AIRA Town Hall on MU Stage 3 and CEHRT Rule Comments

Transcription

1 AIRA Town Hall on MU Stage 3 and CEHRT Rule Comments Mary Beth Kurilo, MPH, MSW, Policy and Planning Director, AIRA Eric Larson, Senior Technical Project Manager, AIRA

2 Goals for Today s Call Share information about AIRA s current compiled draft comments on the Meaningful Use Stage 3, Certified EHR Technology, and MU Modifications Proposed Rules Poll the community on which comments have general consensus, and which need further discussion Discuss and approach a consensus response But a window of fine-tuning is still open 2

3 Process for Collecting Community Comments CMS and ONC Proposed Rules were released and shared with AIRA membership on March 20, 2015, followed by CMS Modifications Proposed rules on April 28, 2015 Held community call to discuss IIS impact with Jim Daniel, ONC on April 16, 2015 Solicited member comments up through May 6, 2015 Thank you to the many AIRA members who submitted comments! Held Standards and Interoperability Steering Committee (SISC) calls to discuss and refine comments on May 11 th and May 13th Holding All-Member Town Hall to share and discuss comments today 3

4 Approach for Today s Call Provide brief overview of comments planned for submission with limited discussion Conduct polls to gather community agreement Circle back on comments in need of further discussion Next Step: Refine and share written comments for integration as desired into members organizations comments 4

5 CMS Rule Medicare and Medicaid Programs; Electronic Health Record Incentive Program-Stage 3 Overall Goals: Align all three stages of MU into single program/rule as an option in 2017 and as a requirement for all providers in 2018 Align reporting periods Provide simplified objectives and measures Comments Due: 5pm ET, May 29,

6 ONC Rule 2015 Edition Health Information Technology (Health IT) Certification Criteria, 2015 Edition Base Electronic Health Record (EHR) Definition, and ONC Health IT Certification Program Modifications Overall Goals: Provides new 2015 Base EHR Definition Eliminates optional/required criteria for measures systems can choose measures from selected list Comments Due: 5pm ET, May 29,

7 CMS Rule Medicare and Medicaid Programs; Electronic Health Record Incentive Program Modifications to Meaningful Use in Overall Goals: Align and streamline the MU program by removing reporting requirements on measures which have become redundant, duplicative, or topped out through advancements in EHR function and provider performance for Stage 1 and Stage 2 of the Medicare and Medicaid EHR Incentive Programs Comments Due: 5pm ET, June 15 th,

8 Summary of Objective 8: Public Health and Clinical Data Registry Reporting Proposed Objective: The EP, eligible hospital, or Critical Access Hospitals (CAH) is in active engagement with a PHA or CDR to submit electronic public health data in a meaningful way using certified EHR technology, except where prohibited, and in accordance with applicable law and practice. Six possible measures to meet the objective Eligible professionals must meet three measures Eligible Hospitals and Critical Access Hospitals must meet four measures 8

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10 CMS MU Stage 3 EHR reporting period would change so that all providers would report under a full calendar year timeline with a limited exception for first time MU participants AIRA supports the changes to both the reporting period start and end dates and the duration: Calendar year reporting Full year reporting period Exception if you are a Medicaid EP or EH demonstrating MU for the first time, then a continuous 90-day period 10 CMS MU Poll #1:

11 CMS MU Stage 3 State Flexibility The rule proposes to offer state flexibility in the PH and clinical data registry reporting objective as long as it does not exceed requirements for stage 3 rule AIRA is seeking clarification to determine if State Flexibility to specify the means of transmission of the data includes Immunization Registries or not This could affect transport (CDC SOAP WSDL or other IIS preferred transport) This could affect HL7 local IGs which are derived from the National IG AIRA is recommending that IIS be allowed a level of state flexibility 11 CMS MU Poll #2:

12 CMS MU Stage 3 Objective 8: Public Health Objective 8 moves IIS away from core (required) to 1 of 6 measures, of which EPs must meet 3 and EH/CAH must meet 4 AIRA is recommending that IIS remain as a core measure IIS was a core measure in Stage 2 Concern with jeopardizing existing transmissions if providers opt to implement other measures and neglect updating for Stage 3 IIS measure (Submission and Query/Response) 12 CMS MU Poll #3:

13 CMS MU Stage 3 Ongoing Submission Ongoing submission phrase was replaced with Active engagement Providers must still respond to requests within 30 days No other changes suggested to promote actual forward movement towards interoperability AIRA is in favor of the new phrasing However, AIRA is further recommending that public health would have authority to determine if respondent is working to make actual progress not just responding 13 CMS MU Poll #4:

14 CMS MU Stage 3 Active Engagement Providers that have registered in previous years do not need to submit additional registration. AIRA is seeking clarification if this applies to IIS since the immunization measure adds bi-directional onto existing Stage 1 and 2 submission requirements. 14 CMS MU Poll #5:

15 CMS MU Stage 3 Objective 8: IIS Query/Response Immunization Measure now includes Submission and Bidirectional (query/response) exchange Comment #1: AIRA supports the inclusion of query/response into the immunization measure, as it represents significant value for providers and patients. Over half of IIS have query response in production This number is increasing, and could include most, if not all, IIS by 2017/ CMS MU Poll #6:

16 CMS MU Stage 3 Objective 8: IIS Query/Response Immunization Measure now includes Submission and Bidirectional (query/response) exchange Comment #2 (for consideration): AIRA requests that the final rule allow registries to declare their readiness for submission separate from query, to ensure that the current immunization reporting pathways are not disrupted in the expansion to bidirectional exchange 16 CMS MU Poll #7:

17 CMS MU Stage 3 Exclusion for Immunization 2 clauses in the exclusion criteria were carried forward from Stage 2 If the IIS isn t capable of accepting the specific standards required to meet the CEHRT definition at the start of the reporting period IIS doesn t declare readiness to receive immunization data AIRA is seeking clarification that the first bullet (although identical to previous stage) doesn t mean an exclusion can be claimed if an IIS has local HL7 requirements AIRA is noting that the second bullet is void of exclusion language for bidirectional which needs to be considered 17 CMS MU Poll #8:

18 ONC CEHRT Rule Base EHR Contradiction exists between Table 2 which states transmission to IIS is not included in what is defined as a Base EHR, but a footnote suggests that it s possible transmission to IIS could be part of the Base EHR Concern is that of confusion for implementers AIRA is requesting the final rule clarify the inclusion and timing of the measure 18 ONC Poll #9:

19 ONC CEHRT Rule Means of Transmission The NPRM is silent on transport in the Transmission to IIS section The NPRM section devoted to SOAP specifies XDR/XDM standard AIRA is asking confirmation that transport will continue to be allowed to be specified at the state or jurisdictional level AIRA also acknowledges the CDC SOAP WSDL as a common interface across the community 19 ONC Poll #10:

20 ONC CEHRT Rule Minimum Standard Code Sets Three important items in this section Requires release 1.5 of the National Implementation Guide Table Lists code sets for transmission to IIS, but neglects MVX Requires NDC as the code set for recording administered vaccines rather than CVX/MVX AIRA supports release 1.5 and asks for MVX to be included in table AIRA is NOT in favor of requiring only NDC for administered, but rather prefer that CVX/MVX continue to be used, while also requiring NDC More on this in the next two slides 20 ONC Poll #11:

21 ONC CEHRT Rule Recording Historical Doses NPRM asks for comments on 1 of 2 approaches: 1) Use CVX and MVX (if known) 2) Use NDC syntax and create NDC-like codes for vaccines of unspecified formulation AIRA s recommendation is to stay with our current approach which is option 1 above Further, AIRA added information from MIROW on the definition of historical and administered doses 21 ONC Poll #12:

22 ONC CEHRT Rule Recording Administered Doses NPRM is requiring NDC for administered doses: Cites 2D barcoding, inventory management, and patient safety for reasons NDC is best suited for administered doses 22 AIRA s recommendation is to stay with our current approach of CVX/MVX but also require NDC as a secondary representation (HL7 can carry both in one message) Concerns with moving to NDC: NDC s are much more fluid and CVX/MVX NDC is not a commonly leveraged data element currently in EHRs requiring significant development Unclear at this time if NDC s would be appropriate for bidirectional exchange ONC Poll #13:

23 ONC CEHRT Rule Bidirectional Exchange Immunization Measure now includes Submission and Bidirectional (query/response) exchange Refer to previous poll results 23

24 ONC CEHRT Rule Imm History Reconciliation NPRM seeking comment on whether immunization history reconciliation should be considered AIRA believes that the inclusion of immunization history reconciliation capability would add significant value to the EHR product while lowering the burden on the end user, who otherwise would need to rekey the queried data into their EHR manually 24 ONC Poll #14:

25 ONC CEHRT Rule Version release 1.5 NPRM cites Version release 1.5 for transmission to IIS AIRA is requesting greater specificity regarding the use of release 1.5 to point out the profiles required for submission (Z22 and Z23) and bidirectional (Z44, Z23, Z33, and Z42) 25 ONC Poll #15:

26 ONC CEHRT Rule Race and Ethnicity NPRM cites a Health IT module must be able to express both detailed races and ethnicity according to the Race and Ethnicity CDC code system and the aggregate OMB code for each race and ethnicity identified by the patient The Race and Ethnicity CDC code set contains 900+ codes AIRA is requesting that the traditional aggregate OMB codes be used 26 ONC Poll #16:

27 ONC CEHRT Rule NDC to CVX Mapping NPRM believes it would not be a heavy burden to map from an NDC code to a CVX code because a mapping from NDC codes to CVX codes is publicly available AIRA believes mapping NDC to CVX may, in fact, be a more challenging effort in a dynamic environment. Given that new NDCs can be created at the discretion of vaccine manufacturers, it may be more challenging to be timely in maintaining a complex mapping table that can then be leveraged by all EHRs (and their providers) as well as IIS. 27 ONC Poll #17:

28 ONC CEHRT Rule Common Clinical Data Set NPRM typo incorrectly linking Transmission to IIS with C-CDA Release 2.0 AIRA simply points out the typo for correction 28 ONC Poll #18:

29 ONC CEHRT Rule Future Certification Criteria NPRM states: We believe this proposal best addresses the full range of health IT that has and might be certified to adopted certification criteria now and in the future AIRA response: While the Meaningful Use incentive program will conclude with Stage 3 (per the CMS rule), it s not entirely clear if the standards named in certification rule will be updated in future versions. Please clarify if the EHR certification program will continue to evolve in the future. 29 ONC Poll #19:

30 ONC CEHRT Rule MVX Codes NPRM states: The MVX table includes both active and inactive vaccines available in the U.S. AIRA response: AIRA wishes to clarify that the MVX code set isn t a table of vaccines, but rather vaccine manufacturers 30 ONC Poll #20:

31 CMS Mods to MU Summary This rule attempts to streamline requirements for stages 1, 2, and 3 AIRA is seeking clarification on the summary section is it is unclear which parts of the NPRM will actually be retroactive to 2015 and which will not 31 CMS Mods Poll #21:

32 CMS Mods to MU IIS Reporting AIRA is seeking clarification as the Modifications rule appears to escalate the timetable for all Stage 3 Public Health readiness. For IIS, this would mean bidirectional exchange would be accelerated into this Modification Rule. AIRA is supportive of bidirectional in Stage 3, but not as part of the Modification Rule directed at the timeline 32 CMS Mods Poll #22:

33 Open Conversation on Comments Needing Further Discussion 33

34 Next Steps AIRA and representatives from the SISC will continue to fine tune comments, with the goal of sharing with AIRA membership by May 18 for integration into members organizations comments Final comments will also be shared and discussed with partner organizations 34

35 Thank You! Please Contact Us with Questions or Comments Mary Beth Kurilo Eric Larson