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A Quick Glance at Meaningful Use “Proposed” Modifications for 2015 and MIPS

September 16, 2015Antonio Vega Sandy Swallow

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“Pending Review” Status

Changes mid-year and mid-program in the Final Rule

Proposed

Modified

Stage 2

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A Quick Glance:• Program goals and long term program alignment• Updated participation timeline • Significant program changes for 2015• Medicare Incentives beyond 2017• MIPS

Today’s ObjectivesProposed

Modified

Stage 2

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Modified Stage 2 Goals• Align with Stage 3 proposed rule• Align reporting period with full calendar year for ALL• Change reporting period to 90-day period in 2015

– EH 10/1/2014 to 12/31/15– EP 1/1/15 to 12/31/15

• Synchronize objectives and measures to reduce burden– Remove redundant, duplicative, and topped out– Modify patient action measures related to patient engagement

Program GoalsProposed

Modified

Stage 2

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Timeline, Stages and Vendor Requirements

2015

• All participants attest to modified version of Stage 2; with accommodations for Stage 1 Providers; 2014 CEHRT

2016

• All EH and EP attest to modified version of Stage 2, at stage 2 thresholds; 2014 or 2015 CEHRT

2017

• Attest to either modified version of Stage 2 or full version of Stage 3; 2014 or 2015 CEHRT

2018

• Attest to full version of Stage 3 with 2015 CEHRT

Long Term Program Alignment Proposed

Modified

Stage 2

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Updated MU Timeline Proposed

Modified Stage 2

First Payment

YearStages of Meaningful Use

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021

2011 1 1 1 2 2 2 2 or 3 3 3 3 3

2012 1 1 2 2 2 2 or 3 3 3 3 3

2013 1 1 2 2 2 or 3 3 3 3 3

2014 1 2* 2 2 or 3 3 3 3 3

2015 2* 2 2 or 3 3 3 3 3

2016 2 2 or 3 3 3 3 3

2017 2 or 3 3 3 3 3

* Special accommodations for Stage 1 providers

Everyone Moves to Stage 3 in 2018

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Program Changes

• 9 Core Criteria

• 1 Public Health Criterion

Proposed

Modified

Stage 2

Applies to all eligible professionals, hospitals and critical access hospitals

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Objective EP Measure EH MeasureProtect Elec Health Info Conduct SRA/correct deficiencies Same

Clinical Decision Support 5 rules related to 4+ CQM; drug/drug and drug/allergy interaction check

Same

CPOE >60% med, >30% lab, > 30% radiology Same

eRx >50%; drug formulary query >10%; drug form. query

Summary of Care Use CEHRT to create summary; >10% electronically transmit

Same

Patient Specific Education >10% unique patients Same

Medication Reconciliation >50% transitions of care Same

Patient Elec Access (VDT) >50% timely access; 1 patient VDT Same

Secure Messaging Fully enabled n/a

Public Health 5 measure options 6 measure options

MU Objectives 2015 -2017

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Removed Measures

• Record Demographics• Record Vital Signs• Record Smoking Status• Structured Lab Results• Patient List• Electronic Notes• Imaging Results• Family Health History

• Summary of Care– Measure 1 and 3

• Clinical Summaries (EP)• Patient Reminders (EP)• eMAR (EH)• Advanced Directive (EH)• Structure Labs to

Ambulatory Providers (EH)

Proposed

Modified

Stage 2

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Relaxed MeasuresProposed

Modified

Stage 2

Objective Old CurrentPatient Electronic

Access (View, Download or Transmit)

Measure = 5% of the patients

Measure = 1 patient

Secure Messaging with Patients

Measure = 5% of the patients

Yes/No, stating “functionality fully

enabled”Public Health Objective

and Clinical Data Registry

Multiple One consolidate with 6 measures

- EH must attest to 3- EP must attest to 2

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Modified Stage 2 Objectives

Public Health and Clinical Data Registry (CDR) Reporting

Attest to any 2 (EP) or 3 (EH)…1. Immunization registry reporting (bi-directional)2. Syndromic surveillance reporting3. Case reporting4. Public health registry reporting*5. Clinical data registry reporting*6. Electronic Reportable Laboratory Reporting

https://www.idph.state.ia.us/meaningful_use.aspm

*May choose to report to more than one registry to meet the number of measures required

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Modified Stage 2 - Clinical Quality Measures

Clinical Quality Measures

• 9 measures out of 64, covering at least three domains

• None are “required” but some are recommended

• Zero in the denominator is a positive response

• Can report through the PQRS portal

• CQM reporting period can be different than the rest of MU

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Accommodations for Stage 1 Providers

You are attesting to Stage 1 in 2015…

• Stage 1 based on the same 10 objectives

• Attest to Stage 1 thresholds• Will take an exclusion for the

Stage 2 measures if there is no equivalent Stage 1 measure

• Menu objectives move to core objectives

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Objective Alternate Measure, Exclusion/SpecificationsProtect Elec Health Info None

CDS Implement one CDS rule EP; no exclusion EH

CPOE >30% med, exclusion for lab and radiology

eRx >40 % EP; exclusion EH Stage 1 and Stage 2 did not intend to demonstrate as a Menu in Stage 2

Summary of Care Exclusion

Pt-Specific Education Exclusion, if did not intend to demonstrate as a Menu objective in Stage 1

Med. Reconciliation Exclusion, if did not intend to demonstrate as a Menu objective in Stage 1

Pt. Electronic Access Exclusion

Secure Electronic Messaging Exclusion

Public Health None

Accommodations for Stage 1 Providers

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Hospital-Based EPsProposed

Modified

Stage 2

Qualifications for Hospital-Based EPs• Include place of service 22 (outpatient) for those EPs

considered hospital-based*• EP is ineligible for incentive payment and payment

adjustments if >90% covered professional services in sites of service identified as:– POS 21 (inpatient)– POS 22 (outpatient)*– POS 23 (emergency room)

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• Attestation will not begin until after January 1, 2016

• In 2015 only - First time EH and EP participants will have until February 29, 2016 to attest; but may be subject to a payment adjustment on claims submitted prior to attestation to MU for an EHR reporting period in 2015

Attestation UpdatesProposed

Modified

Stage 2

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• Hardship Exceptions were due July 1, 2015– Lack of Infrastructure– Unforeseen and/or Uncontrollable Circumstances– Lack of Control over the Availability of Certified EHR Technology– Lack of Face-to-Face Interaction

• Began in January 2015; 1% and increases every year until 2018 when government makes a decision

• Annual attestation required to avoid adjustment

Payment Adjustments Facts

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Merit-Based Incentive Payment System (MIPS)

• Federal Quality Program combines PQRS, MU and VBM• Replaces the SGR reimbursement formula• Goal is to lower cost while improving quality of care by

rewarding high-performers and penalizing low-performers based on a composite threshold score

• 2017 will be the first performance year

Medicare Incentives Beyond 2017

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• 2019 & 2020 (First two years)– Physicians, PAs, Certified Registered Nurse Anesthetists, NPs, Clinical

Nurse Specialists, Dentists, Podiatrist and Groups that include such professionals

• 2021 onward– Dietitians, Midwives, Psychologist and most other healthcare

professionals

• Excluded EPs– Qualifying APM participants– First year Medicare participation– Low volume threshold exclusions

• MIPS DOES NOT apply to RHC or FQHC payments

Eligibility for MIPS

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Potential Annual Score 0-100 Points

Quality 30 pts.

Resource Use 30 pts.

Meaningful Use 25 pts.

Clinical Practice Improvement

15 pts.

MIPS Assessment Categories

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Payment Alignment

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• Telligen: Quality Innovation Network-Quality Improvement Organization (QIN-QIO) for Colorado, Illinois and Iowa

Telligen QIN QIO

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Thank you!

QIN-QIO Contact:Sandy Swallow515.223.2105

Sandy.swallow@area-d.hcqis.orgtelligenqinqio.com

IHIN Contact:Antonio Vega515.362.8311

avega@telligen.com

This material was prepared by Telligen, the Medicare Quality Innovation Network Quality Improvement Organization, under contract with the Centers for Medicare & Medicaid Services (CMS), an agency of the U.S. Department of Health and Human Services. The contents presented do not necessarily reflect CMS policy. 11SOW-QIN-B4-9/2015-11239