Overview and Analysis of Proposed Changes to Meaningful Use in

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1 Overview and Analysis of Proposed Changes to Meaningful Use in A White Paper April 2015 Impact Advisors LLC 400 E. Diehl Road Suite 190 Naperville IL Impact- Advisors.com

2 Executive Summary On April 10, 2015 CMS published the highly anticipated proposed rule on changes to meaningful use in 2015 and This proposed rule comes on the heels of the recently published proposed rule on Stage 3 (which only pertains to requirements in 2017 and 2018). The proposed rule from April 10 th would make many important changes to meaningful use requirements in 2015 and 2016: Beginning in 2015, the EHR reporting period for all hospitals and EPs would follow the calendar year. For 2015 only, all hospitals and EPs would be able to attest to 90 consecutive days of meaningful use, instead of an entire year. A revised version of Stage 2 would be required for all hospitals and EPs in 2015 and 2016; though, providers currently scheduled to demonstrate Stage 1 this year would have a number of exclusions and alternate measures available. Changes to 2015 Reporting Period Beginning in 2015, the EHR reporting period for all hospitals and EPs would follow the calendar year. (Note that the reporting period for EPs is already based on the calendar year, but for hospitals the reporting period is currently based on the Federal Fiscal Year.) For 2015, all EPs and hospitals would be able to attest to an EHR reporting period of any consecutive 90 days: EPs would be able to choose any consecutive 90-day period between January 1, 2015 and December 31, Hospitals would be able to choose any consecutive 90-day period between October 1, 2014 and December 31, The 90-day reporting period which many providers have been calling for would only be for In 2016, a full, 365-day reporting period would again be required (except for first time MU participants, who would continue to be able to attest to any consecutive 90-day period). Revised Stage 2 Objectives and Measures Beginning in 2015, CMS is proposing to replace the existing Stage 1 and Stage 2 requirements with a revised version of Stage 2. The revised Stage 2 requirements are essentially a consolidated version of the current Stage 2 objectives and measures. The biggest change would be structural. There would no longer be a core and menu set. Instead, there would be 9 objectives (and 18 measures) for hospitals, and 10 objectives (and 18 measures) for EPs. Overview and Analysis of Proposed Changes in MU in

3 In the revised version of Stage 2, many existing Stage 1 and Stage 2 measures specifically those CMS believes to be redundant, duplicative or topped out would be removed. Removed HOSPITAL Objectives / Measures Record Demographics Record Vital Signs Record Smoking Status Structured Lab Results Patient List Summary of Care - Measure 1 - Measure 3 emar Advanced Directives Electronic Notes Imaging Results Family Health History Structured Labs to Ambulatory Providers Removed EP Objectives / Measures Record Demographics Record Vital Signs Record Smoking Status Clinical Summaries Structured Lab Results Patient List Patient Reminders Summary of Care - Measure 1 - Measure 3 Electronic Notes Imaging Results Family Health History Of the existing objectives and measures that CMS would retain in the revised version of Stage 2, virtually all would have the exact same scope and threshold that they currently do. There are four important exceptions: The second measure of the Patient Electronic Access objective would only require that at least 1 patient discharged from the hospital during the EHR reporting period views, downloads or transmits his or her health information to a third party. The EP-only Secure Messaging measure would only require a yes/no attestation to the statement the capability for patients to send and receive a secure electronic message was enabled during the EHR reporting period. The threshold of the Summary of Care measure requiring a summary of care document to be electronically transmitted at transitions of care would stay at 10%, but the transmission would be able to occur via any electronic means rather than only via Direct. All of the existing public health measures (including a few new ones) would be grouped together under a single objective. Hospitals would have to meet 3 of the 6 public health measures to satisfy the objective, while EPs would have to meet 2 of 5. The requirement to achieve ongoing submission would also be replaced with active engagement. Active engagement is defined by CMS as the process of moving towards sending or actually sending production data to a public health agency or clinical data registry. Overview and Analysis of Proposed Changes in MU in

4 Attesting to the Revised Version of Stage 2 All hospitals and EPs regardless of current Stage would be required to attest to the revised version of Stage 2 in but there would be many exclusions and alternate measures available for providers currently scheduled to demonstrate Stage 1 this year. For example, CMS would allow Stage 1 providers to use a lower threshold for certain Stage 2 measures in Additionally, there would be exclusions available for revised Stage 2 measures that do not have a Stage 1 equivalent. [See the table below for details.] The only exclusion available for providers currently scheduled to be on Stage 2 in 2015 would be for hospitals that had not planned to select the (previously optional) e-prescribing measure this year. Revised Stage 2 Objectives and Measures [Note: measures in red represent proposed changes from current Stage 2 requirements] PROPOSED OBJECTIVES AND MEASURES FOR ALL HOSPITALS AND EPs IN 2015, 2016 & 2017 Objective CPOE Measure(s) For Providers Scheduled to Be on Stage 1 in 2015 ONLY Measure Exclusion 1. Medication orders (more than 60%) Yes Lab orders (more than 30%) 3. Radiology orders (more than 30%) e-rx CDS Hospital measure: Electronic prescribing (more than 10% of discharge medications) [Note: exclusion available for Stage 2 hospitals in 2015] EP measure: Electronic prescribing (more than 50% of prescriptions) 1. Implement 5 clinical decision support rules Yes -- Yes Drug-drug and drug-allergy alerts enabled Patient Electronic Access (V/D/T) 1. Online access to information (more than 50% of unique patients) 2. View, Download, Transmit (at least one patient views, downloads, or transmits his or her health information to a third party) Protect EHI Conduct or review a security risk analysis Patient Specific Education Patient-specific education resources identified by CEHRT are provided to patients (more than 10% of unique patients) Overview and Analysis of Proposed Changes in MU in

5 PROPOSED OBJECTIVES AND MEASURES FOR ALL HOSPITALS AND EPs IN 2015, 2016 & 2017 Objective Med Rec Summary of Care Secure Messaging [EP only] Public Health Measure(s) Medication reconciliation performed (more than 50% of transitions of care) Create summary of care document using CEHRT and transmit summary of care document electronically (more than 10% of transitions of care; no specific transport standards required) EP measure: During the EHR reporting period, the capability for patients to send and receive a secure electronic message with the provider was fully enabled. EPs: 2 of 5 measures must be successfully met* Hospitals: 3 of 6 measures must be successfully met* 1. Immunization Registry Reporting (active engagement with a public health agency) 2. Syndromic Surveillance Reporting (active engagement with a public health agency) 3. Case Reporting (active engagement with a public health agency) 4. Public Health Registry Reporting (active engagement with a public health agency)** 5. Clinical Data Registry Reporting (active engagement to submit data to a clinical data registry)** 6. Electronic Reportable Laboratory Result Reporting (active engagement with a public health agency) [Hospital only] For Providers Scheduled to Be on Stage 1 in 2015 ONLY Measure Exclusion *In 2015 only: EPs scheduled to be on Stage 1 would only have to successfully meet 1 of 5 public health measures; hospitals scheduled to be on Stage 1 would only have to successfully meet 2 of 6 public health measures. **Measures #4 and #5 for Public Health Registry Reporting and Clinical Data Registry Reporting may be counted more than once if more than one Public Health Registry or Clinical Data Registry is available. It is important to note that the proposed exclusions and alternate measures would only be for 2015 and, except for the inpatient e-prescribing exclusion, would only apply to providers scheduled to be on Stage 1 this year. In 2016, all hospitals and EPs would be required to attest to a full year of the revised version Stage 2 and the proposed exclusions or alternate measures would no longer be available. This means a hospital that had been planning to defer e-prescribing (which is currently a menu set objective) until Stage 3 would now be responsible for meeting that measure next year. Similarly, an EP that had been expecting to still be on Stage 1 next year would suddenly be responsible for all of the Overview and Analysis of Proposed Changes in MU in

6 requirements under the revised version of Stage 2 in The following chart provides details on the proposed timeline. Key Takeaways The proposed change to shorten the length of the 2015 reporting period was expected; the revised version of Stage 2 was not. The sheer number of changes CMS is proposing in the 200+ page document caught almost everyone by surprise especially since many of the changes would apply to the current reporting period. Between the various exclusions, alternate measures, and other modifications, there is A LOT of information for providers to digest, and the reality is this proposed rule is nowhere near as straightforward and simple as most were expecting. Although the proposed rule is complex, most of the changes in theory should make it easier to achieve meaningful use in However, 2016 could now be unexpectedly challenging, especially for hospitals that had been planning to defer the e-prescribing measure until Stage 3. The reduced number of Stage 2 measures wouldn t really mean fewer requirements. Many of the measures CMS is proposing to remove are already requirements under other objectives. For example, hospitals already have to capture vital signs and demographic data to populate the C-CDA for the summary of care objective. So, even though providers would not have to report specific numerators and denominators for those removed measures, the underlying requirement behind many of them would not really change. Overview and Analysis of Proposed Changes in MU in

7 Perhaps the most important item to keep in mind is this is a proposed rule, not an interim final rule. So, there will be a 60-day comment period, and then CMS will publish the final rule (probably in the late summer or fall). Given the changes will apply to the current meaningful use reporting period though, this timetable could very well make planning tricky for providers, since we won t know for sure which of the proposed changes will actually be finalized until the 2015 reporting period is more than halfway over! About Impact Advisors Impact Advisors provides high-value strategy and implementation services to help healthcare clients drive clinical and operational performance excellence through the use of technology. We partner with industry-leading organizations to identify and implement improvements in quality, safety and value. Our Associates are experienced professionals with deep domain expertise and a commitment to delivering results. For more information visit: Follow us on Facebook and LinkedIn Copyright 2015 Impact Advisors, LLC. All rights reserved. These materials are provided to you by Impact Advisors as a professional courtesy for personal use only and may not be sold. Please appropriately credit/cite your source as Impact Advisors, LLC. All copying for commercial use requires written prior permission secured from impact-advisors.com. Overview and Analysis of Proposed Changes in MU in