Modified Stage 2 Final Rule

Transcription

1 Modified Stage 2 Final Rule

2 Illinois Health Information Technology Regional Extension Center (ILHITREC) SUPPORT PROVIDED BY ILHITREC: The Illinois Health Information Technology Regional Extension Center (ILHITREC), under contract with the Illinois Department of Health and Family Services (HFS), is providing education, outreach and support to Medicaid providers for the Electronic Health Record (EHR) Provider Incentive Payment (PIP) Program. Northern Illinois University serves as the Illinois Health Information Technology Regional Extension Center providing EHR and meaningful use services to providers in Illinois. For more information,

3 Speaker Biography Brenda Simms, RN, BSN, CHTS-CP Brenda is a Clinical Informatics Specialist at ILHITREC. She works with physicians, practice managers, clinical staff, billing representatives, physicians and EHR vendors to successfully plan, coordinate, and implement an electronic health record (EHR) system, as well as assist practices with workflow redesign and assists with development of required quality reporting. Brenda also worked for a time with the Central Illinois Health Information Exchange (CIHIE) to facilitate the implementation and effective adoption of HIE. Patty Tobin, MBA Patty is a Clinical Informatics Specialist at ILHITREC, where she assists practices in quality improvement, achievement of Meaningful Use, an optimization of EHR systems. She has over 15 years dedicated to healthcare informatics. Prior to joining ILHITREC, Patty previously worked as a Healthcare IT Consultant, where she delivered a broad range of consulting engagements focused on implementing and managing healthcare data and information projects.

4 INTRODUCTION

5 Disclaimer The target audience of this presentation is Eligible Providers, but some references will be made related to Eligible Hospitals. This webinar is based on official guidance provided by the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator (ONC), experiences from ILHITREC, and other Regional Extension Centers. This presentation was prepared as a tool to assist providers enrolled in the EHR Incentive Program administered by CMS. The ultimate responsibility for compliance, submission and response to any remittance from CMS rests with the provider. Medicare policy changes frequently. It is highly recommended that providers and their designee review rules and regulations frequently. The focus of this presentation is an introduction to the Modified Rule for The contents apply to both the Medicare and Medicaid EHR Incentive Programs through CMS and the ONC.

6 Modified Final Rule The Modification Rule responds to provider concerns about software implementation and information exchange readiness: Restructures Stage 1 and Stage 2 Objective measures to align with Stage 3: EP: 10 Objectives, including 1 consolidated public health objective EH/CAH: 9 Objectives, including 1 consolidated public health objective Streamlines program by removing redundant, duplicative and topped out measures Modifies patient action measures in Stage 2 objectives related to patient engagement that requires patient action Starting in 2015, aligns reporting period with the calendar year for all providers Changes EHR reporting period in 2015 to 90-day period to accommodate modifications All providers attest to Modified Stage 2 Objectives unless this is the first year of participation CQM reporting for all remains as previously finalized

7 Blending of Objective Measures Beginning in 2015, Stage 1 and Stage 2 objectives and measures are Blended into a single set of objectives Replaces previous structure of Core and Menu measures Accommodations are made for Stage 1 providers Stage objectives are based on 1 st payment year (excluding AIU) First Payment Stage of Meaningful Use Year Modified Stage Modified Stage 2 Modified Stage 2 Stage 3 Or Stage 3 Modified Stage Modified Stage 2 Modified Stage 2 Stage 3 Or Stage 3 Modified Stage Modified Stage 2 Modified Stage 2 Stage 3 Or Stage 3 Modified Stage Modified Stage 2* Modified Stage 2 Stage 3 Or Stage 3 Modified Stage Modified Stage 2* Modified Stage 2 Stage 3 Or Stage 3 Modified Stage NA - Modified Stage 2 Stage 3 Or Stage 3

8 Participation Timeline 2015 Attest to Modified Stage 2 (with accommodations for Stage 1 providers) 2016 Attest to Modified Stage 2 (Some alternate exclusions remain for Stage 1 providers) 2017 Attest to either Modified Stage 2 or full version of Stage Attest to full version of Stage 3

9 Reporting Periods All providers attest to EHR reporting period of any continuous 90-day period within calendar year First-time participants may use any 90-day period - Returning participants must report the full calendar year First-time participants may use any 90-day period - Returning participants must report the full calendar year - Stage 3 participants may use any 90-day period First-time Medicaid participants may use any 90-day period - Returning participants must report the full calendar year

10 Changes from Stage 1 Previous EP Stage 1 Objectives EP 13 Core Objectives 5 of 9 Menu Objectives EP Objectives for (Modified Stage 2) 10 Objectives (including one consolidated public health reporting objective with 3 measure options) Previous EH/CAH Stage 1 Objectives EH/CAH 11 Core Objectives 5 of 10 Menu Objectives EH/CAH Objectives for (Modified Stage 2) 9 Objectives (including one consolidated public health reporting objective with 4 measure options)

11 Changes from Stage 2 Previous EP Stage 1 Objectives EP 17 Core Objectives (including public health objectives) 3 of 6 Menu Objectives EP Objectives for (Modified Stage 2) 10 Objectives (including one consolidated public health reporting objective with 3 measure options) Previous EH/CAH Stage 1 Objectives EH/CAH 16 Core Objectives (including public health objectives) 3 of 6 Menu Objectives EH/CAH Objectives for (Modified Stage 2) 9 Objectives (including one consolidated public health reporting objective with 4 measure options)

12 EHR Certification 2015 No changes to the 2014 CEHRT currently in use 2018 Required to update CEHRT to 2015 standards Reporting Year Certified EHR Technology Edition CEHRT or 2015 CEHRT CEHRT Note: Providers may upgrade early to technology certified to the 2015 Edition for EHR reporting period prior to 2018 as outlined in the rule

13 Major Changes to Objectives Beginning in 2015 Changing threshold from Stage 2 objective for Patient Electronic Access measure #2, from 5%, to equal to or greater than 1 patient seen by provider or discharged from hospital Changing threshold from Stage 2 objective Secure Electronic Messaging from percent to functionality fully enabled (yes/no) Consolidating all public health reporting objectives into one objective with measure options following structure of Stage 3 Public Health Reporting objective Changing eligible hospital electronic prescribing objective from menu to core with an exclusion available for certain eligible hospitals/cahs

14 Alternate Exclusions and Specifications for Stage 1 Providers for Meaningful Use in 2015 Any provider scheduled to demonstrate Stage 1 who was not intending to attest to the Stage 1 Patient Specific Education menu objective, may claim an exclusion to the measure. Please note that beginning in 2016, all providers must attest to the objective and measure, and meet the Modified Stage 2 specifications and threshold, in order to successfully demonstrate meaningful use, except for CPOE.

15 *Modified Stage 2 Topped Out Measures No Longer Required to Report Core Problem List Core Record Demographics Core Record Vital Signs* Core Record Smoking Status* Core Clinical Summaries Menu Structured Lab Results Menu Patient Lists Menu Patient Reminders Menu Summary of Care (Measures 1 & 3) Scheduled for Stage 2 Beginning in 2015 Electronic Notes Scheduled for Stage 2 Beginning in 2015 Image Results Scheduled for Stage 2 Beginning in 2015 Family Health History

16 Modified Stage 2 Objectives for Eligible Providers Objective Objective 1: Protect Patient Health Information Modified Stage 2 Data in Certified EHR only Minimum Required for Providers Scheduled for Stage 1 Data in Certified EHR only Objective 2: Clinical Decision Support 5 rules, 4 related to CQMs 1 CDS Rule Objective 3: CPOE Meds/Labs/Radiology 60% / 30% / 30% 30% / Exclusion / Exclusion Objective 4: Electronic Prescribing 50% 40% Objective 5: Health Information Exchange Part 2: Electronically submit summary 10% May claim an exclusion Objective 6: Patient Specific Education 10% May claim an exclusion if EP did not intend to select this Stage 1 Menu Objective Objective 7: Medication Reconciliation 50% May claim an exclusion if EP did not intend to select this Stage 1 Menu Objective Objective 8: Patient Electronic Access Part 1: Timely Access 50% 50% Part 2: Patient VDT 1 patient VDT May claim an exclusion Objective 9: Secure Electronic Messaging Function Enabled May claim an exclusion Objective 10: Public Health Reporting Report on 2 Options Report on 1 Option

17 Payment Adjustment and Hardship Exceptions The EHR reporting periods for the payment adjustment will begin and end prior to the year of the payment adjustment Reporting 2015 Penalty Year Reporting 2016 Penalty Year Any 90-day Period CY Any 90-day Period* (1/1/16-10/1/16) CY 2018 New Participant Returning Participant Any 90-day Period CY 2016 Full Calendar Year CY 2018 Attestation Deadline for CY: Medicare = February 29, 2016 (Website available January 4, 2016) Medicaid = March 31, 2016 (To Be Announced) Providers may apply for a hardship exception to avoid the payment adjustments. Hardship exceptions are granted on a case-by-case basis. Information on how to apply is posted on the CMS EHR Incentive Program Website

18 Preparing for participation in 2015 Confirm your Stage Check registration information: NPPES Login Information Make sure address is correct Make sure payment information is correct Identify and Access Management (I&A) and/or Surrogate Users Info up to date Illinois Medicaid EHR Incentive Program Participants: Register and Link surrogates to providers in Medi Impact Registrations (Must register in both systems) Complete Attestations EARLY, do not wait until the last minute ILHITREC is available to provide assistance and answer questions.

19 OBJECTIVE OVERVIEW

20 Modified Stage 2 Objectives for EPs Objective 1: Protect Patient Health Info/Security Risk Assessment Objective 2: Clinical Decision Support + Drug Interactions Objective 3: CPOE for Medication, Laboratory, and Radiology Orders Objective 4: Electronic Prescribing (erx) Objective 5: Health Information Exchange (Summary of Care) Objective 6: Patient Specific Education Objective 7: Medication Reconciliation Objective 8: Patient Electronic Access (VDT) Objective 9: Secure Electronic Messaging (EPs Only) Objective 10: Public Health Reporting

21 Progression of Stages for Eligible Providers Retired Stage 1 Retired Stage 2 Modified Stage 2 Core 1: CPOE for Medication Orders Core 1: CPOE for Medication, Laboratory, Radiology Objective 3: CPOE for Medication, Laboratory, Radiology Core 2: Drug Interaction Checks No longer a separate objective (incorporated into CDS) No longer a separate or required objective Core 3: Maintain Problem List No longer a separate objective (incorporated into SOC) No longer a separate or required objective Core 4: Electronic Prescribing (erx) Core 2: Electronic Prescribing (erx) Objective 4: Electronic Prescribing (erx) Core 5: Active Med List No longer a separate objective (incorporated into SOC) No longer a separate or required objective Core 6: Active Med Allergy List No longer a separate objective (incorporated into SOC) No longer a separate or required objective Core 7: Record Demographics Core 3: Record Demographics No longer a separate or required objective Core 8: Record Vital Signs Core 4: Record Vital Signs No longer a separate or required objective Core 9: Record Smoking Status Core 5: Record Smoking Status No longer a separate or required objective Core 10: Clinical Decision Support Core 6: Clinical Decision Support + Drug Interactions Objective 2: Clinical Decision Support + Drug Interactions Core 11: Patient Electronic Access Core 10: Patient Electronic Access Objective 8: Patient Electronic Access Core 12: Clinical Summaries Core 11: Clinical Summaries No longer a separate or required objective Core 13: Protect Electronic Health Info/SRA Core 17: Protect Electronic Health Info/SRA Objective 1: Protect Electronic Health Info/SRA Menu 1: Drug Formulary Checks No longer a separate objective (incorporated into erx) No longer a separate or required objective Menu 2: Clinical Lab-test Results Core 7: Clinical Lab-test Results No longer a separate or required objective Menu 3: Patient Lists Core 8: Patient Lists No longer a separate or required objective Menu 4: Patient Reminders Core 9: Patient Reminders No longer a separate or required objective Menu 5: Patient-specific Education Core 12: Patient-specific Education Objective 6: Patient-specific Education Menu 6: Medication Reconciliation Core 14: Medication Reconciliation Objective 7: Medication Reconciliation Menu 7: Summary Care Record Core 15: Summary of Care Objective 5: Health Information Exchange Menu 8: Immunization Registry Core 16: Immunization Registry Objective 10: Public Health Option Menu 9: Syndromic Surveillance Menu 3: Syndromic Surveillance Objective 10: Public Health Option Core 13: Secure Electronic Messaging Objective 9: Secure Electronic Messaging Menu 1: Imaging Results Menu 2: Family History Menu 4: Cancer Registry Menu 5: Specialized Registry Menu 6: eprogress Notes No longer a separate or required objective No longer a separate or required objective No longer a separate or required objective (May count towards the Specialized Registry Reporting) Objective 10: Public Health Option No longer a separate or required objective

22 Modified Stage 2 Objectives for EPs Objective 1: Protect Patient Health Info/Security Risk Assessment Objective 2: Clinical Decision Support + Drug Interactions Objective 3: CPOE for Medication, Laboratory, and Radiology Orders Objective 4: Electronic Prescribing (erx) Objective 5: Health Information Exchange (Summary of Care) Objective 6: Patient Specific Education Objective 7: Medication Reconciliation Objective 8: Patient Electronic Access (VDT) Objective 9: Secure Electronic Messaging Objective 10: Public Health Reporting

23 Objective 1: Protect Patient Health Information/SRA Measure: Conduct or review a security risk analysis including addressing the encryption/security of data stored in Certified EHR Technology, and implement security updates as necessary and correct identified security deficiencies as part of the EPs risk management process. Note: This measure should be in accordance with the Code of Federal Regulations: 45CFR (a)(1); 45CFR (a)(2)(iv); 45CFR (d)(3), and organizations must follow the risk analysis guidance in accordance with the HIPAA Security Rule (issued by the Office for Civil Rights). Alternate Exclusions and Specifications for Stage 1 Providers in 2015 Objective Modified Stage 2 Requirements Alternate Stage 1 Requirements Protect Patient Health Info Conduct or review security risk analysis None Note: Free Security Risk Assessment (SRA) Tool developed by ONC and OCR:

25 Objective 2: Clinical Decision Support + Drug Interactions Measure 1: Measure 2: Implement five clinical decision support interventions related to four or more clinical quality measures at a relevant point in patient care for the entire EHR reporting period. The EP has enabled and implemented the functionality for drug-drug and drug allergy interaction checks for the entire reporting period. Exclusion: Any EP who writes fewer than 100 medication orders during the reporting period. Alternate Exclusions and Specifications for Stage 1 Providers in 2015 Measure Modified Stage 2 Requirements Alternate Stage 1 Requirements 1. Clinical Decision Support 5 rules, 4 related to CQMs 1 CDS Rule 2. Drug Interactions Functionality Enabled None

27 Objective 3: Computerized Provider Order Entry Measure 1: Measure 2: Measure 3: Medication Orders - More than 60% of medication orders created by the EP during the reporting period are recorded using CPOE. Exclusion: Any EP who writes fewer than 100 medication orders during the reporting period. Laboratory Orders - More than 30% of laboratory orders created by the EP during the reporting period are recorded using CPOE. Exclusion: Any EP who writes fewer than 100 laboratory orders during the reporting period. Radiology Orders - More than 30% of radiology orders created by the EP during the reporting period are recorded using CPOE. Exclusion: Any EP who writes fewer than 100 radiology orders during the reporting period. Alternate Exclusions and Specifications for Stage 1 Providers Measure Modified Stage 2 Requirements Alternate Stage 1 Requirements 1. Medication Orders 60% 2015: 30% 2. Laboratory Orders 30% 2015 and 2016: Exclusion 3. Radiology Orders 30% 2015 and 2016: Exclusion

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30 Objective 4: Electronic Prescribing (erx) Measure: More than 50% of all permissible prescriptions, or all prescriptions, written by the EP are queried for a drug formulary and transmitted electronically using Certified EHR Technology. Exclusions: Any EP who writes fewer than 100 permissible prescriptions during the reporting period. Or any EP who does not have a pharmacy within his or her organization and there are no pharmacies that accept electronic prescriptions within 10 miles of the EP's practice location at the start of the reporting period. Alternate Exclusions and Specifications for Stage 1 Providers in 2015 Objective Modified Stage 2 Requirements Alternate Stage 1 Requirements Electronic Prescribing 50% 40%

32 Objective 5: Health Information Exchange Measure: The EP that transitions or refers their patient to another setting of care or provider of care that: (1) uses CEHRT to create a summary of care record, and (2) electronically transmits such summary to a receiving provider for more than 10% of transitions of care and referrals. Exclusion: Any EP who transfers a patient to another setting or refers a patient to another provider less than 100 times during the reporting period. Alternate Exclusions and Specifications for Stage 1 Providers in 2015 Measure Modified Stage 2 Requirements Alternate Stage 1 Requirements Part 2: Electronically Transmit Summary of Care 10% May claim an exclusion in 2015

34 Objective 6: Patient Specific Education Measure: Patient specific education resources identified by Certified EHR Technology are provided to patients for more than 10 percent of all unique patients with office visits seen by the EP during the EHR reporting period. Exclusion: Any EP who has no office visits during the reporting period. Alternate Exclusions and Specifications for Stage 1 Providers in 2015 Objective Modified Stage 2 Requirements Alternate Stage 1 Requirements Patient Specific Education 10% May claim an exclusion if EP did not intend to select this Stage 1 Menu Objective

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37 Objective 7: Medication Reconciliation Measure: 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 EHR reporting period. Alternate Exclusions and Specifications for Stage 1 Providers in 2015 Objective Modified Stage 2 Requirements Alternate Stage 1 Requirements Medication Reconciliation 50% May claim an exclusion if EP did not intend to select this Stage 1 Menu Objective

39 Objective 8: Patient Electronic Access Measure 1: Measure 2: More than 50% of all unique patients seen by the EP during the EHR reporting period are provided timely (within 4 business days after the information is available to the EP) online access to their health information. In 2015 or 2016 reporting period, at least one patient seen by the EP during the reporting period views, downloads, or transmits his or her health information to a third party. In 2017 reporting period, more than 5% of unique patients seen by the EP during the reporting period view, download, or transmit their health information to a third party. Exclusions: Any EP who neither orders nor creates any of the info listed for inclusion as part of the measures; or the EP practices in a county with less than 4 Mbps broadband. Alternate Exclusions and Specifications for Stage 1 Providers in 2015 Measure Modified Stage 2 Requirements Alternate Stage 1 Requirements Measure 1: Timely Access 50% 50% Measure 2: Patient View, Download, or Transmit (VDT) 2015: 1 patient 2016: 1 patient 2017: 5% May claim an exclusion in 2015

40 Modified Stage 2 Objectives for EPs Objective 1: Protect Patient Health Info/Security Risk Assessment Objective 2: Clinical Decision Support + Drug Interactions Objective 3: CPOE for Medication, Laboratory, and Radiology Orders Objective 4: Electronic Prescribing (erx) Objective 5: Health Information Exchange (Summary of Care) Objective 6: Patient Specific Education Objective 7: Medication Reconciliation Objective 8: Patient Electronic Access (VDT) Objective 9: Secure Electronic Messaging (EPs Only) Objective 10: Public Health Reporting

41 Objective 9: Secure Electronic Messaging Measure: In 2015, the capability for patients to send and receive a secure electronic message with the EP was fully enabled during the reporting period. In 2016, for at least 1 patient seen by the EP during the reporting period, a secure message was sent using the electronic messaging function to the patient, or in response to a secure message sent by the patient during the reporting period. In 2017, for more than 5% of unique patients seen by the EP during the reporting period, a secure message was sent using the electronic messaging function to the patient, or in response to a secure message sent by the patient during the reporting period. Exclusions: An EP has no office visits during the reporting period, or the EP practices in a county with less than 4 Mbps broadband. Alternate Exclusions and Specifications for Stage 1 Providers in 2015 Objective Modified Stage 2 Requirements Alternate Stage 1 Requirements Secure Electronic Messaging 2015: Fully Enabled 2016: 1 Patient 2017: 5% May claim an exclusion in 2015 if EP did not intend to select this Stage 1 Menu Objective

43 Objective 10: Public Health Reporting Measure: The EP is in active engagement with a Public Health Agency (PHA) to submit electronic public health data in a meaningful way. The EP is required to successfully attest to any combination of 2 of the possible 3 measures: Measure 1: Immunization Registry Reporting Measure 2: Syndromic Surveillance Reporting Measure 3: Specialized Registry Reporting Exclusions: Measure 1: EP does not administer any immunizations during the reporting period. Measure 2: EP does not treat or diagnose any disease or condition associated with syndromic surveillance. Measure 3: EP does not diagnose or treat any disease or condition associated with or collect relevant data that is required by a specialized registry. Applies to all 3 measures: The registry cannot accept electronic information, or the registry has not announced readiness to accept information. Alternate Exclusions and Specifications for Stage 1 Providers in 2015 Objective Modified Stage 2 Requirements Alternate Stage 1 Requirements Public Health Reporting Report on 2 Options Report on 1 Option

44 Clinical Quality Measures No changes to CQM selection or reporting scheme (EPs must report on 9 of the 64 approved CQMs) For EHR reporting period in 2015 (and for providers participating for first time in 2016), providers attest to any continuous 90-day period of CQM data Registration and Attestation site Providers also have option to electronically report CQM data using established methods for electronic reporting For 2016 and subsequent years, providers beyond first year of meaningful use may attest to one full calendar year of CQM data or electronically report CQM data using established methods for electronic reporting outlined

45 Stage 3 Objectives for Eligible Providers Objective 1: Protect Patient Health Information Objective 2: Electronic Prescribing Objective 3: Clinical Decision Support Objective 4: Computerized Provider Order Entry Objective 5: Patient Electronic Access to Health Information Objective 6: Coordination of Care through Patient Engagement Objective 7: Health Information Exchange Objective 8: Public Health and Clinical Data Registry

46 Summary First Year in MU Returning Participant Any 90-day Period (1/1/15 12/31/15) Any 90-day Period Any 90-day Period (By October 1, 2016) One Year Any 90-day Period (By October 1, 2017) Stage 2 One Year Stage 3 90-days One Year One Year Penalty Year Modified Stage 2 (With Alternate Exclusions and Specifications for Stage 1 Providers) Modified Stage 2 (With Alternate Exclusions and Specifications for Stage 1 Providers) Modified Stage 2 (Or Stage 3) Stage Objectives and CQMs 9 Objectives 2 Public Health Objectives 9 CQMs Minimum of 3/6 Domains (Alternative for Stage 1 Providers) Modified Stage 2 (Some alternate exclusions remain for Stage 1 providers) Modified Stage 2 (Or Stage 3) Stage 3

47 Additional References Final Rule Modification CMS EHR Incentive Program CMS FAQs Requirements IDPH Public Health Objectives (MURS) IMPACT

48 Questions? Contact Information: Brenda Simms Patty Tobin (815)