2014 EPsto report 12 Clinical Quality Measures (CQMs) that align with existing quality programs such as measures used for: Physician Quality Reporting System (PQRS) CMS Shared Savings Program National Council for Quality Assurance Children s Health Insurance Program Reauthorization Act (CHIPRA) 14

15 Proposed Options for CQM Reporting in 2014 EHR Incentive Program Only 1a: EPs report 12 CQMs, at least 1 CQM from each domain: Patient and Family Engagement Patient Safety Care Coordination Population and Public Health Efficient Use of Healthcare Resources Clinical Process/Effectiveness 1b: EPs would report 11 "core" CQMs plus 1 menu CQM Proposed Options for CQM Reporting in 2014 EHR Incentive Program + PQRS 2: Align PQRS and Meaningful Use Stage for EPs Submit and report CQMs under the PQRS EHR Reporting Option 15

16 Proposed Methods for CQM Reporting in 2014 Medicaid reporting methods determined by the State Medicare Options 1(a) & 1(b) CMS portal Option 2 PQRS Group Reporting Two or more EPs Medicare EPs participating in Medicare Shared Savings Program and testing for Accountable Care Organizations Medicare EPs who report to PQRS Group Practice Reporting Option, using CEHRT Proposed Payment Adjustments and Exceptions Medicare EP can avoid penalty in the 2015 payment adjustment by successfully demonstrating MU in EPs whose first year of attestation is 2014 can avoid payment adjustment by registering and attesting by October 1, Adopt, Implement and Upgrade (AIU) does not constitute meaningful use. 16

17 Exceptions There are 3 categories of Exceptions: 1. Insufficient internet accesstwo years prior to the payment adjustment year for EPs practicing in a rural area 2. Newly practicing EPs for two years 3. Extreme circumstances such as unexpected closures, natural disaster, EHR vendor going out of business, etc. Medicaid EHR Incentive Program 17

18 Proposed Modifications to Medicaid EHR Incentive Program Patient Volume Requirements Allow calculation to include most recent 12 months or previous calendar year Expand definition of encounter to include services rendered to an individual enrolled in a Medicaid Program. Practices Predominantly Allow to be determined on the most recent 12 months prior to attestation or most recent calendar year Resources: NPRM Meaningful Use Stage 2: /pdf/ pdf Public Comment Submission: Electronically: See NPRM document for additional submission methods Registration and Attestation: CCME EHR Consulting site: 18

19 Contact Information Marnivia Spencer EHR Consultant Chris Hudson EHR Consultant (803)

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