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Meaningful Use 3 Proposed Rule Paul Kleeberg, MD, FAAFP, FHIMSS Burning Issues Webinar May 26, 2015 Objectives Provide an overview of the proposed changes Stage 3 starting in 2017 Provide a framework for colleting feedback for the


  1. Meaningful Use 3 Proposed Rule Paul Kleeberg, MD, FAAFP, FHIMSS Burning Issues Webinar May 26, 2015

  2. 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 1

  3. 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 2

  4. Bending the Curve Towards Transformed Health Improved outcomes Advanced clinical processes “Phased -in series of improved clinical data capture supporting more Data capture and rigorous and robust quality sharing measurement and improvement.” Stage 1 Stage 2 Stage 3 Source: Connecting for Health, Markle Foundation “Achieving the Health IT Objectives of the American Recovery and Reinvestment Act” April 2009 3 3

  5. 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 4

  6. 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 5

  7. NPRM 3 Calendar X 2 2 X X 6

  8. 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 7

  9. 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. 8

  10. 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. 9

  11. 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 10

  12. 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. 11

  13. 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 12

  14. 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). 13

  15. 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. 14

  16. 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. 15

  17. Clinical Decision Support (1 of 2) • Measure 1: – Implement 5 CDS interventions related to 4 or more CQMs or – Related to high-priority health conditions absent four CQMs related to scope of practice or patient population • Exclusion : – None 16

  18. 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 orders 17

  19. Computerized Provider Order Entry (CPOE) 3 Measures • Proposed Objective: – Use computerized provider order entry (CPOE) for medication, laboratory, and diagnostic imaging orders 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. 18

  20. 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. 19

  21. 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. 20

  22. 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 21

  23. 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 22

  24. 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 23

  25. 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 24

  26. 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 25

  27. 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 26

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