Meaningful Use 3 Proposed Rule Paul Kleeberg, MD, FAAFP, FHIMSS - - PowerPoint PPT Presentation

Meaningful Use 3 Proposed Rule

Paul Kleeberg, MD, FAAFP, FHIMSS Burning Issues Webinar May 26, 2015

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Objectives

• Provide an overview of the proposed

changes Stage 3 starting in 2017

• Provide a framework for colleting

feedback for the Proposed Rule

• Enable you to provide your feedback to

CMS

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Lake Superior Quality Innovation Network

• Three quality improvement organizations:

– MPRO in Michigan – Stratis Health in Minnesota – MetaStar in Wisconsin

• Collaboration to improve health care for

Medicare consumers, share best practices and maximize efficiencies

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3

Bending the Curve Towards Transformed Health

Data capture and sharing Advanced clinical processes Improved

• utcomes

Stage 1 Stage 2 Stage 3 “Phased-in series of improved clinical data capture supporting more rigorous and robust quality measurement and improvement.”

Source: Connecting for Health, Markle Foundation “Achieving the Health IT Objectives of the American Recovery and Reinvestment Act” April 2009

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Meaningful Use Overview: Statutory Framework

• In HITECH, Congress established three

fundamental criteria of requirements for meaningful use:

– Use of certified EHR technology in a meaningful manner – The exchange of health information – Submission of clinical quality data

Adapted from: Brian Wagner, Senior Director of Policy and Public Affairs, eHealth Initiative (eHI) presentation to the MN Exchange and Meaningful Use Workgroup January 15, 2010

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The Proposed Rule for Stage 3

• Meaningful Use Stage 3

– Released: March 30, 2015 available in html at:

• https://www.federalregister.gov/articles/2015/03/

30/2015-06685/medicare-and-medicaid- programs-electronic-health-record-incentive- program-stage-3

– Comments Due: May 29, 2015 at:

• http://www.regulations.gov/#!submitComment;D=

CMS-2015-0033-0002

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NPRM 3 Calendar

2 2 X X X

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Reporting and Attestation for 2017 on

• Reporting:

– A full reporting year for all Medicare providers, even those in their first year – First year Medicaid only may report any 90 days

• However a full year will be required for Medicare

– Hospitals will have a calendar reporting year

• Attesting:

– No changes to the method – Reporting deadline is the last day of February

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Penalties and Exceptions

• Unchanged Except:

– Since reporting in 2017 on requires a full year, first timers will no longer be able to attest early in in the year to avoid the penalty in the next year.

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Miscellaneous Changes

• State Flexibility

– Unchanged

• Paper-based documents

– No longer count in numerators

• Medicaid providers who fall below the

threshold, can attest under Medicare to avoid the penalty without it constituting a switch in programs.

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Proposed Program Goals and Objectives

• Protect Patient Health Information
• Electronic Prescribing
• Clinical Decision Support
• Computerized Provider Order Entry
• Patient Electronic Access to Health

Information

• Health Information Exchange
• Public Health and Clinical Data Registry

Reporting

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Protect Patient Health Information

• Proposed Objective:

– Protect electronic protected health information (ePHI) created or maintained by the certified EHR technology (CEHRT) through the implementation of appropriate technical, administrative, and physical safeguards.

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Protect Patient Health Information

• Proposed Measure:

– Conduct or review a security risk analysis including addressing the security and encryption of protected health information (ePHI) stored in CEHRT

• ePHI includes all forms of electronic media, such as hard

drives, floppy disks, CDs, DVDs, smart cards or other storage devices, personal digital assistants, transmission media, or portable electronic media.

– Implement security updates as necessary, – Correct identified security deficiencies as part of the provider's risk management process.

• Measurement:

– Done each calendar year y/n

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Electronic Prescribing (eRx)

• Proposed Objective:

– EPs must generate and transmit permissible prescriptions electronically, and eligible hospitals and CAHs must generate and transmit permissible discharge prescriptions electronically (eRx).

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Electronic Prescribing (eRx)

• Proposed Measure:

– Prescriptions queried for a drug formulary, and transmitted electronically using CEHRT

• EPs: >80% all prescriptions (was 50%)
• EH/CAH: >25% discharge prescriptions (was10% & menu)
• Denominator:

– Number of prescriptions written (? Controlled substances, ? OTCs)

• Exclusions:

– EP: <100 prescriptions – EP and EH: No a pharmacy within their organization and none that accept eRx within 10 miles at the start of the reporting period.

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Clinical Decision Support (CDS) 2 Measures

• Proposed Objective:
• Implement clinical decision support (CDS)

interventions focused on improving performance on high-priority health conditions.

• Measures

– Must meet both measures.

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Clinical Decision Support (1 of 2)

• Measure 1:

– Implement 5 CDS interventions related to 4

• r more CQMs or

– Related to high-priority health conditions absent four CQMs related to scope of practice or patient population

• Exclusion:

– None

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Clinical Decision Support (2 of 2)

• Measure 2:

– Drug-drug and drug-allergy interaction checks enabled for the entire EHR reporting period.

• Exclusion:

– EP who writes fewer than 100 medication

• rders

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Computerized Provider Order Entry (CPOE) 3 Measures

• Proposed Objective:

– Use computerized provider order entry (CPOE) for medication, laboratory, and diagnostic imaging

• rders directly entered by any licensed healthcare

professional, credentialed medical assistant, or a medical staff member credentialed to and performing the equivalent duties of a credentialed medical assistant; who can enter orders into the medical record per state, local, and professional guidelines.

• Measures

– Must meet all three measures.

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Computerized Provider Order Entry (CPOE)

• Proposed Measures

– >80% of med orders (was 60%) – >60% of all lab orders (was 30%) and – >60% radiology orders (expanded definition) must be entered using CPOE (was 30%)

• Denominators:

– Unique orders

• Exclusions:

– Any EP who writes <100 medication, <100 radiology, or <100 laboratory orders during the EHR reporting period.

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Patient Electronic Access to Health Information (2 Measures)

• Proposed Objective:

– The EP, eligible hospital, 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. – (Ed materials not mentioned in objective)

• Proposed Measures:

– Must meet both measures.

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Patient Electronic Access to Health Information (1 of 2)

• Proposed Measure 1

– >80% of patients or their representative are provided timely eAccess to health information within within 24 hours of its availability to the provider to either:

• View, download, or transmit (VDT) their health information (was 50%

within 4 days)

• Access via an ONC approved application programming interface

(API)

• Denominator

– Unique patients

• Exclusions

– EP: No office visits. – All: ≥50% in a county with <50% of its housing units have 4 Mbps broadband at the start of the reporting period

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Patient Electronic Access to Health Information (2 of 2)

• Proposed Measure 2

– >35% of all unique patients are provided eAccess to patient-specific education resources identified by Certified EHR Technology (was 10%).

• Denominator

– Unique patients

• Exclusions

– EP: No office visits – All: ≥50% in a county with <50% of its housing units have 4 Mbps broadband at the start of the reporting period

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Coordination of Care through Patient Engagement

• Proposed Objective:

– Use communications functions of certified EHR technology to engage with patients or their authorized representatives about the patient’s care.

• Proposed Measures

– Attest to all 3 measures and pass 2

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Coordination of Care through Patient Engagement (1 of 3)

• Proposed Measure 1: VDT/API

– >25% of all patients or representatives

• View, download or transmit to a third party their health

information (was 5%) OR

• Access their health information through the use of an ONC-

certified API

– Note: Measure is not cumulative

• Denominator:

– Unique patients

• Exclusions:

– EP: No office visits – All: ≥50% in a county with <50% of its housing units have 4 Mbps broadband at the start of the reporting period

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Coordination of Care through Patient Engagement (2 of 3)

• Proposed Measure 2: Messaging

– >35% of all patients or their representatives were sent a secure message (was 5% EP Only)

• Denominator:

– Unique patients

• Exclusions:

– EP: No office visits – All: ≥50% in a county with <50% of its housing units have 4 Mbps broadband at the start of the reporting period

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Coordination of Care through Patient Engagement (3 of 3)

• Proposed Measure 3: Outside Data

– >15% of all patients charts have patient generated health data or data from a non-clinical setting incorporated into it. (New)

• Denominator:

– Unique patients

• Exclusions:

– EP: No office visits – All: ≥50% in a county with <50% of its housing units have 4 Mbps broadband at the start of the reporting period

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Health Information Exchange

• Proposed Objective:

– Provides a summary of care record when transitioning or referring their patient to another setting of care – Retrieves a summary of care record upon the first patient encounter with a new patient – Incorporates summary of care information from other providers into their EHR using the functions of certified EHR technology

• NOTE:

– View only access no longer qualifies – Labs and notes may be limited to clinically relevant but all must be e-retrieved if needed

• Proposed Measures

– Attest to all 3 measures and pass 2

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Health Information Exchange (1

• f 3)
• Proposed Measure 1: SoC

– >50% of transitions of care and referrals, the provider:

• Creates a summary of care record
• Electronically exchanges the summary of care record (was

10%).

• Denominator:

– Number of transitions of care and referrals.

• Exclusions:

– EP: No transfers or referrals – All: ≥50% in a county with <50% of its housing units have 4 Mbps broadband at the start of the reporting period

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Health Information Exchange (2

• f 3)
• Proposed Measure 2: Incorporate SoC

– >40% of available SoCs are incorporated for referrals, transitions or new patients (New)

• Denominator:

– Number of encounters that are referrals, transitions or new patients

• Exclusions:

– All:

• <100 referrals, transitions or new patients
• ≥50% in a county with <50% of its housing units have

4 Mbps broadband at the start of the reporting period

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Health Information Exchange (3

• f 3)
• Proposed Measure 3: Clin Info Rec

– >80% of referrals, transitions or new patients the provider reconciles:

• Medications (was 50%)
• Medication allergies (New)
• Current problem list (New)
• Denominator:

– Number of referrals, transitions or new patients .

• Exclusions:

– All:

• <100 referrals, transitions or new patients
• ≥50% in a county with <50% of its housing units have 4 Mbps

broadband at the start of the reporting period

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Public Health and Clinical Data Registry Reporting

• Proposed Objective:

– Active engagement with a public health agency (PHA) or clinical data repository (CDR) 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. – Active Engagement Definition:

• Completed Registration to Submit Data
• Testing and Validation
• Production
• Proposed Measures:

– Six possible measures for this objective

• EPs attest to any 3 of measures 1 through 5.
• EHs attest to any 4 of measures 1 through 6.

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Public Health and Clinical Data Registry Reporting 1 of 6

• Proposed Measure 1: Immunization

Registry

– 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).

• Exclusion:
• Does not administer immunizations
• No capable registry

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Public Health and Clinical Data Registry Reporting 2 of 6

• Proposed Measure 2: Syndromic

Surveillance

– Active engagement with a public health agency to submit syndromic surveillance data from a non-urgent care ambulatory setting for EPs, or an emergency or urgent care department for EHs.

• Exclusion:

– EP: Does not treat or diagnose or any disease

• r condition associated with a syndromic

surveillance system

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Public Health and Clinical Data Registry Reporting 3 of 6

• Proposed Measure 3: Case Reporting

– Active engagement with a public health agency to submit case reporting of reportable conditions.

• Exclusion:

– All:

• Does not treat reportable cases
• No capable agency or agency not ready

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Public Health and Clinical Data Registry Reporting 4 of 6

• Proposed Measure 4: Public Health

Registry

– Active engagement with a public health agency to submit data to public health

• registries. (Can count more than once)
• Exclusion:

– All:

• Does not treat reportable cases
• No capable agency or agency not ready

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Public Health and Clinical Data Registry Reporting 5 of 6

• Proposed Measure 5: Clinical Data

Registry

– Active engagement to submit data to a clinical data registry. (Can count more than

• nce)
• Exclusion:

– All:

• Does not treat reportable cases
• No capable agency or agency not ready

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Public Health and Clinical Data Registry Reporting 6 of 6

• Proposed Measure 5: Lab Results (EH)

– Active engagement with a public health agency to submit electronic reportable laboratory results.

• Exclusion:

– All:

• Does not perform reportable tests
• No capable agency or agency not ready

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• Eligible Professional

– Record Demographics – Record Vital Signs – Record Smoking Status – Clinical Summaries – Structured Lab Results – Patient List – Patient Reminders – Summary of Care Measure

• Any Method Measure
• Test different vendor and system

– Electronic Notes – Imaging Results – Family Health History

• Eligible Hospital/CAH

– Record Demographics – Record Vital Signs – Record Smoking Status – Structured Lab Results – Patient List – Summary of Care Measure

• Any Method Measure
• Test different vendor and system

– eMAR – Advanced Directives – Electronic Notes – Imaging Results – Family Health History – Structure Labs to Ambulatory Providers

Topped Out Measures

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Changes from 2014 Stage 2 to Stage 3

Measure Stage 2 2014 Stage 3 Security Risk Analysis C Y/N C Y/N ePrescribing (EP) C 50% C 80% Drug Formulary (EP) C Y/N C Y/N eRx with Formulary (EH) M 10% C 25% CDS C 5 C 5 Drug Interactions C Y/N C Y/N CPOE Medications C 60% C 80% CPOE labs C 30% C 60% CPOE Radiology C 30% C 60% Patient Ed C 10% C 35%

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Changes from 2014 Stage 2 to Stage 3

Measure Stage 2 2014 Stage 3 Have access to VDT (or API Stage 3) C 50% C 80% Actually VDT C 5% 2/3 25% Patients Use API 25% Secure messages C 5% 2/3 35% Incorporate Pt or other provider data 2/3 15% eSummary of Care C 10% 2/3 50% Incorporate eSummary 2/3 40% Clinical Info Reconcilliation 2/3 80% Immunization Registry C y/n EP: 3 of 5 EH: 4 of 6 Y/N Syndromic Surveillance EP: M EH: C y/n Y/N Case Reporting Y/N Public Health Registry Y/N Clinical Data Registry Y/N Reportable Labs (EH) C y/n Y/N

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2014 Stage 2 Measures Proposed to be Omitted from Stage 3

Measure Stage 2 2014 Stage 3

Summary of Care Any Method C 50% No paper eSoC Diff EHR & system C y/n ? Med Rec C 50% Clin Reg Demographics C 80% (eAccess) Vital Signs C 80% (eAccess) Smoking C 80% (eAccess) Family History M 20 ? Advanced Directives (EH) M 50% ? eMAR (EH) C 10% ? Provider Notes M 30% (SoC) Imaging Results M 10% ? Incorporate Labs C 55% (eAccess) Clinical Summaries (EP) C 50 (eAccess) Patient Lists C y/n ? Patient Reminders (EP) C 10% ? Provide eLab Results (EH) M 20% (eAccess)

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CQM Reporting in 2017

• Full year for all except first year MU

Medicaid only.

• May electronically report 2017 eCQMs or

attest to the 2016 eCQMs

• Want EP vendors to certify to all

measures

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CEHRT

• Use 2014 or 2015 Certified EHR

Technology (CEHRT) or any combination in 2017 for MU 1 & 2

• Use only 2015 CEHRT for MU 3

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eCQM Flexibility in 2017

• 2014 CEHRT with 2015 CEHRT CQMs

– Report 2017 measures

• 2015 CEHRT with 2014 CEHRT CQMs

– Report 2017 measures

• Electronically report eCQMs with latest

version

• Attest to CQMs with 2014 or 2015

CEHRT

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The Proposed Rule for Stage 3

• Meaningful Use Stage 3

– Released: March 30, 2015 available in html at:

• https://www.federalregister.gov/articles/2015/03/

30/2015-06685/medicare-and-medicaid- programs-electronic-health-record-incentive- program-stage-3

– Comments Due: May 29, 2015 at:

• http://www.regulations.gov/#!submitComment;D=

CMS-2015-0033-0002

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LSQIN Meaningful Use Consultation Services

• Meaningful Use 2 & 3
• Education
• Technical Assistance
• Learning Action Networks
• Free of Charge

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LSQIN Contacts

Michigan Rebecca Ciaverilla rciaveri@mpro.org Minnesota Candy Hanson chanson@stratishealth.org Wisconsin Marni Anderson manderso@metastar.com

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Questions?

Paul Kleeberg, MD

CMIO Stratis Health

pkleeberg@stratishealth.org

This material was prepared by the Lake Superior Quality Innovation Network, under contract with the Centers for Medicare & Medicaid Services (CMS), an agency of the U.S. Department of Health and Human Services. The materials do not necessarily reflect CMS policy. 11SOW-MN-B4-15-05 022315