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Upcoming Webinars: 4 Part Series Government Regulations & Ramifications • Meaningful Use Audits (November 11 th ) • EHR Cloning (November 18 th ) • The Dangers of Information Blocking and Its Effect on Interoperability (December) • HITECH Security and HIPAA (December)
ITENTIVE WEBINAR SERIES Meaningful Use Final Rule
Introductions Kathy Thompson Lindsey Lanning Cindi Kincade Managing Consultant Healthcare Informatics Vice President, Coordinator Consulting Solutions
Finalized Meaningful Use Rules
The Good News: We finally know exactly what we need to do…
The Bad News: It requires a lot of changes and stringent timelines.
And…We’re Already Behind Before We’ve Even Gotten Started…
What has happened since the proposed rule?
There has been Pressure There have been 6 separate times over a 4 month period where industry stakeholders, hospital associations, provider associations, and even Congress have published letters or press releases calling for the proposed rules to be finalized and/ or delayed.
There has been New Legislation • New legislation has been introduced that would modify Stage 2 and delay Stage 3 Meaningful Use. This bill, called the Flex- IT 2 Act, points out five provisions: • Delay Stage 3 rulemaking until at least 2017, unless at least 75% of EPs and hospitals are successful in meeting the Stage 2 requirements; • Harmonize government quality reporting requirements to remove duplicative measurement and streamline requirements from CMS; • Institute a 90-day reporting period for each year, regardless of stage or program experience; • Encourage interoperability among EHR systems; and • Expand hardship exemption categories • Medicare Access and CHIP Reauthorization Act
There have been Changes from the Proposed Rules • 90-day Reporting Period Extended All new MU participants 2015-2017 Providers who choose to attest to Stage 3 in 2017 • Stage 3 Measure Thresholds CPOE E-prescribing Coordination of Care • Public Health Reporting Requirements Only have to attest to 2 out of 3 measures
Meaningful Use Modified Stage 2 Final Rule
CMS Finalized MU Relaxation Rule On October 6, 2015 The Centers for Medicare & Medicaid Services (CMS) released final rules that simplify requirements and add new flexibilities for providers to make, electronic health information available when and where it matters most and for health care providers and consumers to be able to readily, safely, and securely exchange that information.
Changes for Modified Stage 2 Changes the reporting period requirements for 2015 to a 90-day period and aligns it with the calendar year. Modifies patient action measures in Stage 2 objectives related to patient engagement. Removes reporting requirements on redundant, duplicative, or topped out measures, therefore reducing the overall number of objectives. Modifies public health reporting requirements.
Purpose of Modifications CMS has heard from physicians and other providers about the challenges they face making this technology work well for their individual practices and for their patients. In recognition of these concerns, the regulations make significant changes in current requirements. They will ease the reporting burden for providers, support interoperability, and improve patient outcomes.
Changes to Participation Timeline 2015 Attest to modified version of Stage 2 with accommodations for Stage 1 providers 2016 Attest to modified version of Stage 2 2017 Attest to either modified version of Stage 2 or full version of Stage 3 2018 Attest to full version of Stage 3
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. However, if you do attest to Stage 3 in 2017 you are now being offered a 90-day reporting period. • Every provider will be Meaningful Use Stage 3 in 2018 even if 2018 is the provider’s first reporting year – In order to simplify the Meaningful Use program, all providers will be in the same stage at that point. All providers will also be using EHR certified to the 2015 ONC standards.
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 are the only MU stages available for attestation.
Reporting Period Changes Any continuous 90 days for all providers 2015 with a February 29, 2016 attestation deadline. Any continuous 90 days for all first-time 2016 attesters and a full year for all returning attesters. Any continuous 90 days for all first- 2017 time attesters and providers pursuing Stage 3 option. A full year for all returning attesters. 2018 Full year for all providers.
Goals of Provisions 1. Align with Stage 3 to achieve overall goals of the program. 2. Synchronize reporting period objectives and measures to reduce provider burden. 3. Continue to support advance use of health IT to improve patient outcomes by focusing on interoperability and advanced EHR usage. 4. Align with the new MACRA law. 5. Get all providers to the same place in Meaningful Use.
Aligning Modified Stage 2 with Stage 3 • This rule reconciles measures to align the new modified Stage 2 with Stage 3 by: Preparing providers to report Stage 3 criteria in 2018. Reducing the provider burden and creating a single set of sustainable objectives that promote best practices for patients. Enabling providers to focus on objectives which support advances use of health IT, such as: • Health information exchanges • Consumer engagement • Public health 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 objectives. • The new reporting structure is outlined here:
Removed MU Objectives CMS has identified the following objectives as either redundant, duplicative, or topped out and will no longer require attestation on them. • Record Demographics • Patient Reminders • Record Vital Signs • Electronic Notes • Record Smoking Status • Imaging Results • Clinical Summaries • Family Health History • Structured Lab Results • Summary of Care • Patient List Measure 1 – Any Method Measure 3 – Test CMS states that many of these redundant, duplicative, or topped out 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.
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 • Changes the threshold that more than 5% of patients must view, download, or transmit health information to just ‘1’ patient needing to do so. • Changes the threshold that 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 objectives into one objective with measure options following the same structure of Stage 3 Public Health Reporting.
What will 2015 look like? • Providers will attest to a single set of blended Stage 1 and Stage 2 objectives and measures. No core or menu measures. This single set of blended objectives is being called modified Stage 2. • All reporting will be for 90 days. • Accommodations by multiple exclusions and alternative measures within individual objectives will be made for providers who would have been in different stages of MU. • CQMs will be reported electronically or attested to; CQM 90 day period doesn’t need to coincide with the 90 day MU attestation period.
Finalized Rules for MU Modified Stage 2 Broken down by Notable Objectives
Modified Stage 2 Objectives 1. Protect patient heath information 2. Clinical decision support 3. Computerized physician order entry (CPOE) 4. E-prescribing 5. Health information exchange 6. Patient Specific Education 7. Medication Reconciliation 8. Patient access to health information 9. Secure Messaging 10. Public health reporting
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