EHR Incentive Program Focus on Stage One Meaningful Use Kim Davis-Allen, Outreach Coordinator Kim.davis@ahca.myflorida.com October 16, 2014
Checklist Participation Explanation Program Updates Stage One Measures Certification Flexibility Rule Florida s Health Information Exchange
Understanding Participation Program Year Program Year Payment Year Payment Year January 1 st December 31 st Year in which you met program requirements Program Years through 2021 Simple count For Medicaid: 1 6 Payment Year One: $21,250 Payment Years Two Six: $8,500 For Medicare: 1-5 Payments vary based on when participation began and program year participation
Meaningful Use Stages Adopt, Implement, Upgrade 2014 Stage One 2014 Stage Two Stage Three Not actually using system Must be more than a planned implementation 13 core measures 5 out of 9 menu measures 9 out of 64 Clinical Quality Measures (CQMs) 17 cores measures 3 out of 6 menu measures 9 out of 64 CQMs Begins January 1, 2017 for Eligible Professionals (EPs) **Providers are to complete a minimum of two reporting periods per MU stage before progressing.
Program Updates Program Year 2013 applications completed Processing of Program Year 2014 applications: must have proof of 2014 certified technology Audits have begun: submit requested documentation within timeframes New material on website CMS reopened the Hardship Exemption Application Process for providers who have been unable to: Fully implement 2014 Edition CEHRT due to delays in 2014 Edition CEHRT availability Attest by October 1, 2014 using the flexibility options provided in the CMS 2014 CEHRT Flexibility Rule.
Meaningful Use Documentation Meaningful use report from your EHR system Screenshots Dashboard Summary report Documents must contain numeric measures Core measures Menu measures Clinical Quality Measures (CQMs) If reporting from multiple systems must have documentation from the systems Add numerators/denominators for application Additional Documentation (AD) Form Sections A and B not required if only practicing at one location or using same system at different locations Section C is based on location
2014 Eligible Professional (EP) Stage One Core Measures www.cms.gov/regulations-and-guidance/legislation/ehrincentiveprograms/meaningful_use.html
EP 2014 Stage One Meaningful Use Utilize 2014 Certified Technology Meet both General Requirements Attest to 13 Core Measures Attest to five out of nine Menu Measures (including one Public Health Measure) Report on nine Clinical Quality Measures
2014 Stage One General Requirements 50% of encounters must be at locations equipped with certified EHR technology. 80% of unique patients seen at locations with certified EHR technology must have their records in a certified EHR system.
2014 Stage One Core Measures 1. Use computerized order entry (CPOE) for medication orders. 2. Implement drug-drug, drug-allergy checks. 3. Generate and transmit permissible prescriptions electronically. 4. Record demographics. 5. Maintain an up-to-date problem list of current and active diagnoses. 6. Maintain active medication list.
2014 Stage One Core Measures (cont.) 7. Maintain active medication allergy list. 8. Record and chart changes in vital signs. 9. Record smoking status for patients 13 years old or older. 10. Implement one clinical decision support rule. 11. Timely electronic access (view, download, and transmit). 12. Provide clinical summaries to patients for individual office visits. 13. Protect electronic health information (privacy & security).
Computerized Order Entry (CPOE) Objective Use CPOE for medication orders directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local, and professional guidelines. Measure More than 30% of unique patients OR total medication orders with at least one medication in their medication list seen by the EP have at least one medication order entered using CPOE. Exclusion An EP who writes fewer than 100 prescriptions during the EHR reporting period. Tips Internal to the practice. If excluding from CPOE can also exclude from e-prescribing. The order must be entered by someone who could exercise clinical judgment in the case that the entry generates any alerts about possible interactions or other clinical decision support aides. This necessitates that the CPOE occurs when the order first becomes part of the patient s medical record and before any action can be taken on the order. Common question: Is the physician the only person who can enter information in the EHR in order to qualify for the EHR Incentive Programs? CMS FAQ New ID #2771, Old #10071
Drug-Drug; Drug Allergy Objective Implement drug-drug and drug-allergy interaction checks. Measure The EP has enabled this functionality for the entire EHR reporting period. Exclusion None Tips Screenshots throughout the EHR reporting period. Cannot be used to satisfy the Clinical Decision Support measure.
Problem List Objective Maintain an up-to-date problem list of current and active diagnoses. Measure More than 80% of unique patients seen by the EP have at least one entry or an indication that no problems are known for the patient recorded as structured data. Exclusion None Tips For patients with no current or active diagnoses, an entry must still be made to the problem list indicating that no problems are known. An EP is may not be required to update the list at each contact with the patient. The EP can use his or her clinical judgment to decide when additional updating is required.
E-Prescribing Objective Generate and transmit permissible prescriptions electronically (e-prescribing). Measure More than 40% of permissible prescriptions written by the EP are transmitted electronically using certified EHR technology. Exclusion An EP who writes fewer than 100 prescriptions during the EHR reporting period. An EP that does not have a pharmacy within their organization and there are no pharmacies that accept electronic prescriptions within 10 miles of the EP s practice at the start of his/her EHR reporting period. Tips Only applies to permissible prescriptions. Prescription is defined as the authorization by an EP to a pharmacist to dispense a drug that the pharmacist would not dispense to the patient without such authorization. Instances where patients specifically request a paper prescription may not be excluded from the denominator of this measure.
Active Medication List Objective Maintain active medication list. Measure More than 80% of unique patients seen by the EP have at least one entry (or an indication that the patient is not currently prescribed any medication) recorded as structured data. Exclusion None Tips Screenshots throughout the EHR reporting period. For patients with no active medications, an entry must still be made to the active medication list indicating that there are no active medications. An EP is may not be required to update this list at each contact with the patient. The EP can use his or her clinical judgment to decide when additional updating is required.
Active Medication Allergy List Objective Maintain active medication allergy list. Measure More than 80% of unique patients seen by the EP have at least one entry (or an indication that the patient has no known medication allergies) recorded as structured data. Exclusion None Tips For patients with no active medication allergies, an entry must still be made to the active medication allergy list indicating that there are no active medication allergies. An EP may not be required to update this list at each contact with the patient. The EP can use his or her clinical judgment to decide when additional updating is required.
Demographics Objective Record the following demographics: preferred language, gender, race, ethnicity, date of birth. Measure More than 50% of unique patients seen by the EP have demographics recorded as structured data. Exclusion None Tips If a patient declines to provide part of the demographic information, or if capturing a patient s ethnicity or race is prohibited by state law, such a notation entered as structured data would count as an entry for purposes of meeting the measure.
Vital Signs Objective Record and chart changes in the following vital signs: height, weight, blood pressure, calculate and display body mass index (BMI), and plot and display growth charts for children 2-20 years, including BMI. Measure More than 50 percent of unique patients seen by the EP during the EHR reporting period have blood pressure (for patients age 3 and over only) and height and weight (for all ages) recorded as structured data. Exclusion Sees no patients 3 years or older is excluded from recording blood pressure. Believes that blood pressure, height, and weight have no relevance to their practice. Believes that height and weight are relevant, but blood pressure is not, is excluded from recording blood pressure. Believes that blood pressure is relevant to their scope of practice, but height and weight are not, is excluded from recording height and weight. Tips None
Smoking Status Objective Record smoking status for patients 13 years old and older. Measure More than 50% of unique patients 13 years or older seen by the EP have smoking status recorded as structured data. Exclusion An EP who sees no patients 13 years or older. Tips This is a check of the medical record for patients 13 years old or older. If this information is already in the medical record available through certified EHR technology, an inquiry does not need to be made time a provider sees a patient 13 years old or older. The frequency of updating this information is left to the provider and guidance is provided already from several sources in the medical community.
Clinical Decision Support (CDS) 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. Exclusion None Tips Defined as HIT functionality that builds upon the foundation of an EHR to provide persons involved in care processes with general and person-specific information, intelligently filtered and organized, at appropriate times, to enhance health and health care. Screenshots throughout the EHR reporting period.
Timely Electronic Access Objective Provide patients the ability to view online, download, and transmit their health information (with 4 business days of the information being available to the EP). Measure More than 50% of unique patients seen by the EP during the EHR reporting period are provided timely access (within 4 business days after the information is available to the EP) online access to their health information subject to the EP s discretion to withhold certain information. Exclusion Any EP who neither orders nor creates any of the information listed for inclusion, except for "Patient name" and "Provider's name and office contact information. Tips Not required that patient actually access BUT must have information necessary to access.
Clinical Summaries Objective Provide clinical summaries for patients for each office visit. Measure Clinical summaries provided to patients for more than 50% of office visits within 3 business days. Exclusion An EP who has no office visits during the EHR reporting period. Tips An after-visit summary that provides a patient with relevant and actionable information and instructions. Minimal data elements required. If an EP believes that substantial harm may arise from the disclosure of particular information, an EP may choose to withhold that particular information from the clinical summary. Providers should determine how their system captures and tracks provision of the clinical summary for reporting purposes. For example, some systems only count printing the summary if it occurs after the visit is completed and signed off by the provider in the EHR. Stamp the copy given to the patient with patient copy. If found later, then it is evident that the content was under the control of the patient.
Protect Electronic Health Information 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 164.308(a)(1) and implement security updates as necessary and correct identified security deficiencies as part of its risk management process. Exclusion None Tips This analysis is more than a checklist. A checklist can be used as a starting point, but the analysis is meant to be a complete review of the components specified in the federal regulation, including policies and procedures, and responsible parties. Staff training should be done to review the analysis once the analysis is completed. Risks and deficiencies must be identified and a mitigation plan in place; including who will complete the task, how will you complete the task, and when will you complete the task. The analysis must be reviewed, updated, and documented each year as part of your EHR program attestation.
2014 Menu Exclusions Providers - Regardless of Stage -------------------- No longer be permitted to count an exclusion toward the minimum required if there are other objectives that can be met. -------------------- Can claim exclusions for an objective if qualify for remaining menu objectives ----------------------- If you exclude from any menu measure, MAPIR will require you to answer the remaining menu measures
2014 Stage One Menu Measures 1. Implement drug-formulary checks. 2. Incorporate clinical lab-test results into certified EHR as structured data. 3. Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research, or outreach. 4. Send reminders to patients per patient preference for preventive/follow-up care. 5. Use certified EHR to identify patient-specific education resources and provide to patient if appropriate.
2014 Stage One Menu Measures (cont) 6. Perform medication reconciliation as relevant. 7. Provide summary care record for transitions in care or referrals. 8. Capability to submit electronic data to immunization registries and actual submission. 9. Capability to provide electronic syndromic surveillance data to public health agencies and actual transmission.
Drug Formulary Checks Objective Implement drug formulary checks. Measure The EP has enabled this functionality and has access to at least one internal or external formulary for the entire EHR reporting period. Exclusion An EP who writes fewer than 100 prescriptions during the EHR reporting period. Tips At a minimum an EP must have at least one formulary that can be queried. This may be an internally developed formulary or an external formulary. The formularies should be relevant for patient care during the prescribing process.
Incorporate Lab Results Objective Incorporate clinical lab test results into EHR as structured data. Measure More than 40% of clinical lab test results ordered by the EP during the EHR reporting period who results are either in a positive/negative or numerical format are incorporated in certified EHR technology as structured data. Exclusion An EP who orders no lab tests whose results are either in a positive/negative or numerical format during the EHR reporting period. Tips Providers may limit the denominator to only those lab tests that were ordered during the EHR reporting period and for which results were received during the same EHR reporting period. CMS FAQ New ID #3263, Old ID #10642 Results can be electronically or manually entered.
Generate Patient Lists Objective Generate lists of patients by specific conditions to use for quality improvements, reduction of disparities, research, or outreach. Measure Generate at least one report listing patients of the EP with a specific condition. Exclusion None Tips This objective does not dictate the report(s) which must be generated. An EP is best positioned to determine which reports are most useful to their care efforts. The report generated could cover individual patients whose records are maintained using certified EHR technology or a subset of those patients at the discretion of the EP. Run the list to maintain as part of the documentation file. A new list must be generated prior to the end of the reporting period.
Patient Reminders Objective Send reminders to patients per patient preference for preventive/follow-up care. Measure More than 20% of patients 65 years old or older or 5 years old or younger were sent an appropriate reminder during the EHR reporting period. Exclusion An EP who has no patients 65 years old or older or 5 years old or younger with records maintained using certified EHR technology. Tips Can use an outside reminder system but must be captured within the EHR. Stage 2 significantly changes this measure.
Patient Education Objective Use certified EHR technology to identify patient-specific education resources and provide those resources to the patient if appropriate. Measure More than 10% of unique patients seen by the EP provided patient-specific education resources. Exclusion None Tips Patient-Specific Education Resources Resources identified through logic built into certified EHR technology which evaluates information about the patient and suggests education resources that would be of value to the patient. Education resources or materials do not have to be stored within or generated by the certified EHR. Providers should maintain supporting documentation (e.g. screen shot) showing the certified technology suggesting educational resources for a patient.
Medication Reconciliation Objective The EP who receives a patient from another setting of care or provider of care or believes an encounter is relevant should perform medication reconciliation. Measure The EP performs medication reconciliation for more than 50% of transitions of care in which the patient is transitioned into the care of the EP. Exclusion An EP who was not the recipient of any transitions of care during the EHR reporting period. Tips Transition of Care The movement of a patient from one setting of care (hospital, ambulatory primary care practice, ambulatory specialty care practice, long-term care, home health, rehabilitation facility) to another. The measure of this objective does not dictate what information must be included in medication reconciliation. Information included in the process of medication reconciliation is appropriately determined by the provider and patient.
Summary Care Record Objective The EP who transitions their patient to another setting of care of provider of care or refers their patient to another provider of care should provide a summary care record for each transition of care or referral. Measure The EP who transitions or refers their patient to another setting of care or provider of care provides a summary of care record for more than 50% of transitions of care and referrals. Exclusion An EP who neither transfers a patient to another setting nor refers a patient to another provider during the EHR reporting period. Tips Transition of Care The movement of a patient from one setting of care (hospital, ambulatory primary care practice, ambulatory specialty care practice, long-term care, home health, rehabilitation facility) to another. The EP can send an electronic or paper copy of the summary care record directly to the next provider or can provide it to the patient to deliver to the next provider, if the patient can reasonably expected to do so.
Immunization Registry Objective Capability to submit electronic data to immunization registries or immunization information systems and actual submission according to applicable law and practice. Measure Performed 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 (unless none of the immunization registries to which the EP submits such information has the capacity to receive the information electronically). Exclusion An EP who administers no immunizations during the EHR reporting period or where no immunization registry has the capacity to receive the information electronically. Tips http://flshotsusers.com/resources/meaningful-use-verification/ Full year reporting will probably not allow for an exclusion. Must have documentation form Florida Shots, including verification on ongoing submission. Shared physical setting only requires one test.
Syndromic Surveillance Objective Capability to submit electronic syndromic surveillance data to public health agencies and actual submission according to applicable law and practice. Measure 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 has the capacity to receive the information electronically). Exclusion An EP who does not collect any reportable syndromic information on their patients during the EHR reporting period or does not submit such information to any public health agency that has the capacity to receive the information electronically. Tips DOH only accepts syndromic surveillance from urgent care clinics and hospitals.
2014 Clinical Quality Measures (CQM) Regardless of Stage Eligible Professionals- 9 out of 64 Eligible Hospitals- 16 out of 29 Cover at least three of the National Quality Strategy Domains Core Sets for Adult and Children Choices driven by what vendor is offering No threshold that must be met CQM Reporting Dually eligible hospitals beyond 1 st year of Meaningful Use must electronically report CQM data. Medicaid only providers will report to the state through the on-line application
2014 Quality Domains Patient Safety (PS) Care Coordination (CC) Population and Public Health (PPH) Clinical Process and Effectiveness (CPE) Efficient Use of Healthcare Resources (EHR) Patient and Family Engagement (PFE)
EPs - Recommended Adult CQMs Controlling High Blood Pressure (CPE) Use of High-Risk Medications in the Elderly (PS) Tobacco Use: Screening and Cessation Intervention (PPH) Use of Imaging Studies for Low Back Pain (EHR) Screening for Clinical Depression & Follow-Up Plan (PPH) Documentation of Current Medications in the Medical Record (PS) Body Mass Index (BMI) Screening and Follow-Up (PPH) Closing the referral loop: receipt of specialist report (CC) Functional status assessment for complex chronic conditions (PFE)
EPs - Recommended Child CQMs Appropriate Testing for Children with Pharyngitis (EHR) Weight Assessment and Counseling for Nutrition and Physical Activity for Children and Adolescents (PPH) Chlamydia Screening for Women (PPH) Use of Appropriate Medications for Asthma (CPE) Childhood Immunization Status (PPH) Appropriate Treatment for Children with Upper Respiratory Infection (EHR) ADHD: Follow-Up Care for Children Prescribed Attention-Deficit/Hyperactivity Disorder (ADHD) Medication (CPE) Screening for Clinical Depression and Follow-Up (PPH) Children who have dental decay or cavities (CPE)
Progress to Stage Two ONLY After Two Reporting Periods of Stage One Eligible Professional 17 Core Measures 3 Menu Measures 9 CQMS Eligible Hospital 16 Core Measures 3 Menu Measures 16 CQMS
Preparing for Stage Two Many of the measure are what you are doing Know what is expected and incorporate now Focus on patient engagement Know Problem Areas
Certification Flexibility Rule Effective October 1, 2014
Program Year 2014 The rule grants flexibility to providers who are unable to fully implement 2014 Edition Certified Electronic Health Record Technology (CEHRT) for an EHR reporting period in 2014 due to delays in 2014 CEHRT availability. Implementation- a provider s ability to fully implement the functionality may be limited by the availability and timing of product installation, deployment of new processes and workflows, and employee training. Providers may now use EHRs that have been certified under the 2011 Edition, a combination of the 2011 and 2014 Editions, or the 2014 Edition for 2014 participation. Rule effective October 1, 2014
Attestation Options
Unable To Fully Implement Due To... Software development delays Missing or delayed software updates Being able to implement 2014 CEHRT for only part of the reporting period not the full reporting period Unable to train staff, test the updated system, or put new work flows in place because of delays associated with installation of 2014 CEHRT Unable to meet stage 2 summary of care measures due to recipient of transmittals impacted by 2014 CEHRT issues
NOT Allowable Reasons... Financial issues Inability to meet one or more measures Staff turnover and changes Provider waited too long to engage a vendor Refusal to purchase the requisite software updates Providers who fully implemented 2014 Edition CEHRT and can report in 2014.
Adopt, Implement, Upgrade in 2014 To qualify for an incentive payment under Medicaid for 2014 for AIU, a provider must adopt, implement, or upgrade to 2014 Edition CEHRT only. System use not required but cannot be a planned implementation e.g. will be installed in November.
Revised Stage 3 Timeline Stage 3: FY 2017 (October 2016 September 2017) for EHs and CAHs CY 2017 (January December) for EPs Two reporting periods per stage Medicaid does not require calendar quarter reporting
Additional Considerations Clinical Quality Measure (CQM) reporting will be tied to the reporting option chosen. For example, providers will not be allowed to attest to 2014 Stage 1 measures and 2013 CQMs. Additional attestation documents will be required documenting why a 2014 CEHRT could not be fully implemented. Changes to MAPIR allowing a provider to attest using a previous edition of CEHRT are expected to be completed Spring 2015. Certification Number entered will determine options Medicare Payment Adjustment Request due by November 30, 2014 Only for the reasons specified http://www.cms.gov/regulations-and-guidance/legislation/ehrincentiveprograms/paymentadj_hardship.html
What Does This Mean Providers are encouraged to talk to their vendor about their options in accessing 2013 Meaningful Use reports as this ability may no longer be available once you begin installing 2014 CEHRT. Providers must have 2014 CEHRT for Program Year 2015 If not your first MU reporting period then Program Year 2015 will require a full year reporting period The rule does not fully address what is allowed but it is very specific on what is not
Additional Contacts and Resources Website: www.ahca.myflorida.com/medicaid/ehr Phone: EHR Incentive Program Call Center: (855) 231-5472 Email: MedicaidHIT@AHCA.MyFlorida.com Kim.davis@ahca.myflorida.com Website: www.florida-hie.net Phone: Florida HIE Help Desk: 850-412-3752 Email: FLHII@ahca.myflorida.com http://www.cms.gov/regulations-and- Guidance/Legislation/EHRIncentivePrograms/Educa tionalmaterials.html
Upcoming Events Webinars October 30 th Understanding the Auditing Process November 13 th Focus on Stage Two Meaningful Use Jacksonville Provider Workshop November 6th Orlando Provider Workshop November 19 th www.ahca.myflorida.com/medicaidehr