1. Introduction Please review Medflow s document " Finalized!" in order to get background information on the recent CMS Final Rule for "Modified Stage 2" which is retroactively applicable to the 2015 Meaningful Use reporting period. You should be aware that no new release of software is required to successfully demonstrate for 2015, and you will be able to use your existing Medflow EHR V8.1 Automated Measure Reports to attest to Meaningful Use for 2015. This document will provide you the information you need to attest for using the existing Medflow EHR V8.1 Automated Measure Report (AMR), for the reporting year 2015 only. This document does not walk you through the attestation process step-by-step, and it cannot do so, because the CMS MU attestation web site has not yet been updated for and is currently unavailable. CMS has promised the new attestation web site will be available Jan. 4, 2016. Before we get into the step-by-step details, it is important to understand that the way you will use the AMR will be different in nature for 2015 than for prior years of Meaningful Use. At the beginning of the Meaningful Use program, we all thought Stage 1 would be Stage 1, and if CMS was going to change something they would change it in Stage 2; we thought Stage 2 would be Stage 2, and if CMS was going to change something, they would change it in Stage 3. This is not how things have worked out! Stage 1 was introduced in 2011, had a minor update to its measures in 2013, a major update in 2014, an even bigger, retroactive update for 2015, and will be essentially gone by 2016. In other words, the only year in which Stage 1 was not modified was 2012! Stage 2 was introduced in 2014 and is getting a major, retroactive update for 2015. Because of measure logic rule changes already specified in the Final Rule, there will be at least a minor change for the measures required for Modified Stage 2 in 2016 and 2017 before it is retired in 2018. In other words, there will not have been a single year in which Stage 2 was not modified! What does this mean for your use of the AMR? It had been Medflow's intention to allow you to use your AMR as a primary tool for planning, monitoring and completing your demonstration of Meaningful Use each year. We anticipated that you would go through the report measure by measure each time you used it to monitor your performance or used it to attest. Because of the extremely late changes CMS made to the regulations, it is certainly not possible to use the AMR in this manner, since it is not tailored to the Final Rule. Instead, you will use this document for step-by-step instructions, and these step-by-step instructions in turn will reference the AMR. This guide will instruct you to pick only certain measures from the AMR (for example by highlighting on a paper copy); you can disregard other parts of the AMR which will not be necessary for you to attest to Meaningful Use in 2015! Since the prior MU measure numbering has been obsoleted by CMS and since many measures have been eliminated, you should no longer go through the AMR measure by measure! www.medflow.com Copyright 1999-2015. Medflow, Inc. All Rights Reserved. pg. 1
For 2015, you will only for certain numeric measures, to obtain the numerator, denominator and percentage values reported by your Medflow certified EHR. You do not need to consult your AMR for non-numeric MU measures, even though in some cases those non-numeric measures may still be applicable to you for. Step 1: Determine Your 2015 Schedule Status CMS chose to eliminate the term "Stage 1" with its new Final Rule. Instead, it has defined the new "Modified Stage 2" objectives and measures to be applicable to all Meaningful Use program participants for the years 2015 through 2017. Nevertheless, for 2015 only, CMS has provided full accommodations for those participants who previously had been scheduled for Stage 1. This is in the form of "alternate measures" and "alternate exclusions" for specific measures which are only available in case the participant previously had been scheduled for Stage 1 for 2015. The first step, therefore, is very simple: determine for which stage of Meaningful Use you as the participant had previously been scheduled, for 2015, and 2. if this had been Stage 1, proceed to Step #2, or 3. if this had been Stage 2, proceed to Step #3. Step 2: Map the Medflow Stage 1 AMR to Congratulations! If you are reading this, you had previously been scheduled for Stage 1 for 2015, and you are eligible for special accommodations for 2015 only, so that your demonstration of Meaningful Use should be very easy this year! Although CMS prefers to say that you are also now demonstrating "Modified Stage 2", with these Stage 1 accommodations, you will not be required to demonstrate any measure beyond those previously defined for Stage 1. CMS refers to these Stage 1 accommodations as "alternate measures" and "alternate exclusions" applicable only to those participants who had previously been scheduled for Stage 1, and these have the following meaning: Alternate Measures - these are essentially the previous Stage 1 measures which may be used instead of the more stringent, standard Modified Stage 2 measures where applicable. Alternate s - these are exclusions to standard Modified Stage 2 measures which are available only participants who previously had been scheduled for Stage 1. If you are in this category, you can automatically skip over these Modified Stage 2 measures for 2015! The list of measures has been entirely restructured relative to the 2014 Stage 1 measures. Some of the Stage 1 measures have been eliminated entirely, those measures left have been reorganized into just 10 objectives, and there is no longer any division into "core" and "menu" measures. Some objectives have multiple measures, and in one case you still have a choice in selecting from amongst those multiple measures, but only within that objective. Your remaining measures will essentially be the same as what they would have been prior to the Final Rule. www.medflow.com Copyright 1999-2015. Medflow, Inc. All Rights Reserved. pg. 2
You must: Select a 90-day reporting period entirely within CY2015. Run your Medflow Stage 1 AMR for that 90-day period. Verify that your AMR shows that you have passed according to the objectives and measures listed in Table 1 below. For readability, the alternate measures and alternate exclusions have been underlined in the table below to draw attention to them. If one of the numeric measures does not meet the threshold requirements, try selecting a different 90-day reporting period and go back to Step B above. Otherwise, if all the numeric measures meet the threshold requirements, proceed to Step #4 below. www.medflow.com Copyright 1999-2015. Medflow, Inc. All Rights Reserved. pg. 3
1. Protect Patient Health Information with Stage 1 Accommodations Conduct or review SRA 2. CDS Alternate Measure #1: 1 CDS rule Medflow Stage 1 AMR Not a numeric measure, no need to consult the AMR Not a numeric measure, no need to consult the AMR Attestation/Audit Guidance Keep a copy of the SRA Take a screen shot of the CDS rule set up in the CQM and CDS Configuration screen in Medflow V8.1 Measure #2: Drug-drug & drug-allergy checks Not a numeric measure, no need to consult the AMR Take a screen shot of a Drug-drug & Drug-allergy check in Medflow V8.1 3. CPOE Alternate Measure #1: (i) > 30% of unique patients with at least 1 medication have at least 1 medication order entered using CPOE; or (ii) >30% of medication orders recorded using CPOE Measure #2: Alternate Measure #3: Alternate 4. erx Alternative Measure: >40% of permissible transmitted electronically using CEHRT 1) Computerized Provider Order Entry a.) Measure 1: Medication or b.) Measure 2: Optional Alternative Medication Use the Medflow V8.1 Automated Measure Report for the Numerator and Denominator calculation Keep a copy of the AMR 4) E-Prescribing Use the Medflow V8.1 Automated Measure Report for the Numerator and Denominator calculation Keep a copy of the AMR 5. Summary of Care 6. Patient Specific Education 7. Medication Reconciliation Measure: Alternate Measure: Alternate Measure: Alternate Measure: Alternate www.medflow.com Copyright 1999-2015. Medflow, Inc. All Rights Reserved. pg. 4
8. Patient Electronic Access 9. Secure Messaging 10. Public Health Reporting (any 1 out of 3 measures) with Stage 1 Accommodations #1: >50% of unique patients provided timely online access to their health information, with the ability to view, download, and transmit Measure #2: Alternate Measure: Alternate #1: Active engagement with a public health agency to submit immunization data #2: Active engagement with a public health agency to submit syndromic surveillance data #3: Active engagement to submit data to specialized registry Medflow Stage 1 AMR 12) Patient Electronic Access Not a numeric measure, no need to consult the AMR Attestation/Audit Guidance Use the Medflow V8.1 Automated Measure Report for the Numerator and Denominator calculation Keep a copy of the AMR Choose any 1 out of the 3 measures If you choose #3, be sure to have supporting documentation from the IRIS Registry that you have done one of the following: o Requested to submit data to the IRIS Registry OR o Actively submit data to the IRIS Registry Table 1: Mapping Medflow Stage 1 AMR to (Only for participants who had been scheduled for Stage 1 previously) www.medflow.com Copyright 1999-2015. Medflow, Inc. All Rights Reserved. pg. 5
Step 3: Map the Medflow Stage 2 AMR to The list of measures has been entirely restructured relative to the 2014 Stage 2 measures. Many of the previous Stage 2 measures have been eliminated entirely, several have been significantly simplified, those measures left have been reorganized into just 10 objectives, and there is no longer any division into "core" and "menu" measures. Some objectives have multiple measures, and in one case you still have a choice in selecting from amongst those multiple measures, but only within that objective. Your remaining measures will essentially be the same as what they would have been prior to the Final Rule. You must: A) Select a 90-day reporting period entirely within CY2015. B) Run your Medflow Stage 2 AMR for that 90-day period. C) Verify your AMR, whether or not it shows that you have passed according for the objectives and measures listed in Table 2 below. D) If one of the numeric measures does not meet the threshold requirements, try selecting a different 90-day reporting period and go back to Step B above. E) Otherwise, if all the numeric measures meet the threshold requirements, proceed to Step #4 below. 1. Protect Patient Health Information Measure: Conduct or review SRA 2. CDS Measure #1: 5 CDS rule related to 4+ CQMs Measure #2: Drug-drug & drug-allergy checks 3. CPOE Measure #1: >60% of medication orders Measure #2: >30% of lab orders Measure #3: >30% of imaging orders Medflow Stage 2 AMR Attestation/Audit Guidance 1) Computerized Provider Order Entry a.) Measure 1: Medication c.) Measure 3: Laboratory b.) Measure 2: Radiology Keep a copy of the SRA Take a screen shot of the CDS rule set up in the CQM and CDS Configuration screen in Medflow V8.1 Take a screen shot of a Drugdrug & Drug-allergy check in Medflow V8.1 Use the Medflow V8.1 Denominator calculation Keep a copy of the AMR www.medflow.com Copyright 1999-2015. Medflow, Inc. All Rights Reserved. pg. 6
4. erx Measure: >50% of permissible or all prescriptions queried for drug formulary & transmitted electronically using CEHRT 5. Summary of Care Measure: Uses CEHRT to create a SoC record and electronically transmit to a receiving provider for >10% of transitions of cares and referrals Medflow Stage 2 AMR Attestation/Audit Guidance 2) E-Prescribing Use the Medflow V8.1 Denominator calculation Keep a copy of the AMR 15) Provide Summary of Care for Each Transition of Care b.) Measure 2: Send Summary of Care Through Direct Use the Medflow V8.1 Denominator calculation for b.) Measure 2 Keep a copy of the AMR 6. Patient Specific Education Measure: Patientspecific education resources identified by CEHRT are provided to >10% of patients 13) Patient-Specific Education Resources Use the Medflow V8.1 Denominator calculation Keep a copy of the AMR 7. Medication Reconciliation Measure: Medication reconciliation for >50% of transitions into the care of the EP 14) Medication Reconciliation Use the Medflow V8.1 Denominator calculation Keep a copy of the AMR 8. Patient Electronic Access Measure #1: >50% of unique patients provided timely online access to their health information, with the ability to view, download, and transmit Measure #2: At least 1 patient views, downloads or transmits his or her health information 7) View Online, Download and Transmit a.) Measure 1: Online Access to Health Information b.) Measure 2: View, Download, or Transmit to 3rd Party Use the Medflow V8.1 Automated Measure Report Measure 1: for the Numerator and Denominator calculation Measure 2: for the Numerator calculation to atleast increase by one Keep a copy of the AMR www.medflow.com Copyright 1999-2015. Medflow, Inc. All Rights Reserved. pg. 7
9. Secure Messaging 10. Public Health Reporting (any 2 out of 3 measures) Measure: The capability for patients to send and receive a secure message was fully enabled during the reporting period Measure #1: Active engagement with a public health agency to submit immunization data Measure #2: Active engagement with a public health agency to submit syndromic surveillance data Measure #3: Active engagement to submit data to specialized registry Medflow Stage 2 AMR Attestation/Audit Guidance Keep a copy of the Portal contract and the date it was activated Choose any 2 out of the 3 measures If you choose #3, be sure to have supporting documentation from the IRIS Registry that you have done one of the following: o Requested to submit data to the IRIS Registry OR o Actively submit data to the IRIS Registry Table 2: Mapping Medflow Stage 2 AMR to (Only for participants who had been scheduled for Stage 2 previously) Step 4 (All Participants): Public Health Reporting The objective for Public Health Reporting requires you to report 2 out of 3 measures in case you had been scheduled for Stage 2, or only 1 out of 3 measures in case you had previously been scheduled for Stage 1. One of these 3 measures is for "specialized registry reporting". Medflow recommends you satisfy this measure for "active engagement to submit data" by signing up with the IRIS registry, assuming you are an AAO member. AAO can provide you with a letter stating that IRIS, as a "Qualified Clinical Data Registry", may be used for this Meaningful Use measure, or Medflow can provide you a copy of this AAO letter. It is not necessary to have the IRIS team electronically integrate your Medflow EHR database with IRIS in 2015 as long as you have signed up for IRIS in 2015 and are on the waiting list, this will count as "active engagement". Determine your eligibility for exclusion to the first two measures of this objective. You may be eligible for one of the non-alternate exclusions for one or both of the first two measures for this objective. Please particularly consider the underlined exclusion to see if it may be applicable to you. The exclusions for Measure #1 (Immunization registry reporting) are as follows: www.medflow.com Copyright 1999-2015. Medflow, Inc. All Rights Reserved. pg. 8
Does not administer any immunizations to any of the populations for which data is collected by his or her 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 his or her EHR reporting period. Operates in a jurisdiction in which 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. The exclusions for Measure #2 (Syndromic surveillance reporting) are as follows: i. Is not in a category of providers from which ambulatory syndromic surveillance data is collected by their jurisdiction's syndromic surveillance system. ii. Operates in a jurisdiction for which no public health agency is capable of receiving electronic syndromic surveillance data from EP's in the specific standards required to meet the CEHRT definition at the start of the EHR reporting period. iii. 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. Step 5: Prepare Your Meaningful Use Audit File You should include a printout of your Medflow AMR to document your numeric measures, and supporting documentation for each non-numeric measure or exclusion. If you had previously been scheduled for Stage 1, you should include documentation establishing your eligibility for the alternate measures and exclusions for the 2015 accommodations for Stage 1. Information on maintaining a suitable Meaningful Use audit file is available from CMS at the following URL: https//www.cms.gov/regulations-andguidance/legislation/ehrincentiveprograms/downloads/ehr_supportingdocumentation_audits.pdf Step 6: Prepare Your CQM Report As mentioned in the introduction of this document, the requirements for CQM reporting have not been modified by the Final Rule, so proceed as planned. Step 7: Attest As mentioned in the introduction of this document, the CMS MU attestation web site has not yet been updated for and is currently unavailable. CMS has promised the new attestation web site will be available Jan. 4, 2016. It may be advisable to wait until Jan. 11 to attempt to attest in case there are any "teething problems" when CMS does make the web site available after the holidays. Be sure not to miss the attestation deadline of Feb. 28, 2016. www.medflow.com Copyright 1999-2015. Medflow, Inc. All Rights Reserved. pg. 9