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practices and overviews, generalities, and some laws. This should not be used as legal advice. Itentive recognizes that
there is not a “one size fits all” solution for the ideas expressed in this webinar;
we invite you to follow up directly with us for more personalized information as it pertains to your specific practice and
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Thank you, and enjoy the webinar.
Upcoming Webinars: 4 Part Series
Government Regulations & Ramifications • Meaningful Use Audits (November 11th)
• EHR Cloning (November 18th)
• The Dangers of Information Blocking and Its Effect on Interoperability (December)
• HITECH Security and HIPAA (December)
Meaningful Use Final Rule
ITENTIVE WEBINAR SERIES
Introductions
Kathy ThompsonManaging Consultant
Cindi KincadeVice President,
Consulting Solutions
Lindsey LanningHealthcare Informatics
Coordinator
Finalized Meaningful Use Rules
The Good News: We finally know exactly what we need to do…
The Bad News: It requires a lot of changes and stringent timelines.
And…We’re Already Behind Before We’ve Even Gotten
Started…
What has happened since
the proposed rule?
There has been Pressure
There have been 6 separate times over a 4 month period where industry stakeholders, hospital associations, provider associations, and even Congress have published letters or press releases calling for the proposed rules to be finalized and/ or delayed.
There has been New Legislation • New legislation has been introduced that would modify Stage
2 and delay Stage 3 Meaningful Use. This bill, called the Flex-IT 2 Act, points out five provisions:
• Delay Stage 3 rulemaking until at least 2017, unless at least 75% of EPs and hospitals are successful in meeting the Stage 2 requirements;
• Harmonize government quality reporting requirements to remove duplicative measurement and streamline requirements from CMS;
• Institute a 90-day reporting period for each year, regardless of stage or program experience;
• Encourage interoperability among EHR systems; and
• Expand hardship exemption categories
• Medicare Access and CHIP Reauthorization Act
There have been Changes from the Proposed Rules
• 90-day Reporting Period Extended All new MU participants 2015-2017
Providers who choose to attest to Stage 3 in 2017
• Stage 3 Measure Thresholds CPOE
E-prescribing
Coordination of Care
• Public Health Reporting Requirements Only have to attest to 2 out of 3 measures
Meaningful Use Modified Stage 2
Final Rule
CMS Finalized MU Relaxation Rule
On October 6, 2015 The Centers for Medicare & Medicaid Services (CMS) released final rules that simplify requirements and add new flexibilities for providers to make, electronic health information available when and where it matters most and for health care providers and consumers to be able to readily, safely, and securely exchange that information.
Changes for Modified Stage 2
Modifies patient action measures in Stage 2 objectives related to patient engagement.
Changes the reporting period requirements for 2015 to a 90-day period and aligns it with the calendar year.
Removes reporting requirements on redundant, duplicative, or topped out measures, therefore reducing the overall number of objectives.
Modifies public health reporting requirements.
Purpose of Modifications
CMS has heard from physicians and other providers about the challenges they face making this technology work well for their individual practices and for their patients. In recognition of these concerns, the regulations make significant changes in current requirements. They will ease the reporting burden for providers, support interoperability, and improve patient outcomes.
Changes to Participation Timeline
2015 Attest to modified version of Stage 2 with accommodations for Stage 1 providers
2016 Attest to modified version of Stage 2
2017 Attest to either modified version of Stage 2 or full version of Stage 3
2018 Attest to full version of Stage 3
Participation Changes• Meaningful Use Stage 3 was originally slated to begin in
2017 for providers that had completed Stage 2; now 2017 is a flex year. This means that providers who would have progressed from Stage 2 to Stage 3 in 2017 now have the option to stay in Stage 2 an additional year. Only providers who use an EHR certified to the 2015 ONC standards will be allowed to attest to Stage 3. However, if you do attest to Stage 3 in 2017 you are now being offered a 90-day reporting period.
• Every provider will be Meaningful Use Stage 3 in 2018 even if 2018 is the provider’s first reporting year – In order to simplify the Meaningful Use program, all providers will be in the same stage at that point. All providers will also be using EHR certified to the 2015 ONC standards.
Participation Changes
This means Stage 1 of Meaningful Use is essentially gone with additional exemptions for those scheduled to meet Stage 1. Stage 2 and 3 are the only MU stages available for attestation.
Reporting Period Changes
2015Any continuous 90 days for all providers
with a February 29, 2016 attestation deadline.
2016Any continuous 90 days for all first-time attesters and a full year for all returning
attesters.
2017Any continuous 90 days for all first-
time attesters and providers pursuing Stage 3 option. A full year for all
returning attesters.
2018 Full year for all providers.
Goals of Provisions
1. Align with Stage 3 to achieve overall goals of the program.
2. Synchronize reporting period objectives and measures to reduce provider burden.
3. Continue to support advance use of health IT to improve patient outcomes by focusing on interoperability and advanced EHR usage.
4. Align with the new MACRA law.
5. Get all providers to the same place in Meaningful Use.
Aligning Modified Stage 2 with Stage 3
• This rule reconciles measures to align the new modified Stage 2 with Stage 3 by:
Preparing providers to report Stage 3 criteria in 2018.
Reducing the provider burden and creating a single set of sustainable objectives that promote best practices for patients.
Enabling providers to focus on objectives which support advances use of health IT, such as:
• Health information exchanges
• Consumer engagement
• Public health reporting
Core and Menu Concept Change
• Because of the restructuring of measures, the concept of core and menu will be discontinued in favor of choices within certain objectives.
• The new reporting structure is outlined here:
Removed MU Objectives
CMS states that many of these redundant, duplicative, or topped out objectives and measures may be valuable to providers and patients–They encourage providers to continue to conduct these activities if it suits their practice and patient population.
• Patient Reminders• Electronic Notes• Imaging Results• Family Health History• Summary of Care
Measure 1 –Any Method Measure 3 –Test
• Record Demographics• Record Vital Signs• Record Smoking Status• Clinical Summaries• Structured Lab Results• Patient List
CMS has identified the following objectives as either redundant, duplicative, or topped out and will no longer require attestation on them.
Changes to MU Objectives
Changes made to objectives listed below will be effective for EHR reporting for EP’s beginning in 2015. • Patient Access Objectives
• Public Health Objectives
Changes to Patient Access Objectives
• Changes the threshold that more than 5% of patients must view, download, or transmit health information to just ‘1’ patient needing to do so.
• Changes the threshold that a secure message must be sent using electronic messaging of CEHRT by more than 5% of patients to just having secure messaging fully enabled.
Changes to Public Health Objectives
• Stage 2 provider is required to ‘successfully engage’ in any combination of 2 public health measures, unless through exclusions less than 2 options remain.
• Stage 1 provider is required to ‘successfully engage’ in 1 public health measure, unless all exclusions are met.
• This consolidates all public health reporting objectives into one objective with measure options following the same structure of Stage 3 Public Health Reporting.
What will 2015 look like?• Providers will attest to a single set of
blended Stage 1 and Stage 2 objectives and measures.
No core or menu measures.
This single set of blended objectives is being called modified Stage 2.
• All reporting will be for 90 days.
• Accommodations by multiple exclusions and alternative measures within individual objectives will be made for providers who would have been in different stages of MU.
• CQMs will be reported electronically or attested to; CQM 90 day period doesn’t need to coincide with the 90 day MU attestation period.
Finalized Rules for MU Modified Stage 2
Broken down by Notable Objectives
Modified Stage 2 Objectives1. Protect patient heath information
2. Clinical decision support
3. Computerized physician order entry (CPOE)
4. E-prescribing
5. Health information exchange
6. Patient Specific Education
7. Medication Reconciliation
8. Patient access to health information
9. Secure Messaging
10. Public health reporting
Protect Patient Health Information
Protect electronic health information created or maintained by the CEHRT through the implementation of appropriate technical capabilities.
Conduct or review a security risk analysis including addressing the security (including encryption) of data stored in CEHRT and implement security updates as necessary, and correct identified security deficiencies as part of the provider’s risk management process. • No exclusion
Ob
ject
ive
Mea
sure
(s)
Clinical Decision Support
Use clinical decision support to improve performance on high-priority health conditions.
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 CQMs related to EP’s scope of practice or patient population, the clinical decision support interventions must be related to high-priority health conditions.
Measure 2: The EP has enabled and implemented the functionality for drug-drug and drug-allergy interaction checks for the entire EHR reporting period.
• For Measure 2, you can be excluded if you write fewer than 100 medication orders during the reporting period.
Ob
ject
ive
Mea
sure
(s)
Computerized Provider Order EntryUse CPOE for medication, laboratory, and radiology orders directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local, and professional guidelines.
Measure 1: More than 60% of medication orders created by the EP or authorized providers during the EHR reporting period are recorded using CPOE.Measure 2: More than 30% of laboratory orders created by the EP or authorized providers during the EHR reporting period are recorded using CPOE.Measure 3: More than 30% of radiology orders created by the EP or authorized providers during the EHR reporting period are recorded using CPOE.
You can be excluded individually from meeting each of the above measures for the ones that you have fewer than 100 orders during the reporting period.
Ob
ject
ive
Mea
sure
(s)
Electronic Prescribing
Generate and transmit permissible prescriptions electronically (eRx).
More than 50% of all permissible prescriptions written by the EP are queried for a drug formulary and transmitted electronically using CEHRT.• You can be excluded from meeting this objective if you write
fewer than 100 prescriptions during the reporting period, or
• Do not have a pharmacy within your organization and there are no pharmacies that accept electronic prescriptions within 10 miles of the EP's practice location at the start of your EHR reporting period.
Ob
ject
ive
Mea
sure
(s)
Health Information Exchange
The EP who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care provides a summary care record for each transition of care or referral.
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.
You can be excluded from meeting this objective if you transfer a patient to another setting or refer a patient to another provider fewer than a 100 times during the reporting period.
Ob
ject
ive
Mea
sure
(s)
Patient Specific EducationUse clinically relevant information from CEHRT to identify patient-specific education resources and provide those resources to the patient.
Patient specific education resources identified by CEHRT are provided to patients for more than 10% of all unique patients with office visits during the reporting period. To count for this objective educational material given must be identified by the CEHRT.
• You can be excluded if you have no office visits during the reporting period.
Ob
ject
ive
Mea
sure
(s)
Medication Reconciliation
The EP that receives a patient from another setting of care or provider of care or believes an encounter is relevant performs medication reconciliation.
The EP performs medication reconciliation for more than 50% of transitions of care in which the patient is transitioned into your care. • You can be excluded if you are not the recipient of
any transitions of care during the EHR reporting period.
Ob
ject
ive
Mea
sure
(s)
Patient Electronic AccessProvide patients the ability to view online, download, and transmit their health information within 4 business days of the information being available to the EP.
Measure 1: More than 50% of all unique patients are provided timely (within 4 business days after the info is available to the EP) access to view online, download, and transmit to a third party 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 reporting period (or their authorized representatives) views, downloads, or transmits their health information to a third party during the EHR reporting period.
You can be excluded if you neither order nor create any of the info listed for inclusion. You can be excluded if you conduct 50% or more of encounters in a county that does not
have 50% or more housing units with 4Mbps broadband availability according to the latest information available on the first day of the EHR reporting period.
For an EHR reporting period in 2017, more than 5% of unique patients seen by the EP during the EHR reporting period view, download or transmit to a third party their health information during the EHR reporting period.
Ob
ject
ive
Mea
sure
(s)
Secure Electronic MessagingUse secure electronic messaging to communicate with patients on relevant health information.
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.
For an EHR reporting period in 2016, for 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.
For an EHR reporting period in 2017, for more than 5 percent of unique patients 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.
• You can be excluded if you have no office visits.
• You can be excluded if you conduct 50% or more of encounters in a county that does not have 50% or more housing units with 4Mbps broadband availability according to the latest information available on the first day of the EHR reporting period.
Ob
ject
ive
Mea
sure
(s)
Public Health Reporting
The EP is actively engaged with a PHA or CDR to submit electronic public health data in a meaningful way using CEHRT, except where prohibited, and in accordance with applicable law and practice.
The EP is required to successfully attest to any combination of 2 measures from 3 available:
*Exclusions are available for Eligible Providers
Reporting MeasuresMax times measure can count
towards objective
Immunization registry reporting 1
Syndromic surveillance reporting 1
Specialized registry reporting 2
Ob
ject
ive
Mea
sure
(s)
NextGen Share and Registries • Clients may register intent with these
registries for 2015 MU Reporting
• Testing and implementation dates TBA
• Pricing is based on what each registry charges American College of Physicians Genesis Registry
American College of Physicians Diabetes Registry
American College of Physicians Immunization Registry
American Academy of Allergy Asthma and Immunology Clinical Data Registry
Oncology Nursing Society Quality Improvement Registry
American Joint Replacement Registry Orthopaedic Quality Resource Center
American Gastroenterological Association Clinical Data Registry
National Osteoporosis Foundation Quality Improvement Registry
Renal Physicians Association Kidney Quality Improvement Registry
Active Engagement Active engagement is defined as:
• Option 1: Completed registration to submit data:
Registration was completed within 60 days of the start of the EHR reporting period and the EP is awaiting an invitation from the PHA or CDR to begin testing.
• Option 2: Testing and Validation:
EP is in the process of testing and validation of the electronic submission of data. EPs must respond to requests from the PHA within 30 days; failure to respond twice within a reporting period would result in failure to meet this objective.
• Option 3: Production:
EP has completed testing and validation and is electronically submitting production data to PHA or CDR.
Finalized Objectives Modified Stage 2 vs. Stage 3
(Modified) Stage 2 Objectives Stage 3 Objectives
1. Protect Health Information 1. Protect Health Information
2. e-Prescribing 2. e-Prescribing
3. Clinical Decision Support 3. Clinical Decision Support
4. CPOE 4. CPOE
5. Health Information Exchange 5. Patient Electronic Access
6. Patient- Specific Education6. Coordination of Care through Patient
Engagement
7. Medication Reconciliation 7. Health Information Exchange (HIE)
8. Patient Electronic Access 8. Public Health and Clinical Registry
Reporting
9. Secure Messaging
10. Public Health
Meaningful Use Stage 3 Important Facts
• There were some changes made from the proposed stage 3 rule that were relaxed: CPOE and e-prescribing measures decreased from the
proposed threshold of 80% to 60%
Coordination of Care measures all decreased from 25%, 35%, and 15% to 5%
Public health reporting changed from 3 out of 5 measures to 2 out of 5 measures
• The final rule also includes a 60-day comment period on the stage 3 portion of the rule.
• In order to attest to MU Stage 3 you will need to have CERHT to the 2015 Criteria.
2015 Participation and Reporting• EHR reporting period is based on the calendar
year (1/1/2015-12/31/2015) and is any continuous 90-day period within that date range.
• Providers can attest for EHR reporting period in 2015 beginning 1/4/2016
• For EHR reporting period 2015, all Medicare providers must attest by 2/29/2016
• Use of CEHRT certified to the 2014 Criteria is necessary
• Still need to submit CQMs
CQM Basics
• For EHR reporting period 2015, all EP’s may attest for any continuous 90-day period of CQM data. Same rule applies for first-time EPs in 2016
• For all returning providers for reporting period 2016 and beyond, one full calendar year of attestation is required.
• CQM selection and reporting requirements have not changed and providers do have the option to electronically report.
NextGen HQM• Stage 1 Users:
Users will be automatically enrolled in MU2 program, Stage 1 measure from Modified rule, and Stage 2 Modified measures.
Provider, Practice, and Date configuration will be intact.
• Stage 2 Users:
Automatically enrolled in Modified Stage 2.
Existing configurations will be intact.
• All Users:
Need to complete new configurations with adding or removing measures, changes to date range, and new measures listed first.
• All measures, including removed ones, will remain in HQM with the core/menu naming convention changed.
Q: The final rule was released so late what if I can’t meet the
modified stage 2 MU requirements for 2015?
A: CMS states you can apply for the hardship exception under the extreme and uncontrollable
circumstances category.
Take Action Now
• Confirm your Stage Determine if you are considered a Stage 1
provider scheduled for 2015 or a Stage 2 provider
• Check Registration Information Login Payment Information Email Address EHR certification number
Questions• Lindsey Lanning
Healthcare Informatics Coordinator [email protected] 224-220-5621
• Kathy Thompson Managing Consultant [email protected] 224-220-5531
• Cindi Kincade Vice President, Client Solutions [email protected] 224-220-5575
Thank you
