Meaningful Use Qualification Plan Overview Certified EHR technology used in a meaningful way is one piece of a broader Health Information Technology infrastructure intended to reform the health care system and improve health care quality, efficiency, and patient safety. Under the HITECH Act, the Medicare EHR incentive programs provide incentive payments up to $44,000 over five years to eligible professionals 1 (EPs) that are meaningful users of certified EHRs. The Medicaid EHR incentive program provides incentive payments up to $63,750 over six years to eligible professionals 2 for efforts to adopt, implement or upgrade certified EHR technology or for meaningful use in the first year and for meaningful use for up to another five years. CMS proposed three stages of criteria over the initial years of the program given the on-going advancement in EHR technology and standards, as well as change in quality measurement and other healthcare-related reporting. The focus of Meaningful Use Stage 1 is on the capture of health information in coded format and: The use of it to track key clinical conditions; The communication of coded health information for care coordination purposes; and Initial reporting of clinical quality measures and public health information. Table 1: The Meaningful Use Timeline for the Medicare Incentives and Penalties Meaningful 2011 2012 2013 2014 2015 2016 2017 Total EHR User 2011 $18,000 $12,000 $8,000 $4,000 $2,000 $44,000 2012 $18,000 $12,000 $8,000 $4,000 $2,000 $44,000 2013 $15,000 $12,000 $8,000 $4,000 $39,000 2014 $12,000 $8,000 $4,000 $24,000 2015-1% -2% -3% 1 Eligible professionals for the Medicare Program are defined as physicians as defined in the Social Security Act and include MDs, DOs, dentists, optometrists, chiropractors and podiatrists 2 Eligible professionals with 30%+ Medicaid patient volume will qualify for the Medicaid program, EP is expanded to also include certified Nurse Mid-Wife, Nurse Practitioner; PA practicing in an FQHC or RHC that is led by a PA; pediatrician with at least 20% Medicaid patient volume. Kareo EHR Meaningful Use Qualification Plan February 2013 1
The incentive is calculated as 75% of the provider s Medicare Part B allowed charges based on claims submitted to Medicare during the incentive payment year up to the maximum shown in Table 1. The final Medicare incentive payment will be earned in 2016, but starting as early as 2015, if the eligible professional does not demonstrate meaningful use of a certified EHR, Medicare reimbursements will be reduced by one percent (1%). Table 2: The Meaningful Use Timeline for the Medicaid Incentives 30% Provider 20% Pediatrician Year 1 $21,250 $14,167 Year 2 $8,500 $5,667 Year 3 $8,500 $5,667 Year 4 $8,500 $5,667 Year 5 $8,500 $5,666 Year 6 (up to 2021) $8,500 $5,666 TOTAL $63,750 $42,500 The full Medicaid incentive payments can be realized over a six year period calculated as 85% of EHR net average allowable cost not exceeding $25,000 in the first year, followed by 85% of annual costs not exceeding $10,000 over the next five years shown in table 2 above. EPs must show efforts to adopt, implement or upgrade certified EHR technology in the first year and for meaningful use for up to another five years. The final Medicaid incentive payment will be earned in 2021. Use Health Information Technology to Transform Care The focus of the HITECH Act is to leverage the power of HIT to improve efficiency, reduce costs and ultimately, transform the delivery of care in the United States. The focus is presented through five health outcomes policy priorities with associated care goals as displayed in Table 3. Table 3: Health Outcomes and Care Goals Health outcomes policy priority Improving quality, safety, efficiency, and reducing health disparities. Care goals Provide access to comprehensive patient health data for patient s health care team. Use evidence-based order sets and CPOE. Apply clinical decision support at the point of care. Generate lists of patients who need care and use them to reach out to patients. Report information for quality improvement and public reporting. Kareo EHR Meaningful Use Qualification Plan February 2013 2
Health outcomes policy priority Engage patients and families in their health care. Improve care coordination. Improve population and public health. Ensure adequate privacy and security protections for personal health information. Care goals Provide patients and families with timely access to data, knowledge, and tools to make informed decisions and to manage their health. Exchange meaningful clinical information among professional health care team. Communicate with public health agencies. Ensure privacy and security protections for confidential information through operating policies, procedures, and technologies and compliance with applicable law. Provide transparency of data sharing to patient. The Care Goals have defined objectives with specific measures that must be achieved to demonstrate meaningful use. Each EP must meet all 15 required Core objectives (Table 4). In addition to the 15 required Core objectives, each eligible professional must select between two population health-focused Menu set objectives (Table 5) plus an additional choice of four of eight optional Menu set of objectives (Table 6) for a total of five Menu objectives. The Path to Meaningful Use using Kareo EHR Kareo EHR is a certified 3 solution and includes the functionality providers need to fulfill the stage 1 Meaningful Use requirements necessary to achieve government incentives. With Kareo EHR capabilities, your practice can be on its way to achieving MU and its associated incentives in 2012 and beyond. What must you do to qualify? Tables 4 through 6 specify each of the objectives and the required measure for each objective. The last column includes implications for staff and practice workflow as well as high-level guidance on how Kareo EHR can support the data collection for each objective. A single eligible professional in a group practice can qualify even if all eligible professionals in the group do not qualify. 3 Kareo EHR v2 is 2011/2012 compliant and has been certified as a Complete EHR by Drummond Group Inc., an ONC-ATCB, in accordance with the applicable certification criteria adopted by the Secretary of Health and Human Services. This certification does not represent an endorsement by the U.S. Department of Health and Human Services or guarantee the receipt of incentive payments. The ONC certification number is 02022012-1326-8 and was granted on February 2, 2012. The clinical quality measures to which Kareo EHR v2 has been certified include: NQF0013, NQF0018, NQF0024, NQF0028, NQF0038, NQF0041, NQF0043, NQF0061, NQF0421. The additional software that Kareo EHR v2 relied upon to demonstrate compliance includes: AHRQ epss, LabSoft, Healthwise, OpenSSL, pophealth. Kareo EHR Meaningful Use Qualification Plan February 2013 3
Table 4: The Required Core Set of Objectives (all 15 are required) # Objective Measure How will you meet this requirement using the Kareo EHR? 1 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. More than 30% of unique patients with at least one medication in their medication list seen by the EP have at least one medication order entered using CPOE collecting and entering all patient medications. To count for this measure, there must be at least one medication on the med list. Medication orders are entered using the eprescribing functionality during a patient encounter or by retrieving the patient s chart and accessing the Medications Tab and selecting the Prescribe button. 2 Implement drugdrug and drugallergy interaction checks The EP has enabled this functionality for the entire EHR reporting period Detected alerts will appear when a medication is added to the medication list or at the time of prescribing. A Drug-Drug Interaction Alert appears if the EHR identifies the potential for significant drug-drug interactions. A Drug- Allergy Interaction Alert appears when the EHR identifies the potential for the patient to have a significant allergic reaction to the drug being prescribed based on the patient s allergy profile. 3 Maintain an up-todate problem list of current and active diagnoses More than 80% of all 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 collecting and entering all patient problems. Problems are entered during a patient encounter or by retrieving the patient s chart and accessing the Problems Tab and selecting the + Problem button. If the patient does not have any known problems, select the No Known Problems check box. Kareo EHR Meaningful Use Qualification Plan February 2013 4
# Objective Measure How will you meet this requirement using the Kareo EHR? 4 Generate and transmit permissible prescriptions electronically (erx) More than 40% of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technology Only those providers with prescribing privileges will be able to generate electronic prescriptions. Electronic prescriptions are entered using the eprescribing functionality during a patient encounter or by retrieving the patient s chart and accessing the Medications Tab and selecting the Prescribe button. Prescribers must transmit the prescription to the patient s preferred pharmacy for it to count in this measure. 5 Maintain active medication list More than 80% of all 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 collecting and entering all patient medications. Medications are entered during a patient encounter or by retrieving the patient s chart and accessing the Medications Tab and selecting the Add to Med List button. If the patient is not taking any medications, select the No Known Medications check box. 6 Maintain active medication allergy list More than 80% of all 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 collecting and entering all patient medication allergies. Allergies are entered during a patient encounter or by retrieving the patient s chart and accessing the Allergies Tab and selecting the + Allergies button. If the patient does not have any medication allergies, select the No Known Medication Allergies check box. Kareo EHR Meaningful Use Qualification Plan February 2013 5
# Objective Measure How will you meet this requirement using the Kareo EHR? 7 Record demographics -preferred language -gender -race -ethnicity -date of birth More than 50% of all unique patients seen by the EP have demographics recorded as structured data collecting and validating patient demographics. Each of the required demographic fields must be entered for the patient to be counted in this measure. A declined status is valid and will be counted. Demographic information is entered by adding a new patient or updating an existing patient s chart through the Demographics Tab. 8 Record and chart changes in vital signs: -height -weight -blood pressure -calculate and display BMI -plot and display growth charts for children 2-20 years, including BMI 9 Record smoking status for patients 13 years old or older For more than 50% of all unique patients age 2 and over seen by the EP, height, weight and blood pressure are recorded as structured data More than 50% of all unique patients 13 years old or older seen by the EP have smoking status recorded In the final rule, smoking status must include: current every day smoker; current some day smoker; former smoker; never smoker; smoker, current status unknown; and unknown if ever smoked. recording and charting all required vital signs. Growth charts plot and display height and weight for children age 2 through 20 years. A declined status for height and weight is valid and will be counted. Vitals are entered during a patient encounter or by retrieving the patient s chart and accessing the Vitals Tab and selecting the + Vitals button. capturing and recording smoking status. Smoking status is entered during a patient encounter or by retrieving the patient s chart and accessing the History tab and selecting the Social History link. Kareo EHR Meaningful Use Qualification Plan February 2013 6
# Objective Measure How will you meet this requirement using the Kareo EHR? 10 Report ambulatory clinical quality measures to CMS or the States (See Tables 8, 9 and 10 for clinical quality measures.) For 2011, provide aggregate numerator, denominator, and exclusions through attestation. For 2012, electronically submit the clinical quality measures. Physicians must report on six total measures: three core measures (or alternate core measures where necessary) and three additional measures. However, according to CMS, providers are not responsible for determining the status of CQMs that their certified EHR does not calculate. Physicians and staff should review the final quality measures and establish processes and procedures to ensure compliance. Providers and staff should complete patient information in the FlowSheet Tab for patients to be captured for the CQM measures. The legislation requires that EHR technology be certified to the 6 core CQMs (3 core and 3 alternate core CQMs found in Tables 8 and 9) and at least 3 CQMs from the additional set found in Table 10. Kareo EHR certified with the following CQMs: NQF 0024, NQF 0038, NQF 0041, NQF 0013, NQF 0028 (a&b), NQF 0421, NQF 0043, NQF 0061 and NQF 0018. Access to the CQM Dashboard and Report is found on the Reports Tab. 11 Implement one clinical decision support (CDS) rule relevant to specialty or high clinical priority along with the ability to track compliance with the rule Implement one clinical decision support rule In the final rule, CDS is described as HIT functionality that builds upon the foundation of an EHR to provide those involved in care processes with general and person-specific information, intelligently filtered and organized, at appropriate times, to enhance health and health care. CDS functionality is available through seamless integration with the Electronic Preventive Services Selector (epss) offered by the Department of Health & Human Services Agency for Healthcare Research and Quality (AHRQ). epss is an interactive application that is based on the current evidence-based recommendations of the U.S. Preventive Services Task Force (USPSTF.) Kareo EHR automatically passes specific patient characteristics such as age, sex, and selected behavioral risk factors to the epss tool and recommendations are presented on the Patient Face Sheet. Kareo EHR Meaningful Use Qualification Plan February 2013 7
# Objective Measure How will you meet this requirement using the Kareo EHR? 12 Provide patients with an electronic copy of their health information (including diagnostic lab results, problem list, medication lists, medication allergies), upon request More than 50% of all patients of the EP who request an electronic copy of their health information are provided it within 3 business days For the purposes of meaningful use criteria, a business day is defined as Monday through Friday excluding Federal or State holidays on which the EP or their respective administrative staffs are unavailable. capturing and recording all required patient health information. An electronic version of a patient s health information can be made available to patients through the patient portal. Practices can choose the patients they will invite to have access to the portal. 13 Provide clinical summaries (including diagnostic lab results, problem list, medication lists, medication allergies), for patients for each office visit Clinical summaries provided to patients for more than 50% of all office visits within 3 business days capturing and recording all required patient information. Clinical summaries with the required personal health information can be made available to patients through the patient portal. Practices can choose the patients they will invite to have access to the portal. 14 Capability to exchange key clinical information (for example, problem list, medication list, medication allergies, diagnostic test results), among providers of care and patient authorized entities electronically Performed at least one test of certified EHR technology s capacity to electronically exchange key clinical information capturing and recording all required patient information. The ability to import and export a patient summary in the required format enables you to electronically exchange patient health information with other providers of care and patient authorized entities. The patient summary includes a list of problems, medications, allergies and electronically ordered lab results for a specific patient. Kareo EHR Meaningful Use Qualification Plan February 2013 8
# Objective Measure How will you meet this requirement using the Kareo EHR? 15 Protect electronic health information created or maintained by the certified EHR technology through the implementation of appropriate technical capabilities Conduct or review a security risk analysis and correct identified security deficiencies as part of risk management process Identify a compliance or security officer to conduct or review a security risk analysis per 45 CFR 164.308 (a)(1). Implement security updates as necessary and correct identified security deficiencies. Table 5: One of the following two MENU set of objectives are required: # Objective Measure How will you meet this requirement using the Kareo EHR? 1 Capability to submit electronic data to immunization registries or Immunization Information Systems and actual submission in accordance with applicable law and practice 2 Capability to submit electronic syndromic surveillance data to public health agencies and actual submission in accordance with applicable 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 have the capacity to receive the information electronically) Performed at least one test of certified EHR technology s capacity to provide electronic syndromic surveillance data to public health agencies and followup submission if the test is successful (unless none of the public health agencies to which an EP submits such information have the Physicians and staff should use the Immunizations Tab to enter and track detailed information about the immunizations administered both inside and outside your practice. The ability to export immunization data is enabled through the Exchange button. This function creates a file that can be uploaded to a state immunization registry. Practices will need to check with their state agency to determine if they have the capacity to receive the information electronically. The ability to export electronic syndromic data is enabled through the Exchange button. This function creates a file that can be uploaded to a local public health agency. Practices will need to check with their local agency to determine if they have the capacity to receive the information electronically. Kareo EHR Meaningful Use Qualification Plan February 2013 9
law and practice capacity to receive the information electronically) Table 6: MENU set of objectives (select 4 of 8) # Objective Measure How will you meet this requirement using the Kareo EHR? 3 Implement drugformulary checks The EP has enabled this functionality and has access to at least one internal or external drug formulary for the entire EHR reporting period A formulary check will be performed and onformulary medication alternatives will be presented at the point of prescribing for patients with Medicare Part D prescription benefits. 4 Incorporate clinical lab test results into certified EHR technology as structured data 5 Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research or outreach 6 Send reminders to patients per patient preference for preventive/follow up care More than 40% of all clinical lab tests results ordered by the EP during the EHR reporting period whose results are either in a positive/negative or numerical format are incorporated in certified EHR technology as structured data Generate at least one report listing patients of the EP with a specific condition The final rule defines specific conditions as those conditions listed in the active patient problem list. More than 20% of all unique patients 65 years or older or 5 years old or younger were sent an appropriate reminder during the EHR reporting period Providers should request to implement an electronic lab interface in the Admin module. Electronic results received by the EHR will be stored as structured data and counted in this measurement. capturing and recording all active patient problems. The ability to generate a patient list by condition is found on the Reports Tab. documenting the patient s preferred communication method as part of the patient s demographic information. Demographic information is entered by adding a new patient or updating an existing patient s chart through the Demographics Tab. Kareo EHR Meaningful Use Qualification Plan February 2013 10
# Objective Measure How will you meet this requirement using the Kareo EHR? The ability to generate a list of patient reminders is found on the Reports Tab. Note: Providers and staff will need to create a manual procedure for tracking how many reminders were actually sent. This task is typically handled through phone calls, letters or electronic communications with patients outside of the use of the EHR. Providers that choose to report the measure for this menu requirement will need to manually enter the number of reminders sent to patients in the Functional Measures report. 7 Provide patients with timely electronic access to their health information (including lab results, problem list, medication lists, medication allergies) within four business days of the information being available to the EP 8 Use certified EHR technology to identify patientspecific education resources and provide those resources to the patient if appropriate 9 The EP who receives a patient from another setting of care or More than 10% of all unique patients seen by the EP are provided timely (available to the patient within four business days of being updated in the certified EHR technology) electronic access to their health information subject to the EP s discretion to withhold certain information More than 10% of all unique patients seen by the EP are provided patient-specific education resources The EP performs medication reconciliation for more than 50% of transitions of care in which the patient is Providers and staff will choose patients to invite to have access to the Patient Portal where they will have secure online access to their personal health information. Once authenticated to the portal, patients can view their recent vital signs, see a list of current conditions, allergies and medications and access results from lab tests electronically ordered by your practice. Patient Education content is available through seamless integration with Healthwise, a leading provider of health content and patient education solutions. Providers and staff can access relevant patient education materials based on a patient s age, gender and active ICD-9 codes and then print the desired materials for patients. Providers will meet this requirement with a 2-step process: 1. The Note for a patient transferred into the Kareo EHR Meaningful Use Qualification Plan February 2013 11
# Objective Measure How will you meet this requirement using the Kareo EHR? provider of care or believes an encounter is relevant should perform medication reconciliation 10 The EP who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care should provide summary of care record information (including diagnostic lab results, problem list, medication lists, medication allergies) for each transition of care or referral transitioned into the care of the EP The final rule defines medication reconciliation as the process of identifying the most accurate list of all medications that the patient is taking, including name, dosage, frequency and route, by comparing the medical record to an external list of medications obtained from a patient, hospital or other provider. A paper based process will count toward this 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 The final rule defines transition of care as the movement of a patient from one setting of care (hospital, ambulatory primary care practice, ambulatory specialty care practice, longterm care, home health, rehabilitation facility) to another. provider s care should be marked as Transition of Care - Receiving in the patient encounter note. 2. In the same encounter, providers must select Medication Reconciliation Performed on the Medications Tab. Providers will meet this requirement with a 2-step process: 1. The Note for a patient that is being transitioned to another setting or provider of care, should be marked as Transition of Care - Transferring in the patient encounter note. 2. In the same encounter, providers must create the summary of care record by selecting Export Patient Summary on the exchange button within the patient encounter note. Kareo EHR Meaningful Use Qualification Plan February 2013 12
Exclusions Some MU objectives are not applicable to every provider s clinical practice and would not have any eligible patients or actions for the measure denominator. EPs will be allowed to be excluded from those requirements. Acceptable exclusions are listed in Table 7. Table 7: Meaningful Use Exclusions Measure Incorporate discrete clinical lab results into EHR Send reminders to patients per patient preference Provide patient with electronic access to health information Perform medication reconciliation on transition Provide summary care record on transition Submit data to immunization registries Exclusions Any EP who orders no lab tests whose results are either in positive/negative or numeric format during the EHR reporting period Any EP who has no patients 65 years old or older or 5 years old or younger with records maintained using certified EHR technology Any EP that neither orders nor creates any of the information listed at 45 CFR 170.304(g) in the July 13, 2010 Final Rule during the EHR reporting period 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 Any EP who administers no immunizations during the EHR reporting period or where no immunization registry has the capacity to receive the information electronically Measure Submit surveillance data Exclusions Any 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 Clinical Quality Measures Each eligible professional must report on the Core (Table 8) or Alternate Core (Table 9) quality measures as well as three additional clinical quality measures (Table 10). If the quality measures are outside the scope of practice, the eligible professional must still report the measure with a denominator of zero. Table 8: Core Quality Measures Measure number Quality Measure Title Staff support NQF 0013 Blood pressure measurement taking blood pressure. NQF 0421 PQRI 128 Adult weight screening and follow up capturing the patient s weight and based on protocol make a referral to weight management program. Kareo EHR Meaningful Use Qualification Plan February 2013 13
Measure number Quality Measure Title Staff support NQF 0028 Preventive Care and Screening: Tobacco Use Assessment / Tobacco Cessation Intervention capturing smoking status and making a referral to a smoking cessation program. Table 9: Alternate Core Quality Measures Measure number Quality Measure Title Staff support NQF 0024 NQF 0041 PQRI 110 Weight Assessment and Counseling for Children and Adolescents Preventive Care and Screening: Influenza Immunization for Patients 50 years and older capturing the patient s weight and based on protocol make a referral to weight management program. Providers should develop rules to prompt staff for preventive care screening. NQF 0038 Childhood Immunization Providers should develop rules to prompt staff for immunization screening. Table 10: Kareo EHR Certified Clinical Quality Measures (each Eligible Professional must report on all three measures) Measure Developer Recommended Quality Measure Title 0018 NCQA Controlling High Blood Pressure 0043 NCQA Pneumonia Vaccination Status for Older Adults 0061 NCQA Diabetes: Blood Pressure Management For detailed information, reference the electronic specifications for the measures on the CMS website. Registration and Reporting Provider registration and the attestation reporting process for both the Medicare and Medicaid programs occurs on the CMS website using the Medicare & Medicaid EHR Incentive Program Registration & Attestation System. In the first meaningful use reporting year, Medicare providers will need to prove meaningful use of required measures over any continuous 90-day period. In the subsequent years, the reporting period will be based on the full calendar year. Medicare providers will need to begin their 90-day reporting period no later than October 1, 2012 to be eligible for the maximum incentive payment. Incentives will be paid to providers in single, consolidated annual payments. Kareo EHR Meaningful Use Qualification Plan February 2013 14
For Medicaid providers, providers only need to report that they are adopting, implementing, or upgrading for their first payment year. However, in their second payment year or first year of demonstrating meaningful use they have to prove meaningful use of required measures over any continuous 90-day period. It is in the third payment year or second year of demonstrating meaningful use that Medicaid EPs must report for a 12-month EHR period. Additional Resources For more information on the program and access to all of the CMS developed resources, visit the Official Web Site for the Medicare and Medicaid EHR Incentive Programs. Kareo EHR Meaningful Use Qualification Plan February 2013 15