How to get Prepared and Find Success with Meaningful Use Stage 2 and 3

Presented By: Iatric Systems Presenter Name: Kay Jackson

PROPOSED NPRM: Meaningful Use Stage 3: How You Can Succeed

Breaking News: Friday April 10th

•  New NPRM Outlines Proposed EHR Requirements •  Providers in 2015 through 2017 •  May not release final until August. Comment Period closed on June 15 PM https://s3.amazonaws.com/public-inspection.federalregister.gov/2015-08514.pdf

What Does this Mean????

First Change for Eligible Hospitals, removing: •  Demographics •  Vitals •  Smoking Status •  Structured Lab Results •  Patient List •  Summaries of Care (Core 12.1 and Core 12.3

only) •  eMAR •  Advance Directives •  Electronic Notes •  Imaging Results •  Family Health History

Change in Reporting Period •  Proposing a 90-day MU period for

2015 only-any 90 days! •  2015 Reporting Period: Hospitals

would be able to choose any 90-day range between 10/1/14 through 12/31/15-does not need to match a quarter!

Change Portal Measure Core 6

•  The View/Download/Transmit changed

•  From >5% to AT LEAST 1 PATIENT •  Not 10 or 10%, but 1 patient!

eRX Will be Required-Menu now

•  No more Menu and Core •  The remainder of the measures will be required •  BUT FYI: Stage 2 objectives for an EHR reporting period in 2015 who were not intending to attest to the eRx menu objective and measure may also claim an exclusion

What About Core 12?

Goodbye Core 12.1 and Core 12.3: (1) uses CEHRT to create a summary of care record; and (2) electronically transmits such summary to a receiving provider for more than 10 percent of transitions of care and referrals.

How Many Comments?

Medicare and Medicaid Programs; Electronic Health Record Incentive Program--Modifications to Meaningful Use in 2015 through 2017 http://www.regulations.gov/#!documentDetail;D=CMS-2015-0045-0001 What is your guess for total?

Stage 3 Update-Now just waiting game

How Many Comments? (Closed 5/29)

EHR Incentive Program Stage 3 http://www.regulations.gov/#!documentDetail;D=CMS-2015-0033-0002 What is your guess for total?

First Thing to Know About Stage 3:

•  Stage 3 info is All Proposed at this time •  Final regulations due this Fall?? •  NPRM released on March 20, 2015 •  Comment Period ended: Friday May 29th •  Cost of program from 2017-2020 is $3.7 billion •  Have not yet seen the Method Description Overview: •  EHs, CAHs and EPs have same 8 Objectives •  Core and Menu no longer apply

Proposed Transitions of Care

•  All discharges from an inpatient setting are considered transitions of care

•  For transitions from an emergency department, eligible hospitals and CAH's must count any discharge where follow up care is ordered by an authorized provider, regardless of how complete the information available to the receiving provider

Stage 3 will bring enormous change:

•  Data deluge and unprecedented access and interoperability of clinical information in electronic health records

•  Liberation of clinical data •  Empowering payer to push for standardized

data and assist ACO’s •  $45 billion annually paid by Medicare for medical

care that was medically unnecessary or not acceptable documentation

Electronic Submission of Medical Documentation (esMD )

•  Uses C-CDA (term used over 100 times in the proposed rule)

•  ID and reduce cost for federal payers •  Private payers will also use

http://www.healthit.gov/sites/default/files/c-cda_and_meaningfulusecertification.pdf

What are key dates?

1/1/2017 •  Changing reporting period to calendar year and full 365 days •  Voluntary Stage 3 reporting •  Attestation between 1/1/18 and 2/28/2018 1/1/2018 •  All providers regardless of Stage must to track Stage 3 and EP, EH

and CAH all same measures •  Attestation between 1/1/19 and 2/28/2019 12/31/2019 •  Stage 3 ends-as of now Stage 4 will not occur •  Attestation between 1/1/2020 and 2/28/2020 •  BUT appears you may need to continue to report measures

Payment Adjustments and Hardships

•  Lack of internet •  New EP or EH-one time exception •  Natural disasters case by case •  EP only exceptions due to a combination of

clinical features limiting a provider's interaction with patients

Certification Requirements

•  Some changes in criteria •  2015 Edition Health IT Certification Criteria-all

providers use starting 2018 •  API cert added •  ONC ACBs has new and revised conduct •  “Common Clinical Data Set” replaces “Common

MU Dataset” •  Have you seen the facelift for CHPL?

New Terms

•  “ONC HIT Certification Program” to “ONC Health IT Certification Program”

•  “EHR Module” to “Health IT Module” •  “EHR” and “EHR Technology” to “Health IT”

Proposed Objective 1: Protect Health Information

•  Yes/No Measure •  Expanded explanation •  Administrative safeguards •  Risk Analysis-reviewed each year-365 days •  Risk Analysis upon upgrade to a new Edition

of certified EHR technology •  Review and update ongoing

Proposed Objective 1 Resources:

Guidance of Risk Analysis Requirement under HIPAA Security Rule: http://www.hhs.gov/ocr/privacy/hipaa/administrative/securityrule/rafinalguidancepdf.pdf Security Risk Assessment Tool (SRA Tool): http://www.healthit.gov/providers-professionals/security-risk-assessment-tool

Proposed Objective 2: Electronic Prescribing •  >80% measure •  Permissible prescriptions •  Controlled substances (EPCS) now legal in many

states-why? •  Median Rate 53% •  OTC not included •  EP and EH exclusions •  Stage 3 will be only new and changed RX •  Formulary unavailable –can count

Proposed Objective 3: Clinical Decision Support (CDS)

•  Two Yes/No Measures •  Same as Stage 2 except:

•  Explained relevant point of care •  Types of CDS allowed •  Implement CDS interventions which relate to care

quality improvement goals and a related outcome measure CQM

•  Only exclusions are for EP

Objective 3: Measure 1

•  Must implement five clinical decision support interventions related to four or more CQMs at a relevant point in patient care for the entire EHR reporting period.

•  Absent four CQMs related to an EP, EH, or CAH's scope of practice or patient population, the clinical decision support interventions must be related to high-priority health conditions.


•  The Provider must enable and implement the functionality for drug-drug and drug-allergy interaction checks for the entire EHR reporting period

Proposed Objective 4: CPOE •  Three % Measures to track-just like Stage 2 but Stage 3 expands to include diagnostic imaging to included ultrasound, magnetic resonance and computed tomography •  Orders entered by any licensed healthcare professional

or credentialed medical assistant •  CPOE function should be used the first time the order

becomes part of the patient's medical record and before any action can be taken on the order

•  Protocol and standing orders still excluded


•  >80% Medication orders via CPOE •  Median score of 93% •  Stage 2 requirement is >60%


•  >60% lab orders via CPOE •  Median score of 80% •  Stage 2 requirement is >30%


•  >60% diagnostic imaging orders •  Unique Patient Measure •  Median score of 83% required •  Stage 2 requirement is >30%

Proposed Objective 5: Patient Electronic Access to Health Information •  Two % measures to track •  Some exclusions •  Unique patient measure •  API-new functionality to support data access

and patient exchange (application programming interface)

•  Patients will be able to collect their health information from multiple providers and potentially incorporate all of their health information into a single portal

Example: Apple Health

NEW for Stage 3: API

If the provider elects to implement an API, the provider would only need to: •  Fully enable the API functionality •  Provide patients with detailed instructions

on how to authenticate •  Provide supplemental information on

available applications which leverage the API

Proposed Objective 5 Measure 1:

•  >80% The EP, EH or CAH provides access for patients to view online, download, and transmit their health information, or retrieve their health information through an API, within 24 hours of its availability

•  Stage 2 requirement is >50% •  Stage 2 currently is EH/CAH within 48 hours, and EP

is within 4 business days ** Use Demo Recall –historical measures

Quote from CMS:

“The Objective does not require the Provider to made extraordinary efforts to assist patients in use or access of the information, but the provider must inform patients of these options, and provide sufficient guidance so that all patients could leverage this access.” WHAT???? How else would you reach the %?

Proposed Objective 5 Measure: Three Options: 1.  Access provided with a portal 2.  Access provided with an ONC-certified API 3.  Access provided to an ONC-certified API that

can be used by third-party applications or devices to provide patients (or patient-authorized representatives) access to their health information


•  >35% The EP, EH or CAH must use clinically relevant information from CEHRT to identify patient-specific educational resources and provide electronic access to those materials of unique patients seen by the EP or discharged from the EH or CAH inpatient or emergency department (POS 21 or 23) during the EHR reporting period

•  For Stage 2, Patient Education was covered in Core 10 and required >10%

In Proposed Objective 5:

•  The providers may withhold from online disclosure any information either prohibited by federal, state, or local laws or if such information provided through online means may result in significant harm.

Proposed Objective 6: Coordination of Care through Patient Engagement

•  Three % Measures and Providers must report on all three but must meet two

•  Some exclusions •  Unique patient measure •  Stage 3 removed “paper communications”


•  >25% VDT patient or authorized representative •  Stage 2 requirement is >5% and EH struggled •  EH Median score of 11% •  Two options:

•  Standard method portal •  Or API


•  >35% a secure message was sent using electronic messaging function of CEHRT to the patient OR in response to a secure message sent by the patient (or authorized representative) and provider must respond.

Provider/Patient situation:

“For measure 2, we propose to include in the measure numerator situations where providers communicate with other care team members using the secure messaging function of certified EHR technology, and the patient is engaged in the message and has the ability to be an active participant in the conversation between care providers.”

Q: What types of communication is excluded?

A: “However, we note that messages with content exclusively relating to billing questions, appointment scheduling, or other administrative subjects should not be included in the numerator.”


>15% non clinical incorporated into EHR-ED and inpatients

Proposed Objective 7: Health Information Exchange

•  Three % Measures and providers must report on all three but must meet two

•  Some exclusions •  Stage 3 must include the requirements and

specifications included in the Common Clinical Data Set (CCDS)

•  Unique device identifier (UDI) for implantable medical devices

Note: Big Changes to Summary of Care

•  The purpose of this objective is to ensure a summary of care record is transmitted or captured electronically and incorporated into the EHR for patients seeking care among different providers in the care continuum, and to encourage reconciliation of health information for the patient

•  Provider incorporates summary of care information from other providers into their EHR using the functions of certified EHR technology

Referral Definition

•  Referrals are cases where one provider refers a patient to another provider, but the referring provider also continues to provide care to the patient

•  Stage 3 Change: The inclusion of transitions of care and referrals in which the recipient provider may already have access to the medical record maintained in the referring provider's CEHRT, as long as the providers have different billing identities within the EHR Incentive Program


•  >50% patients create a summary of care and electronically exchange

•  Stage 2 requirement is combination of paper and electronic paper-NO MORE PAPER

•  Allows just clinically relevant lab tests •  Provider discretion where beneficial


•  >40% of transitions or referrals incorporated in the EHR

•  Recipients actively seek to incorporate an electronic summary of care into the patients record


•  >80% where provider has never encountered the patient to perform clinical information reconsolidation:

•  Medication •  Medication allergy •  Problem list

Proposed Objective 8: Public Health and Clinical Data Registry Reporting: •  Yes/No measures •  EH and CAH must attest to a total of 4 •  Importance of communication that should

exist between providers and public health agencies

•  Some exclusions •  Remove "ongoing submission" requirement

and replace it with an "active engagement”

Active Engagement Option 1:

•  Registration to submit data •  Completed within 60 days of the start of the

reporting period •  If you are already registered, do not need to

submit registration


•  Testing and validation •  Providers must respond from PHA within 30

days •  Failure to response twice within a reporting

period –would not meet the measure


•  Production •  Completed testing and validation and

electrically submitting production date to the PHA (Public Health) or CDR (Clinical Data Registry)

CQMs

•  16 required CQMs •  Alignment between EHR Incentive Program and

CQM reporting programs such as IQR or PQRS •  CMS encourages EH/CAH to submit eCQMs for

2017 •  Starting 1/1/2018 must submit eCQMs *** •  CQM measure Certification not required until RP

2018 •  Between now and 2017, CQM can attest with

Core Measures, any version of the CQM’s OK

July 23, 2015

http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/eCQM_Library.html

FAQ 7/2/15

New FAQ related to reporting CQMs with a zero numerator and/or denominator

Resources

•  NPRM https://www.federalregister.gov/regulations/0938-AS26/electronic-health-record-ehr-incentive-programs-stage-3-cms-3310-p-

•  Data and Reports Median http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/March2015_HITPCPresentation.pdf •  HIMSS One Source http://www.himss.org/library/meaningful-use

•  Interoperable http://www.healthit.gov/sites/default/files/CMS-Stage-3-Meaningful-Use-proposed-rule%20_FactSheet.pdf

•  Federal Register https://s3.amazonaws.com/public-inspection.federalregister.gov/2015-06685.pdf •  Infographic Stage 3 http://www.healthcareitnews.com/infographic/infographic-stage-3-objectives-hospitals?mkt_tok=3RkMMJWWfF9wsRoisqjIZKXonjHpfsX56e8kX6G3lMI/0ER3fOvrPUfGjI4ETsZrI+SLDwEYGJlv6SgFQ7LHMbpszbgPUhM=

•  20 Things to know about MU http://www.beckershospitalreview.com/healthcare-information-technology/20-things-to-know-about-meaningful-use.html

Meaningful Use Stage 3: How You Can Succeed

Follow Us

Contact Us Iatric Systems Account Executive: [email protected] or visit our blog http://new.iatric.com/blog-home

Download the on-demand webcast here: http://bit.ly/1fwO18t

How to get Prepared and Find Success with Meaningful Use Stage 2 and 3

Healthcare

Transcript of How to get Prepared and Find Success with Meaningful Use Stage 2 and 3