Meaningful Use Update Eligible Professionals. December 2011

Transcription

1 Meaningful Use Update Eligible Professionals December 2011

2 Discussion Topics Welcome, HITECH Program Update Topics for Clarification (Stage 1) CPOE Quality Measures PQRI e-prescribing verses Meaningful Use e-prescribing Clinical Decision Support Public Health Reporting (Immunization and Syndrome Surveillance) Security Audit Data Exchange Requirement Audits and Documentation suggestion How to register, obtain vendor number, attest Stage 2 Update and Closing 2

3 3 HITECH PROGRAM UPDATE

4 National Numbers (By Program) As of 10/31 The Medicare EHR Incentive Program has made payments of more than $527 million (actual MU achievement) Over $711 million has been paid in Medicaid EHR incentives since the program began in January (AIU and Achievement) There are 138,570 active registrations of eligible professionals and eligible hospitals for the Medicare and Medicaid programs 4

5 National Numbers (By State) MI 5

6 Michigan Numbers 6

7 TOPICS FOR CLARIFICATION (STAGE 1) 7

8 CPOE Requirements medications directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local and professional guidelines Requirement: >30% of patients Denominator: Unique patients during the reporting period Numerator: At least one medication entered by licensed healthcare professional Rationale: Relationship to action on clinical alerts Drug-allergy, drug-drug, drug-condition FAQ response Exclusion: <100 Rxs during reporting period 8

9 PFR & PFP MU Quality Measures, PQRP, and erx Similarities, differences, and cross-overs

10 MU and Medicare Incentives Meaningful use Core Measures Use erx for 40% of nonnarcotic Rxs Report on 6 Quality Measures erx Medicare incentives PQRP

11 MU and Medicare Incentives Medicare MU $ Medicaid MU $ erx $ No Yes PQRP $ Yes Yes

12 MU and other incentives Medicare MU $ Medicaid MU $ erx $ No Yes PQRP $ Yes Yes CMS clarification: Reporting erx codes will not impede receiving MU incentives.

13 erx 1. Goal: erx usage 2. Fax and efax does not count 3. Only eligible Rxs (not narcotics) 4. MU erx core requirement 40% 1. numerator and denominator 2. exclusion <100 Rxs 5. erx Incentive/Penalty 1. Registry or claims based reporting to claim incentive 2. Claims based reporting to avoid penalty

14 Medicare erx Incentive or Penalty Incentive 2% 1% 1% Penalty - 1% 1.5% 2.0% 2011 Requirement G reporting events required Avoid 2012 Penalty Process If >10 claims with correct G codes First 6 months of 2011 Penalty exemptions

15 erx Recommendation A. Optimize erx utilization ASAP B. erx $ or MU $ in 2011 MU 1. Monitor provider % 2. > 40 % goal erx Incentive/Penalty 1. Report >50 erx G codes (G8553) in Review exemption criteria 3. Review 2012 Criteria

16 MU and other incentives Medicare MU $ Medicaid MU $ erx $ No Yes PQRP $ Yes Yes

17 PFR Quality Measures MU Report on 6 measures 3 core/alternative core 3 additional Attestation 2011 Web based 2012 PQRP Report on any 3 measures Claims or Registry

18 MU Quality Measures 3 Core or alternative Core, and 3 Additional 38 NQF measures 2011 Attestation Numerator and denominator 2012 Web based

19 Quality Measures Must Have 3 Above & Below Measures EP1 - PC EP2 - PC EP3 - Spec EP4 - Spec 3 Core 20/200 17/150 1/150 20/200 17/150 0/0 20/200 0/185 0/0 3 Alt 32/200 16/150 0/0 0/0 0/0 Menu (38) 1-32/ / / / / / / / /125 0/0 0/0 0/ / / /40 Must report 3 measures above the line and three below 0 in the numerator is not the same as 0 in the denominator Menu items limited by Measures Certified by EMR vendor 19

20 MU Core and Alternative Quality Measures Core NQF 0013 BP measurement in hypertensives NQF 0028 Tobacco assessment and cessation NQF 0421 Adult weight and follow up Alternative Core NQF 0024 Pediatric weight and follow up NQF 0041 Flu vacc > 50 years old NQF 0038 Pediatric immunization status

21 MU Additional Quality Measures 38 Additional Measures Limited number of specialty specific measures Need to report on 3

22 Stage 1 Menu Quality Measures Detailed list provided on CD

23 PQRP 2011 Most are also NQF measures Some identical to MU CQM Claims based reporting >80% eligible encounters for 3 measures Registry based reporting Report on three measures No quality threshold 1% 2011 Medicare MAC

24 Quality Measures Recommendations A. Identify measures for your practice B. PQRP $ and/or MU $ in 2011 MU 1. Identify 3 core/alternative core 2. Identify =>3 additional 3. Practice measurements PQRP Incentive/Penalty 1. Identify >3 measures 2. Choose claims or registry method Find a registry!

25 Clinical Decision Support Requirement Implement one clinical decision support rule relevant to specialty or high clinical priority along with the ability to track compliance to that rule Must enable and configure Decision Support engine within the certified EMR Select a standard rule or define/configure a custom rule (appropriate for your practice) Demonstrate ability to track compliance How many times was the rule triggered? If possible, what action was taken or not taken Examples Next Slide 25

26 Rule Examples 1. For diabetic patients, an alert which allows the physician to order a hemoglobin A1c test if there is no hemoglobin A1c result in the past six months 2. For a patient with a history of ischemic vascular disease without contraindications for aspirin use, and who does not have aspirin on his medication list, an alert which asks the provider if the patient is currently taking aspirin and if not, allows the provider to order it 3. For women age with no mammogram in the past year, an alert and/or an order set to facilitate ordering of this diagnostic study 4. For patients 18 and older alert if have NOT received smoking cessation counseling 26

27 Public Health Reporting Requirements EPs must include 1 Public Health Reporting Objective in the chosen Menu Items Submission to Immunization Registries - Capability to submit electronic data to immunization registries or Immunization Information Systems and actual submission in accordance with applicable law and practice. Submission of Syndromic Surveillance Data - Capability to submit electronic syndromic surveillance data to public health agencies and actual submission in accordance with applicable law and practice. 27

28 Immunization Registry Michigan Care Improvement Registry (MCIR) is the approach most MI EHs and EPs are using for Public Health Reporting MDCH has determined MCIR has the capacity to receive immunization data in accordance with the established meaningful use vocabulary and content exchange standards. Therefore, all eligible professions and hospitals administering immunizations in Michigan do not qualify for exclusion The old EXT MCIR Transfer format is not eligible for the MU incentive The Michigan Department of Community Health (MDCH) has developed a testing process Testing to certify for meaningful use will be conducted in a test environment using the version 2.5 or HL7 VXU message 28 Perform at least one test of certified EHR technology's capacity to submit electronic data to immunization registries and follow up submission if the test is successful The Medicare program is already active; A Medicaid program is schedule to begin in Jan Get more information at

29 Syndromic Surveillance Data Performed at least one test of certified EHR technology's capacity to provide electronic syndromic surveillance data to public health agencies and follow-up submission if the test is successful (unless none of the public health agencies to which an EP submits such information have the capacity to receive the information electronically.) More complicated and advanced public health requirement "the systematic process of data collection and analysis for the purposes of detecting and characterizing outbreaks of disease in humans and animals in a timely manner" The CDC contracted with International Society for Disease Surveillance (ISDS) to develop business and infrastructure requirements for syndromic surveillance using clinical data from health information exchanges The PHIN Messaging Guide for Syndromic Surveillance: Emergency Department and Urgent Care Data Version 1.0 (HL7 v2.5.1 (v2.3.1 Compatible)) was released on 10/18/11 and includes minimum syndromic surveillance data standards This standards are intended to help local, state, and federal public health agencies get information to detect and respond to more outbreaks and health events more quickly 29

30 Security Audit Requirements Objective: Protect electronic health information created or maintained by the certified EHR technology through the implementation of appropriate technical capabilities. Measure: Conduct or review a security risk analysis in accordance with the requirements under 45 CFR (a)(1) and implement security updates as necessary and correct identified security deficiencies as part of its risk management process. Must be conducted during the reporting year in which you attest Must be conducted every year thereafter. Act upon findings of security audit 30

31 Security Audit Requirements Audit logs (your certified software should do this) Access granted is appropriate Terminated employees removed Policy on password strength Computers and Screens secure and locked Fax machines secure Concurrent sessions limited Security patches Virus protection Policy on PHI release Wireless secure Firewall enabled 31

32 Security Audit Requirements Shredders used PHI disposed of properly Electronic media disposed of properly HIPAA training in place Signed confidentiality in place Employees aware how to report breaches BAA (Business Associate Agreements) in place Vendors properly identified ID s worn Backups of PHI conducted and stored properly. Restores tested Downtime policies in place Network security analyzed 32

33 Security Audit Requirements Encryption in place Secure s in place for PHI Paper records secure Policy for subpoenas, court orders, etc. Policy in place for accessing own records PDA s secure Inappropriate Internet access restricted Keys tracked Audits conducted Printers secure No PHI is common folders, drives Automatic log outs in place 33

34 Security Audit Requirements Sample long version and short version on CD. Do not just check pass. Auditors will want to see details and documentation 34

35 Data Exchange Requirements Objective: Capability to exchange key clinical information (for example, problem list, medication list, medication allergies, and diagnostic test results), among providers of care and patient authorized entities electronically Measures: Performed at least one test of certified EHR technology s capacity to electronically exchange key clinical information. 35

36 Data Exchange Requirements Notes: Different legal entities Distinct Certified EHR technology Exchange CCD/CCR Exchanging lab or transcribed data is not appropriate Actual patient data is not required (test data in production environment is encouraged) Test can be unsuccessful Test every reporting period Cannot exchange through CD, USB, hard drive 36

37 Data Exchange Requirements Can exchange with Munson through or a Munson drop box (instructions on the CD provided) Practice to receive letter stating participating. 37

38 Data Exchange Requirements 38

39 Audit Documentation The table below outlines HIMformatics generic documentation recommendations for Stage 1 Meaningful Use Audit Documentation. All of these items may not be necessary for each requirement. Artifact Description Comment Interpretation Rationale Document rationale for any requirement specific interpretations or assumptions Especially important on any requirements where MMH might stay closer to the letter of the law Certified EMR Document your overall certification strategy and provide a specific approach to requirements that are not simple Example - if you choose not to use your AEMR vendor s hub product to meet the data exchange requirement, explain your understanding of how you meet the Process Flow Process Documentation Measure Threshold Proof/Confirmat ion Other An overview flowchart or swim lanes are an important part of documenting processes Process definitions that support the process flow and identify roles and responsibilities Document the value of your measure for each requirement and how you tracked it Provide any work objects that may support and give evidence to the achievement of a requirements Think through each requirement and provide any information or results that would help MMH defend their attestation in the future certification requirement Example - Problem list flow showing who does what, when, with what tool Define a standard and follow it for each requirement and measure Again, do this in a standard and consistent way for each measure (it can be simple) Example - letter from testing partner in Exchange of Clinical Data requirements; OR screen prints or reports that prove a capability was turned on and in use Remember you are subject to audit for up to 6-10 years after attestation. The documentation should be standalone, solid, and locked down 39

40 MHC Audit Documentation Recommendations 40

41 MHC Audit Documentation Recommendations 41

42 MHC Audit Documentation Recommendations 42

43 EP Registration Process Registration User Guide (provided on CD) Medicaid EHR Guide (provided on CD). Medicaid State Level Registration (provided on CD). EP Attestation Webinar (provided on CD) EP Attestation Worksheet (provided on CD) a must for filling out in advance of attesting 43

44 EP Registration Process (Certified Health IT Product List) RHC and FQHC do not qualify for Medicare (loophole in the system right now and my never be fixed). RHC and FQHC have different criteria for Medicaid eligibility Get all your ID s before you register, can take weeks or months to track down (and apply for). The billing office may be able to help. Suggest not register really far in advance (too many physicians change practices). 44

45 45 Stage 2 and Stage 3

46 Goals by Stages The initial HITECH stage goals show the program vision Stage 2 Expand Stage 3 Improve Stage 1 Capture 46

47 Stage 2 Meaningful Use All Stage 1 Menu requirements will be mandatory EPs and EHs must meet Stage 2 requirements in their third year of program participation or 2014, whichever is later Thresholds for Stage 1 requirements will been increased and new requirements will also been added 47

48 Stage 2 & 3: Adjustments Requirements Stage 2 Stage 3 CPOE Increase to 60% Include med, lab & rad orders erx 50% med orders (EP & hospital discharge) 80% 80% Clinical Quality Measures TBD TBD Clinical Decision Support (CDS) Use CDS Rules on high priority conditions Use CDS Rules to improve performance Patient lists Generate pt list for multiple parameters Use pt lists to manage highpriority patients HIE Connect to at least 3 external providers in primary referral network or 1 HIE Connect to 30% of external providers or 1 HIE 48 Med Rec 80% 90% Other All Stage 1 menu items required Problem list, meds, allergy lists are up-to-date

49 Stage 2 & 3: Major New Criteria Requirement Hospital EP Clinical Documentation Patient Portal Physician, PA, NP Notes Electronic MAR Electronic relevant information about hospital encounter Physician Notes Download relevant information about a clinical encounter Download data from a longitudinal record 20% of patient use a web-based portal (30% in Stage 3) Use online patient messaging Continuity of Care List of care team members Longitudinal care plan for pts with high-priority conditions List of care team members Longitudinal care plan for pts with highpriority conditions 49

50 Key Dates for Stage 2 Q CMS publishes NPRM on Stage 2 Criteria ONC publishes Interim Final Rule on standards and certification for Stage 2 Mid-to-late 2012 Final rules for Stage 2 published 50