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Improving Patient Satisfaction with the Portal Wednesday August 12 12:00 PM CDT

CMS Meaningful Use Relaxation Rule What does it mean?

Introductions

Lindsey Lanning

Healthcare Informatics Coordinator

Cindi Kincade

Vice President, Consulting Solutions

Preview of the CMS Proposed MU Relaxation Rule

Agenda

This session will cover:

• Proposed Modifications

to Meaningful Use in 2015-2017

• Clinical Quality

Measures

• Proposed Rule for

Meaningful Use Stage 3

• Proposed 2015 EHR

Certification Criteria

Meaningful Use Stage Breakdown

Modifications to Meaningful Use in 2015-2017

CMS Proposed MU Relaxation Rule

On April 10, 2015, the Centers for Medicare & Medicaid Services issued a new proposed rule for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs to align Stage 1 and Stage 2 objectives and measures with the long-term proposals for Stage 3, to build progress toward program milestones, to reduce complexity, and to simplify providers’ reporting.

Modifications to Meaningful Use

Modifies patient action measures in Stage 2

• bjectives related to patient engagement

Changes reporting period in 2015 to a 90-day period aligned with the calendar year Removes reporting requirements on redundant, duplicative, or topped out measures, therefore reducing the overall number of objectives.

Purpose of Modifications

These modifications will allow providers to refocus on the advanced use objectives and

• measures. These advanced measures are at

the core of IT supported health care which drives toward improving the way electronic health information is shared among providers and with their patients, enhancing the ability to measure quality and set improvement goals, and ultimately improving the way health care is delivered and experienced.

Changes to Participation Timeline

2015

Attest to modified version of Stage 2 with accommodations for Stage 1 providers

2016

Attest to modified version of State 2

2017

Attest to either modified version of Stage 2 or full version of Stage 3

2018

Attest to full version of Stage 3

Proposed 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.

• Every provider will be Meaningful Use Stage 3 in 2018

even if 2018 is the provider’s first reporting year – In

• rder to simplify the Meaningful Use program, all

providers will be in the same stage at that point. This will allow group practices to focus on a single set of measures for all providers.

Proposed 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 would be the

• nly MU stages available for attestation.

Proposed Reporting Period Changes

• In 2015 and 2016, new meaningful use participants would be

allowed to attest for any 90-day period within the calendar year;

• For 2015 only, all eligible providers would be allowed to

attest for any 90-day period within the calendar year regardless of their previous participation;

• For 2016, all eligible professionals, eligible hospitals and

critical access hospitals who are first-time attesters would be allowed to attest for any 90-day period within the calendar year, while returning participants would use a full calendar year reporting period; and

• For 2017, all providers, regardless of their previous

participation, would use a full calendar year reporting period as proposed in the Stage 3 proposed rule.

Alignment with MU Stage 3

• Reduce burden by creating a single set of

sustainable objectives.

• Enable providers to focus on objectives

that support advance use of health IT such as health information exchange, public health reporting, and quality measures 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

• bjectives.
• The new reporting structure is outlined here:

Removed MU Objectives

CMS states that many of these redundant, duplicative, or topped

• ut 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

• n 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

• The proposed threshold changed that more

than 5% of patients must view, download,

• r transmit health information to just ‘1’

patient needing to do so.

• The proposed threshold changed 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
• bjectives into one objective with measure
• ptions following the same structure of Stage

3 Public Health Reporting.

What will 2015 look like?

This proposed rule has a 2-month comment period and therefore we expect the final rule around Aug-Sept. After the final rule is published, EHR vendors will need to update their Meaningful Use Report Cards and the measurement period options in their software. While there may be a few 90-day reporting options available, we expect another year where most providers will be reporting on the last quarter of the year.

Clinical Quality Measures (CQMs)

Still Required to be a Meaningful User

CQM Basics

• CQMs are tools that help measure and track

the quality of health care services provided.

• These measures use data associated with

providers’ ability to deliver high-quality care

• r relate to long term goals for quality health

care.

• To participate in the Medicare and Medicaid

Electronic Health Record (EHR) Incentive Programs and receive an incentive payment, providers are required to submit CQM data from certified EHR technology.

CQM Basics

• For 2015 -EPs will need to report 9 (of 64

possible) measures.

• These 9 measures must cover at least

3 of the 6 National Quality Strategy domains:

• 1. Patient and Family Engagement
• 2. Patient Safety
• 3. Care Coordination
• 4. Population/Public Health
• 5. Efficient Use of Healthcare Resources
• 6. Clinical Process/Effectiveness

Proposed Rules for MU Stage 3

Broken down by Notable Objectives

Meaningful Use Stage 3 goals

• Increased data interoperability;
• Advanced use of EHR technology to

improve patient engagement and coordination of care;

• Improve program efficiency,

effectiveness, and flexibility by aligning the EHR Incentive Program with other CMS quality reporting programs.

Meaningful Use Stage 3 Criteria Focus

• Improving quality, safety, and efficiency,

leading to improved health outcomes

• Decision support for national high-

priority conditions

• Patient access to self-management tools
• Access to comprehensive patient data

through patient-centered HIE

• Improving population health

Stage 3 Objectives

Retained Stage 2 objectives with modifications include:

• Protecting electronic heath information
• E-prescribing
• Clinical decision support
• Computerized physician order entry

(CPOE)

Objectives with expanded scope include:

• Patient access to health information
• Coordination of Care
• Health information exchange
• Public health reporting

Protect Electronic Health Information

Conduct or review a security risk analysis including addressing the encryption/security of data stored in CEHRT and implement security updates as needed and correct identified security deficiencies as part of the risk management process

• No exclusion

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

Modified Stage 2 Stage 3

Electronic Prescribing

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.

More than 80% 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. Modified Stage 2 Stage 3

Clinical Decision Support

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. 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

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. 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 order during the reporting period

Modified Stage 2 Stage 3

Computerized Provider Order Entry

You must create using CPOE the following:

• Measure 1: More than 60% of medication orders.
• Measure 2: More than 30% of laboratory orders.
• Measure 3: More than 30% of radiology orders.
• You can be excluded individually from meeting each of the above measures for the
• nes that you have fewer than 100 orders during the reporting period.

Use CPOE for medication, lab, & diagnostic imaging orders directly entered by any licensed healthcare professional, credentialed medical assistant, or medical staff member credentialed to and performing the duties of a credentialed medical assistant; who can enter orders into the medical record per state, local and professional guidelines.

• Measure 1: More than 80% of medication orders.
• Measure 2: More than 60% of laboratory orders.
• Measure 3: More than 60% of diagnostic imaging orders.
• Includes radiology, ultrasound, MRI, computed tomography, and other diagnostic

imaging.

• You can be excluded individually from meeting each of the above measures for the
• nes that you have fewer than 100 orders during the reporting period.

Modified Stage 2 Stage 3

Patient Electronic Access to Health Information

• Measure 1: More than 50% of all unique patients are provided timely (within 4

business days after the info is available to the EP) online access to their health 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.

• 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 3Mbps broadband availability.

• Measure 1: For more than 80% of all unique patients seen by the EP
• (1) The patient (or patient-authorized rep) is provided access to view online, download,

and transmit their health information within 24 hours of its availability to the provider.

• (2) The patient (or authrep) is provided access to an ONC-certified API that can be used by

third-party apps or devices to provide patients access to their health information, within 24 hours of its availability to the provider.

• Measure 2: EP must use clinically relevant information from CEHRT to identify

patient-specific educational resources and provide electronic access to those materials to more than 35% of unique patients seen by the EP during the reporting period.

• You can be excluded from both measures if you have no office visits during the reporting

period.

• You can be excluded from Measure 1 if you conduct 50% or more of encounters in a

county that does not have 50% or more housing units with 4Mbps broadband availability.

Modified Stage 2 Stage 3

Summary of Care Record

• The EP that transitions or refers their patient to another

setting of care or provider of care must:

• Measure 1: Use CEHRT to create a summary of care record.
• Measure 2: Electronically transmit such summary to a

receiving provider more than 10% of transitions of care and referrals.

• You can be excluded if you transfer a patient to another setting or

refer a patient to another provider less than 100 times during the EHR reporting period.

• Covered under the new Stage 3 Objective: Health Information

Exchange

Modified Stage 2 Stage 3

Patient Specific Education

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.

Covered under the new Stage 3 Objective: Patient Electronic Access to Health Information

Modified Stage 2 Stage 3

Medication Reconciliation

The EP performs medication reconciliation (including name, dosage, frequency, and route) 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.

Covered under the new Stage 3 Objective: Health Information Exchange

Modified Stage 2 Stage 3

Secure Electronic Messaging

During the entire reporting period, the capability for patients to send and receive a secure electronic message with the provider was fully enabled.

• You can be excluded if you have no office visits.
• You can be excluded if you conduct 50% or more
• f encounters in a county that does not have 50%
• r more housing units with 3Mbps broadband

availability.

Covered under the new Stage 3 Objective: Coordination of Care

Modified Stage 2 Stage 3

Stage 3 Objective #6: Coordination of Care

• Proposed Objective:
• Use communications functions of CEHRT to engage with patients or their

authorized representatives about the patient’s care.

• Proposed Measures:
• During the reporting period, >25% of unique patients seen by the EP

actively engage with the EHR made accessible by the provider by viewing, downloading, or transmitting their health information; or accessing their health information through an ONC-certified API.

• For >35% of unique patients seen by the EP, a secure message was sent

using the electronic messaging function of the CEHRT to the patient (or authorized representative), or in response to a secure message sent by the patient (or authorized representative).

• Patient-generated health data or data from a non-clinical setting is

incorporated into the CEHRT for >15% of unique patients seen by the EP during the reporting period.

Stage 3 Objective #7: Health Information Exchange

• Proposed Objective:
• The EP 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, and incorporates summary of care information from other providers using the functions of CEHRT.

• Proposed Measures:
• For >50% of transitions of care and referrals, the EP that transitions or refers

their patient to another setting of care or provider must: create a summary of care record using CEHRT; and electronically exchange the summary care record.

• For >40% of transitions or referrals received and patient encounters in which the

provider has never before encountered the patient, the EP incorporates into the patient’s EHR an electronic summary of care document from a source other than the provider’s EHR system.

• For >80% of transitions or referrals received and patient encounters in which the

provider has never before encountered the patient, the EP performs a clinical information reconciliation for medications, medication allergies, and current problem list.

Stage 3 Objective #8: Public Health Reporting

• Proposed Objective:
• 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.

• Proposed Measures:
• The EP is required to successfully attest to any combination of 3

measures from 5 available:

Reporting Measures Max times measure can count towards objective Immunization registry reporting 1 Syndromic surveillance reporting 1 Public health registry reporting 3 Case reporting 1 Clinical data registry reporting 3

Active Engagement

Active engagement is defined as:

• Option 1: Completed registration to submit data:
• Registration was completed within 60 days after the start
• f 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.

Proposed Objectives

Modified Stage 2 vs. Stage 3

Proposed (Modified) Stage 2 Objectives Proposed 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. Summary of Care*
• 5. Patient Electronic Access
• 6. Patient Education**
• 6. Care Coordination/Patient Engagement
• 7. Medication Reconciliation**
• 7. Health Information Exchange (HIE)
• 8. Patient Electronic Access Measure #1

Patient Electronic Access Measure #2*

• 8. Public Health and Clinical Registry

Reporting

• 9. Secure Messaging
• 10. Public Health and Clinical Registry Reporting

Take Action Now

• Don’t forget about the deleted measures
• Continue to monitor them and utilize them because they impact
• ther measures and CQMs.
• Run Stage 2 reports for all providers (even those in Stage

1 for 2015)

• This will identify gaps and workflow issues to meet the modified

Stage 2 Objectives.

• Start planning now
• Be prepared but understand the changes discussed today are

proposed and won’t be final until August/September.

• Thresholds and exclusions may change in the Final Rule.
• Make sure you keep in contact with NextGen or any
• ther vendors that impact your MU reporting

Proposed 2015 EHR Certification Criteria

Broken down by Notable Changes

Proposed 2015 EHR Certification Criteria

• The new proposed EHR criteria incorporates

elements of the 2011 and 2014 editions, and it aligns with ONC’s draft Nationwide Interoperability Roadmap that calls for expanded use of interoperable health IT by 2020.

• The 2015 edition includes provisions that address

certification criteria to support population health management, interoperability, data portability and access, improved transparency, and enhanced privacy and security capabilities.

Proposed 2015 EHR Certification Criteria (cont.)

• Changes to criteria for transitions of care
• ONC proposes to revise the 2014 edition’s requirement to

demonstrate both “content” and “transport” to reflect two separate testing and certification opportunities. This will create potentially more opportunities for health information exchange entities to certify transport capabilities.

• Adoption of new minimum standard code sets
• ONC proposes to adopt newer versions of four previously adopted

minimum standard code sets.

• (i.e., the September 2014 release of the US Edition of SNOMED CT; LOINC

version 2.50; the Feb. 2, 2015 monthly version of RxNorm; and the February 2, 2015 version of the CVX code set).

• It also proposes to adopt two new minimum standard code sets—the

National Drug Codes (NDC) and the Centers for Disease Control and Prevention’s Race and Ethnicity Code System.

Proposed 2015 EHR Certification Criteria (cont.)

• Discontinuation of the complete EHR definition
• The original definition required that providers use certified

technology that met all of the setting-specific certification

• criteria. Under the CEHRT definition for fiscal/calendar year

2014 and beyond, providers only need EHR technology certified to the 2014 rule that meets the base definition (i.e., possessing a finite set of capabilities) and includes only the other capabilities they need for the meaningful use stage to which they are attesting.

Note: In 2017, providers may use EHR technology that is certified using either the 2014 edition or the new proposed 2015 edition. But for the reporting period in 2018, all providers must use an EHR that has been certified with the 2015 criteria.

Version and Criteria

Version EHR Certification Criteria

5.6 2011 5.8 2014 5.8 UD 1 2014 5.8 UD 2 2014

• If you upgraded to version 5.8 it follows 2014 EHR

Certification Criteria. This could not be back certified with 2011 EHR Certification Criteria.

• All clients should be using 2014 EHR Certification Criteria,

2011 is essentially gone.

• 2015 EHR Certification Criteria will be mandated by 2018.

Special Note: The CMS website to attest is not available and will not be up until the first quarter of 2016.

Questions

• Lindsey Lanning
• Healthcare Informatics Coordinator
• llanning@Itentive.com
• 224-220-5621
• Cindi Kincade
• Vice President, Client Solutions
• ckincade@Itentive.com
• 224-220-5575

Thank you