Meaningful Use: It s Not Too Late For 2015! Jeffrey D. Lehrman, DPM, FACFAS, FASPS, FAPWH APMA Coding Committee Expert Panelist, Codingline.com Fellow, American Academy of Podiatric Practice Management John Guiliana, DPM, MS Managing Partner of Collaborative Practice Solutions Fellow, American Academy of Podiatric Practice Management James R. Christina, DPM
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On October 7 th, CMS released the Medicare and Medicaid EHR Program Final Rules for CY 2015 These changes were made to continue to try to bring all the government reporting programs in line with one another
Everyone is in Modified Stage 2 in 2015
Need to know if you were scheduled for Stage 1 or Stage 2 in 2015 under old guidelines
Everyone was scheduled for Stage 2 in 2015 unless 2014 was or 2015 is first year attesting
STAGE OF MEANINGFUL USE CRITERIA BYFIRSTYEAR First Year as a Meaningful User Stage of Meaningful Use 2015 2016 2017 2018 2011 Modified Stage2 Modified Stage2 Modified Stage2 OrStage3 Stage3 2012 Modified Stage2 Modified Stage2 Modified Stage2 OrStage3 Stage3 2013 Modified Stage2 Modified Stage2 Modified Stage2 OrStage3 Stage3 2014 Modified Stage2* Modified Stage2 Modified Stage2 OrStage3 Stage3 2015 Modified Stage2* Modified Stage2 Modified Stage2 OrStage3 Stage3 2016 -NA- Modified Stage2 Modified Stage2 OrStage3 Stage3
Final Rule Reporting Periods Reporting period for all providers in 2015 will be any 90 consecutive days. * Reporting period in 2016 (other than first time providers) will be the calendar year. Reporting period if attesting for the first time in 2016 will be 90 consecutive days.
Meaningful Use Stage 2 Attestation For an EHR reporting period in 2015, all Medicare providers must attest by February 29, 2016. Despite the change to a 90-day EHR reporting period in 2015, providers will not be able to attest to meaningful use for an EHR reporting period in 2015 prior to January 4, 2016.
Meaningful Use Stage 2 All EP are required to attest to a single set of objectives and measures There are 10 objectives, including one public health measure NO Menu Options
Meaningful Use Stage 2 Major Changes Patient Electronic Access: For 2015, instead of the 5 percent threshold, this measure requires that at least 1 patient seen by the EP during the EHR reporting period (or patient authorized representative) views, downloads, or transmits to a third party his or her health information during the EHR reporting period.
Meaningful Use Stage 2 Major Changes Secure Electronic Messaging: The 5 percent threshold has been changed to the capability for patients to send and receive a secure electronic message with the EP was fully enabled during the EHR reporting period (yes/no).
MODIFIED STAGE 2 MEASURES
1. Protect Electronic Health Information Conduct or review a security risk analysis in accordance with the requirements in 45 CFR 164.308(a)(1), including addressing the security (to include encryption) of data stored in Certified EHR Technology in accordancewith requirements in 45 CFR 164.312(a)(2)(iv) and 45 CFR 164.306(d)(3), and implement security updates as necessary and correct identified security deficiencies as part of the eligible provider (EP) risk management process.
Need. Documentation of: What they did What risks were identified What steps were taken to address these risks.you took steps
2. Clinical Decision Support 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. Alternate Objective and Measure (For those scheduled for Stage 1) Implement ONE clinical decision support rule. Enable and implement the functionality for drug-drug and drug-allergy interaction checks for the entire EHR reporting period.
Potential CQMs for Podiatrists Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention (Population and Public Health) Preventive Care and Screening: Influenza Immunization (Population and Public Health) Pneumonia Vaccination Status for Older Adults (Clinical Processes/Effectiveness) Diabetes: Eye Exam (Clinical Processes/Effectiveness) Diabetes: Foot Exam (Clinical Processes/Effectiveness) Diabetes: Hemoglobin A1c Poor Control (Clinical Processes/Effectiveness) Hemoglobin A1c Test for Pediatric Patients (Clinical Processes/Effectiveness) Diabetes: Urine Protein Screening (Clinical Processes/Effectiveness) Diabetes: Low Density Lipoprotein (LDL) Management (Clinical Processes/Effectiveness) Falls: Screening for Future Fall Risk (Patient Safety) Documentation of Current Medications in the Medical Record (Patient Safety) Closing the referral loop: receipt of specialist report (Care Coordination) Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up (Population and Public Health) Preventive Care and Screening: Screening for High Blood Pressure and Follow-Up Documented (Population and Public Health)
3. Computerized Physician Order Entry (CPOE) Eligible provider must meet all three: More than 60 percent of medication orders created by EP are recorded using computerized provider order entry. More than 30 percent of laboratory orders created by EP are recorded using computerized provider order entry. More than 30 percent of radiology orders created by EP are recorded using computerized provider order entry. Alternate Measure 1 (Stage 1): More than 30 percent of medication orders created by the EP are recorded using computerized provider order entry. Alternate Exclusion for Measure 2 (Stage 1): Provider may claim an exclusion for measure 2 (laboratory orders). Alternate Exclusion for Measure 3 (Stage 1): Provider may claim an exclusion for measure 3 (radiology orders). Stage 2 Exclusions: Any EP who writes fewer than 100 medication orders (Measure 1), fewer than 100 laboratory orders (Measure 2), or fewer than 100 radiology orders (Measure 3) during the EHR reporting period.
4. Electronic Prescribing More than 50 percent of all permissible prescriptions written by the EP are queried for a drug formulary and transmitted electronically using Certified EHR Technology. Alternate (Stage 1) EP Measure: More than 40 percent of all permissible prescriptions written by the EP are transmitted electronically using Certified EHR Technology. Sate 2 Exclusions: EPs who: (1) write fewer than 100 permissible prescriptions during the EHR reporting period; or (2) do not have a pharmacy within their organization and there are no pharmacies that accept electronic prescriptions within 10 miles of their practice location at the start of their EHR reporting period.
5. Summary of Care 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. Alternate Exclusion (Stage 1): Provider may claim an exclusion for the measure which requires the electronic transmission of a summary of care document Stage 2 Exclusion: Any EP who transfers a patient to another setting or refers a patient to another provider less than 100 times during the EHR reporting period.
5. Summary of Care Summary of Care Document contains:. Patient name Provider s name and office contact info Current problem list Current medication allergy list and medication allergy history Vital signs (height, weight, blood pressure, BMI, growth charts) PMH Procedures Laboratory test results Current medication list and medication history Smoking status Demographic information (preferred language, sex, race, ethnicity, date of birth) Care plan field(s), including goals and instructions; and any known care team members including the primary care provider of record.
6. Patient Specific Education Patient-specific education resources identified by Certified EHR Technology are provided to patients for more than 10 percent of all unique patients. Alternate Exclusion (Stage 1): Provider may claim an exclusion for this measure Stage 2 Exclusion: Any EP who has no office visits during the EHR reporting period.
7. Medication Reconciliation 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 (Stage 1): Provider may claim an exclusion for the measure Stage 2 Exclusion: Any EP who was not the recipient of any transitions of care during the EHR reporting period.
8. Patient Electronic Access Measure 1: More than 50 percent of all unique patients seen by the EP during the EHR reporting period are provided timely (within 4 business days after the information is availableto the EP) online access to their health information* subject to the EP's discretion to withhold certain information. Measure 2: At least one patient seen by the EP during the EHR reporting period (or their authorized representatives) views, downloads, or transmits his or her health information to a third party. Alternate Exclusion Measure 2 (Stage 1): Provider may claim an exclusion for the second measure Stage 2 Exclusions: Any EP who (a) Neither orders nor creates any of the information listed for inclusion as part of the measures; or (b) Conducts 50 percent or more of his or her patient encounters in a county that does not have 50 percent or more of its housing units with 4Mbps broadband availability according to the latest information available from the Federal Communications Commission (FCC) on the first day of the EHR reporting period.
Health Information to be Provided Patient name Provider s name and office contact info Current problem list PMH Procedures Laboratory test results Current medication list and medication history Current medication allergy list and medication allergy history Vital signs (height, weight, blood pressure, BMI, growth charts) Smoking status Demographic information (preferred language, sex, race, ethnicity, date of birth) Care plan field(s), including goals and instructions; and any known care team members including the primary care provider of record.
9. Secure Electronic Messaging Measure: During the EHR reporting period, the capability for patients to send and receive a secure electronic message with the provider was fully enabled. Alternate Exclusion (Stage 1): An EP may claim an exclusion for the measure EP Exclusions: Any EP who--(a) Has no office visits during the EHR reporting period; or (b) Conducts 50 percent or more of his or her patient encounters in a county that does not have 50 percent or more of its housing units with 4Mbps broadband availability according to the latest information available from the FCC on the first day of the EHR reporting period.
Objective #10 Public Health Reporting Stage 2 Measure Option 1 Immunization Registry Reporting: The EP is in active engagement with a public health agency to submit immunization data. Exclusions: Any EP meeting one or more of the following criteria may be excluded from the immunization registry reporting measure if the EP-- Does not administer any immunizations to any of the populations for which data is collected by its jurisdiction's immunization registry or immunization information system during the EHR reporting period; Operates in a jurisdiction for which no immunization registry or immunization information system is capable of accepting the specific standards required to meet the CEHRT definition at the start of the EHR reporting period; or Operates in a jurisdiction where no immunization registry or immunization information system has declared readiness to receive immunization data from the EP at the start of the EHR reporting period
Objective #10 Public Health Reporting Stage 2 Measure Option 2 Syndromic Surveillance Reporting: The EP is in active engagement with a public health agency to submit syndromic surveillance data. Exclusion for EPs: Any EP meeting one or more of the following criteria may be excluded from the syndromic surveillance reporting measure if the EP: Is not in a category of providers from which ambulatory syndromic surveillance data is collected by their jurisdiction's syndromic surveillance system; Operates in a jurisdiction for which no public health agency is capable of receiving electronic syndromic surveillance data from EPs in the specific standards required to meet the CEHRT definition at the start of the EHR reporting period; or Operates in a jurisdiction where no public health agency has declared readiness to receive syndromic surveillance data from EPs at the start of the EHR reporting period.
Objective #10 Public Health Reporting Stage 2 Measure Option 3 Specialized Registry Reporting: The EP is in active engagement to submit data to a specialized registry. Exclusions: Any EP meeting at least one of the following criteria may be excluded from the specialized registry reporting measure if the EP-- Does not diagnose or treat any disease or condition associated with, or collect relevant data that is collected by, a specialized registry in their jurisdiction during the EHR reporting period; Operates in a jurisdiction for which no specialized registry is capable of accepting electronic registry transactions in the specific standards required to meet the CEHRT definition at the start of the EHR reporting period; or Operates in a jurisdiction where no specialized registry for which the EP is eligible has declared readiness to receive electronic registry transactions at the beginning of the EHR reporting period.
https://questions.cms.gov/faq.php?faqid=12985&id=5005
www.uswoundregistry.com
Clinical Quality Measures (CQMs) Need to report 9 CQMs covering at least 3 National Quality Strategy (NQS) domains No threshold requirements!
Hardship to 2015 MU If a provider is unable to meet the requirements of meaningful use for an EHR reporting period in 2015 for reasons related to the timing of the publication of the final rule, a provider may apply for a hardship exception under the "extreme and uncontrollable" circumstances category. Each hardship exception application will be reviewed on a case-by-case basis, as required by law. In the past, CMS has considered these applications seriously and, in fact, has approved over 85% of hardship exemptions. Hardship applications will be available in early 2016 on https://www.cms.gov/ehrincentiveprograms https://questions.cms.gov/faq.php?id=5005&faqid=12845
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