Meaningful Use Guidelines: Radiologists

Transcription

1 Meaningful Use Meaningful Use (MU) criteria allows providers to demonstrate that they are using certified EHR technology in ways that can be measured significantly in quality and in quantity. Many assume that they cannot meet Meaningful Use since many of the MU measures do not reflect the clinical work done in a Radiology practice. This is not true. If a certain MU measure does not apply to or is not done in the normal scope of a specialty or Radiology practice, then the Radiologist can claim an exclusion, if applicable, for that measure. It is the provider s responsibility to determine whether he or she may claim an exclusion for specific measures that offer exclusions. The goal of the Medicaid EHR Incentive Program is to have eligible professionals (EPs) file (or attest ) for 6 years in total. However, if problems arise such as system tracking of MU measures, providers can skip a year s filing. The first year is always AIU (adopting, implementing or upgrading to a certified EHR), followed by a second year of meeting the MU measures for 90 days. The third and subsequent years require a full years tracking of the measures. NYC REACH Services Overview may qualify for up to $63,750 under the Medicaid EHR Incentive Program for the adoption, implementation, and upgrade (AIU) of a certified EHR and Meaningful Use achievement. The Medicaid Specialist Program at NYC REACH aims to assist eligible healthcare specialists including with achieving Meaningful Use (MU) requirements via New York State s Medicaid EHR Incentive Program. are eligible if they are: Meeting a 30% Medicaid patient volume Enrolled as Medicaid Fee for Service Billable and payable by Medicaid In good standing with New York State Year 1: Adopting, Implementing, or Upgrading (AIU) Incentive Payment: $21,250 For the first year, eligible providers must complete AIU of a certified EHR. This is accomplished by either implementing an EHR or upgrading to a certified EHR. Year 2: 90-day Meaningful Use Reporting Period Incentive Payment: $8,500 For the second year, eligible providers must meet a set of 15 core and 5 of 10 menu MU measures over a consecutive 90-day period, including the submission of Clinical Quality Measures, to demonstrate meaningful use of the EHR to improve and coordinate patient care. As your partners in health IT, NYC REACH staff are committed to ensuring that your practice attests for year 1 and year 2 of the program. Year 3* to Year 6: Continuing Meaningful Use Incentive Payment per year: $8,500 After the second year participation, successful attestation requires an entire calendar years tracking of MU, including the submission of Clinical Quality Measures. This leads to a maximum payment total of $63,750 over all six participation years. *If the provider is attesting for Medicaid Year 3 in 2014, then he or she can complete Meaningful Use for a 90-day period and not the original rule of a full year. This is only for 2014.

2 2 Exclusion Example for Meaningful Use (MU) Measures The MU measures relating to electronic prescriptions (e-prescribing) demonstrate an instance whereby a Radiologist could qualify to claim an exclusion (e.g., the MU objectives may not be applicable to a particular specialist s scope of practice.) For example, one MU measure requires a provider to enter prescription orders into his or her EHR system (e.g., Computerized Prescription Order Entry, or CPOE). Another MU measure requires the provider to generate and submit/transmit these prescriptions electronically. If a Radiologist does little or no prescribing, however, then he or she could claim an exclusion for this measure. The exclusion does not prevent a provider from meeting MU. The exclusion for these two measures states: An Eligible Professional (EP) who writes fewer than 100 prescriptions during the EHR reporting period would be excluded from this requirement. Exclusion from this requirement does not prevent an EP from achieving meaningful use. Be sure to maintain all documentation justifying any exclusions that one decides to claim for certain MU measures. In this way, can still successfully attest for MU even if several of the measures do not apply to their specialty or practice. Requirements for Meaningful Use Stage 1: EPs must complete these requirements for a 90-day reporting period during participation year 2 and for a 1 year reporting period in the calendar year for participation years 3 to 6.* *If the provider is attesting for Medicaid Year 3 in 2014, then he or she can complete Meaningful Use for a 90-day period and not the original rule of a full year. This is only for MU Stage 1: Core Set Requirements Eligible Professionals (EPs) must attest to (or take an exclusion, where applicable, for) all 15 MU Stage 1 Core Set objectives. MU Stage 1 Core Set Requirements: 10 core threshold objectives (measures reported for a minimum % of patients) 5 core activity objectives (measures to illustrate capabilities, functionality, and security) MU Stage 1: Menu Set Requirements In addition to meeting all MU Stage 1 Core Requirements, EPs must also attest to (or take an exclusion, where applicable, for) 5 out of 10 MU Stage 1 Menu Set Objectives. MU Stage 1 Menu Set Requirements: 5 out of 10 Menu Set Measures, including: -Public Health Reporting (PHR) Requirement: Must pick 1 of 2 public health reporting objectives Please see the accompanying charts on pages 3-7 for specific details about each Core and Menu Set Objective, including applicable exclusion policies. For a comprehensive list of all MU measures (including attestation requirements for each measure), visit: EHRIncentivePrograms/Downloads/EP-MU-TOC.pdf

3 3 Meaningful Use: CORE Set Measures (ALL 15 Required) 1: CPOE for medication orders: More than 30% of unique patients with at least one medication in their medication list seen by the EP have at least one medication order entered using CPOE. Optional Alternate: More than 30% of medication orders created by the EP during the EHR reporting period are recorded using CPOE. Exclusion: Any EP who writes fewer than 100 prescriptions 2: Drug-drug and drug-allergy checks: The EP has enabled this functionality (e.g. it is turned on in your EHR system) for the entire reporting period. 3: Up-to-date problem list: More than 80% of all unique patients seen by the EP have at least one entry (or an indication that no problems are known for the patient) recorded as structured data. 4: E-Prescribing: More than 40% of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technology. Exclusion: Any EP who writes fewer than 100 prescriptions 5: Active medication list: More than 80% of all unique patients seen by the EP have at least one entry (or an indication that the patient is not currently prescribed any medications) recorded as structured data. 6: Active medication allergy list: More than 80% of all unique patients seen by the EP have at least one entry (or an indication that the patient has no known medication allergies) recorded as structured data. Suggested Methods for -Order all medications through the EHR. - may be exempt if they order fewer than 100 prescriptions during the reporting period. EPs must attest to the number of prescriptions written during the reporting period to qualify for exclusion. -Work with your EHR vendor, system administrator and/or site manager to make sure this functionality is enabled. -Review and update the problem list prior to treatment. -If the patient has no active problems, indicate/document this data in the EHR. -Order/transmit all prescriptions electronically through EHR (faxing does not count) in place of a written prescription, whether the pharmacy is on-site or off-site - may be exempt if they order fewer than 100 prescriptions during the reporting period. EPs must attest to the number of prescriptions written during the reporting period to qualify for exclusion. -Review and update the medication list prior to treatment. -If patient was prescribed medications from an outside provider or had any prescription filled outside the facility, enter current medications into the active medication list in the EHR. -If patient is not on any medications, indicate/document this data in the EHR. -Review and update the medication allergy list prior to treatment. -If patient has no medication allergies, indicate/document this data in the EHR. 7: Demographics: More than 50% of all unique patients seen by the EP have preferred language, gender, race, ethnicity, and date of birth recorded as structured data. - Ensure that your facility has a process to capture this data for all patients. This information is typically obtained through patient registration. For NYC For REACH NYC REACH members members only only DO NOT DO DISTRIBUTE. NOT DISTRIBUTE.

4 4 Meaningful Use: CORE Set Measures (ALL 15 Required) 8: Vital signs: For more than 50% of all unique patients age 2 and over seen by the EP, height, weight and blood pressure are recorded as structured data. New Measure (Optional 2013; Required 2014 and beyond): For more than 50% of all unique patients seen by the EP during the EHR reporting period have blood pressure (for patients age 3 and over only) and height and weight (for all ages) recorded as structured data. Suggested Methods for -Review the patient s EHR data at each visit to verify that height, weight, and blood pressure have been recorded. -If height, weight, and blood pressure are not current, take these measurements and record in the EHR as structured data Exclusion: Any EP who either sees no patients 2 years or older, or who believes that all three vital signs of height, weight, and blood pressure of their patients have no relevance to their scope of practice. New Exclusion (Optional 2013; Replaces exclusion above in 2014): Any EP who : 1. Sees no patients 3 years or older is excluded from recording blood pressure; 2. Believes that all three vital signs of height, weight, and blood pressure have no relevance to their scope of practice is excluded from recording them; 3. Believes that height and weight are relevant to their scope of practice, but blood pressure is not, is excluded from recording blood pressure; or 4. Believes that blood pressure is relevant to their scope of practice, but height and weight are not, is excluded from recording height and weight. 9: Smoking status: More than 50% of all unique patients 13 years old or older seen by the EP have smoking status recorded as structured data. Exclusion: Any EP who sees no patients 13 years old or older during the reporting period. 10: Report Clinical Quality Measures to CMS: -Each EP must report on the 3 CQMs in the core set (hypertension, tobacco use assessment/intervention, and adult weight screening). -Each EP must substitute CQMs from the alternate core set (weight assessment/counseling for children, influenza immunization for adults, and childhood immunizations) for any measure in the core set with a zero denominator. -Each EP must also select and report on three additional clinical quality measures that are relevant to the EP s practice. 11: Clinical decision support: Implement one clinical decision support rule relevant to specialty or high clinical priority along with the ability to track compliance of that rule. 12: Electronic copy of health information: More than 50% of all patients seen by the EP who request an electronic copy of their health information are provided it within 3 business days. Exclusion: Any EP who receives no requests for electronic copies of health information. -Review the patient s Health Summary or the EHR at each visit to verify that smoking status has been recorded. -If not, record smoking status in the EHR as structured data Based on the measure choices available through the specific EHR model/vendor being used, might consider selecting the following measures from the 38 additional CQM choices: - Oncology Breast Cancer: Hormonal Therapy for Stage IC-IIIC Estrogen Receptor/Progesterone Receptor (ER/PR) Positive Breast Cancer (NQF# 0387) - Oncology: Medical & Radiation Pain Intensity Quantified (NQF# 0384) (2014+ only) - Oncology Colon Cancer: Chemotherapy for Stage III Colon Cancer Patients (NQF# 0385) - Diabetes: Blood Pressure Management (NQF #0061) - Pneumonia Vaccination Status for Older Adults (NQF #0043) -Work with your EHR vendor, system administrator and/or site manager to make sure reminders are configured correctly. -Radiology-specific clinical decision support rules are not required. -Ensure that your facility has a process to capture requests for electronic copies of health information and to fulfill these requests.

5 5 Meaningful Use: CORE Set Measures (ALL 15 Required) 13: Clinical summaries: Clinical summaries provided to patients for more than 50% of all office visits within 3 business days. Exclusion: Any EP who has no office visits during the reporting period. 14: Exchange key clinical information: Performed at least one test of certified EHR technology's capacity to electronically exchange key clinical information. ***No longer required for Stage 1 MU starting in 2013.*** 15: Privacy and security: Conduct or review a security risk analysis and implement security updates as necessary and correct identified security deficiencies as part of its risk management process. Conduct or review a security risk analysis using HIPAA guidelines. Suggested Methods for -Work with your EHR vendor, system administrator and/or site manager to configure clinical summaries reporting -Ensure clinical summaries are printed and provided to patient. -Work with your EHR vendor, system administrator and/or site manager to perform this test. -This criteria will become significant in Stage 2 of MU -Work with your EHR vendor, system administrator and/or site manager to perform this analysis. A Note on Certified EHRs must use certified EHRs in order to participate in the NY Medicaid EHR Incentive Program. The ONC (Office of the National Coordinator for Health Information Technology) has confirmed, however, that EPs may use an uncertified product to feed information into a certified EHR product. As long as required MU information is being captured by the certified EHR product it will count towards achieving meaningful use. For additional information on ONC Certified EHR Technology visit: Guidance/Legislation/ EHRIncentivePrograms/ Certification.html More on Clinical Quality Measure (CQM) Reporting For reporting in 2013, to meet Meaningful Use when there are fewer than 6 CQMs that relate to a Radiology practice, use the following: Report on the 3 core clinical quality measures (blood pressure, tobacco use assessment and adult weight screening). If not all 3 measures apply to the scope of practice, then: Report on any alternate core clinical quality measures that will bring the total of CQMs to 3 (weight assessment/counseling for children, childhood immunization, flu immunizations for patients over 50). If the only core CQM that applies to Radiology practice is tobacco use assessment, the Radiologist would report the numerator and denominator for that CQM, then report a 0 for all the remaining core and alternate core CQMs. Report on any three additional clinical quality measures of the Radiologist s choosing.* If there is only 1 additional CQM that applies to Radiology scope of practice (i.e., medical assistance for smoking and tobacco use cessation), the Radiologist would report the numerator and denominator for this CQM, then report a 0 for 2 additional CQMs. The Radiologist would also be required to attest to the fact that all remaining CQMs have 0 in the denominator, which would indicate that no other CQMs fit the Radiology scope of practice. *The specific CQMs capable of being documented within an EHR vary from system to system. Discuss specific CQM reporting capabilities with your EHR vendor, system administrator and/or site manager. Note: It has been announced that beginning in 2014, new CQMs have been added to the list of reportable measures. (For more information, visit: Legislation/EHRIncentivePrograms/Downloads/Stage2_Toolkit_EHR_0313.pdf)

6 6 Meaningful Use MENU Set Measures: Report on 5 of the 10 measures. Must include 1 Public Health Reporting Measure (Measure 9 or 10). 1 Drug formulary checks: The EP has enabled this functionality and has access to at least one internal or external drug formulary for the entire EHR reporting period. Exclusion: Any EP who writes fewer than 100 prescriptions Suggested Methods for -Work with your EHR vendor, system administrator and/or site manager to make sure this functionality is enabled. - may be exempt if they order fewer than 100 prescriptions during the reporting period. EPs must attest to the number of prescriptions written during the reporting period to qualify for exclusion. 2 Lab test results: More than 40% of all clinical lab tests results ordered by the EP during the EHR reporting period whose results are either in a positive/negative or numerical format are incorporated in certified EHR technology as structured data. N/A Exclusion: who do not order labs with test results reported as either positive/negative or numeric during the reporting period, can take an exclusion; also, lab results do not need to be electronically delivered, can be entered manually into EHR. 3 Patient list: Generate at least one report listing patients of the EP with a specific condition. 4 Patient reminders: More than 20% of all unique patients 65 years or older or 5 years old or younger were sent an appropriate preventive/follow-up care reminder during the EHR reporting period. Exclusion: Any EP who has no patients 65 years old or older or 5 years old or younger with records maintained using certified EHR technology. 5 Timely electronic access to health information: More than 10% of all unique patients seen by the EP are provided timely (available to the patient within four business days of being updated in the certified EHR technology) electronic access to their health information subject to the EP s discretion to withhold certain information. -Generate a list of patients with a medical condition relevant to radiology service delivery (e.g. pneumonia). -Work with your EHR vendor, system administrator and/or site manager to configure the patient reminders. -Ensure patient reminders are printed and provided to patient. Can use any form of reminder: calls, s, postcards, etc. -Check with your EHR vendor, system administrator and/or site manager about availability. Exclusion: Any EP who neither orders nor creates lab tests or information that would be contained in the problem list, medication list, or medication allergy list during the reporting period. 6 Patient education resources: More than 10% of all unique patients seen by the EP during the EHR reporting period are provided patient-specific education resources. 7 Medication reconciliation: The EP performs medication reconciliation for more than 50% of transitions of care in which the patient is transitioned into the care of the EP. Exclusion: Any EP who was not the recipient of any transitions of care during the reporting period. -Provide patient education materials to patient and document patient education in the EHR. -Perform medication reconciliation for transitions of care, and document medication reconciliation in the EHR.

7 7 Meaningful Use MENU Set Measures: Report on 5 of the 10 measures. Must include 1 Public Health Reporting Measure (Measure 9 or 10) Summary of care: The EP who transitions or refers their patient to another setting of care or provider of care provides a summary of care record for more than 50% of transitions of care and referrals. Exclusion: An EP who neither transfers a patient to another setting nor refers a patient to another provider Immunization registries: Perform at least one test of certified EHR s capacity to submit electronic data to immunization registries and follow-up submission if the test is successful. Exclusion: Any EP who administers no immunizations during the reporting period. Syndromic surveillance: Perform at least one test of certified EHR s capacity to submit electronic data to public health agencies and follow-up submission if the test is successful. Exclusion: Any EP who does not collect any reportable syndromic surveillance information on their patients during the reporting period or does not submit such information to any public health agency that has the capacity to receive the information electronically. Suggested Methods for -Record all referrals in EHR. -Each EP must select one of the two public health measures (immunization registries and syndromic surveillance). -As radiologists do not administer immunizations, this measure is unlikely to apply to radiologists. It is acceptable to report an exclusion for this public health measure, if selected. -Each EP must select one of the two public health measures (immunization registries and syndromic surveillance). -It is acceptable to report exclusion for the selected public health measure, if applicable and documented. -The NYC Department of Health and Mental Hygiene does have the capacity to receive the information electronically. Looking Forward: Health Information Exchange in Stages 2 and 3 of Meaningful Use You should be looking ahead to becoming part of a health information exchange (HIE) in New York State to allow for the sharing of your patients records. Connectivity to a hospital or other providers will be an important part of Meaningful Use in later years. For more information on HIE, visit our free NYC REACH Resource Library: resourcelibrary. If you are interested in connecting to an HIE to exchange your records with other NYC providers, contact an NYC REACH representative for additional information. Works Cited American College of Radiology (ACR). Summary of Meaningful Use Rules. N.p.: American College of Radiology (ACR), Oct Web. 6 Aug < ACRSummaryCMSandONCStage1MeaningfulUseFinalRules.pdf>. California Primary Care Association. Dentist Crosswalk. N.p.: California Primary Care Association, n.d. California Primary Care Association. Web. 24 May < Center for Diagnostic Imaging/Merge Healthcare. Meaningful Use Guide for Radiology. N.p.: Center for Diagnostic Imaging/Merge Healthcare, Center for Diagnostic Imaging/Merge Healthcare, Sept Web. 6 Aug Costello, Cathy, J.D, and Herminio S. Navia, Jr. RN. "Knowing the Basics of EHR Incentive Programs." Educational Materials. American Dental Association, n.d. Web. 24 May Dentrix/Henry Schien Dental. Facts and Myths of Meaningful Use. N.p.: Dentrix/Henry Schien Dental, n.d. Dentrix.com. Web. 24 May < National Indian Health Board. EHR Incentive Program MU Measures for Dentists. N.p.: National Indian Health Board, n.d. HITECH Resource Center. Web. 24 May < U.S. Department of Health and Human Services. Health Resources and Services Administration. N.p., n.d. Web. 24 May < USA. Agency for Healthcare Research and Quality. Quality Oral Health Care in Medicaid Through. By Cheryl A. Casnoff, M.P.H., Lisa Rosenberger, M.P.H., Nancy Kwon, M.P.H., and Hilary Scherer. N.p., n.d. Web. 24 May < USA. Centers for Medicare & Medicaid Services (CMS). EHR Incentive Program. Stage 2 Toolkit. CMS, Feb Web. 6 Aug < USA. CMS. Stage 2 Overview Tipsheet. N.p., n.d. Web. 31 May < USA. NYC REACH. NY Medicaid EHR Incentive Program/NYC REACH Medicaid Specialist Program. NYC REACH Resource Library, n.d. Web. 24 May < USA. Office of the National Coordinator (ONC). National Learning Consortuim. Clinical Quality Measures: Recommendations for Specialists. By Specialty EHR Workgroup. HITRC Collaborative Portal, Web. 6 Aug