MEANINGFUL USE STAGE 2 REQUIREMENTS FOR ELIGIBLE PROVIDERS USING CERTIFIED EMR TECHNOLOGY

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1 MEANINGFUL USE STAGE 2 REQUIREMENTS FOR ELIGIBLE PROVIDERS USING CERTIFIED EMR TECHNOLOGY On August 24, the Centers for Medicare & Medicaid Services (CMS) posted the much anticipated final rule for Stage 2 of meaningful use of EHRs. While CMS and ONC acknowledge the critical role that specialty providers have played in the meaningful use of health IT for quality improvement, there are few changes in the Stage 2 rule that are beneficial. NEW FOR STAGE 2 EPs must meet or qualify for an exclusion to 17 core objectives EPs must meet 3 of the 6 menu measures. EPs must report on 9 out of 64 total CQMs. Two years of reporting time for each stage Increased thresholds for many measures Increased patient engagement requirements Changes to exclusion for Vital Signs can report on blood pressure and exclude height/weight October 1, 2014 as the latest date by which an EP can attest for the first time and avoid a 1% payment adjustment in For 2014 only, all providers regardless of their stage of meaningful use are only required to demonstrate meaningful use for a three-month EHR reporting period. TIMELINE FOR IMPLEMENTATION CMS is pushing back the start date for Stage 2 compliance to January 1, Those that attest to meaningful use first in 2011 must meet Stage 2 criteria in 2014 and Stage 3 in All others will be required to demonstrate 2 years at, 2 years at Stage 2 and then 2 years at Stage 3 (assuming the cut-off date for the program s payments have not passed). Providers attesting to Year 1, criteria, regardless of when they start, will continue to use a 90-day reporting period. 3 Month Reporting Option for providers attesting to either or Stage 2 in 2014 in order to allow time for EPs to implement newly certified EHR ( allow EP flexibility in the first year of meeting Stage 2, to avoid delay in reporting for Stage 3, which CMS is proceeding with implementing by 2016.) MEDICARE PAYMENT ADJUSTMENTS/REDUCTIONS Penalties begin in 2015 for not being a meaningful user. To avoid the -1% 2015 payment reduction, the EP must attest no later than October 1, 2014 (must begin 90 day EHR reporting period no later than July 1, 2014.) 1

2 To Avoid Payment Adjustments: EPs must continue to demonstrate meaningful use every year to avoid payment adjustments in subsequent years. (-1% in 2015, -2% in 2016, -3% in 2017; subject to increase annually at the discretion of CMS.) FIRST PAYMENT YEAR REQUIREMENTS FOR EACH PAYMENT YEAR Stage 2 Stage 2 Stage 2 Stage 2 MEDICARE PAYMENTS Maximum Total Amount of EHR Incentive Payments for a Medicare EP First CY EP Receives an Incentive Payment and later 2011 $18,000 Calendar Year 2012 $12,000 $18, $8,000 $12,000 $15, $4,000 $8,000 $12,000 $12,000 $ $2,000 $4,000 $8,000 $8,000 $ $2,000 $4,000 $4,000 $0 Total $44,000 $44,000 $39,000 $24,000 $0 HARDSHIP EXCEPTIONS 1. Infrastructure - EPs must demonstrate that they are in an area without sufficient internet access or face insurmountable barriers to obtaining infrastructure (e.g., lack of broadband). 2. New EPs - Newly practicing EPs who would not have had time to become meaningful users can apply for a 2-year limited exception to payment adjustments. 3. Unforeseen Circumstances - Examples may include a natural disaster or other unforeseeable barrier. 4. EPs must demonstrate that they meet the following criteria: a. Lack of face-to-face or telemedicine interaction with patients b. Lack of follow-up need with patients 5. EPs who practice at multiple locations must demonstrate lack of control over availability of CEHRT for more than 2

3 50% of patient encounters Deadlines: Applications need to be submitted no later than July 1 for EPs of the year before the payment adjustment year; however, CMS encourages earlier submission. BATCH REPORTING Starting in 2014, groups will be allowed to submit attestation information for all of their individual EPs in one file for upload to the Attestation System, rather than having each EP individually enter data. STAGE 2 MEANINGFUL USE CRITERIA The charts below list the measures (and specialty exclusions) that eligible providers must demonstrate to become a Stage 2 meaningful user to qualify for Medicare or Medicaid incentives. EPs must report: 1.) All 17 of the Core Set Objectives and Measures 2.) 3 out of 6 of the Set Objectives and Measures 3.) A minimum of 9 Clinical Quality Measures (CQM) STAGE 2 MEANINGFUL USE 17 Core Measures + 3 Measures + 9 Clinical Quality Measures = Stage 2 Meaningful Use The following are charts of Stage 2 meaningful use objectives that must be met, and applicable exclusions: CORE MEASURES IN STAGE 2 - SCOPE AND/OR THRESHOLD CHANGED (CHANGES FROM STAGE 1 UNDERLINED; **DENOTES NEW MEASURE) MEASURE STAGE 2 REQUIREMENT EXCLUSION 1 CPOE - Use computerized physician order entry (CPOE) for medication orders More than 60% of unique patients with a medication in their medication list have at least one medication order entered using CPOE [up from 30 percent] Any EP who writes fewer than 100 medication, laboratory, and radiology orders during the EHR reporting period. 3

4 2 ERX- Generate and transmit permissible prescriptions electronically (e-rx) 3 DEMOGRAPHICS- Record patient demographics (preferred language, gender, race, ethnicity, date of birth) 4 VITAL SIGNS- Record and chart vital signs (height, weight, blood pressure) 5 SMOKING STATUS- Record smoking status for patients 13 years or older 6 CLINICAL DECISION- Implement one clinical decision support rule More than 50% of all permissible prescriptions written by the EP are compared to at least one drug formulary and transmitted electronically using Certified EHR. [up from 40 percent of medication orders] Technology. More than 80% of patients have demographics recorded and can use them to produce stratified quality reports [up from 50 percent and includes more granular categories] More than 80% of patients have vital signs recorded during the reporting year [up from 50 percent; BP age increased from 2 years to 3 years] More than 80% of unique patients over 13 years old have smoking status recorded as structured data [up from 50 percent] Use clinical decision support to improve performance on highpriority health conditions [up from implement one rule] Any EP who writes fewer than 100 prescriptions during the EHR reporting period or does not have a pharmacy within their organization and there are no pharmacies that accept electronic prescriptions NA Any EP who-- (A) Sees no patients 3 years or older is excluded from recording blood pressure; (B) Believes that all three vital signs of height/length, weight, and blood pressure have no relevance to their scope of practice is excluded from recording them; (C) Believes that height/length and weight are relevant to their scope of practice, but blood pressure is not, is excluded from recording blood pressure; or (D) Believes that blood pressure is relevant to their scope of practice, but height/length and weight are not, is excluded from recording height/length and weight Any EP who sees no patients 13 years old or older. A. Implement five clinical decision support interventions related to five or more clinical quality measures, if applicable, at a relevant point in patient care for the entire EHR reporting period; B. The EP has enabled the functionality for drug-drug and drug-allergy interaction checks for the entire EHR reporting period. 4

5 7** CLINICAL LAB RESULTS- Incorporate lab information as structured data 8 PATIENT LISTS- Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research, or outreach. 9 PATIENT REMINDERS- Send reminders for preventive, follow-up care More than 55% of all clinical lab tests Any EP who orders no lab tests whose results ordered by the EP during the EHR results are either in a positive/negative reporting period whose results are either in or numeric format during the EHR a positive/negative or numerical format are reporting period. incorporated in Certified EHR Technology as structured data. Generate at least one report listing patients of the EP with a specific condition. 10% of all unique patients who have had an office visit with the EP within the 24 months, per patient preference [threshold decreased from 20 percent to 10 percent, but scope expanded from patients 65 years or years or older or 5 years or younger to all active patients ] NA Any EP who has had no office visits in the 24 months before the beginning of the EHR reporting period. 10 ** PATIENT ACCESS to HEALTH INFO 50% have access and 10% of patients Any EP who neither orders nor creates Provide patients with an have used the capability to access and any of the information listed for electronic copy of their health download their information (available to inclusion as part of this measure is information (including diagnostic the patient within 4 business days after excluded test results, problem list, the information is available to the EP). medication lists, allergies) upon request. 11 PATIENT ACCESS to CLINICAL SUMMARIES- Provide clinical summaries for patients for each office visit 50% of all visits within 24 hours (pending Any EP who has no office visits during the information, such as lab results, should be EHR reporting period. available to patients within 4 days of becoming available to EPs) [up from more than 50 percent of all visits within 3 business days ] 12 EDUCATIONAL RESOURCES- Identify patient-specific education resources and provide those resources to the patient if appropriate More than 10% of patients are provided with EHR-enabled patient-specific educational resources [threshold unchanged but If appropriate removed] Any EP who has no office visits during the EHR reporting period. 13 TRANSITIONS IN CARE- Perform medication reconciliation for a patient from another care setting or provider of care 14 SUMMARY of CARE RECORD- Summary of care record transmitted between providers at transitions in care Medication reconciliation performed for more than 50% of transitions in care when the EP or hospital was the receiving provide. Required for 65% of care transitions [up from 50 percent]; must be electronic for 10% ( was one test) Any EP who was not the recipient of any transitions of care during the EHR reporting period. Any EP who neither transfers a patient to another setting nor refers a patient to another provider during the EHR reporting period is excluded from both measures. 5

6 15 Submit electronic immunization Submit actual immunization data to at data to immunization registries or least one organization in accordance Immunization Information Systems with applicable law and practice [up from performing just a test; test or dummy data not permissible] 16 Conduct security analysis Conduct or review a security risk analysis, and implement security updates and correct identified security deficiencies. 17 ** Secure Messaging Patients are offered secure messaging online and at least 5% have been sent secure messages online. NA A. The EP does not administer any of the B. The EP operates in a jurisdiction for which no immunization registry or immunization information system is capable of receiving electronic immunization data. Any EP who has no office visits during the EHR reporting period. MENU MEASURES IN STAGE 2 (**denotes a new measure) MEASURE #1** IMAGING More than 20% of imaging results are accessible through Certified EHR Technology EXCLUSION Any EP who does not perform diagnostic interpretation of scans or tests whose result is an image during the EHR reporting period. #2** FAMILY HISTORY Record family health history for more than 20% Any EP who has no office visits during the EHR reporting period. #3 SYNDROMIC SURVEILLANCE Successful ongoing transmission of syndromic surveillance data A. The EP is not in a category of providers who collect ambulatory syndromic surveillance information on their patients during the EHR reporting period. B. The EP operates in a jurisdiction for which no public health agency is capable of receiving electronic syndromic surveillance data in the specific standards required for Certified EHR Technology at the start of their EHR reporting period. C. The EP operates in a jurisdiction for which no public health agency is capable of accepting the version of the standard that the EP's Certified EHR Technology can send at the start of their EHR reporting period. #4** SUBMISSION OF CANCER CASE INFORMATION Successful ongoing transmission of cancer case information A. Does not diagnose or directly treat cancer; or B. Operates in a jurisdiction for which no public health agency is capable of receiving electronic cancer case information in the specific standards required for Certified EHR Technology at the start of their EHR reporting period. 6

7 #5** SPECIALIZED REGISTRY (New) Successful ongoing transmission of data to a specialized registry A. Does not diagnose or directly treat any disease associated with a specialized registry; or B. Operates in a jurisdiction for which no registry is capable of receiving electronic specific case information. #6** PROGRESS NOTES (New) Enter an electronic progress note for more than 30% of unique patients A. Does not diagnose or directly treat any disease associated with a specialized registry; or B. Operates in a jurisdiction for which no registry is capable of receiving electronic specific case information. CRITERIA FOR REPORTING CLINICAL QUALITY MEASURES 2013 (STAGE 1) An EP must report 6 Clinical Quality Measures (CQM) starting with the 3 Core Clinical Quality Measures. If your EHR reports zero in the denominator on one of the Core Clinical Quality Measures, replace it with one of 3 Alternate Core Clinical Quality Measures. Choose 3 Additional Clinical Quality Measures (from list of 38) that are relevant to your scope of practice. Clinical Quality Measures CQM do not have thresholds that you have to meet you simply have to report data on them. Certified EHR will produce a report with clinical quality measure data, and you must enter that data exactly as the certified EHR produced it. Ophthalmology-Specific Additional Clinical Quality Measures: o 12. Primary Open Angle Glaucoma Optic Nerve Head Evaluation (PQRS Measure 12) o 13. Diabetic Retinopathy Documentation of Presence or Absence of Macular Edema and Level of Severity of Retinopathy (PQRS Measure 18) o 14. Diabetic Retinopathy Communication with the Physician Managing Ongoing Diabetes Care (PQRS Measure 19) o 22. Diabetes Eye Exam (PQRS Measure 114) Which will often be the case for ophthalmology; if all three of the core/alternate core CQMs have zeros for the denominators (this would imply that the physician s patient population is not addressed by these measures) then the EP is still required to report on the three additional clinical measures. There are two reporting methods available for reporting the measures that began in 2012 and are continuing into 2013: Attestation - Physician Quality Reporting System EHR Incentive Program Pilot for EPs 7

8 2014 and Beyond (STAGE 2 and Beyond) EPs must report on 9 of the 64 approved CQMs (Final specification sheets for the CQMs for stage 2 are targeted to be released in October 2012.) o Selected CQMs must cover at least 3 of the National Quality Strategy domains (See Measure Selection Process below.) Beginning in 2014, all Medicare-eligible providers beyond their first year of demonstrating meaningful use must electronically report their CQM data to CMS. Measure Selection Process Providers must select 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 A complete list of 2014 CQMs and their associated National Quality Strategy domains will be posted on the CMS EHR Incentive Programs website ( in the future. The measures that we have right now.guidance/legislation/ehrincentiveprograms/downloads/clinicalqualitymeasurestipsheet.pdf 8