barbara connors, d.o., m.p.h. patrick hamilton
DESCRIPTION
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 PresentationTRANSCRIPT
Stage 2 Meaningful Use and 2013 PQRS Updates Webinar
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Barbara Connors, D.O., M.P.H.Patrick Hamilton
Centers for Medicare & Medicaid ServicesPhiladelphia Regional Office
January 15, 2013
Physician Quality Reporting System (PQRS)
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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
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PQRS – Who is an Eligible Professional?
• 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
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PQRS Goals
• 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)
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CMS Quality and Reporting Program Alignment
• 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
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PQRS Group Practice Reporting Option (GPRO) & Medicare Shared Savings Program
• 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
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PQRS and the Value-based Payment Modifier
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
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PQRS Reporting Periods
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
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Incentive and Payment Adjustment Amounts
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
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Reporting Mechanisms
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
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Reporting Mechanisms
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
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Benefits of Participating as an Individual Eligible Professional
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!
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How to Participate as an Individual
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%
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PQRS Payment Adjustment
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.
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How to Avoid the Payment Adjustment in 2015
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.
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How to Avoid the Payment Adjustment in 2016
• 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)
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Definition of a PQRS Group Practice
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
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GPRO Reporting
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!
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How to Participate as GPRO
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%
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GPRO Payment Adjustment
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
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How to Avoid the Payment Adjustment in 2016
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
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PQRS Measures
e-Prescribing Initiative
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• 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
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The eRx Incentive Program: Updates
• 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
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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
• 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
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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
• 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
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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
• 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
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eRx Informal Review Process
HITECH Meaningful Use: Stage 2 & Payment
Adjustments
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• 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
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HITECH Meaningful Use Stage 2 Final Rule
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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
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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
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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
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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
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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.
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Stages of Meaningful Use
Data capturing and sharing
Advanced clinical processes
Improved outcomes
Stage 1
Stage 2
Stage 3
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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
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.
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2014 Changes
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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:
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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
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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
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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
• 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.
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Clinical Quality Measures
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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.
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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
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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
• 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
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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.
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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%
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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
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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
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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
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.
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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.
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
• 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
• 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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