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Kim Davis-Allen Outreach Coordinator [email protected] Florida’s Medicaid EHR Incentive Program Overview of Modified Stage 2 February 10, 2016 1
Kim Davis-Allen
Outreach Coordinator
Florida’s Medicaid EHR Incentive Program
Overview of Modified Stage 2
February 10, 2016
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2015 Program Applications• Adopt, Implement, or Upgrade (AIU)
– Attestations can be submitted now through the grace period– Grace period for Program Year (PY) 15 AIU applications ends March 31,
2016
• Meaningful Use (MU) Applications– Applications should not be started until system changes are complete– System changes are anticipated to be complete July 2016– Grace Period for MU applications is August 31, 2016
• New Application Documentation Requirement – EPs are required to upload their Security Risk Assessment (SRA) to
applications
• Note: PY16 AIU applications can be submitted through March 31, 2017
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PY16 is the Last Year to Begin Program Participation
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Important Note
Medicare Payment Adjustment - EPs• EPs who first demonstrated meaningful use (MU) in 2014 must have
demonstrated for a 90-day reporting period to avoid payment adjustments in 2015 and 2016
– Submit reconsideration forms for 2016 adjustment based on the 2014 EHR reporting period by February 29, 2016
• Returning EPs successfully demonstrate MU in any continuous 90-day reporting period in 2015 will avoid the payment adjustment in 2017
– Can attest with Medicaid for meaningful use– If Medicaid attestation is after the February 29, 2016 deadline – attestation
data will be provided to CMS– If attesting with Medicare – must successfully attest by February 29, 2016
• EPs, EHs, and Critical Access Hospitals (CAHs) that use streamline application must submit the application according to timeline
– Deadlines for Submission:• EPs: March 15, 2016• EHs & CAHs: April 1, 2016
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Hardship Exception Reasons
Applications can be submitted individually or as a group
• Section 2.1 – Insufficient Internet Connectivity
• Section 2.2 Extreme and Uncontrollable Circumstances– Disaster
– Practice or Hospital Closure
– Severe Financial Issues– EHR Certification/Vendor Issues
• Section 2.3 Lack of Control over the Availability of Certified EHR Technology – EP Only
• Section 2.4 Lack of Face-to-Face Patient Interaction – EP Only
https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/PaymentAdj_Hardship.html
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Medicare Alternative Attestation aka Non-Payment Track
• Attest for the purpose of avoiding the Medicare payment adjustment
• Can be used by Medicare providers registered with Medicaid who are not going to be able to successfully attest with the Medicaid program
– e.g. no longer meet volume requirements
• Those planning to attest with Medicaid for Program Year 2015 do not need to use the alternative attestation method with Medicare.
– The state provides attestation data to CMS
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Overview of Modified Stage 2
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• Attest to a single set of objectives and measures– Replaces the objectives structure of previous stages– 10 objectives for Eligible Professionals (EPs), including one consolidated public
health objective– 9 objectives for Eligible Hospitals (EHs), including one consolidated public
health objective
• Attest using 2014 Certified Electronic Health Reporting Technology (CEHRT)
• Exclusions included within objectives for EPs scheduled to demonstrate Stage 1 in 2015
– Lower thresholds for certain measures– Exclusions for Modified Stage 2 measures for which there is no Stage 1
equivalent– Exclusions for Modified Stage 2 measures where a previous menu measure is
now a requirement– There are also alternate exclusions for CPOE measures for 2016
EP Participation Timeline
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• 2015: All EPs 90 days– Attest to modified version of Stage 2 with alternative
measures/exclusions for providers in their 1st or 2nd MU reporting period
• 2016: 1st year 90 days; all other full year– Attest to modified version of Stage 2– Certain measures still have alternative measures/exclusions for
providers in their 1st or 2nd MU reporting period
• 2017: 1st year 90 days; all other full year– Attest to modified version of Stage 2 or Stage 3– If attesting to Stage 3, 90 day reporting period
• 2018: 1st year 90 days; all other full year– Attest to Stage 3
Protect Patient Health Information
• Measure: Conduct or review a security risk analysis in accordance with the requirements 45 CFR 164.308(a)(1), including addressing the security (to include encryption) of ePHI created or maintained in CEHRT in accordance with requirements under 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 EP’s risk management process
• Exclusion: None
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Protect Patient Health Information –Additional Information• Timing
– Must occur prior to attesting
– An EP cannot use the same Security Risk Analysis (SRA) for more than one program year
• EPs are now required to upload their Security Risk Analysis or Review with their application
– Several audits resulted in a finding because the EP/practice had not completed an SRA or completed an inadequate one
– Acceptance of the uploaded document does not guarantee it will be acceptable in an audit
– Documentation must include an asset inventory and the final report
– Asset inventory lists where Protected Health Information (PHI) comes in, is stored, and is transmitted out
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Clinical Decision Support• Measure 1: 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. Absent four clinical quality measures related to an EP’s scope of practice or patient population, the clinical decision support interventions must be related to high priority health conditions
PY 15 Alternate Measure 1: For an EP scheduled to participate in Stage 1 in 2015, implement one clinical decision support rule
• Measure 2: The EP has enabled and implemented the functionality for drug-drug and drug allergy interaction checks for the entire EHR reporting period
• Exclusion: For Measure 2, any EP who writes fewer than 100 medication orders during the EHR reporting period
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Computerized Provider Order Entry - 1 of 3
• Measure 1: More than 60 percent of medication orders created by the EP during the EHR reporting period are recorded using computerized provider order entry (CPOE)
• PY 15 Alternate Measure 1: For Stage 1 providers in 2015, more than 30 percent of all unique patients with at least one medication in their medication list seen by the EP during the EHR reporting period have at least one medication order entered using CPOE; or more than 30 percent of medication orders created by the EP during the EHR reporting period are recorded using CPOE
• Exclusion: Any EP who writes fewer than 100 medication orders during the EHR reporting period
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CPOE- 2 of 3• Measure 2: More than 30 percent of laboratory orders created
by the EP during the EHR reporting period are recorded using CPOE
• PY 15 and 16 Alternate Exclusion: EPs scheduled for Stage 1 in 2015 or 2016 may claim an exclusion for measure 2 (lab orders) of the Stage 2 CPOE objective for an EHR reporting period in 2015 and 2016
• Exclusion 2: Any EP who writes fewer than 100 laboratory orders during the EHR reporting period
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CPOE- 3 of 3• Measure 3: More than 30 percent of radiology orders created
by the EP during the EHR reporting period are recorded using CPOE
• PY 15 and 16 Alternate Exclusion: EPs scheduled for Stage 1 in 2015 or 2016 may claim an exclusion for measure 3 (radiology orders) of the Stage 2 CPOE objective for an EHR reporting period in 2015 and 2016
• Exclusion: Any EP who writes fewer than 100 radiology orders during the EHR reporting period
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Electronic Prescribing (e-Rx)• Measure: More than 50 percent of permissible prescriptions
written by the EP are queried for a drug formulary and transmitted electronically using CEHRT
• PY 15 Alternate Measure: For Stage 1 providers in 2015, more than 40 percent of all permissible prescriptions written by the EP are transmitted electronically using CEHRT
• Exclusions: – EP who writes fewer than 100 permissible prescriptions during
the EHR reporting period; or– EP who does not have a pharmacy within his or her organization
and there are no pharmacies that accept electronic prescriptions within 10 miles of the EP's practice location at the start of his or her EHR reporting period
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Health Information Exchange (HIE)• Measure: The EP that transitions or refers their patient to
another setting of care or provider of care must (1) use CEHRT to create a summary of care record; and (2) electronically transmit such summary to a receiving provider for more than 10 percent of transitions of care and referrals
• 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
• PY15 Alternate Exclusion: EP may claim an exclusion for the Stage 2 measure that requires the electronic transmission of a summary of care document if for an EHR reporting period in 2015, they were scheduled to demonstrate Stage 1, which does not have an equivalent measure
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HIE – Additional Information• In cases where providers share access to CEHRT, transition may still
count if referring provider creates the summary of care document in CEHRT and sends the summary of care document electronically
• No longer required that the Summary of Care document be transmitted using Direct Protocol
• The exchange must comply with the privacy and security protocols under ePHI under HIPAA
• The referring provider must have reasonable certainty of receipt by the receiving provider to count the action toward the measure
• The Florida Health Information Exchange’s Direct Messaging Service meets the security requirements
• The EHR may not calculate a transition into the numerator. EPs will have to provide documentation to support the numerator if different from their EHR report
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Health Information Exchange – Resources
• CMS FAQ #12817 – use of a third party
• CMS FAQ #9690 – sharing of CEHRT
• CMS Tip Sheet at https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/HIE_FactSheet.pdf
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Patient Specific Education• Measure: Patient specific education resources identified by
CEHRT are provided to patients for more than 10 percent of all unique patients with office visits seen by the EP during the EHR reporting period
• PY 15 Alternate Exclusion: EP may claim an exclusion for the measure of the Stage 2 Patient Specific Education objective if for an EHR reporting period in 2015 they were scheduled to demonstrate Stage 1 but did not intend to select the Stage 1 Patient Specific Education menu objective
• Exclusion: Any EP who has no office visits during the EHR reporting period
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Medication Reconciliation• Measure: 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
• PY 15 Alternate Exclusion: EP may claim an exclusion for the measure of the Stage 2 Medication Reconciliation objective if for an EHR reporting period in 2015 they were scheduled to demonstrate Stage 1 but did not intend to select the Stage 1 Medication Reconciliation menu objective
• Exclusion: Any EP who was not the recipient of any transitions of care during the EHR reporting period
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Patient Electronic Access – 1 of 2• Measure 1: More than 50 percent of all unique patients seen
by the EP during the EHR reporting period are provided timely access to view online, download, and transmit to a third party their health information subject to the EP's discretion to withhold certain information
• Exclusion for Measure 1 : An EP who neither orders nor creates any of the information listed for inclusion as part of the measures except for “Patient Name” and “Provider’s name and office contact information”
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Patient Electronic Access – 2 of 2• Measure 2: For an EHR reporting period in 2015, at least one 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
• PY 15 Alternate Exclusion for Measure 2: EP may claim an exclusion for the 2nd measure if for an EHR reporting period in 2015 they were scheduled to demonstrate Stage 1 which does not have an equivalent measure
• Exclusion for Measure 2: – An EP who neither orders nor creates any of the information listed for
inclusion as part of the measures except for “Patient Name” and “Provider’s name and office contract information”; or
– An EP who 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
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Secure Messaging• PY15 Measure: For an EHR reporting period in 2015, the
capability for patients to send and receive a secure electronic message with the EP was fully enabled during the EHR reporting period
• PY16 Measure: At least 1 patient seen by the EP during the EHR reporting period, a secure message was sent using the electronic messaging function of CEHRT to the patient (or the patient- authorized representative), or in response to a secure message sent by the patient (or the patient-authorized representative) during the EHR reporting period
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Secure Messaging - Exclusions• Any EP who has no office visits during the EHR reporting
period, or any EP who 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
• PY15 Alternate Exclusion: An EP may claim an exclusion for the measure if for an EHR reporting period in 2015 they were scheduled to demonstrate Stage 1, which does not have an equivalent measure
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Public Health Reporting
• An EP scheduled to be in Stage 1 in 2015 must meet one measure or be able to exclude from all
• An EP scheduled to be in Stage 2 in 2015 must meet two measures in 2016 or meet fewer and exclude from the rest
• All EPs in 2016 must meet two or meet fewer and exclude from the rest
– Measure Option 1 – Immunization Registry Reporting: The EP is in active engagement with a public health agency to submit immunization data
– Measure Option 2 – Syndromic Surveillance Reporting: The EP is in active engagement with a public health agency to submit syndromic surveillance data
– Measure Option 3 – Specialized Registry Reporting: The EP is in active engagement to submit data to a specialized registry
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Active Engagement
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• Completed Registration to Submit Data– EP has registered to submit data. Registration was completed within 60
days after the start of the EHR Reporting period and the provider is awaiting an invitation to begin testing and validation.
• Testing and Validation – EP is in the process of testing and validation of the electronic
submission of data. Providers must to respond to requests from the sponsor of the registry within 30 days; failure to respond twice within an EHR reporting period would result in the EP not meeting the measure.
• Production– EP has completed testing and validation of the electronic submission
and is electronically submitting production data.
• Having to pay for an interface is not a valid reason for exclusion
Public Health Reporting - ExclusionsExclusions for Measure 1
• 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.
Exclusions for Measure 2
• 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.
Exclusions for Measure 3
• 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.
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Public Health Reporting – Alternate Exclusions
• Providers may claim an alternate exclusion for a measure if they did not intend to attest to the equivalent prior menu objective
– EPs scheduled to be in Stage 1:• May claim an Alternate Exclusion for Measure 1, Measure 2 or
Measure 3
• An Alternate Exclusion may be claimed for up to two measures, then the provider must either attest to or meet the exclusion requirements for the remaining measure
– EPs scheduled to be in Stage 2: • May claim an Alternate Exclusion for Measure 2 or Measure 3
or both
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Immunization Registry Reporting • CMS FAQ #11984 – when to claim an exclusion
• CMS FAQ #13409 – when scheduled to be in Stage 1
• CMS FAQ #12985 – alternate exclusions
• https://www.flshots.com/
• Providers must register within 60 days of the start of their EHR reporting period
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Specialized Registry Reporting • Identification
– Determine if the jurisdiction (state, territory, etc.) endorses or sponsors a registry; and
– Determine if a National Specialty Society or other specialty society with which the provider is affiliated endorses or sponsors a registry
– If neither has a registry the provider can report, an exclusion can be claimed
• Reporting– Specialty societies with specialized registries can dictate the method in
which they receive the data. The data must be generated from the certified EHR.• The specialized registry accepts data via a secure email. If the provider can
send data through a secure email, they can generate the report from their EHR and follow the registry’s instructions on securely emailing it
• If the provider is a member of a specialty and the only way to electronically report to the registry is to pay the EHR vendor for the connection, then provider cannot take an exclusion because there is a registry available for their reporting
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Florida Registry Links
Florida Shots
https://www.flshots.com/
Cancer Registry
http://fcds.med.miami.edu/inc/welcome.shtml
E-FORCSE
http://www.floridahealth.gov/statistics-and-data/e-forcse
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Clinical Quality Measures (CQMs)
• EPs - 9 out of 64
– Regardless of reporting year
• Cover at least three of the National Quality Strategy Domains
• Core Sets for Adult and Children
• No threshold that must be met
• CQMs reported through the online application (MAPIR)
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Additional Documentation FormMeasure
Protect Patient Health
Information
CPOE for medication orders
CPOE for laboratory orders
CPOE for radiology orders
Electronic Prescribing
Electronic Prescribing
Electronic Prescribing
Patient-Specific Education
Patient Electronic Access
(aka view, download,
transmit )
Public Health Reporting:
Immunization Registry
Reporting
Public Health Reporting:
Specialized Registry
Reporting
Information Requested
IF EXCLUDING for fewer than 100 orders, indicate the total number
of medication orders for the EHR reporting period.
IF EXCLUDING, indicate reason: Fewer than 100 prescriptions in
reporting period - indicate number of RXs ; OR No in-house
pharmacy or one within 10 miles accepting e-prescriptions.
IF NOT EXCLUDING: Name of eRx service(s) used.
IF EXCLUDING for fewer than 100 orders, indicate the total number
of laboratory orders for the EHR reporting period.
IF EXCLUDING for fewer than 100 orders, indicate the total number
of radiology orders for the EHR reporting period.
IF EXCLUDING: Details on why you are excluding.
IF NOT EXCLUDING: a copy of your documentation from Florida
Shots.
IF EXCLUDING: Details on why you are excluding.
IF NOT EXCLUDING: a copy of your documentation from the
specialized registry.
IF NOT EXCLUDING: Name and location of the three pharmacies
you most frequently transmit to.
Who provides your patient portal or personal health record
(PHR)?
Name and title of person completing the SRA or review. Date
completed. Must occur between 1/1/2015 and 12/31/2015.
How did you identify the education resources provided to your
patients?
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Additional Contacts and Resources
www.ahca.myflorida.com/medicaid/ehr
EHR Incentive Program Call Center: (855) 231-5472
www.Florida-HIE.net
Florida HIE Help Desk: 850-412-3752
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