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Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal...

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A Focused Look at MU in MACRA Jim Brulé, Solutions Director - Regulatory
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Page 1: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

A Focused Look at MU in

MACRA

Jim Brulé, Solutions Director - Regulatory

Page 2: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Copyright © 2016 Allscripts Healthcare Solutions, Inc. 2

First, a word.The information contained within this presentation is intended for informational purposes only. While the information and recommendations presented in this presentation are good-faith interpretations made by Allscripts based on the publicly available information referenced within, it does not constitute legal advice or guidance. Thus, any decisions, and associated risks, made by the client pertaining to the information within this presentation are solely the responsibility and liability of the client. Clients are strongly advised that such decisions be made in consultation with their legal representatives.

The information presented within this presentation (1) should not be considered complete, exhaustive, or customized to an individual client’s needs; and (2) is subject to change due to new laws, regulations, or Department of Health and Human Services policies issued after May 18, 2016.

This presentation neither modifies any signed agreements Allscripts has with the client nor creates any Allscripts attestations, representations, warranties, guarantees or covenants related to MU or MACRA compliance, meeting MU or MACRA standards and requirements, whether Allscripts EHR software will meet new or modified requirements for certified EHR technology, or for any other matter.

Page 3: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Overview

Page 4: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Copyright © 2016 Allscripts Healthcare Solutions, Inc. 4

MIPS calculation

ACI(MU)

Cost (VM)

Quality (PQRS+VM)

50

10

25

15 CPIA

ACI

Cost

Quality

ACI: Advancing Care Information | CPIA: Clinical Practice Improvement Activities

VM: Value-Based Modifiers | PQRS: Physician Quality Reporting System

MIPS Score(100 pts)

Category

CPIA

Page 5: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Advancing Care Information

Formerly “Meaningful Use”

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Copyright © 2016 Allscripts Healthcare Solutions, Inc. 6

Advancing Care Information Category• Base score = 50

– 11-16 measures, all or nothing

– Yes/no or num/denom, num >= 1

• Performance score = 80

– Eight measures, up to 10 pts each

– Each measure score = (numerator/denominator) / 10

• Public Health Registry = 1

– Reporting beyond Immunization Registry

• Translates into 25% of MIPS score

– >= 100 translates into 25 MIPS points

Page 7: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Copyright © 2016 Allscripts Healthcare Solutions, Inc. 7

Table 9 – Performance Score CalculationObjectives Patient Electronic Access Coordination of Care Through Patient Engagement Health Information Exchange (HIE)

Measures Patient AccessPatient-Specific

EducationVDT

Secure Messaging

Patient-Generated Health Data

Patient Care Record Exchange

Request / Accept Patient Care

Record

Clinical Information

Reconciliation

Pe

rfo

rma

nce

Ra

te S

core 95%

65%

57%

33% 31% 38%

25% 21%

Percentage Points Earned

9.5% 6.5% 3.3% 3.1% 2.5% 2.1% 3.8% 5.7%

Performance Score = 36.5 percent

Page 8: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Copyright © 2016 Allscripts Healthcare Solutions, Inc. 8

Table 10: Category Score Calculation

Base Score Performance Score Components

Tota

l Per

form

ance

Sco

re

Pu

blic

Hea

lth

an

d C

linic

al

Dat

a R

egis

try

Bo

nu

s P

oin

t

Tota

l Per

cen

tage

Pro

tect

Pat

ien

t H

ealt

h

Info

rmat

ion

Ob

ject

ives

an

d

Mea

sure

s

Patient Electronic Access

Coordination of Care Through Patient Engagement

Health Information Exchange (HIE)

50% 9.5% 6.5% 3.3% 3.1% 2.5% 2.1% 3.8% 5.7% 36.5% 1% 87.5%

87.5% of 25 possible percentage points =

21.88 percentage points for the Advancing Care Information performance category

Page 9: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Base Score

Page 10: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Copyright © 2016 Allscripts Healthcare Solutions, Inc. 10

Scoring Principles: Base Score• Worth 50 points

• All-or-nothing

• Each measure is either Yes/No or numerator >= 1

• If Protect Health Information is not achieved, entire ACI score is 0.

Page 11: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Copyright © 2016 Allscripts Healthcare Solutions, Inc. 11

Two options: 2017 only• Primary Proposal

– Base score uses Stage 3 measures

• Alternate Proposal

– Base score uses Stage 3 + additional Stage 2 measures

• Choice based on certification edition:

– Use the 2015 Edition all year

• Primary Proposal OR

• Alternate Proposal

– Use the 2014 Edition all year

• Alternate Proposal

– Use combination of 2014 and 2015 Editions

• Primary Proposal OR

• Alternate Proposal

Page 12: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Copyright © 2016 Allscripts Healthcare Solutions, Inc. 12

Primary Proposal – Base ObjectivesObjective Measure Stage 2 Stage 3

1 Protect Patient Health Information Security Risk Analysis

2 Electronic Prescribing ePrescribing

3 Patient Electronic Access Patient Access

Patient-Specific Education

4 Coordination of Care Through

Patient Engagement

View, Download or Transmit (VDT)

Secure Messaging

Patient-Generated Health Data

5 Health Information Exchange Patient Care Record Exchange

Request/Accept Patient Care Record

Clinical Information Reconciliation

6 Public Health and Clinical Data

Registry Reporting

Immunization Registry Reporting

(Optional) Syndromic Surveillance Reporting

(Optional) Electronic Case Reporting

(Optional) Public Health Registry Reporting

(Optional) Clinical Data Registry Reporting

Page 13: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Copyright © 2016 Allscripts Healthcare Solutions, Inc. 13

Alternate Proposal – Base ObjectivesObjective Measure Stage 2 Stage 3

1 Protect Patient Health Information Security Risk Analysis

2 Electronic Prescribing ePrescribing

3 Clinical Decision Support (CDS) Clinical Decision Support Interactions (CDS)

Drug Interaction and Drug-Allergy Checks

4 Computerized Provider Order

Entry (CPOE)

Medication Orders

Laboratory Orders

Diagnostic Imaging Orders

5 Patient Electronic Access Patient Access

View, Download or Transmit (VDT)

6 Patient-Specific Education Patient-Specific Education

7 Secure Messaging Secure Messaging

8 Health Information Exchange Health Information Exchange

9 Medication Reconciliation Medication Reconciliation

10 Public Health Reporting Immunization Registry Reporting

Syndromic Surveillance Reporting

Specialized Registry Reporting

Page 14: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Base Score – Primary

Proposal

Base score is Stage 3 rules

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Copyright © 2016 Allscripts Healthcare Solutions, Inc. 15

(1) Protect Patient Health Information• Must meet current MU objective for Security Risk Analysis

• Failure to meet measure is failure of entire category!

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Copyright © 2016 Allscripts Healthcare Solutions, Inc. 16

(2) Electronic Prescribing• At least one permissible prescription written by the MIPS eligible clinician is queried for a drug

formulary and transmitted electronically using certified EHR technology.

• Counting of controlled substances is optional.

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Copyright © 2016 Allscripts Healthcare Solutions, Inc. 17

(3) Patient Electronic Access• 3.2 The MIPS eligible clinician ensures the patient’s health information is available for the patient

(or patient-authorized representative) to access using any application of their choice that is

configured to meet the technical specifications of the Application Programing Interface (API) in the

MIPS eligible clinician’s certified EHR technology.

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Copyright © 2016 Allscripts Healthcare Solutions, Inc. 18

(3) Patient Electronic Access• 3.3 The MIPS eligible clinician must use clinically relevant information from certified EHR

technology to identify patient-specific educational resources and provide electronic access to

those materials to at least one unique patient seen by the MIPS eligible clinician.

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Copyright © 2016 Allscripts Healthcare Solutions, Inc. 19

(4) Coordination of Care Through Patient Engagement

• 4.1 View-Download-Transmit

• During the performance period, at least one unique patient (or patient-authorized

representatives) seen by the MIPS eligible clinician actively engages with the EHR made accessible

by the MIPS eligible clinician.

– view, download or transmit to a third party their health information

– access their health information through the use of an API

– a combination of the above

Page 20: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Copyright © 2016 Allscripts Healthcare Solutions, Inc. 20

(4) Coordination of Care Through Patient Engagement

• 4.2 Secure Messaging

• For at least one unique patient seen by the MIPS eligible clinician during the performance period,

a secure message was sent using the electronic messaging function of certified EHR technology to

the patient (or the patient-authorized representative), or in response to a secure message sent by

the patient (or the patient-authorized representative).

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Copyright © 2016 Allscripts Healthcare Solutions, Inc. 21

(4) Coordination of Care Through Patient Engagement

• 4.3 Patient-Generated Health Data

• Patient-generated health data or data from a non-clinical setting is incorporated into the certified

EHR technology for at least one unique patient seen by the MIPS eligible clinician during the

performance period.

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Copyright © 2016 Allscripts Healthcare Solutions, Inc. 22

(5) Health Information Exchange• 5.1 Patient Care Record Exchange

• For at least one transition of care or referral, the MIPS eligible clinician that transitions or refers

their patient to another setting of care or health care provider:

– creates a summary of care record using certified EHR technology; and

– electronically exchanges the summary of care record.

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Copyright © 2016 Allscripts Healthcare Solutions, Inc. 23

(5) Health Information Exchange• 5.2 Request/Accept Patient Care Record

• For at least one transition of care or referral received or patient encounter in which the MIPS

eligible clinician has never before encountered the patient, the MIPS eligible clinician receives or

retrieves and incorporates into the patient’s record an electronic summary of care document.

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Copyright © 2016 Allscripts Healthcare Solutions, Inc. 24

(5) Health Information Exchange• 5.3 Clinical Information Reconciliation

• For at least one transition of care or referral received or patient encounter in which the MIPS

eligible clinician has never before encountered the patient, the MIPS eligible clinician performs

clinical information reconciliation of:

1. Medication. Review of the patient’s medication, including the name, dosage, frequency, and

route of each medication.

2. Medication allergy. Review of the patient’s known medication allergies.

3. Current Problem list. Review of the patient’s current and active diagnoses.

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Copyright © 2016 Allscripts Healthcare Solutions, Inc. 25

(6) Public Health and Clinical Data Registry Reporting

• The MIPS eligible clinician is in active engagement with a public health agency to submit

immunization data and receive immunization forecasts and histories from the public health

immunization registry/immunization information system (IIS).

Page 26: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Base Score - Alternate

Proposal

Base score has Stage 2 rules

Page 27: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Copyright © 2016 Allscripts Healthcare Solutions, Inc. 27

(3) Clinical Decision Support • 3.1 Clinical Decision Support (CDS) Interventions

• Implement three clinical decision support interventions related to three CQMs at a relevant point

in patient care for the entire performance period.

• Absent three CQMs related to a MIPS eligible clinician’s scope of practice or patient population,

the clinical decision support interventions must be related to high-priority health conditions.

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Copyright © 2016 Allscripts Healthcare Solutions, Inc. 28

(3) Clinical Decision Support • 3.2 Drug Interaction and Drug-Allergy Checks

• The MIPS eligible clinician has enabled and implemented the functionality for drug-drug and

drug-allergy interaction checks for the entire performance period.

Page 29: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Copyright © 2016 Allscripts Healthcare Solutions, Inc. 29

(4) Computerized Provider Order Entry (CPOE)• 4.1 Medication Orders

• At least one medication order created by the MIPS eligible clinician during the performance

period is recorded using CPOE.

Page 30: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Copyright © 2016 Allscripts Healthcare Solutions, Inc. 30

(4) Computerized Provider Order Entry (CPOE)• 4.2 Laboratory Orders

• At least one laboratory order created by the MIPS eligible clinician during the performance

period is recorded using CPOE.

Page 31: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Copyright © 2016 Allscripts Healthcare Solutions, Inc. 31

(4) Computerized Provider Order Entry (CPOE)• 4.3 Diagnostic Imaging Orders

• At least one diagnostic imaging order created by the MIPS eligible clinician during the

performance period is recorded using CPOE.

Page 32: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Copyright © 2016 Allscripts Healthcare Solutions, Inc. 32

Health Information Exchange• Uses certified EHR technology to create a summary of care record

• Electronically transmits such a summary to a receiving health care provider for at least one

transition of care or referral

Page 33: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Copyright © 2016 Allscripts Healthcare Solutions, Inc. 33

Medication Reconciliation• Performs medication reconciliation for at least one transition of care in which the patient is

transitioned into the care of the MIPS eligible clinician

Page 34: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Copyright © 2016 Allscripts Healthcare Solutions, Inc. 34

Public Health Reporting• In active engagement with a public health agency or clinical data registry to submit electronic

public health data in a meaningful way using certified EHR technology, except where prohibited,

and in accordance with applicable law and practice.

• Options:

– Immunization Registry

– Syndromic Surveillance

– Specialized Registry

Page 35: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Performance Measures

Same for Primary and Alternative

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Copyright © 2016 Allscripts Healthcare Solutions, Inc. 36

Performance Measures Method• Eight measures total

• Calculate percent achievement for each measure across each measure

• Divide each achievement percent by 10

• Maximum score is 80

• Sum all the scores

Page 37: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Copyright © 2016 Allscripts Healthcare Solutions, Inc. 37

Performance Measures

Objective Measure StagePatient Electronic Access Timely Access 2

Patient Education 2Coordination of Care View / Download / Transmit 2

Secure Messaging 2Patient Generated Health Data 3

Health Information

Exchange

Patient Care Record Exchange 2Request/Accept Patient Care Record 3Clinical Information Reconciliation 3

Page 38: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Registry Bonus

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Copyright © 2016 Allscripts Healthcare Solutions, Inc. 39

Registry Bonus Point • May earn 1 point towards ACI score for participation in one or more extra registries

• Maximum score is 1 point, no matter how many registries

• Potential registries:

– Syndromic Surveillance

– Electronic Case Reporting

– Public Health Registry Reporting

– Clinical Data Registry Reporting

Page 40: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

In closing…

Page 41: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Copyright © 2016 Allscripts Healthcare Solutions, Inc. 41

Questions

Page 42: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Copyright © 2016 Allscripts Healthcare Solutions, Inc. 42

Further information• ClientConnect: MACRA Quality Payment Program (QPP)

– https://clientconnect.allscripts.com/groups/macra/overview

• CMS QPP website:

– https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-

Based-Programs/MACRA-MIPS-and-APMs/Quality-Payment-Program.html

Page 43: Jim Brulé, Solutions Director - Regulatory A Focused Look ... · Base Score - Alternate Proposal Base score has Stage 2 rules. Copyright © 2016 Allscripts Healthcare Solutions,

Thank you!


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