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THE MEANING OF MEANINGFUL USE CHANGES IN THE STAGE 2 MU FINAL RULE
Angel L. Moore, MAEd, RHIA Eastern AHEC REC
WE WILL BRIEFLY DISCUSS…
Meaningful Use (MU)
Incentive Programs, Eligibility & Timelines
WE WILL BRIEFLY DISCUSS…
CMS Stage 2 Final Rule
Stage 2 Criteria
Stage 1 Changes
Additional Changes/Revisions (2013 and 2014)
Medicaid Volume Calculation Changes
Payment Adjustments & Hardship Exemptions
The meaning behind all of it…
Meaningful Use
• Health Information Technology for Economic and Clinical Health Act (HITECH Act)
• CEHRT
• Meaningful Use Requirements
• Core and Menu HIT Objectives
• Core and Menu Clinical Quality Measures
• Incentive
• Penalty
MEANINGFUL USE
Using certified technology in EHR implementation to:
• Improve quality, safety, efficiency, and reduce health disparities
• Engage patients and family
• Improve care coordination, and population and public health
• Maintain privacy and security of patient health information
MEANINGFUL USE
Incentive Programs,
Eligibility & Timelines
WHEN DO I MEET STAGE 2 MEANINGFUL USE?
Brief Synopsis of Stage 2
Changes (Core and Menu)
STAGE 1 VS. STAGE 2
STAGE 1
• 15 CORE OBJECTIVES
• 5 OF 10 MENU OBJECTIVES
STAGE 2
• 17 CORE OBJECTIVES
• 3 OF 6 MENU OBJECTIVES
STAGE 1 OBJECTIVES ≠ STAGE 2 OBJECTIVES
Implement drug-drug & drug-allergy interaction checks
Maintain up to date problem list
Maintain active medication list
Maintain active med allergy list
STAGE 1 OBJECTIVES ≠ STAGE 2 OBJECTIVES
Report CQMs to CMS or the States
Conduct test to demonstrate capability to exchange key clinical health information among providers
Enable and have access to at least one drug formulary
Provide patients with timely electronic access to their health information within 4 days
STAGE 1 MENU OBJECTIVES = STAGE 2 CORE OBJECTIVES
Clinical lab test results
Generate a list of patients
by diagnosis
Use EHR to
identify and
provide patient
education
Patient Reminders
Summary of Care
Medication Reconciliation
Submit data to NCIR
NEW MEASURES TO STAGE 2 CORE OBJECTIVES
SECURE ELECTRONIC MESSAGING
Ability to view online,
download and transmit health
information
PATIENT ENGAGEMENT *5% of patients must
message provider
*5% of patients must access their health information online
A Comparative Analysis of
Stages 1 and 2
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure Summary of Changes
Use CPOE for medication orders directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local and professional guidelines
More than 30% of unique patients with at least one medication in their medication list seen by the EP have at least one medication order entered using CPOE
Use computerized provider order entry (CPOE) for medication, laboratory and radiology orders directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local and professional guidelines
More than 60% of medication, 30% of laboratory, and 30% of radiology orders created by the EP during the EHR reporting period are recorded using CPOE
*Increased
thresholds/percentages
*Additional order types
*FINAL RULE PRESENTS
ADDITIONAL CHANGES-
see additional slides for
details
Implement drug-drug and drug-allergy interaction checks
The EP has enabled this functionality for the entire EHR reporting period
No longer a separate objective for Stage 2
This measure is incorporated into the Stage 2 Clinical Decision Support measure
*Removed
Generate and transmit permissible prescriptions electronically (eRx)
More than 40% of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technology
Generate and transmit permissible prescriptions electronically (eRx)
More than 50% of all permissible prescriptions written by the EP are compared to at least one drug formulary and transmitted electronically using Certified EHR Technology
*Increased from 40% to
50%
*Stage 1 Menu item
incorporated into the
Stage 2 Core Item
*FINAL RULE PRESENTS
ADDITIONAL CHANGES-
see additional slides for
details
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure Summary of Changes
Record demographics Preferred language Gender Race Ethnicity Date of birth
More than 50% of all unique patients seen by the EP have demographics recorded as structured data
Record the following demographics Preferred language Gender Race Ethnicity Date of birth
More than 80% of all unique patients seen by the EP have demographics recorded as structured data
*Increased threshold
from 50% to 80%
Maintain an up-to-date problem list of current and active diagnoses
More than 80% of all unique patients seen by the EP have at least one entry or an indication that no problems are known for the patient recorded as structured data
No longer a separate objective for Stage 2
This measure is incorporated into the Stage 2 measure of Summary of Care Document at Transitions of Care and Referrals
*Removed
Maintain active medication list
More than 80% of all unique patients seen by the EP have at least one entry (or an indication that the patient is not currently prescribed any medication) recorded as structured data
No longer a separate objective for Stage 2
This measure is incorporated into the Stage 2 measure of Summary of Care Document at Transitions of Care and Referrals
*Removed
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure Summary of Changes
Maintain active medication allergy list
More than 80% of all unique patients seen by the EP have at least one entry (or an indication that the patient has no known medication allergies) recorded as structured data
No longer a separate objective for Stage 2
This measure is incorporated into the Stage 2 measure of Summary of Care Document at Transitions of Care and Referrals
*Removed
Record and chart changes in vital signs: Height Weight Blood pressure Calculate and display BMI Plot and display growth charts for children 2-20 years, including BMI
For more than 50% of all unique patients age 2 and over seen by the EP, blood pressure, height and weight are recorded as structured data
Record and chart changes in vital signs: Height Weight Blood pressure (age 3 and over) Calculate and display BMI Plot and display growth charts for patients 0-20 years, including BMI
More than 80% of all unique patients seen by the EP have blood pressure (for patients age 3 and over only) and height and weight (for all ages) recorded as structured data
*Measure changes
**FINAL RULE PRESENTS
ADDITIONAL CHANGES-
see additional slides for
details
Record smoking status for patients 13 years old or older
More than 50% of all unique patients 13 years old or older seen by the EP have smoking status recorded as structured data
Record smoking status for patients 13 years old or older
More than 80% of all unique patients 13 years old or older seen by the EP have smoking status recorded as structured data
*Increased threshold
from 50% to 80%
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure Summary of Changes
Implement one clinical decision support rule relevant to specialty or high clinical priority along with the ability to track compliance that rule
Implement one clinical decision support rule
Use clinical decision support to improve performance on high-priority health conditions
1. Implement 5 clinical decision support interventions related to 4 or more clinical quality measures, if applicable, at a relevant point in patient care for the entire EHR reporting period. 2. The EP has enabled the functionality for drug-drug and drug-allergy interaction checks for the entire EHR reporting period
*Increased number of
CDSRs must be
enabled
*Previous stage 1 core
item (drug interaction
checks) incorporated
into this stage 2
measure
Report clinical quality measures (CQMs) to CMS or the States
Provide aggregate numerator, denominator, and exclusions through attestation or through the PQRS Electronic Reporting Pilot
No longer a separate objective for Stage 2, but providers must still submit CQMs to CMS or the States in order to achieve meaningful use
Starting in 2014, all CQMs will be submitted electronically to CMS
*Removed
*Deemed as a part of
the definition of
meaningful use
*FINAL RULE PRESENTS
ADDITIONAL CHANGES-see
additional slides for details
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure Summary of Changes
Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, medication allergies), upon request
More than 50% of all patients of the EP who request an electronic copy of their health information are provided it within 3 business days
Provide patients the ability to view online, download and transmit their health information within four business days of the information being available to the EP
i. More than 50% of all unique patients seen by the EP during the EHR reporting period are provided timely (available to the patient within 4 business days after the information is available to the EP) online access to their health information ii. More than 5% of all unique patients seen by the EP during the EHR reporting period (or their authorized representatives) view, download, or transmit to a third party their health information
*New
*Changed from “upon
request” to a
requirement
*Additional
requirement that
patient must access
their health
information
*PATIENT
ENGAGEMENT
*FINAL RULE
PRESENTS
ADDITIONAL
CHANGES-see
additional slides for
details
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure Summary of Changes
Provide clinical summaries for patients for each office visit
Clinical summaries provided to patients for more than 50% of all office visits within 3 business days
Provide clinical summaries for patients for each office visit
Clinical summaries provided to patients within one business day for more than 50% of office visits
*Decreased time to
provide clinical
summaries
Capability to exchange key clinical information (for example, problem list, medication list, medication allergies, diagnostic test results), among providers of care and patient authorized entities electronically
Performed at least one test of certified EHR technology's capacity to electronically exchange key clinical information
This objective is eliminated from Stage 1 in 2013 and is no longer an objective for Stage 2
This measure is eliminated from Stage 1 in 2013 and is no longer a measure for Stage 2
*Removed
*FINAL RULE PRESENTS
ADDITIONAL CHANGES-
see additional slides for
details
Protect electronic health information created or maintained by the certified EHR technology through the implementation of appropriate technical capabilities
Conduct or review a security risk analysis per 45 CFR 164.308 (a)(1) and implement security updates as necessary and correct identified security deficiencies as part of its risk management process
Protect electronic health information created or maintained by the Certified EHR Technology through the implementation of appropriate technical capabilities.
Conduct or review a security risk analysis in accordance with the requirements under 45 CFR 164.308 (a)(1), including addressing the encryption/security of data at rest and implement security updates as necessary and correct identified security deficiencies as part of its risk management process
*None
*Please review new
HIPAA Omnibus Final
Rule
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure Summary of Changes
Implement drug-formulary checks (MENU)
The EP has enabled this functionality and has access to at least one internal or external drug formulary for the entire EHR reporting period
No longer a separate objective for Stage 2
This measure is incorporated into the e-Prescribing measure for Stage 2
*Removed
Incorporate clinical lab-test results into certified EHR technology as structured data (MENU)
More than 40% of all clinical lab tests results ordered by the EP during the EHR reporting period whose results are either in a positive/negative or numerical format are incorporated in certified EHR technology as structured data
Incorporate clinical lab-test results into Certified EHR Technology as structured data (CORE)
More than 55% of all clinical lab tests results ordered by the EP during the EHR reporting period whose results are either in a positive/negative or numerical format are incorporated in Certified EHR Technology as structured data
*Moved from menu to
core
*Increased threshold
from 40% to 55%
Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research or outreach (MENU)
Generate at least one report listing patients of the EP with a specific condition
Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research, or outreach (CORE)
Generate at least one report listing patients of the EP with a specific condition
*Moved from menu to
core
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure Summary of changes
Send reminders to patients per patient preference for preventive/ follow up care (MENU)
More than 20% of all unique patients 65 years or older or 5 years old or younger were sent an appropriate reminder during the EHR reporting period
Use clinically relevant information to identify patients who should receive reminders for preventive/follow-up care (CORE)
Use 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
*Measure change
Provide patients with timely electronic access to their health information (including lab results, problem list, medication lists, medication allergies) within four business days of the information being available to the EP (MENU)
More than 10% of all unique patients seen by the EP are provided timely (available to the patient within four business days of being updated in the certified EHR technology) electronic access to their health information subject to the EP’s discretion to withhold certain information
This objective is eliminated from Stage 1 in 2014 and is no longer an objective for Stage 2
This measure is eliminated from Stage 1 in 2014 and is no longer a measure for Stage 2
*Removed
*FINAL RULE PRESENTS
ADDITIONAL CHANGES-
see additional slides for
details
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure Summary of Changes
Use certified EHR technology to identify patient-specific education resources and provide those resources to the patient if appropriate (MENU)
More than 10% of all unique patients seen by the EP are provided patient-specific education resources
Use certified EHR technology to identify patient-specific education resources and provide those resources to the patient if appropriate (CORE)
Patient-specific education resources identified by CEHRT are provided to patients for more than 10% of all unique patients with office visits seen by the EP during the EHR reporting period
*Moved from menu to
core
The EP who receives a patient from another setting of care or provider of care or believes an encounter is relevant should perform medication reconciliation (MENU)
The EP performs medication reconciliation for more than 50% of transitions of care in which the patient is transitioned into the care of the EP
The EP who receives a patient from another setting of care or provider of care or believes an encounter is relevant should perform medication reconciliation (CORE)
The EP performs medication reconciliation for more than 50% of transitions of care in which the patient is transitioned into the care of the EP
*Moved from menu to
core
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure Any additional changes?
The EP who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care should provide summary of care record for each transition of care or referral (MENU)
The EP who transitions or refers their patient to another setting of care or provider of care provides a summary of care record for more than 50% of transitions of care and referrals
The EP who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care should provide summary of care record for each transition of care or referral (CORE)
Provide 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 a CMS test system
*Moved from menu to
core
*Health information
exchange required
Capability to submit electronic data to immunization registries or Immunization Information Systems and actual submission except where prohibited and in accordance with applicable law and practice (MENU)
Performed at least one test of certified EHR technology's capacity to submit electronic data to immunization registries and follow up submission if the test is successful (unless none of the immunization registries to which the EP submits such information have the capacity to receive the information electronically)
Capability to submit electronic data to immunization registries or Immunization Information Systems and actual submission except where prohibited and in accordance with applicable law and practice (CORE)
Successful ongoing submission of electronic immunization data from Certified EHR Technology to an immunization registry or immunization information system for the entire EHR reporting period
*Moved from menu to
core
Stage 1 Objective Stage 1 Measure Stage 2 Objective Stage 2 Measure Any additional
changes?
New Stage 2 Measure (Not a Stage 1 Measure)
New Stage 2 Measure (Not a Stage 1 Measure)
Use secure electronic messaging to communicate with patients on relevant health information
A secure message was sent using the electronic messaging function of Certified EHR Technology by more than 5% of unique patients seen during the EHR reporting period
NO
Stage 2 MENU Objective Stage 2 MENU Measure
Imaging Results More than 10% of imaging results are accessible
through Certified EHR Technology
Family History Record family health history for more than 20%
Syndromic Surveillance Successful ongoing transmission of syndromic surveillance data
Cancer Successful ongoing transmission of cancer case information
Specialized Registry Successful ongoing transmission of data to a specialized registry
Progress Notes Enter an electronic progress note for more than 30% of unique patients
CMS Stage 2 Final Rule:
Stage 1 Changes
• Exchange of key clinical information—no longer required in 2013
• Clinical Quality Measures—no longer separate core objective in 2013, but still required to report CQMs
2013 STAGE 1 CHANGES
2013 STAGE 1 CHANGES
• CPOE—optional alternate measure in 2013 that becomes required in 2014 for stage 2 attesters
• You will always have 2 options for stage 1
• e-Prescribing—new exclusion added effective 2013
• Providers not within a 10 mile radius of a pharmacy that accepts electronic prescriptions
• Vital Signs—optional new measure and exclusions in 2013 that becomes required in 2014
• Electronic Copy of and Electronic Access to Health Information (core and menu)—Replaced with the requirement that you must provide patients ability to view online, download, and transmit their health information within 4 days (to more than 50% of unique patients seen by EP)
• Menu Exclusions—can’t claim exclusion if there are other objectives you can meet
• *Vital Signs—optional new stage 1 measure in 2013 becomes required stage 1 measure
• This impacts both stages in 2014
2014 STAGE 1 CHANGES
• In 2014, providers will have to upgrade to or adopt certified systems that meet the 2014 certification criteria
• 2014 3 month reporting period NO MATTER THE STAGE YOU ARE REPORTING
• 2014 Batch Reporting for Core and Menu Items
CMS STAGE 2 FINAL RULE: ADDITIONAL CHANGES
PAYMENT ADJUSTMENTS & HARDSHIP EXEMPTIONS
• Infrastructure (in an area without internet access)
• Unforeseen circumstances (example: natural disaster)
• New EP’s (newly practicing providers who haven’t had time to meet MU can apply for 2 year extension)
• By specialist/provider type (certain provider types may meet 3 required areas to be exempt)
Follow link for more information
http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/PaymentAdj_HardshipExcepTipSheetforEP.pdf
PAYMENT ADJUSTMENTS & HARDSHIP EXEMPTIONS
• Now includes zero pay claims
• Under Stage 2 rule (applicable to all stages), States also have option to allow providers to calculate Medicaid patient volume across 90-day period in last 12 months preceding provider’s attestation
MEDICAID VOLUME CALCULATION CHANGES
Stage 1: Meaningful use criteria focus on:
Stage 2: Meaningful use criteria focus on:
Stage 3: Meaningful use criteria focus on:
Electronically capturing health information in a standardized format
More rigorous health information exchange (HIE)
Improving quality, safety, and efficiency, leading to improved health outcomes
Using that information to track key clinical conditions
Increased requirements for e-prescribing and incorporating lab results
Decision support for national high-priority conditions
Communicating that information for care coordination processes
Electronic transmission of patient care summaries across multiple settings
Patient access to self-management tools
Initiating the reporting of clinical quality measures and public health information
More patient-controlled data Access to comprehensive patient data through patient-centered HIE
Using information to engage patients and their families in their care
Improving population health
THE MEANING BEHIND IT ALL…
• http://www.youtube.com/watch?v=HIkMCk-zIbI&feature=share&list=UUqynwrKIXFPyUCxqkAZ001w
THE MEANING BEHIND IT ALL…
FOR COMPLETE STAGE 2 INFORMATION…
Stage 1 Changes Tip Sheet http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/Stage1ChangesTipsheet.pdf CMS Webpage with several stage 2 links http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Stage_2.html MU Stage 2 Final Rule http://www.ofr.gov/(X(1)S(uzclbwrx5fwqm2w2mipkysrh))/OFRUpload/OFRData/2012-21050_PI.pdf
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RESOURCES/REFERENCES
• Healthit.gov
• US Department of Health and Human Services
• ONC Website
• CMS Stage 2 MU Final Rule
• CCME (ccmeconsulting.org)
• CMS Website
• Stage 1 Changes Tipsheet
• Stage 1 vs. Stage 2 Comparison