Burning Issues Radio / Webinar: Meaningful Use for EPs Stage 2 in 2014

Transcription

1 Burning Issues Radio / Webinar: Meaningful Use for EPs Stage 2 in 2014 Reid Haase HIT Consultant (REACH) March 19, 2014 REACH - Achieving - Achieving meaningful meaningful use of your use EHR of your EHR

2 Topics for today Medicare penalties & hardship exceptions 2014 EHR Certification Standards Certified Health IT Product List (CHPL) updates Core & menu set objectives for Stage 2 Clinical Quality Measures for 2014 Audits What you can do to prepare Resources 2

3 Medicare Payment Adjustments EPs who demonstrated meaningful use beginning in calendar years will not be penalized 2 years later Payment Adjustment Year EHR Reporting Period For EPs who demonstrates meaningful use in 2014 or later for the first time (using 2014 as an example): Payment Adjustment Year day EHR Reporting Period 2014* 2014 Full Year EHR Reporting Period * If the EP attests no later than October 1,

4 EP Hardship Exceptions Applications for Exceptions: EPs who meet both of the following criteria: Lack of face-to-face or telemedicine interaction with patients AND Lack of follow-up need with patients Disqualifiers: Billing E&M Codes Care plans with follow-up with the EP EPs who practice at multiple locations Attest that they lack of control over availability of CEHRT for more than 50% of patient encounters Show agreements with the locations not equipped Source: 4

5 EP Hardship Exceptions Application for Exceptions: Internet Infrastructure No wired internet is available Internet is available but: Cost prohibitive due to the need to create infrastructure Insufficient speed for Meaningful Use (3Mbs/sec) (?) Timing: Any 90 day period in the 18 months prior to the application deadline of July 1 for EPs the year before the payment adjustment year (Jan 2013 July 2014 for 2015 penalty year) Proof: quotes or correspondence from at least two different Internet service providers For insufficient speed required by your certified EHR technology vendor Source: 5

6 EP Hardship Exceptions Application for Exceptions: Examples: Closure Bankruptcy Other debt restructuring Natural disasters EHR loses certification The Unknown When considering other circumstances the application must outline why meaningful use is unachievable Merely outlining the circumstances with the expectation that CMS will determine the effects on meaningful use is not sufficient Source: 6

7 New 2014 EHR Hardship Exception Issued March 2014 by CMS [If] you are unable to implement the 2014 Edition of Certified Electronic Health Record (EHR) Technology in time to successfully demonstrate meaningful use for the 2014 reporting year, you may be eligible for a hardship exception from the applicable Medicare payment adjustment CMS info sheet for EPs: Guidance/Legislation/EHRIncentivePrograms/Downloads/CEHRT2014 _HEGuidance_EPs.pdf 7

8 Automatic EP Hardship Exceptions Automatic Exceptions (but not shown as automatic per CMS March 2014 tip sheet): For EPs who list the following practice areas as their primary specialty The included Medicare Specialty Codes are diagnostic radiology (30), nuclear medicine (36), interventional radiology (94), anesthesiology (05), and pathology (22). &faqid= Education/Outreach/NPC/Downloads/ EHR-NPC.pdf 8

9 Automatic EP Hardship Exceptions Automatic Exceptions (but not shown as automatic per CMS March 2014 tip sheet): Newly practicing EPs will get a 2-year exception to payment adjustments based on Medicare claims and enrollment data. Education/Outreach/NPC/Downloads/ EHR-NPC.pdf 9

10 Applying for Hardship Exceptions EPs must apply each year to avoid the payment adjustments. Applications need to be submitted by July 1 for EPs of the year before the payment adjustment year Granted if provider demonstrates that the circumstance poses a significant barrier to their achieving meaningful use. Details and applications available at: programs/paymentadj_hardship.h tml Receiving an exception avoids the penalty but the EP misses the incentive payment and advances on the MU timeline 10

11 Topics for today Medicare penalties & hardship exceptions 2014 EHR Certification Standards Certified Health IT Product List (CHPL) updates Core & menu set objectives for Stage 2 Clinical Quality Measures for 2014 Audits What you can do to prepare Resources 11

12 Essential Changes in EHR Certification EHR Certification: From Stage 1 Certified 2011 Certification New Certification criteria 2014 Certification All will need to have 2014 Certified EHR Technology (CEHRT) in payment year 2014 for both Stage 1 & 2 ONC/CMS will not require an EP to purchase components they do not need Vendors will not need to recertify on criteria that have not changed since

13 2014 Edition CEHRT Base: Capabilities certified to meet the definition of Base EHR. Base EHR Core: Capabilities certified for the MU core objectives & measures for the stage of MU they seek to achieve unless the EP/EH/CAH meets an exclusion. Menu: Capabilities certified for the MU menu set objectives & measures for the stage of MU they seek to achieve as well as the selected quality measures 13

14 Base EHR EHR technology that includes fundamental capabilities all providers would need to have. Defined by statute: Demographics Computerized Provider Order Entry (CPOE) Clinical Decision Support (CDS) Quality Reporting Information exchange Security requirements, though not required by statute, were added to the base EHR 14

15 Topics for today Medicare penalties & hardship exceptions 2014 EHR Certification Standards Certified Health IT Product List (CHPL) updates Core & menu set objectives for Stage 2 Clinical Quality Measures for 2014 Audits What you can do to prepare Resources 15

16 How do you know if your EHR is Certified? To achieve Meaningful Use, one must use a ONC Authorized Certification Body (ONC- ACB) certified EHR & obtain a Certification ID each year when attesting to MU Listings of the EHRs and what they are certified for can be found at: This is what you will find 16

17 ONC Certified EHR Products List 17

18 Search for your EHR 18

19 Shopping cart add ALL EHRs! 19

20 Percent of Criteria Met 20

21 The Certification ID 21

22 The Criteria Met 22

23 Topics for today Medicare penalties & hardship exceptions 2014 EHR Certification Standards Certified Health IT Product List (CHPL) updates Core & menu set objectives for Stage 2 Clinical Quality Measures for 2014 Audits What you can do to prepare Resources 23

24 Important Changes to Meaningful Use Starting in 2014 Menu objective exclusions will count as a deferred item For all in the 2014 reporting year not in their first year of attestation: Reporting period reduced to a calendar quarter (Medicare not Medicaid) To allow providers time to adopt 2014 certified EHR technology and prepare for Stage 2 To allow quality measures to correspond with reporting requirements of other quality reporting programs 24

25 Concepts for the Updated Meaningful Use Rules Starting in 2014 For Stage 2: More exchange More patient online access and involvement Stage 1 menu items moved to core Percentages (measures) have increased Turnaround time is shorter to provide info to patients Some measures incorporated into others 25

26 Stage 1 and Stage 2 Meaningful Use for 2014 Stage 1 Stage 2 Eligible Professionals 13 core objectives 5 of 9 menu objectives 18 total objectives Eligible Professionals 17 core objectives 3 of 6 menu objectives 20 total objectives 26

27 Stage 2 Criteria for 2014: Core: Numerator/Denominator: Demographics Medication reconciliation CPOE E-Prescribing Vital signs Smoking status Clinical summaries Labs as structured data Provide patient-specific education resources Provide patients with eaccess with some using it Referral/Transfer of care summary Patient reminders Secure messages from patients Yes or No: Patient list by specific condition 5 clinical decision support rules (with D-D, D- A) Submission of electronic data to immunization registries. Protect electronic health information Menu: Numerator/Denominator: Electronic notes Imaging results Family health history Yes or No: Report to cancer registries Report to specialized registries Provide electronic syndromic surveillance data to public health agencies. 27

28 Stage 2 Core Measures for EPs (in reference to Stage 1 measures) 28

29 CMS EP Core #1 Computerized Provider Order Entry (CPOE) Stage 1 (Core) Measure >30% of patients on any meds with one CPOE med order or may use >30% all orders Unique patients or unique orders) Exclusion: Any EP who writes <100 medication orders during the EHR reporting period. Stage 2 (Core) Measures >60% of all medication orders, >30% of all laboratory and >30% radiology orders must be entered using CPOE s: Unique orders Exclusions: Any EP who writes <100 medication, <100 radiology, or <100 laboratory orders during the EHR reporting period. Starting in 2013, any licensed healthcare professionals and credentialed medical assistants, can enter orders into the medical record for purposes of including the order in the numerator for the objective of CPOE if they can originate the order per state, local and professional guidelines. 29

30 Drug Formulary Check Stage 1 (Menu) Measure Implement drug formulary checks with at least one internal or external formulary Yes/No Attest Exclusion Writes <100 medication orders during the EHR reporting period Stage 2 (Core/Menu) Measure Incorporated into the erx core item 30

31 CMS EP Core #2 eprescribing (EP) Stage 1 (Core) Measure >40% of permissible scripts are generated and transmitted electronically Number of permissible (noncontrolled substance) scripts written by the EP Exclusion Any EP who writes <100 prescriptions during the EHR reporting period. No pharmacies that accept e- prescriptions within 10 miles Stage 2 (Core) Measure >50 percent of permissible or all prescriptions written are queried for a drug formulary and transmitted electronically Number of permissible or all scripts written by the EP Exclusion Any EP who writes <100 permissible prescriptions during the EHR reporting period. No pharmacies that accept e- prescriptions within 10 miles 31

32 CMS EP Core #3 Demographics Stage 1 (Core) Measure >50% of patients seen: preferred language, gender, race, ethnicity, and DOB. For EHs: date and preliminary cause of death Unique Patients Exclusion None Stage 2 (Core) Measure >80% of patients seen: preferred language, sex, race, ethnicity, DOB. For EHs: date and preliminary cause of death Unique Patients Exclusion None 32

33 CMS EP Core #4 Vital Signs Stage 1 (Core) Measure >50% of patients 2yo seen: height, weight, BP, BMI, & for age 2-20: growth charts w/bmi. May split BP and height-weight, also may use only 3 for BP and all ages for H/W/BMI) Unique patients Exclusion If outside scope of practice Stage 2 (Core) Measure >80% of patients height/length, weight, BMI; 3yo: BP; age 0-20: growth charts w/bmi. May split BP and height/length-weight Unique Patients Exclusion If BP or H/L-W is outside scope of practice 33

34 CMS EP Core #4 Vital Signs 34

35 CMS EP Core #5 Smoking Status Stage 1 (Core) Measure >50% of patients 13yo seen, record status as structured data Unique patients Exclusion No patients 13 years old or older. Stage 2 (Core) Measure >80% of patients 13yo seen, record status as structured data Unique patients Exclusion No patients 13 years old or older. 35

36 Drug-Drug and Drug-Allergy Interaction Checks Stage 1 (Core) Measure This functionality is enabled for the entire EHR reporting period Yes/No Attest Exclusion None Stage 2 (Core) Incorporated into the Clinical Decision Support Measure: This functionality is enabled for the entire EHR reporting period 36

37 CMS EP Core #6 Clinical Decision Support Stage 1 (Core) Measure 1 CDS rule relevant to the specialty specific quality metric with the ability to track compliance Yes/No Attest Exclusion None Stage 2 (Core) Measures 5 CDS interventions relevant to 4 quality metrics or high priority condition Drug-drug and drug-allergy interactions turned on Yes/No Attest Exclusion D-D/D-A only if writes <100 medication orders 37

38 CMS EP Core #7 Online Access to Health Information Stage 1 Core for 2014 and later Measure > 50 percent are provided timely online access to their health information within 4 business days of it being available Unique patients Exclusion Creates no information, except for Patient name and Provider's name and office contact information. Stage 2 (Core) Measures >50% are provided timely online access to their health information within 4 business days >5% view, download, or transmit their health information Unique patients Exclusions Creates no information, except for Patient name and Provider's name and office contact information, may exclude both measures. 50% encounters in a county with <50% percent of its housing units have 3Mbps broadband may exclude the second measure. 38

39 CMS EP Core #8 Clinical Summaries (EP) Stage 1 (Core) Measure >50% of office visits, a patient gets a visit summary within 3 business days Office Visits Exclusion No office visits during the EHR reporting period Stage 2 (Core) Measure >50% of office visits, a patient or their representative gets a visit summary within 1 business day Office Visits Exclusion No office visits during the EHR reporting period 39

40 CMS EP Core #8 Clinical Summary Content The Common Meaningful Use Dataset. Patient name. Sex. Date of birth. Race the standard specified in (f). Ethnicity the standard specified in (f). Preferred language the standard specified in (g). Smoking status the standard specified in (h). Problems at a minimum, the version of the standard specified in (a)(3) Medications at a minimum, the version of the standard specified in (d)(2). Medication allergies at a minimum, the version of the standard specified in (d)(2). Laboratory test(s) at a minimum, the version of the standard specified in (c)(2). Laboratory value(s)/result(s). Vital signs height, weight, blood pressure, BMI. Care plan field(s), including goals and instructions. Procedures At a minimum, the version of the standard specified in (a)(3) or (b)(2). Optional. The standard specified at (b)(3). Optional. The standard specified at (b)(4). Care team member(s). In addition 1. The provider s name and office contact information 2. Date and location of visit 3. Reason for visit 4. Immunizations and/or medications administered during the visit 5. Diagnostic tests pending 6. Clinical instructions 7. Future appointments 8. Referrals to other providers 9. Future scheduled tests 10. Recommended patient decision aids. 40

41 CMS EP Core #9 Protect Personal Health Information Stage 1 (Core) Measure Conduct or review a security risk analysis, implement security updates as necessary and correct identified security deficiencies Yes/No Attest Exclusion None Stage 2 (Core) Measure Conduct or review a security risk analysis, including the encryption/security of data stored in CEHRT, implement security updates as necessary and correct identified security deficiencies Yes/No Attest Exclusion None 41

42 CMS EP Core #10 Incorporate Lab Results Stage 1 (Menu) Measure >40% of labs with numeric or +/- result in chart as structured data Unique +/- or numeric lab results Exclusion No results of this type ordered Stage 2 (Core) Measure >55% of labs with numeric or +/- result in chart as structured data Unique +/- or numeric lab results Exclusion No results of this type ordered 42

43 CMS EP Core #11 Patient Lists Stage 1 (Menu) Measure Generate at least one pt list based on a specific condition Yes/No Attest Exclusion None Stage 2 (Core) Measure Generate at least one pt list based on a specific condition Yes/No Attest Exclusion None 43

44 CMS EP Core #12 Patient Reminders (EP) Stage 1 (Menu) Measure >20% of pts 65 or 5yo sent reminders for follow up care Unique Patients Exclusion No patients 65 or 5yo Stage 2 (Core) Measure >10% pts with >1 office visit within 2 years receive reminders for follow-up care sent per patient preference. Unique patients with 2 or more visits in past 24 months Exclusion No office visits in 24 months before the measurement period 44

45 CMS EP Core #13 Patient Education Stage 1 (Menu) Measure >10% of all unique patients are provided patientspecific education resources identified by Certified EHR Technology. Unique patients Exclusion None Stage 2 (Core) Measure >10% of all unique patients are provided patientspecific education resources identified by Certified EHR Technology. Unique patients Exclusion No office visits 45

46 CMS EP Core #14 Medication Reconciliation Stage 1 (Menu) Measure >50% of transitions of care or a relevant encounter # of transitions of care (and relevant encounters if there is a policy) Exclusion No transitions of care or referrals received Stage 2 (Core) Measure >50% of transitions of care or a relevant encounter # of transitions of care (and relevant encounters if there is a policy) Exclusion No transitions of care or referrals received 46

47 Problem List Stage 1 (Core) Measure >80% of patients seen at least one or none as structured data Unique patients Exclusion None Stage 2 Measure Incorporated as a mandatory element in the transfer of care document Referrals or transfers of care Exclusion None 47

48 Medication List Stage 1 (Core) Measure >80% of patients seen at least one or none as structured data Unique patients Exclusion None Stage 2 Measure Incorporated as a mandatory element in the transfer of care document Referrals or transfers of care Exclusion None 48

49 Medication Allergies Stage 1 (Core) Measure >80% of patients seen at least one or none as structured data Unique patients Exclusion None Stage 2 Measure Incorporated as a mandatory element in the transfer of care document Referrals or transfers of care Exclusion None 49

50 CMS EP Core #15 Transfer of Care / Referral Stage 1 (Menu) Measure >50% of referrals and transitions of care Care transitions Exclusion Does not refer or transition Stage 2 (Core) Measure >50% of referrals and transitions of care >10% sent electronically One or more sent electronically to: A different provider with a different EMR The CMS designated test EHR Care transitions Exclusion <100 transfers/referrals during the EHR reporting period 50

51 CMS EP Core #15 Elements of the Stage 2 Transfer of Care / Referral Summary It includes: The Common Meaningful Use Dataset. Patient name. Sex. Date of birth. Race the standard specified in (f). Ethnicity the standard specified in (f). Preferred language the standard specified in (g). Smoking status the standard specified in (h). Problems at a minimum, the version of the standard specified in (a)(3) Medications at a minimum, the version of the standard specified in (d)(2). Medication allergies at a minimum, the version of the standard specified in (d)(2). Laboratory test(s) at a minimum, the version of the standard specified in (c)(2). Laboratory value(s)/result(s). Vital signs height, weight, blood pressure, BMI. Care plan field(s), including goals and instructions. Procedures At a minimum, the version of the standard specified in (a)(3) or (b)(2). Optional. The standard specified at (b)(3). Optional. The standard specified at (b)(4). Care team member(s). In addition Encounter diagnoses. The standard specified in (i) or, at a minimum, the version of the standard specified (a)(3); Immunizations. The standard specified in (e)(2); Cognitive status; Functional status; and Ambulatory setting only. The reason for referral; and referring or transitioning provider s name and office contact information. Inpatient setting only. Discharge instructions. 51

52 CMS EP Core #15 Elements of the Stage 2 Transfer of Care / Referral Summary Uncertainty on implementation of Measurement #2: 10% of all referrals to be sent electronically EHRs with embedded Direct or SOAP transmission protocols can accomplish this Current ONC answer on external, web based Direct solution is that this is not an option See CMS FAQ:

53 CMS EP Core #16 Submit to Immunization Registry Stage 1 (Menu) Measure 1 test of submission to state immunization registry except where prohibited with continued submission if successful Yes/No Attest Exclusions Administers no immunizations No registry with the capacity to receive Stage 2 (Core) Measure Successful ongoing submission of electronic immunization data to an immunization registry or information system for the entire EHR reporting period Yes/No Attest Exclusion Administers no immunizations No registry with the capacity to receive 53

54 CMS EP Core #17 Secure Electronic Messaging (EP) Stage 1 None Stage 2 (Core) Measure >5% of unique patients (or their representatives) seen by the EP during the reporting period send the EP a secure message. Unique patients Exclusion No office visits 50% encounters in a county with <50% percent of its housing units have 3Mbps broadband 54

55 Stage 2 Menu Measures for EPs (in reference to Stage 1 measures) 55

56 CMS EP Menu #1 Syndromic Surveillance Stage 1 (Menu) Measure 1 test of submission to a public health agency except where prohibited with continued submission if successful Yes/No Attest Exclusions Not in a category of providers who collect this data No agency with the capacity to receive Stage 2 (Menu) Measure Successful ongoing submission to a public health agency for the entire EHR reporting period Yes/No Attest Exclusion: Not in a category of providers who collect this data No agency with the capacity to receive 56

57 CMS EP Menu #2 Electronic Provider Notes Stage 1 None Stage 2 (Menu) Measure >30% of unique patients have at least one electronic progress note created, edited and signed by an authorized provider. The text must be text searchable and may contain drawings and other content Unique patients Exclusion None 57

58 CMS EP Menu #3 Imaging Results Stage 1 None Stage 2 (Menu) Measure >10 percent of all tests whose result is one or more images are accessible through Certified EHR Technology Imaging studies Exclusion Orders <100 imaging studies during the EHR reporting period or without access to electronic imaging results at the start of the EHR reporting period. 58

59 CMS EP Menu #4 Family Health History Stage 1 None Stage 2 (Menu) Measure >20% have a structured data entry for one or more firstdegree relatives Unique patients Exclusion No office visits 59

60 CMS EP Menu #5 Cancer Registry (EP) Stage 1 None Stage 2 (Menu) Measure Successful ongoing submission of cancer case information to a public health central cancer registry for the entire EHR reporting period. Attest yes/no Exclusion: EP does not diagnose or directly treat cancer; The EP operates in a jurisdiction for which no public health agency is capable of receiving electronic cancer case information 60

61 CMS EP Menu #6 Specialized Registries (EP) Stage 1 None Stage 2 (Menu) Measure Successful ongoing submission of specific case information to a specialized registry for the entire EHR reporting period. Attest yes/no Exclusion: EP does not diagnose or directly treat a relevant disease; The EP operates in a jurisdiction for which no public health agency is capable of receiving electronic case information 61

62 Topics for today Medicare penalties & hardship exceptions 2014 EHR Certification Standards Certified Health IT Product List (CHPL) updates Core & menu set objectives for Stage 2 Clinical Quality Measures for 2014 Audits What you can do to prepare Resources 62

63 Changes to CQMs Reporting Prior to 2014 Beginning in 2014 EPs Report 6 out of 44 CQMs 3 core or alt. core 3 menu EPs Report 9 out of 64 CQMs Selected CQMs must cover at least 3 of the 6 NQS domains Recommended core CQMs: 9 for adult populations 9 for pediatric Populations Starting in of the 44 CQMs finalized in the Stage 1 final rule will remain 32 new CQMs will be added totalling 64

64 CQM Selection for 2014 All EPs must select 9 of 64 CQMs from at least 3 of the 6 HHS National Quality Strategy domains: Patient and Family Engagement Patient Safety Care Coordination Population and Public Health Efficient Use of Healthcare Resources Clinical Processes/Effectiveness 64

65 2014 Quality Measures Diabetes Cardiovascular disease Preventative care and Screening Pediatrics Geriatrics Appropriate use Asthma Oncology Alcohol and drug dependence Depression Ophthalmology HIV/AIDS Functional assessment Medication management Pregnancy Referral reports 65

66 2014 CQMs Recommended for Adults Patient and Family Engagement. Patient Safety. Care Coordination. Population/Public Health. Efficient Use of Healthcare Resources. Clinical Process/Effectiveness. Functional status assessment for complex chronic conditions Use of High-Risk Medications in the Elderly Documentation of Current Medications in the Medical Record Description Closing the referral loop: receipt of specialist report Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Preventive Care and Screening: Screening for Clinical Depressionand Follow-Up Plan Use of Imaging Studies for Low Back Pain Controlling High Blood Pressure 66

67 2014 CQMs Recommended for Children Weight Assessment and Counseling for Nutrition and Physical Activity for Children and Adolescents Population/Public Health. Efficient Use of Healthcare Resources. Chlamydia Screening for Women Childhood Immunization Status Preventive Care and Screening: Screening for Clinical Depression and Follow-Up Plan Appropriate Testing for Children with Pharyngitis Appropriate Treatment for Children with Upper Respiratory Infection (URI) Use of Appropriate Medications for Asthma Clinical Process/Effectiveness. ADHD: Follow-Up Care for Children Prescribed Attention- Deficit/Hyperactivity Disorder (ADHD) Medication Children who have dental decay or cavities Description: Percentage of children ages 0-20, who have had tooth decay or cavities during the measurement period. 67

68 CQM Reporting in 2014 In 2014, there are two primary reporting methods available for reporting the CQMs: Attestation Beginning in 2014, all Medicare-eligible providers in their second year and beyond of meaningful use may electronically report their CQM data to CMS via the PQRS method in Jan/Feb 2015 Medicaid providers submit CQMs according to their state-based submission requirements. 68

69 Aligning CQMs Across Programs The same CQMs will be used in multiple quality reporting programs beginning in 2014 Other programs include Hospital IQR Program, PQRS, CHIPRA, and Medicare SSP and Pioneer ACOs Hospital Inpatient Quality Reporting Program Physician Quality Reporting System Children s Health Insurance Program Reauthorization Act Medicare Shared Savings Program and Pioneer ACOs 69

70 2014 CQM Quarterly Reporting For Medicare providers, beyond their first attestation year, the month reporting period is fixed to the quarter of either the fiscal or calendar year in order to align with existing CMS quality reporting programs. In subsequent years, the reporting period for CQMs will be the entire calendar year (for EPs) or beyond the 1 st year of MU. Provider Type EP Eligible Hospital/CAH Optional Reporting Period in 2014 Calendar year quarter: January 1 March 31 April 1 June 30 July 1 September 30 October 1 December 31 Fiscal year quarter: October 1 December 31 January 1 March 31 April 1 June 30 July 1 September 30 Reporting Period for Subsequent Years of Meaningful Use 1 calendar year (January 1 - December 31) 1 fiscal year (October 1 - September 30) Submission Period for Subsequent Years of Meaningful Use 2 months following the end of the reporting period (January 1 - February 28) 2 months following the end of the reporting period (October 1 - November 30) 70

71 EP Individual CQM Reporting Beginning in 2014 Eligible Professionals reporting for the Medicare EHR Incentive Program Category Data Level Payer Level Submission Type Reporting Schema First Year of Demonstrating MU* Aggregate All payer Attestation Submit 9 CQMs from EP measures table covering at least 3 domains EPs Beyond the 1 st Year of Demonstrating Meaningful Use Option 1 Aggregate All payer Attestation Option 2 Patient Medicare Electronic Submit 9 CQMs from EP measures table covering at least 3 domains Satisfy requirements of PQRS EHR Reporting Option using CEHRT * Attestation is required for EPs in their 1st year of demonstrating MU because it is the only reporting method that would allow them to meet the submission deadline of October 1 to avoid a payment adjustment. 71

72 EP Group CQM Reporting Beginning in 2014 Eligible Professionals reporting for the Medicare EHR Incentive Program Category EPs in an ACO (Medicare Shared Savings Program or Pioneer ACOs) EPs satisfactorily reporting via PQRS group reporting options EPs Beyond the 1 st Year of Demonstrating Meaningful Use* Data Level Payer Level Submission Type Patient Medicare Electronic Patient Medicare Electronic Reporting Schema Satisfy requirements of Medicare Shared Savings Program or Pioneer ACOs using CEHRT Satisfy requirements of PQRS group reporting options using CEHRT * Groups with EPs in their 1st year of demonstrating MU can report as a group, however the individual EP(s) who are in their 1st year must attest to their CQM results by October 1 to avoid a payment adjustment. 72

73 Topics for today Medicare penalties & hardship exceptions 2014 EHR Certification Standards Certified Health IT Product List (CHPL) updates Core & menu set objectives for Stage 2 Clinical Quality Measures for 2014 Audits What you can do to prepare Resources 73

74 Both Medicare & Medicaid Audits Both Medicare and Medicaid audits are being conducted Medicare audits are conducted by Figliozzi & Co on behalf of CMS Medicaid audit are conducted by the MN Dept. of Human Services (not the MEIP Help Desk those are pre-payment reviews) 74

75 One in 20 Will Face Audits Medicare aims to audit about 5% of all meaningful use attesters by conducting pre-payment and post-payment audits MN Medicaid audits are always post-payment and conducted by DHS (any interaction with the MEIP Help Desk is pre-payment verification and NOT an audit). Medicare has an appeals process but requires that payment be recouped during this process 6 year look back period for audits! 75

76 How are Medicare audits operationalized? EP will receive an letter from Figliozzi & Co. ( address in CMS EHR incentive program registration web page) Letter contains an Information Request List You have 4 weeks from the date on the letter to supply the information to the auditing firm Provide only what is requested and no more Submission options: Figliozzi portal Secure Snail mail 76

77 The Letter Dear Dr. Smith, The Centers for Medicare and Medicaid Services (CMS) has contracted with Figliozzi & Company, CPAs P.C.1 to conduct meaningful use audits of certified Electronic Health Record (EHR) technology... This letter is to inform you that you have been selected by CMS for an audit of your meaningful use of certified EHR technology for the attestation period. Attached to this letter is an information request list. Be aware that this list may not be all-inclusive and that we may request additional information necessary to complete the audit. Please supply all requested items by March 11, 2013, by utilizing one of the following methods: 1. Electronically uploading the information to our secure web portal (see step by step instructions attached) 2. Mailing the information to: Figliozzi & Company, CPAs P.C. 585 Stewart Avenue Suite 416 Garden City, NY If you have any questions, please contact me by at or by telephone at (516) extension 302. Sincerely, Peter Figliozzi CPA, CFF, FCPA 77

78 Example Audit Questions: Meaningful Use Objective Drug-Drug/Drug- Allergy Interaction Checks and Clinical Decision Support Protect Electronic Health Information Exclusions Audit Validation Functionality is available, enabled, and active in the system for the duration of the EHR reporting period. Security risk analysis of the certified EHR technology was performed prior to the end of the reporting period. Documentation to support each exclusion to a measure claimed by the provider Suggested Documentation One or more screenshots from the certified EHR system that are dated during the EHR reporting period selected for attestation. Report that documents the procedures performed during the analysis and the results. Report should be dated prior to the end of the reporting period and should include evidence to support that it was generated for that provider s system (e.g., identified by National Provider Identifier (NPI), CMS Certification Number (CCN), provider name, practice name, etc.). Report from the certified EHR system that shows a zero denominator for the measure or otherwise documents that the provider qualifies for the exclusion. 78

79 Common Problems Identified in Audits Noncompliance with the requirement that health care providers conduct a data security risk assessment and have a mitigation plan in place (EP Core #9) Lack of adequate documentation to support responses to some of the yes or no meaningful use requirements For example, whether Drug-Drug / Drug- Allergy functionality has been on during the full MU measurement period 79

80 Be prepared for an Audit: REACH tools EP Audit Readiness Assessment Tool (Excel document screenshot in next slide) Also useful for pre-attestation checking Contact your REACH consultant to obtain this document and learn how to use REACH offers an audit readiness and review service (fee for service offering) 80

81 Be prepared for an Audit: REACH tools 81

82 Audit Questions or Appeals for Medicare Contact the auditing firm with questions: Peter Figliozzi at (516) x302 or Use the CMS appeals website Guidance/Legislation/EHRIncentivePrograms/Appeals.html for general appeal questions and updates on the status of any pending appeals. CMS Help Desk , between 9 a.m. and 5 p.m. EST, Monday through Friday, for general questions on how to file appeals and the status of any pending appeals. 82

83 Topics for today Medicare penalties 2014 EHR Certification Standards Certified Health IT Product List (CHPL) updates Core & menu set objectives for Stage 2 Clinical Quality Measures for 2014 Audits What you can do to prepare Resources 83

84 What you can do to prepare Prepare for sharing information with patients: Complete patients problem, medication and allergy lists. Make sure they are up to date and current Decide what types of information you will share with patients Patient portals will require a lot of decision making on the part of providers Begin to encourage patients to get involved in their care Talk up the fact that you will be adding technology to allow them to make appointments on line, message their provider and get their lab results Help patients identify where they might access a computer (library, waiting room) and how to manage privacy in such a setting Explore whether you will use your vendor s portal solution or some other option Prepare for exchanging information with others: Establish relationships with other organizations to which you refer in order to begin planning exchange (be sure to include nursing homes and home care) Think about a connecting with acancer registry and/or other national registries to submit data on an ongoing basis 84

85 What you can do to prepare Make sure your technology will be ready Plan to undergo an EHR upgrade in late 2014 Talk with your vendor about upgrade timelines Look at the quality measures and let your vendor know which ones are important to you For hospitals, prepare for bar-coded medication administration Plan for more decision support Understand how your vendor will support having 5 interventions tied to relevant quality measures Begin to think about the types of interventions you will incorporate into your EHR Evaluate your workflows Look for efficiencies and make sure everyone is working at the top of their license 85

86 Topics for today Medicare penalties & hardship exceptions 2014 EHR Certification Standards Certified Health IT Product List (CHPL) updates Core & menu set objectives for Stage 2 Clinical Quality Measures for 2014 Audits What you can do to prepare Resources 86

87 CMS Stage 2 Guide (47 pages) 87

88 CMS Stage 2 Toolkit (158 pages) 88

89 Meaningful Use Specification Sheets The authoritative source on MU Criteria Downloadable PDF index that links to the Stage 2 Criteria: EP: Guidance/Legislation/EHRIncentivePrograms/Downloa ds/stage2_meaningfulusespecsheet_tablecontents_e Ps.pdf EH/CAH: Guidance/Legislation/EHRIncentivePrograms/Downloa ds/stage2_meaningfulusespecsheet_tablecontents_e ligiblehospitals_cahs.pdf Updated by CMS to account for any corrections or changes Includes relevant certification criteria 89

90 CMS Resources: CM Help desk (888) Meaningful Use: Registration instructions: Guidance/Legislation/EHRIncentivePrograms/RegistrationandAttestation.html Meaningful Use Stage 1 Criteria Specifications CMS Stage 2 web page (with information on revised Stage 1 as well as Stage 2): Guidance/Legislation/EHRIncentivePrograms/Stage_2.html Stage 2 Guide for EPs (new as of Sept 2013) Guidance/Legislation/EHRIncentivePrograms/Downloads/Stage2_Guide_EPs_9_23_13.pdf Stage 2 Toolkit for EPs, EHs/CAHs (Updated February 2013) Guidance/Legislation/EHRIncentivePrograms/Downloads/Stage2_Toolkit_EHR_0313.pdf Attestation Worksheet f 90

91 Other Resources: Quality Measure Specifications on the CMS web site: Guidance/Legislation/EHRIncentivePrograms/ClinicalQualityMeasures.html ONC-ACB Certified EHRs and what modules they are certified for: Office of the National Coordinator Health IT site: Regional Extension Assistance Center for Health Information Technology (REACH) Stratis Health HIT Toolkits for hospitals, clinics, home health, nursing homes and chiropractic North Dakota Department of Health Information Technology Minnesota Department of Health Info Sheet on Public Reporting Measures: 91

92 Upcoming BI Radio calls/webinars: Audit readiness (April) HIE for Stage 2 Transitions of Care /Summary of Care (April) Privacy and Security (May or June) 92

93 Q & A Reid Haase rhaase@stratishealth.org REACH - Achieving - Achieving meaningful meaningful use of your use EHR of your EHR