Meaningful Use Modification Rules for Oct. 26, 2015 Author: Jennifer Swinnich, Associate Director, PAMED Practice Support

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1 Meaningful Use Modification Rules for Oct. 26, 2015 Author: Jennifer Swinnich, Associate Director, PAMED Practice Support The following is a summary of the Meaningful Use Modifications for To obtain more information about services and educational products that the Pennsylvania Medical Society (PAMED) has available to you, please contact Member Services at 855-PAMED4U ( ). Modifications...1 Objectives and Measures...2 FAQs...5 Modification Rule Becomes Final The Centers for Medicare and Medicaid Services (CMS) has released the long-awaited final rule on Meaningful Use Modifications for 2015 through Highlights of some of the modifications include: Reduction of the reporting period to 90 continuous days for all providers for calendar year 2015 Timing of the stages aligned to the calendar year, and no longer tied to the provider s year of participation. For example, providers are to report Stage 2 for 2015 and Although, there are alternate measures available for Stage 1 providers. 17 core and six menu measures were streamlined, removing several measures that are redundant, duplicative, or have been topped out. There are now 10 core objectives, many of which have no changes. The following two objectives changed: To provide patients the ability to view, download and transmit their health record information and the big change here is reducing the requirement from a 5 percent minimum to having a minimum of one single patient viewing, downloading, or transmitting their information. However, this modification is effective for only 2015 and In 2017, the requirement returns to a 5 percent minimum. To have the capability to use secure messaging there is a significant change here as well, removing the 5 percent requirement for 2015 to a simple yes or no question. In 2016, the requirement becomes a minimum of a single patient to send a secure message. For 2017, the requirement returns to a 5 percent threshold. CMS has also released the Stage 3 details, giving providers the option to report Stage 2 or Stage 3 in 2017 and all providers reporting Stage 3 in PENNSYLVANIA MEDICAL SOCIETY. (717) DOC-HELP ( ) 1

2 The following table is from the final rule Medicare and Medicaid Programs: Electronic Health Record Incentive Program -- Stage 3 and Modifications to Meaningful Use in 2015 through The final rule was published in the Federal Registry on Oct. 16. Objectives for 2015, 2016 and 2017 Objective 1: Protect Patient Health Information Objective 2: Clinical Decision Support Objective 3: Computerized Provider Order Entry (CPOE) ELIGIBLE PROFESSIONAL (EP) OBJECTIVES AND MEASURES FOR 2015 THROUGH 2017 Measures for Providers in 2015, 2016 and 2017 Measure: Conduct or review a security risk analysis in accordance with the requirements in 45 CFR (a)(1), including addressing the security (to include encryption) of ephi created or maintained by Certified EHR Technology in accordance with requirements in 45 CFR (a)(2)(iv) and 45 CFR (d)(3), and implement security updates as necessary and correct identified security deficiencies as part of the EP s risk management process. Measure 1: 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. Absent four clinical quality measures related to an EPs scope of practice or patient population, the clinical decision support interventions must be related to highpriority health conditions. Measure 2: The EP has enabled and implemented the functionality for drugdrug and drug-allergy interaction checks for the entire EHR reporting period. Measure 1: More than 60 percent of medication orders created by the EP recorded using computerized provider order entry. Measure 2: More than 30 percent of laboratory orders created by the EP recorded using computerized provider order entry. Alternate Exclusions and/or Specifications for Certain Providers NONE If for an EHR reporting period in 2015, the provider is scheduled to demonstrate Stage 1: Alternate Objective and Measure 1: Objective: Implement one clinical decision support rule relevant to specialty or high clinical priority, along with the ability to track compliance with that rule. Measure: Implement one clinical decision support rule. Alternate Measure 1: For Stage 1 providers in 2015 only, more than 30 percent of all unique patients with at least one medication in their medication list seen by the EP during the EHR reporting period have at least one medication order entered using CPOE; or more than 30 percent of medication orders created by the EP during the EHR reporting period during the EHR reporting period, are recorded using computerized provider order entry PENNSYLVANIA MEDICAL SOCIETY. (717) DOC-HELP ( ) 2

3 Objective 4: Electronic Prescribing Objective 5: Health Information Exchange Objective 6: Patient-Specific Education Objective 7: Medication Reconciliation Measure 3: More than 30 percent of radiology orders created by the EP recorded using computerized provider order entry. EP Measure: More than 50 percent of all permissible prescriptions written by the EP are queried for a drug formulary and transmitted electronically using CEHRT. Measure: The EP that transitions or refers their patient to another setting of care or provider of care (1) uses CEHRT to create a summary of care record; and (2) electronically transmits such summary to a receiving provider for more than 10 percent of transitions of care and referrals. EP Measure: Patient-specific education resources identified by CEHRT 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. Measure: The EP, performs medication reconciliation for more than 50 percent of transitions of care in which the patient is transitioned into the care of the EP. Alternate Exclusion for Measure 2: Providers scheduled to be in Stage 1in 2015 may claim an exclusion for measure 2 (laboratory orders) of the Stage 2 CPOE objective for an EHR reporting period in 2015; and, providers scheduled to be in Stage 1 in 2016 may claim an exclusion for measure 2 (laboratory orders) of the Stage 2 CPOE objective for an EHR reporting period in Alternate Exclusion for Measure 3: Providers scheduled to be in Stage 1 in 2015 may claim an exclusion for measure 3 (radiology orders) of the Stage 2 CPOE objective for an EHR reporting period in 2015; and, providers scheduled to be in Stage 1 in 2016 may claim an exclusion for measure 3 (radiology orders) of the Stage 2 CPOE objective for an EHR reporting period in Alternate EP Measure: For Stage 1 providers in 2015 only, More than 40 percent of all permissible prescriptions written by the EP are transmitted electronically using CEHRT. Alternate Exclusion: Provider may claim an exclusion for the measure of the Stage 2 Summary of Care objective, which requires the electronic transmission of a summary of care document if for an EHR reporting period in 2015 they were scheduled to demonstrate Stage 1, which does not have an equivalent measure. Alternate Exclusion: Provider may claim an exclusion for the measure of the Stage 2 Patient-Specific Education objective if for an EHR reporting period in 2015 they were scheduled to demonstrate Stage 1 but did not intend to select the Stage 1 Patient-Specific Education menu objective. Alternate Exclusion: Provider may claim an exclusion for the measure of the Stage 2 Medication Reconciliation objective if for an EHR reporting period in 2015 they were scheduled to PENNSYLVANIA MEDICAL SOCIETY. (717) DOC-HELP ( ) 3

4 EP Measure 1: More than 50 percent of all unique patients seen by the EP provided timely access to view online, download, and transmit to a third party their health information subject to the EP's discretion to withhold certain information. demonstrate Stage 1 but did not intend to select the Stage 1 Medication Reconciliation menu objective. Alternate Exclusion Measure 2: Providers may claim an exclusion for the second measure if for an EHR reporting period in 2015 they were scheduled to demonstrate Stage 1, which does not have an equivalent measure. Objective 8: Patient Electronic Access (VDT) Objective 9: Secure Messaging EP Measure 2: For 2015 and 2016: At least 1 patient seen by the EP during the EHR reporting period (or patient-authorized representative) views, downloads or transmits his or her health information to a third party during the EHR reporting period. For 2017: More than 5 percent of unique patients seen by the EP during the EHR reporting period (or patientauthorized representative) views, downloads or transmits their health information to a third party during the EHR reporting period. Measure: For 2015: For an EHR reporting period in 2015, the capability for patients to send and receive a secure electronic message with the EP was fully enabled. For 2016: For at least 1 patient seen by the EP during the EHR reporting period, a secure message was sent using the electronic messaging function of CEHRT to the patient (or patientauthorized representative), or in response to a secure message sent by the patient (or patient-authorized representative) during the EHR reporting period. For 2017: For more than 5 percent of unique patients seen by the EP during the EHR reporting period, a secure message was sent using the electronic messaging function of CEHRT to the patient (or the patient-authorized Alternate Exclusion: An EP may claim an exclusion for the measure if for an EHR reporting period in 2015 they were scheduled to demonstrate Stage 1, which does not have an equivalent measure PENNSYLVANIA MEDICAL SOCIETY. (717) DOC-HELP ( ) 4

5 Objective 10: Public Health representative), or in response to a secure message sent by the patient (or the patient-authorized representative) during the EHR reporting period. Measure 1 Immunization Registry Reporting: The EP is in active engagement with a public health agency to submit immunization data. Measure 2 Syndromic Surveillance Reporting: The EP is in active engagement with a public health agency to submit syndromic surveillance data. Measure 3 Specialized Registry Reporting: The EP is in active engagement to submit data to a specialized registry. Stage 1 EPs in 2015 must meet at least 1 measure in 2015, Stage 2 EPs must meet at least 2 measures in 2015, and all EPs must meet at least 2 measures in 2016 and Frequently Asked Questions 1. If I performed the Security Risk Analysis earlier this year, must I do it again? Per CMS, the risk analysis can be done during the calendar year from Jan. 1 through the final day of the reporting period. 2. I was scheduled to be in Stage 1 this year. Do the modifications affect me? Yes. Eligible Professionals (EPs) at both Stage 1 and Stage 2 have a new, condensed set of objectives, but there are exclusions specific for Stage 1 EPs this year for some of these new objectives since an equivalent objective was not mandatory under the original set. 3. When can I attest for 2015 Meaningful Use? Providers can attest for any 90 day reporting period in 2015 beginning Jan. 4, The attestation period is open until Feb. 29, Are any exclusions available for public health measures? An EP can be excluded from reporting to an Immunization registry if he/she Does not administer any immunizations; or Operates in a jurisdiction for which no immunization registry is able to accept data; or Operates in a jurisdiction where no immunization registry has declared readiness to receive data. An EP can be excluded from Syndromic Surveillance reporting if he/she Operates in a jurisdiction that does not collect data from their category of providers; or Operates in a jurisdiction for which agency is not able to accept data; or Operates in a jurisdiction where agency has not declared readiness to receive data. An EP can be excluded from Specialized Registry reporting if he/she PENNSYLVANIA MEDICAL SOCIETY. (717) DOC-HELP ( ) 5

6 Does not diagnose or treat any disease associated with or collect relevant data that is required by a specialized registry; or Operates in a jurisdiction for which no registry is able to accept data; or Operates in a jurisdiction where no registry has declared readiness to receive data. In response to numerous questions about the public health reporting measures and their related exclusions, CMS released a clarification and FAQ. In addition to the exclusions above, CMS is offering providers an additional or alternate exclusion. Providers may claim this if they did not intend to attest to the prior measure criteria. CMS will allow alternate exclusions for 2015 under the following conditions: Stage 1 EPs may claim an alternate exclusion for up to two measures for either Measure 1, Measure 2, or Measure 3. Then the EP must either attest or meet the standard exclusion requirements of the remaining measure. Stage 2 EPs may claim an alternate exclusion for Measure 2 or Measure 3 (Syndromic Surveillance or Specialized Registry). They must either attest to or meet the standard exclusion for Measure 1 (Immunization Registry). Providers for whom the alternate exclusion is applicable will be presented that option in the attestation system. You can find the full text of CMS answer here. 5. What registry can I use as a Specialized Registry? The Pennsylvania Department of Health s (DOH s) Cancer Registry is a specialized registry. You can find details about DOH s Registry reporting here PENNSYLVANIA MEDICAL SOCIETY. (717) DOC-HELP ( ) 6