MEANINGFUL USE Stages 1 & 2

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1 MEANINGFUL USE Stages 1 & 2 OVERVIEW Meaningful Use is the third step in the journey to receive funds under the CMS EHR Incentive Programs. Meaningful Use (MU) is the utilization of certified electronic health record (EHR) technology to: Improve quality, safety, efficiency, and reduce health disparities Improve care coordination and population and public health Engage patients and family Maintain privacy and security of patient health information As of August 2012, CMS has paid out over $7.1 billion dollars to eligible providers and hospitals under the Medicare and Medicaid programs. Below is the July summary with program- to- date figures in the far right column. 1

2 You can access a monthly report at: and- Guidance/Legislation/EHRIncentivePrograms/DataAndReports.html Below is the payout information for the state of Georgia through August

3 To view all CMS payouts by state go to: and- Guidance/Legislation/EHRIncentivePrograms/DataAndReports.html and under PAYMENT DATA, Now Available: Individual State Reporting - select XXX Payments by States by Program. For the Medicare EHR Incentive Program, the reporting period in the first calendar year of participation is 90 days. The reporting period for all subsequent years will be the entire calendar year. For the Medicaid EHR Incentive Program for the first year of Meaningful Use there is the AIU rule (adopt, implement or upgrade), which means all you need to do is adopt, implement or upgrade to a fully certified ambulatory EHR. The second year you will need to report on 90 days of Meaningful Use and then years 3-6 you will need to report on 12 months. You will also need to provide financial data for proof of the 90 days of Medicaid data that shows you had 30% Medicaid clients (or 20% for pediatricians). STAGE 1 Many providers, understandably, are very concerned about the challenges of meeting the MU requirements. The 15 required objectives for Stage 1 may seem overwhelming. Below, we have attempted to simplify the 15 core requirements by breaking them down by task and responsible party. Viewing these requirements from this perspective makes it a little easier to understand. 3

4 There are 15 Core Objectives for Stage 1 of Meaningful Use 1. Use of Computerized physician order entry (CPOE) 2. Implement drug- drug and drug- allergy interaction checks 3. Maintain an up- to- date problem list of current and active diagnoses 4. Generate and transmit permissible prescriptions electronically (erx) 5. Maintain active medication list 6. Maintain active medication allergy list 7. Record all of these demographics Preferred language Gender Race Ethnicity Date of birth 8. Record and chart changes in vital signs (5 areas) 9. Record smoking status for patients 13 years or older 10. Report ambulatory clinical quality measures to CMS (to state if Medicaid program) 11. Implement one clinical decision support rule 12. Provide patients with an electronic copy of their health information, upon request 13. Provide clinical summaries for patients for each office visit 14. Capability to exchange key clinical information among providers of care and patient- authorized entities electronically 15. Protect electronic health information You can find detailed information on each of the above 15 measures in this document linked below: use/ep- core- objectives.zip The eligible provider must choose 5 of the optional measures, one of which must be from the Public Health list. That makes a total of 20 objectives for MU Stage 1. These are the 10 Menu Objectives from which 5 must be chosen. 1. Implement drug formulary checks 2. Incorporate clinical lab test results into EHR as structured data 3. Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research or outreach 4. Send patient reminders per patient preference for preventive/follow- up care 4

5 5. Provide patients with timely electronic access to their health information within 4 business days of the information being available to the EP 6. Use certified EHR technology to identify patient- specific education resources and provide those resources to the patient 7. Perform medication reconciliation when a patient is received from another provider of care 8. Provide a summary care record for each transition of care or referral to another setting of care or provider 9. Submit electronic data to immunization registries or immunization information systems 10. Submit electronic syndromic surveillance data to public health agencies according to applicable law and practice You can find detailed information on each of the above 10 measures in the document linked below: use/ep- menu- section- objectives.zip CMS acknowledges that some meaningful use objectives are not applicable to every provider s clinical practice. They clarified that, in such instances, the practitioner would not have any eligible patients or actions for the measure denominator and would therefore be excluded from having to meet that particular measure. These exceptions are outlined in the detailed objectives pages referenced above. STAGE 2 The focus is on quality under Meaningful Use Stage 2. ü Eligible Professionals (EPs) must report on 9 out of 64 Clinical Quality Measures (CQM) ü Hospitals & CAHs must report on 16 out of 29 CQMs ü ALL providers must report on 3 of the 6 key health care policy domains recommended by HHS National Quality Strategy HHS National Quality Strategy has defined the six key health care items as: 1. Patient and Family Engagement 2. Patient Safety 3. Care Coordination 4. Population and Public Health 5. Efficient Use of Healthcare Resources 6. Clinical Processes/Effectiveness 5

6 If you would like more information regarding the National Quality strategy, you can find details at: The table below outlines the various stages of Meaningful Use and when they will be effective. For example, if a provider first attested for Stage 1 in 2011 or 2012, then he/she would be required to meet Stage 2 in Note that providers who were early demonstrators of meaningful use in 2011 will meet three consecutive years of meaningful use under the Stage 1 criteria before advancing to the Stage 2 criteria in All other providers would meet two years of meaningful use under the Stage 1 criteria before advancing to the Stage 2 criteria in their third year. The reporting period for Stage 2 only for year 2014 requires that all providers, regardless of their stage of meaningful use, are required to demonstrate meaningful use for a three- month EHR reporting period. For Medicare providers, this 3- month reporting period is fixed to the calendar year for eligible professionals (EPs) year in order to align with existing CMS quality measurement programs, such as the Physician Quality Reporting System (PQRS) For Medicaid providers only eligible to receive Medicaid EHR incentives, the 3- month reporting period is not fixed, where providers do not have the same alignment needs. EPs must meet 17 core objectives and 3 menu objectives (select from 6) for total of 20 objectives. In general, most objectives from Stage 1 were kept and the percentages were increased and/or the objective modified slightly. Please see the documents Stage 2 Overview and Stage 1 vs Stage Comparison 6

7 PENALTIES AND EXCEPTIONS Effective January 1, 2015, Medicare providers who are not meaningful users will be subject to a payment adjustment by CMS. This payment adjustment will be applied to the Medicare physician fee schedule (PFS) amount for covered professional services furnished by the eligible provider (EP) during the year (including the fee schedule amount for purposes of determining a payment based on the fee schedule amount). The payment adjustment is 1% per year and is cumulative for every year that an EP is not a meaningful user. Depending on the total number of Medicare EPs who are meaningful users under the EHR Incentive Programs after 2018, the maximum cumulative payment adjustment can reach as high as 5%. The table below illustrates the potential application of payment adjustments to covered professional services for a Medicare EP who is not a meaningful user beginning in This table will be used if less than 75% of eligible providers are meaningful users. If more than 75% of eligible providers are meaningful users, the payment adjustments will be as follows. Because payment adjustments are mandated to begin on the first day of the 2015 calendar year, CMS will apply a prospective determination for payment adjustments. Therefore, Medicare providers must demonstrate meaningful use in 2013 (Stage 1) to avoid the adjustments effective 1/1/2015. Eligible providers who first demonstrated meaningful use in 2011 or 2012 must demonstrate meaningful use for a full year in 2013 to avoid payment adjustments in They must continue to demonstrate meaningful use every year to avoid payment adjustments in 7

8 subsequent years. The table below illustrates the timeline to avoid payment adjustments for EPs who must demonstrate meaningful use for a full year in Please refer to the CMS website for more specific information regarding penalties. and- Guidance/Legislation/EHRIncentivePrograms Hardship Exceptions will be granted only under specific circumstances and only if CMS determines that providers have demonstrated that those circumstances pose a significant barrier to their achieving meaningful use. Information on how to apply for a hardship exception will be posted on the CMS EHR Incentive Programs website in the future. ( EPs can apply for hardship exceptions in the following categories: Ø Infrastructure Providers must demonstrate that they are in an area without sufficient internet access or face insurmountable barriers to obtaining infrastructure (e.g., lack of broadband). Ø New EPs Newly practicing Providers who would not have had time to become meaningful users can apply for a 2- year limited exception to payment adjustments. Thus EPs who begin practice in calendar year 2015 would receive an exception to the penalties in 2015 and 2016, but would have to begin demonstrating meaningful use in calendar year 2016 to avoid payment adjustments in Ø Unforeseen Circumstances Examples may include a natural disaster or other unforeseeable barrier. CMS solicited comments on a fourth category of hardship exception - this has not been finalized yet. Ø By Specialist/Provider Type Providers must demonstrate that they meet all three of the following criteria: 1. Lack of face- to- face or telemedicine interaction with patients 2. Lack of follow- up need with patients 3. Lack of control over the availability of Certified EHR Technology at their practice location. (EPs who practice at multiple locations may be granted a hardship exception solely for lack of control over the availability of Certified EHR Technology) 8

9 If you are a Medicare provider it is important that you adopt a certified electronic health record and demonstrate meaningful use as described in the documentation in this section failure to do so could result in a reduction in your Medicare reimbursement. This guide has been compiled for the Physicians Institute by Coker Group, a nationally recognized healthcare consulting firm. If you would like additional information or have questions regarding your specific situation regarding the EHR Incentive Program or meaning use, or if you need assistance selecting an EHR vendor, you may contact a Coker technology representative at