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Stage 2 Meaningful Use and 2013 PQRS Updates Webinar 1 Barbara Connors, D.O., M.P.H. Patrick Hamilton Centers for Medicare & Medicaid Services Philadelphia Regional Office January 15, 2013

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Stage 2 Meaningful Use and 2013 PQRS Updates Webinar. Barbara Connors, D.O., M.P.H. Patrick Hamilton Centers for Medicare & Medicaid Services Philadelphia Regional Office January 15, 2013. Physician Quality Reporting System (PQRS) . PQRS – Who is an Eligible Professional?. EPs include: - PowerPoint PPT Presentation

TRANSCRIPT

Page 1: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

Stage 2 Meaningful Use and 2013 PQRS Updates Webinar

1

Barbara Connors, D.O., M.P.H.Patrick Hamilton

Centers for Medicare & Medicaid ServicesPhiladelphia Regional Office

January 15, 2013

Page 2: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

Physician Quality Reporting System (PQRS)

2

Page 3: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

EPs include:• Physicians

• MD, DO, Doctor of Podiatric Medicine, Doctor of Optometry, Doctor of Dental Surgery, Doctor of Dental Medicine, Doctor of Chiropractic

• Practitioners• PA, NP, Clinical Nurse Specialist, CRNA, Certified Nurse Midwife,

Clinical SW, Clinical Psychologist, RD, Nutrition Professional, audiologists

• Therapists: • PT, OT, Qualified Speech-Language Therapist

3

PQRS – Who is an Eligible Professional?

Page 4: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

• Align with other Medicare quality reporting programs that have quality reporting requirements

• Encourage eligible professionals into reporting for the PQRS payment adjustment by providing alternative means to avoiding the 2015 and 2016 payment adjustments

• Emphasize PQRS facilitates the overall improvement in quality of care

4

PQRS Goals

Page 5: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

• PQRS and the EHR Incentive Program Extension of the PQRS-Medicare EHR Incentive Pilot to 2013

• Satisfactory reporting criteria for the 2014 PQRS Incentive via the EHR-based reporting mechanism and the criteria for meeting the CQM component of meaningful use under the EHR Incentive Program

• Requirement of Certified Electronic Health Record Technology (CEHRT)

5

CMS Quality and Reporting Program Alignment

Page 6: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

• PQRS GPRO measures aligned with measures under MSSP

• Under the Medicare Shared Savings Program, ACOs successfully reporting measures under the Medicare Shared Savings Program via the GPRO Web Interface will not be subject to the PQRS payment adjustments as long as the ACO satisfactorily reports at least 1 measure

6

PQRS Group Practice Reporting Option (GPRO) & Medicare Shared Savings Program

Page 7: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

• The Value-based Payment Modifier and meeting the criteria for satisfactory reporting for the 2013 PQRS incentive and 2015 PQRS payment adjustment – Group practices consisting of 100+ eligible

professionals, beginning in 2013 will be subject to the Value-based Payment Modifier

Note: The 2015 and 2016 Value-based payment modifier does not apply to ACOs

7

PQRS and the Value-based Payment Modifier

Page 8: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

2015 PQRS payment adjustment:• 6-month and 12-month reporting periods that coincide with

the 2013 PQRS incentive reporting periods

2016 PQRS payment adjustment • 6-month and 12-month reporting periods that coincide with

the 2014 PQRS incentive reporting periods

2017 and subsequent PQRS payment adjustments • 12-month reporting periods only

8

PQRS Reporting Periods

Page 9: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

2013: 0.5% Incentive 2014: 0.5% Incentive

2015: 1.5% Payment Adjustment will be applied in 2015 based on reporting in 2013 2016: 2.0% Payment Adjustment will be applied in 2016 based on reporting in 2014

9

Incentive and Payment Adjustment Amounts

Page 10: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

Registry • Expand use of the registry-based reporting mechanism to group practices

participating in the GPRO

EHR• Beginning in 2014: • All direct EHR products and EHR data submission vendor’s products must

be certified by the Office of the National Coordinator as CEHRT. • Expand use of the EHR-based reporting mechanism to group practices

participating in the GPRO in 2014

GPRO Web Interface • Adoption of the Medicare Shared Savings Program method of assignment

and sampling

10

Reporting Mechanisms

Page 11: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

Administrative Claims • A reporting mechanism under which an eligible professional

or group practice elects to have CMS analyze claims data to determine which measures an eligible professional or group practice reports

• For the 2015 PQRS payment adjustment only • Under this reporting mechanism, eligible professionals or

group practices need to complete this election by the October 15, 2013 deadline

11

Reporting Mechanisms

Page 12: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

There is no requirement to register to participate as an individual Exception: If an individual eligible professional wishes to elect the administrative claims-based reporting mechanism to avoid the 2015 PQRS payment adjustment, the eligible professional must affirmatively elect to be analyzed under this reporting mechanism

• For eligible professionals in solo practices, participating in PQRS as an individual is the only option for you

• Eligible professionals within your group practice may freely choose which PQRS measures to report

12

Benefits of Participating as an Individual Eligible Professional

Page 13: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

Choose a reporting period, reporting mechanism, and reporting criterion

• Reporting Periods: 6-month, 12-month • Reporting Mechanisms: Claims, Registry, EHR (EHR direct product and EHR

data submission vendor), and Administrative Claims (to avoid the 2015 PQRS payment adjustment only)

Choose the individual measures or measures groups you wish to report

• Note: For help on choosing measures, please see the “How to Get Started” section of the CMS PQRS website and contact the QualityNet Help Desk if you still have questions

Start Reporting!

13

How to Participate as an Individual

Page 14: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

For 2015 and subsequent years, a payment adjustment with respect to covered professional services furnished by an eligible professional will be applied if the eligible professional does not satisfactorily submit data on quality measures for covered professional services for the quality reporting period for the year

Applicable adjustment amount: 2015: 1.5% 2016 and subsequent years: 2.0%

14

PQRS Payment Adjustment

Page 15: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

There are 3 ways an individual eligible professional may meet the criteria for satisfactory reporting for the 2015 PQRS payment adjustment:

1. Meet the criteria for satisfactory reporting for the 2013 PQRS Incentive 2. Report 1 valid measure or measures group using the claims, registry, or EHR-

based reporting mechanisms 3. Elect to be analyzed under the administrative claims-based reporting

mechanism

Note: If participating in PQRS through another CMS program (such as the Medicare Shared Savings Program), please check the program’s requirements for information on how to simultaneously report under PQRS and the respective program.

15

How to Avoid the Payment Adjustment in 2015

Page 16: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

There is 1 way an eligible professional may meet the criteria for satisfactory reporting for the 2016 PQRS payment adjustment: • Meet the criteria for satisfactory reporting for the 2014

PQRS Incentive

Note: We may establish additional ways to meet the criteria for satisfactory reporting for the 2016 PQRS payment adjustment in future rulemaking.

16

How to Avoid the Payment Adjustment in 2016

Page 17: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

• Group Practice = A single Tax Identification Number (TIN) with 2 or more eligible professionals, as identified by their individual National Provider (NPI), who have reassigned their Medicare billing rights to the TIN

• We have changed the definition of group practice to include groups of 2-24 eligible professionals.

• Beginning in 2013, all group practices can participate in the PQRS group practice reporting option (GPRO)

17

Definition of a PQRS Group Practice

Page 18: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

Benefits of Participating as a Group Practice:Billing and reporting staff may report one set of quality measures data on behalf of all eligible professionals within a group practice, reducing the need to keep track of eligible professionals’ reporting efforts separately

18

GPRO Reporting

Page 19: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

1. Self-Nominate to Participate in the PQRS Group Practice Reporting Option (GPRO) • Group practices will submit a self-nomination statement via a CMS developed website • Deadline to Self-Nominate: October 15, 2013

2. Choose a Reporting Mechanism and Reporting Criterion Available Reporting Mechanisms in 2013• GPRO Web Interface, Registry, and Administrative Claims

3. Beginning in 2014, the EHR-based reporting mechanism will also be available for use under the GPRO

Start Reporting!

19

How to Participate as GPRO

Page 20: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

For 2015 and subsequent years, a payment adjustment with respect to covered professional services furnished by an eligible professional will be applied if the eligible professional does not satisfactorily submit data on quality measures for covered professional services for the quality reporting period for the year

• Applicable adjustment amount: • 2015: 1.5% • 2016 and subsequent years: 2.0%

20

GPRO Payment Adjustment

Page 21: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

There is 1 way a group practice may meet the criteria for satisfactory reporting for the 2016 PQRS payment adjustment: Meet the criteria for satisfactory reporting for the 2014 PQRS Incentive under the GPRO

• Note: We may establish additional ways to meet the criteria for satisfactory reporting for the 2016 PQRS payment adjustment in future rulemaking

21

How to Avoid the Payment Adjustment in 2016

Page 22: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

Total # of Individual PQRS Measures: 2013 there are 259 measures2014 there are 288 measures

Consider Million Hearts measure

GPRO Measures: 18 measures, including 2 composites, for a total of 22 measures (same as the measures available for reporting under the Medicare Shared Savings Program)

• Note: For help on selecting measures on which to report, please see the “How to Get Started” section of the CMS PQRS website and contact the QualityNet Help Desk if you still have questions

22

PQRS Measures

Page 23: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

e-Prescribing Initiative

23

Page 24: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

• Most of the requirements for the remainder of the eRx Incentive Program were established in the CY 2012 Medicare PFS final rule. Please note that, although the self-nomination deadline to participate in the PQRS GPRO was extended to October 15, the self-nomination deadline to participate in the eRx GPRO remains January 31.

Updates to the eRx Incentive Program: • New Criteria for the eRx group practice reporting option (eRx

GPRO) – Since, accordingly with PQRS, we expanded definition of group practice to include

groups of 2-24 eligible professionals, we finalized new criteria for becoming a successful electronic prescriber under the eRx GPRO:

– Report the electronic prescribing measure for at least 75 instances during the applicable 2013 eRx incentive or 2014 eRx payment adjustment reporting period

24

The eRx Incentive Program: Updates

Page 25: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

• Most of the requirements for the remainder of the eRx Incentive Program were established in the CY 2012 Medicare PFS final rule. Please note that, although the self-nomination deadline to participate in the PQRS GPRO was extended to October 15, the self-nomination deadline to participate in the eRx GPRO remains January 31.

Updates to the eRx Incentive Program: • New Criteria for the eRx group practice reporting option (eRx

GPRO) – Since, accordingly with PQRS, we expanded definition of group practice to include

groups of 2-24 eligible professionals, we finalized new criteria for becoming a successful electronic prescriber under the eRx GPRO:

– Report the electronic prescribing measure for at least 75 instances during the applicable 2013 eRx incentive or 2014 eRx payment adjustment reporting period

25

eRx Incentives for 2012 and 2013# of Eligible

Professionals2012 Incentive (1.0% of MPFS) 2013 Incentive (0.5% of MPFS)

Individual (Reporting via Claims, Registry, or Direct EHR & EHR data submission vendor)

Report the eRx measure’s numerator for at least 25 unique denominator-eligible visits between January 1, 2012 and December 31, 2012

Report the eRx measure’s numerator for at least 25 unique denominator-eligible visits between January 1, 2013 and December 31, 2013

2-24 EPs (Reporting via Claims, Registry, or Direct EHR & EHR data submission vendor)

N/A Report the eRx measure’s numerator for at least 75 unique denominator-eligible visits between January 1, 2013 and December 31, 2013

25-99 EPs (Reporting via Claims, Registry, or Direct EHR & EHR data submission vendor)

Report the eRx measure’s numerator for at least 625 unique denominator-eligible visits between January 1, 2012 and December 31, 2012

Report the eRx measure’s numerator for at least 625 unique denominator-eligible visits between January 1, 2013 and December 31, 2013

100+ EPs (Reporting via Claims, Registry, or Direct EHR & EHR data submission vendor)

Report the eRx measure’s numerator for at least 2500 unique denominator-eligible visits between January 1, 2012 and December 31, 2012

Report the eRx measure’s numerator for at least 2500 unique denominator-eligible visits between January 1, 2013 and December 31, 2013

Page 26: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

• Most of the requirements for the remainder of the eRx Incentive Program were established in the CY 2012 Medicare PFS final rule. Please note that, although the self-nomination deadline to participate in the PQRS GPRO was extended to October 15, the self-nomination deadline to participate in the eRx GPRO remains January 31.

Updates to the eRx Incentive Program: • New Criteria for the eRx group practice reporting option (eRx

GPRO) – Since, accordingly with PQRS, we expanded definition of group practice to include

groups of 2-24 eligible professionals, we finalized new criteria for becoming a successful electronic prescriber under the eRx GPRO:

– Report the electronic prescribing measure for at least 75 instances during the applicable 2013 eRx incentive or 2014 eRx payment adjustment reporting period

26

eRx Payment Adjustments for 2014 (-2.0% of MFPS)Reporting

PeriodIndividual EPs 2-24 EPs 25-99 EPs 100+ EPs

12 month (Reporting via Claims, Registry, or Direct EHR & EHR data submission vendor )

Reports on the 2011 eRx measure’s numerator code at least 25 times for encounters associated with at least 1 of the denominator codes between January 1, 2012 and December 31, 2012 (same criteria as the 2012 eRx incentive)

N/A Report the eRx measure’s numerator at least 625 times for encounters associated with at least one of the denominator codes between January 1, 2012 and December 31, 2012 (same criteria for the 2012 eRx incentive)

Report the eRx measure’s numerator at least 2500 times for encounters associated with at least one of the denominator codes between January 1, 2012 and December 31, 2012 (same criteria for the 2012 eRx incentive)

6 month (Claims ONLY)

Report the eRx measure’s numerator code at least 10 times between January 1, 2013 and June 30, 2013

Report the eRx measure’s numerator code at least 75 times between January 1, 2013 and June 30, 2013

Report the eRx measure’s numerator code at least 625 times between January 1, 2013 and June 30, 2013

Report the eRx measure’s numerator code at least 2500 times between January 1, 2013 and June 30, 2013

Page 27: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

• Most of the requirements for the remainder of the eRx Incentive Program were established in the CY 2012 Medicare PFS final rule. Please note that, although the self-nomination deadline to participate in the PQRS GPRO was extended to October 15, the self-nomination deadline to participate in the eRx GPRO remains January 31.

Updates to the eRx Incentive Program: • New Criteria for the eRx group practice reporting option (eRx

GPRO) – Since, accordingly with PQRS, we expanded definition of group practice to include

groups of 2-24 eligible professionals, we finalized new criteria for becoming a successful electronic prescriber under the eRx GPRO:

– Report the electronic prescribing measure for at least 75 instances during the applicable 2013 eRx incentive or 2014 eRx payment adjustment reporting period

27

Hardship Exemptions for eRx Payment AdjustmentsSignificant Hardship Exemption Category Method of

SubmissionDeadline for

2013 Exemption

Deadline for 2014

Exemption

The eligible professional or group practice practices in a rural area with limited high speed internet access

Web-basedCommunicationSupport Page

Extended toJanuary 31, 2013

June 30, 2013

The eligible professional or group practice practices in an area with limited available pharmacies for electronic prescribing

Web-basedCommunicationSupport Page

Extended toJanuary 31, 2013

June 30, 2013

The eligible professional or group practice is unable to electronically prescribe due to local, state, or Federal law or regulation

Web-basedCommunicationSupport Page

Extended toJanuary 31, 2013

June 30, 2013

The eligible professional or group practice has limited prescribing activity, as defined by an eligible professional generating fewer than 100 prescriptions during a 6-month reporting period

Web-basedCommunicationSupport Page

Extended toJanuary 31, 2013

June 30, 2013

2013 Adjustment: Eligible professionals or group practices whoachieve meaningful use during the 2013 12- and 6-month eRx payment adjustment reporting periods (that is, January 1, 2011 – June 30, 2012); 2014 Adjustment: Eligible professionals or group practices who achieve meaningful use during the 2014 12- and 6-month eRx payment adjustment reporting periods (that is, January 1, 2012 – June 30, 2013)

EHR IncentiveProgram’sRegistration/Attestation Page

January 31, 2013

June 30, 2013

Eligible professionals or group practices whodemonstrate intent to participate in the EHR Incentive Program and adoption of Certified EHR Technology

EHR IncentiveProgram’sRegistration/ Attestation Page

January 31, 2013

June 30, 2013

Page 28: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

• Implementation of an eRx Informal Review process • How to Request an eRx Informal Review for the 2012 or 2013

eRx Incentives: – Informal Review Request Method: email – Deadline: 90 days following the receipt of the applicable full year eRx

feedback reports • How to Request an eRx Informal Review for the 2013 or 2014

eRx Payment Adjustments: • Informal Review Request Method: email • Deadline:

– For the 2013 eRx payment adjustment: February 28, 2013 – For the 2014 eRx payment adjustment: February 28, 2014

28

eRx Informal Review Process

Page 29: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

HITECH Meaningful Use: Stage 2 & Payment

Adjustments

29

Page 30: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

• Changes to Stage 1 of meaningful use

• Stage 2 of meaningful use

• New clinical quality measures

• New clinical quality measure reporting mechanisms

• Payment adjustments and hardships

• Medicare Advantage program changes

• Medicaid program changes

30

HITECH Meaningful Use Stage 2 Final Rule

Page 31: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

31

Changes to Stage 1: CPOE

Current Stage 1 Measure New Stage 1 Option

This optional CPOE denominator is available in 2013 and beyond for Stage 1

Denominator=

Unique patient with at least one medication

in their medication

list

Denominator=

Number of orders during

the EHR Reporting

Period

Page 32: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

32

Changes to Stage 1: Vital Signs

Current Stage 1 Measure

Age Limits=

Age 2 for Blood

Pressure & Height/ Weight

New Stage 1 Measure

Age Limits=

Age 3 for Blood

Pressure, No age limit for

Height/ Weight

Exclusion=

All three elements

not relevant to scope

of practice

Exclusion=

Blood pressure to

be separated

from height /weight

The vital signs changes are optional in 2013, but required starting in 2014

Page 33: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

33

Changes to Stage 1: Testing of HIE

Current Stage 1 Measure

One test of electronic

transmission of key clinical information

Stage 1 Measure Removed

The removal of this measure is effective starting in 2013

Page 34: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

34

Changes to Stage 1: E-Copy & Online Access

Current Stage 1 Objective

Objective=

Provide patients with

e-copy of health

information upon request

Provide electronic access to

health information

New Stage 1 Objective

Objective=

Provide patients the

ability to view online, download

and transmit their health information

• The measure of the new objective is 50% of patients have accessed their information; there is no requirement that 5% of patients do access their information for Stage 1.

• The change in objective takes effect in 2014 to coincide with the 2014 certification and standards criteria

Page 35: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

35

Changes to Stage 1: Public Health Objectives

Current Stage 1 ObjectivesImmunizations

Reportable Labs

Syndromic

Surveillance

New Stage 1 Addition

Addition of “except where prohibited” to

all three objectives

This addition is for clarity purposes and does not change the Stage 1 measure for these objectives.

Page 36: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

36

Stages of Meaningful Use

Data capturing and sharing

Advanced clinical processes

Improved outcomes

Stage 1

Stage 2

Stage 3

Page 37: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

37

Meaningful Use: Changes from Stage 1 to Stage 2

Eligible Professionals

15 core objectives5 of 10 menu

objectives20 total objectives

Eligible Professionals

17 core objectives3 of 6 menu objectives

20 total objectives

Eligible Hospitals & CAHs

14 core objectives5 of 10 menu

objectives19 total objectives

Eligible Hospitals & CAHs

16 core objectives3 of 6 menu objectives

19 total objectives

Stage 2Stage 1

Page 38: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

1. EHRs Meeting ONC 2014 Standards – starting in 2014, all EHR Incentive Programs participants will have to adopt certified EHR technology that meets ONC’s Standards & Certification Criteria 2014 Final Rule

2. Reporting Period Reduced to Three Months – to allow providers time to adopt 2014 certified EHR technology and prepare for Stage 2, all participants will have a three-month reporting period in 2014.

38

2014 Changes

Page 39: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

39

Stage 2 EP Core Objectives

Core Objective Measure

1. CPOE Use CPOE for more than 60% of medication, 30% of laboratory, and 30% of radiology

2. E-Rx E-Rx for more than 50%

3. Demographics Record demographics for more than 80%

4. Vital Signs Record vital signs for more than 80%

5. Smoking Status Record smoking status for more than 80%

6. Interventions Implement 5 clinical decision support interventions + drug/drug and drug/allergy

7. Labs Incorporate lab results for more than 55%

8. Patient List Generate patient list by specific condition

9. Preventive RemindersUse EHR to identify and provide reminders for preventive/follow-up care for more than 10% of patients with two or more office visits in the last 2 years

EPs must meet all 17 core objectives:

Page 40: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

40

Stage 2 EP Core Objectives

EPs must meet all 17 core objectives:Core Objective Measure

10. Patient Access Provide online access to health information for more than 50% with more than 5% actually accessing

11. Visit Summaries Provide office visit summaries for more than 50% of office visits

12. Education Resources Use EHR to identify and provide education resources more than 10%

13. Secure Messages More than 5% of patients send secure messages to their EP

14. Rx Reconciliation Medication reconciliation at more than 50% of transitions of care

15. Summary of CareProvide summary of care document for more than 50% of transitions of care and referrals with 10% sent electronically and at least one sent to a recipient with a different EHR vendor or successfully testing with CMS test EHR

16. Immunizations Successful ongoing transmission of immunization data

17. Security Analysis Conduct or review security analysis and incorporate in risk management process

Page 41: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

41

Stage 2 EP Menu Objectives

EPs must select 3 out of the 6:

Menu Objective Measure

1. Imaging Results More than 10% of imaging results are accessible through Certified EHR Technology

2. Family History Record family health history for more than 20%

3. Syndromic Surveillance Successful ongoing transmission of syndromic surveillance data

4. Cancer Successful ongoing transmission of cancer case information

5. Specialized Registry Successful ongoing transmission of data to a specialized registry

6. Progress Notes Enter an electronic progress note for more than 30% of unique patients

Page 42: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

42

Aligning CQMs Across Programs

• CMS’s commitment to alignment includes finalizing the same CQMs used in multiple quality reporting programs for reporting beginning in 2014• Other programs include Hospital IQR Program, PQRS, CHIPRA, and Medicare SSP and Pioneer ACOs

Hospital Inpatient Quality

Reporting Program

Physician Quality

Reporting System

Children’s Health Insurance Program

Reauthorization Act

Medicare Shared Savings

Program and Pioneer ACOs

Page 43: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

• CQM reporting will remain the same through 2013. • 44 EP CQMs

• 3 core or alternate core (if reporting zeroes in the core) plus 3 additional CQMs• Report minimum of 6 CQMs (up to 9 CQMs if any core CQMs were zeroes)

• 15 Eligible Hospital and CAH CQMs • Report all 15 CQMs

• In 2012 and continued in 2013, there are two reporting methods available for reporting the Stage 1 measures:• Attestation• eReporting pilots

• Physician Quality Reporting System EHR Incentive Program Pilot for EPs• eReporting Pilot for eligible hospitals and CAHs

• Medicaid providers submit CQMs according to their state-based submission requirements.

43

Clinical Quality Measures

Page 44: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

44

Electronic Submission of CQMs Beginning in 2014

• Beginning in 2014, all Medicare-eligible providers in their second year and beyond of demonstrating meaningful use must electronically report their CQM data to CMS.

• Medicaid providers will report their CQM data to their state, which may include electronic reporting.

Page 45: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

45

CQM Selection and HHS Priorities

All providers must select CQMs from at least 3 of the 6 HHS National Quality Strategy domains:

Patient and Family Engagement Patient Safety Care Coordination Population and Public Health Efficient Use of Healthcare Resources Clinical Processes/Effectiveness

Page 46: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

46

Changes to CQMs Reporting

Prior to 2014

EPs

Report 6 out of 44 CQMs • 3 core or

alt. core• 3 menu

Beginning in 2014

EPs

Report 9 out of 64 CQMs

Selected CQMs must cover at least

3 of the 6 NQS domains

Recommended core CQMs:

9 for adult populations

9 for pediatric populationsEligible

Hospitals and CAHs

Report 15 out of 15

CQMsEligible Hospitals

and CAHs

Report 16 out of 29 CQMs

Selected CQMs must cover at least

3 of the 6 NQS domains

Page 47: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

• The HITECH Act stipulates that for Medicare EP, subsection (d) hospitals and CAHs a payment adjustment applies if they are not a meaningful EHR user.

• An EP, subsection (d) hospital or CAH becomes a meaningful EHR user when they successfully attest to meaningful use under either the Medicare or Medicaid EHR Incentive Program

47

Payment Adjustments

Adopt, implement and upgrade ≠ meaningful use A provider receiving a Medicaid incentive for AIU would still be subject to the Medicare payment adjustment.

Page 48: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

48

Payment Adjustments

% Adjustment shown below assumes less than 75% of EPs are meaningful users for CY 2018 and subsequent years

2015 2016 2017 2018 2019 2020+

EP is not subject to the payment adjustment for e-Rx in 2014 99% 98% 97% 96% 95% 95%

EP is subject to the payment adjustment for e-Rx in 2014 98% 98% 97% 96% 95% 95%

% Adjustment shown below assumes more than 75% of EPs are meaningful users for CY 2018 and subsequent years

2015 2016 2017 2018 2019 2020+

EP is not subject to the payment adjustment for e-Rx in 2014 99% 98% 97% 97% 97% 97%

EP is subject to the payment adjustment for e-Rx in 2014 98% 98% 97% 97% 97% 97%

Page 49: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

49

EP EHR Reporting Period

•For an EP who has demonstrated meaningful use in 2011 or 2012:Payment Adjustment Year 2015 2016 2017 2018 2019 2020

Based on Full Year EHR Reporting Period 2013 2014* 2015 2016 2017 2018

Payment adjustments are based on prior years’ reporting periods. The length of the reporting period depends upon the first year of participation.

To Avoid Payment Adjustments: EPs must continue to demonstrate meaningful use every year to avoid payment adjustments in subsequent years.

* Special 3 month EHR reporting period

Page 50: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

50

EP EHR Reporting Period

• For an EP who demonstrates meaningful use in 2013 for the first time:

To Avoid Payment Adjustments: EPs must continue to demonstrate meaningful use every year to avoid payment adjustments in subsequent years.

* Special 3 month EHR reporting period

Payment Adjustment Year 2015 2016 2017 2018 2019 2020

Based on 90 day EHR Reporting Period 2013

Based on Full Year EHR Reporting Period 2014* 2015 2016 2017 2018

Page 51: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

51

EP EHR Reporting Period

EP who demonstrates meaningful use in 2014 for the first time:

*In order to avoid the 2015 payment adjustment the EP must attest no later than October 1, 2014, which means they must begin their 90 day EHR reporting period no later than July 1, 2014.

* Special 3 month EHR reporting period

Payment Adjustment Year 2015 2016 2017 2018 2019 2020

Based on 90 day EHR Reporting Period 2014* 2014

Based on Full Year EHR Reporting Period 2015 2016 2017 2018

Page 52: Barbara  Connors, D.O., M.P.H. Patrick  Hamilton

Note: Congress mandated that an EP must be a meaningful user in order to avoid the payment adjustment; therefore receiving a Medicaid EHR incentive payment for adopting, implementing, or upgrading your certified EHR Technology would not exempt you from the payment adjustments.

52

Payment Adjustments for Providers Eligible for Both Programs

Eligible for both programs?

If you are eligible to participate in both the Medicare and Medicaid EHR Incentive Programs, you MUST demonstrate meaningful use according to the timelines in the previous slides to avoid the payment adjustments. You may demonstrate meaningful use under either Medicare or Medicaid.

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EPs can apply for hardship exceptions in the following categories:

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EP Hardship Exceptions

1. InfrastructureEPs must demonstrate that they are in an area without sufficient internet access or face insurmountable barriers to obtaining infrastructure (e.g., lack of broadband).

2. New EPsNewly practicing EPs who would not have had time to become meaningful users can apply for a 2-year limited exception to payment adjustments.

3. Unforeseen CircumstancesExamples may include a natural disaster or other unforeseeable barrier.

4. EPs must demonstrate that they meet the following criteria:

• Lack of face-to-face or telemedicine interaction with patients

• Lack of follow-up need with patients

5. EPs who practice at multiple locations must demonstrate that they:

• Lack of control over availability of CEHRT for more than 50% of patient encounters

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EP Hardship Exceptions

EPs whose primary specialties are anesthesiology, radiology or pathology:

As of July 1st of the year preceding the payment adjustment year, EPs in these specialties will receive a hardship exception based on the 4th criteria for EPs

EPs must demonstrate that they meet the following criteria:• Lack of face-to-face or telemedicine interaction with patients• Lack of follow-up need with patients

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Applying for Hardship Exceptions

Applying: EPs, eligible hospitals, and CAHs must apply for hardship exceptions to avoid the payment adjustments.

Granting Exceptions: Hardship exceptions will be granted only if CMS determines that providers have demonstrated that those circumstances pose a significant barrier to their achieving meaningful use.

Deadlines: Applications need to be submitted no later than April 1 for hospitals, and July 1 for EPs of the year before the payment adjustment year; however, CMS encourages earlier submission

•For More Info: Details on how to apply for a hardship exception will be posted on the CMS EHR Incentive Programs website in the future:

•www.cms.gov/EHRIncentivePrograms

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• Proposed expanded definition of a Medicaid encounter: • Include any encounter with an individual receiving

medical assistance under 1905(b), including Medicaid expansion populations and zero pay Medicaid claims

• Permit inclusion of patients on panels seen within 24 months instead of just 12

• Permit patient volume to be calculated using last 12 months, instead of on the CY

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Medicaid-Specific Changes

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• CMS Stage 2 Webpage:• http://www.cms.gov/Regulations-and-Guidance/Legislation/

EHRIncentivePrograms/Stage_2.html

Links to the Federal Register

Tipsheets:– Stage 2 Overview

– 2014 Clinical Quality Measures

– Payment Adjustments & Hardship Exceptions (EPs & Hospitals)

– Stage 1 Changes

– Stage 1 vs. Stage 2 Tables (EPs & Hospitals)

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Stage 2 Resources

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Contact Info

Patrick HamiltonHealth Insurance SpecialistCenters for Medicare & Medicaid ServicesPhiladelphia Regional OfficePhone: (215) 861-4097E-mail: [email protected]

Barbara Connors, D.O., M.P.H.Chief Medical Officer, Region IIICenters for Medicare & Medicaid ServicesPhiladelphia Regional OfficePhone: (215) 861-4218E-mail: [email protected]

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