S TA G E 2 M O D I F I C AT I O N S. October 2015
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1 MEANINGFUL USE: S TA G E 2 M O D I F I C AT I O N S October 2015
2 M E A N I N G F U L U S E O V E R V I E W Since the program s inception in 2011, the swift rise in payouts for compliant providers continues to exceed expectations August 2015 October 2014 $30B+ October 2013 June 2012 $5B $24B $17B but what about providers not meeting MU requirements? 2
3 M E A N I N G F U L U S E O V E R V I E W Providers not meeting Meaningful Use are subject to Medicare payment adjustments beginning in % penalty to Medicare reimbursement for non compliance in 2013 Penalty increases each year regardless of MU stage Non compliance in 2015 = 3% penalty to Medicare reimbursement 3 3
4 M E A N I N G F U L U S E O V E R V I E W 20%+ (and rising) MU dropout rate highlights barriers Providers must overcome to sustain their EHR incentive payments Lack of MU expertise Resource shortages Frustration Vendor issues Budget constraints Competing priorities Lengthy project lists Short timelines Education/training 4 4
5 M E A N I N G F U L U S E S T A G E 2 Several objectives have proven challenging for providers Patient engagement >50% of patients have online access to their healthcare information >5% of patients view/download/transmit health information >5% of patients send a secure message to their provider Clinical Decision Support Implement 5 CDS interventions related to 4 or more Clinical Quality Measures 5 5
6 M E A N I N G F U L U S E S T A G E 2 including previous menu requirements and increases in compliance Summary of Care Summary of care record provided for >50% of transitions of care and referrals >10% transitions of care have an electronic summary of care record sent to the receiving provider 1 electronic test with a different EHR vendor Patient Reminders (EPs) >10% of patients receive a reminder Reminder must be per patient preference CPOE >60% medication orders >30% radiology orders >30% laboratory orders Clinical Summaries (EPs) >50% of office visits, patients receive a clinical summary Provided within 1 business day 6 6
7 M E A N I N G F U L U S E M O D I F I C A T I O N S The Final Rule for changes the MU timeline for all providers 2015 Reporting Period Continuous 90 day reporting period All providers report based on a calendar year: Hospital reporting can range from October 1, 2014 to December 31, 2015 Attestation submission deadline moved to 2/28/16 Providers cannot attest prior to January 1, 2016 for 2015 reporting period 2016 Reporting Period All providers must attest to Stage 2 for a full calendar year Exception made for providers in their first year of MU 7 7
8 M E A N I N G F U L U S E M O D I F I C A T I O N S The Final Rule changes the MU program stage structure for all providers In 2015 all providers attest to the same criteria o Exclusions made for providers who would have been in Stage 1 in 2015 o Limited exclusions made for providers who would have been in Stage 1 in 2016 (i.e., CPOE, eprescribing) Eliminated core & menu structure Some exclusions made for hospitals unprepared to meet previous menu measures that are now required 8 8
9 M E A N I N G F U L U S E M O D I F I C A T I O N S All providers must attest to modified Stage 2 in 2015 and 2016 First Year of MU Stage of Meaningful Use Modified Stage 2 Modified Stage 2 Modified Stage 2 or 2012 Modified Stage 2 Modified Stage 2 Modified Stage 2 or 2013 Modified Stage 2 Modified Stage 2 Modified Stage 2 or 2014 Modified Stage 2* Modified Stage 2 Modified Stage 2 or 2015 Modified Stage 2* Modified Stage 2 Modified Stage 2 or Not Applicable - Modified Stage 2 Modified Stage 2 or * Includes alternate exclusions for certain objectives and measures for providers that were scheduled to demonstrate Stage 1 in
10 M E A N I N G F U L U S E M O D I F I C A T I O N S The Final Rule modifies the number of requirements for all providers Former Stage 1 Objectives Retained Objectives MU Objectives Physician 13 core 5 of 9 menu (including 1 public health) 6 core 3 menu 2 public health 9 core 1 objective, select 2 of 5 public health Hospital 11 core 5 of 10 menu (including 1 public health) 5 core 3 menu 3 public health 8 core 1 objective, select 3 of 6 public health measures Former Stage 2 Objectives Retained Objectives MU Objectives Physician 17 core (including 1 public health) 3 of 6 menu 9 core 0 menu 4 public health 9 core 1 objective, select 2 of 5 public health Hospital 16 core (including 1 public health) 3 of 6 menu 7 core 1 menu 3 public health 8 core 1 objective, select 3 of 6 public health measures 10 10
11 M E A N I N G F U L U S E M O D I F I C A T I O N S The Final Rule eliminates redundant, duplicative, or topped out MU measures Eliminated Measure Physician Hospital Demographics X X Vital Signs X X Smoking Status X X Clinical Summaries X Structured Lab Results X X Patient List X X Patient Reminders X Summary of Care Measure 1- any method; Measure 2- test X X Electronic Notes X X Imaging Results X X Family Health History X X emar Labs to ambulatory providers Advance Directives X X X 11 11
12 M E A N I N G F U L U S E M O D I F I C A T I O N S The Final Rule eases patient engagement measures Patient Access: remains >50% compliance View /Download /Transmit (VDT): eliminated >5% compliance in 2015 & 2016 o New Measure: 1 patient seen during the reporting period must VDT their health information o 5% compliance renewed in 2017 EP Secure Messaging: eliminated >5% compliance o New Measure 2015: Yes/No, capability was enabled for entire reporting period o New Measure 2016: 1 secure message was sent to a patient or authorized representative during the reporting period o New Measure 2017: secure messages sent to 5% of patients 12 12
13 M E A N I N G F U L U S E M O D I F I C A T I O N S The Final Rule aligns public health reporting with requirements Physicians must select 2 of 5 Measures Hospitals must select 3 of 6 Measures EP/EH can choose to report to more than one public health registry and clinical data registry to meet the required number of measures Immunization Registry Reporting Syndromic Surveillance Reporting Max. times measure can count towards EP Objective Case Reporting 1 1 Public Health Registry Reporting Clinical Data Registry Reporting Electronic Reportable Lab Results N/A 1 Max. times measure can count towards EH Objective 13 13
14 M E A N I N G F U L U S E M O D I F I C A T I O N S Steps providers can take to save their final 90 day reporting period Dedicate Resources MU Project Manager MU Team Focus on Required Measures Learn Available Exclusions Educate Staff Requirements Reporting Period Deadlines Importance to Organization Collect Audit Documentation 14 14
15 A U D I T D O C U M E N T A T I O N The most common types of MU documentation are Proof of ONC Certification Core and Menu Measure reports Clinical Quality Measure reports Yes/No support Screenshots Evidence of compliance throughout reporting period Policies or procedures NHplan
16 A U D I T D O C U M E N T A T I O N Audit failures frequently due to insufficient security assessments Perform initial assessment prior to the end of the reporting period Date of completion & NPI of EH or EPs Must contain all required elements Proof of remediation efforts for identified deficiencies Review/update assessment during each reporting period NHplan
17 N E X T S T E P S Meaningful Use regulations are constantly changing and evolving. WeiserMazars can help you Assess MU readiness Develop 2016 strategy Prepare for a potential audit Focus on building compliance for future program goals Stay alert for MU changes NHplan
18 C O N T A C T Marc Grossman Principal (P) Marc.Grossman@WeiserMazars.com Jenna Barsky Manager (P) Jenna.Barsky@WeiserMazars.com
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