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EHR Reporting Period In 2015

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Meaningful Use: It’s Not Too Late For 2015!

Jeffrey D. Lehrman, DPM, FACFAS, FASPS, FAPWH

APMA Coding Committee

Expert Panelist, Codingline.com

Fellow, American Academy of Podiatric Practice Management

John Guiliana, DPM, MS

Managing Partner of Collaborative Practice Solutions

Fellow, American Academy of Podiatric Practice Management

(2)
(3)
(4)

• On October 7

th

, CMS released the

Medicare and Medicaid EHR Program

Final Rules for CY 2015

(5)
(6)

Need to know if you were

scheduled for Stage 1 or

Stage 2 in 2015 under old

(7)

Everyone was scheduled for

Stage 2 in 2015

(8)

First Year as a Meaningful User

Stage of Meaningful Use

2015 2016 2017 2018 2011 Modified Stage2 Modified Stage2 Modified Stage2 OrStage3 Stage3 2012 Modified Stage2 Modified Stage2 Modified Stage2 OrStage3 Stage3 2013 Modified Stage2 Modified Stage2 Modified Stage2 OrStage3 Stage3 2014 Modified Stage2* Modified Stage2 Modified Stage2 OrStage3 Stage3 2015 Modified Stage2* Modified Stage2 Modified Stage2 OrStage3 Stage3 2016 -NA- Modified Stage2 Modified Stage2 OrStage3 Stage3

STAGE OF MEANINGFUL USE

CRITERIA

(9)

Reporting

period

for

all

providers

in 2015

will

be any

90

consecutive

days.

* Reporting period in 2016 (other than first time providers)

will be the calendar year.

Reporting

period

if attesting

for the

first

time

in

2016

will

be

90

consecutive days.

(10)

Meaningful Use Stage 2

Attestation

• For an EHR reporting period in 2015, all Medicare

providers must attest by February 29, 2016.

(11)

Meaningful Use Stage 2

• All EP are required to attest to a single set of

objectives and measures

• There are

10

objectives, including one public

health measure

(12)

Meaningful Use Stage 2

Major Changes

• Patient Electronic Access: For 2015,

instead of the 5

(13)

Meaningful Use Stage 2

Major Changes

(14)
(15)

Conduct

or

review

a

security

risk

analysis

in

accordance

with

the

requirements

in

45

CFR

164.308(a)(1),

including

addressing

the

security

(to

include

encryption)

of

data

stored

in

Certified

EHR

Technology

in

accordancewith

requirements

in

45

CFR

164.312(a)(2)(iv)

and

45

CFR

164.306(d)(3),

and

implement

security

updates

as

necessary and correct identified security deficiencies as

part

of

the

eligible

provider

(EP)

risk

management

process.

(16)

Need….

• Documentation of:

• What they did

• What risks were identified

(17)

Implement five clinical decision support interventions related to four or more clinical quality measures at a relevant point in patient care for the entire EHR reporting period.

Alternate Objective and Measure (For those scheduled for Stage 1) Implement ONE clinical decision support rule.

2.

Clinical

Decision

Support

(18)

Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention (Population and Public Health)

Preventive Care and Screening: Influenza Immunization (Population and Public Health)

Pneumonia Vaccination Status for Older Adults (Clinical Processes/Effectiveness)

Diabetes: Eye Exam (Clinical Processes/Effectiveness) Diabetes: Foot Exam (Clinical Processes/Effectiveness)

Diabetes: Hemoglobin A1c Poor Control (Clinical Processes/Effectiveness) Hemoglobin A1c Test for Pediatric Patients (Clinical Processes/Effectiveness) Diabetes: Urine Protein Screening (Clinical Processes/Effectiveness)

Diabetes: Low Density Lipoprotein (LDL) Management (Clinical Processes/Effectiveness)

Falls: Screening for Future Fall Risk (Patient Safety)

Documentation of Current Medications in the Medical Record (Patient Safety)

Closing the referral loop: receipt of specialist report (Care Coordination)

Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up (Population and Public Health)

Preventive Care and Screening: Screening for High Blood Pressure and Follow-Up Documented (Population and Public Health)

(19)

3.

Computerized

Physician

Order

Entry

(CPOE)

Eligible provider must meet all three:

More than60 percentof medication orderscreated byEPare recorded using computerized provider orderentry.

More than30 percentof laboratory orderscreatedby EP are recorded using computerized provider order entry.

More than30 percentof radiology orderscreated byEPare recorded using computerized provider orderentry.

Alternate Measure 1 (Stage 1): More than 30 percent of medication orders created by the EP are recorded using computerized provider order entry.

Alternate Exclusion for Measure 2 (Stage 1): Provider may claim an exclusion for measure 2 (laboratory orders). Alternate Exclusion for Measure 3 (Stage 1): Provider may claim an exclusion for measure 3 (radiology orders).

(20)

More than 50 percent

of

all

permissible

prescriptions

written

by

the

EP

are

queried

for

a drug

formulary

and

transmitted

electronically

using Certified

EHR

Technology.

Alternate (Stage 1)

EP

Measure:

More

than

40

percent

of all

permissible prescriptions written by the EP are

transmitted electronically using Certified EHR

Technology.

4.

Electronic

Prescribing

Sate 2 Exclusions: EPs who: (1) write fewer than 100 permissible prescriptions during the EHR reporting period; or (2) do not have a pharmacy within their organization and there are no pharmacies that accept electronic

(21)

The EP that transitions or refers their patient to another setting of care or provider of care :

(1) uses CEHRT to create a summary of care record; and

(2) electronically transmits such summary to a receiving provider for

more than 10 percent of transitions of care and referrals.

Alternate Exclusion (Stage 1): Provider may claim an exclusion for the measure which requires the electronic transmission of a summary of care document

5.

Summary

of

Care

(22)

Summary of Care Document contains: .

5.

Summary

of

Care

• Patient name

• Provider’s name and office contact info • Current problem list • PMH

• Procedures

• Laboratory test results • Current medication list

and medication history

• Current medication allergy list and medication

allergy history

• Vital signs (height, weight, blood pressure, BMI,

growth charts)

• Smoking status

• Demographic information (preferred language, sex,

race, ethnicity, date of birth)

• Care plan field(s), including goals and instructions;

and any known care team members including the

(23)

Patient-specific education resources identified by Certified

EHR Technology are provided to patients for more than 10

percent

of

all

unique

patients.

Alternate Exclusion (Stage 1): Provider may claim an exclusion for

this measure

6.

Patient

Specific

Education

(24)

Stage 2 Exclusion: Any EP who was not the recipient of any transitions of care during the EHR reporting period.

The

EP

performs

medication reconciliation for

more

than

50

percent

of

transitions

of care

in

which

the

patient

is

transitioned

into

the

care

of

the EP.

Alternate Exclusion (Stage 1): Provider may claim an exclusion for

the measure

(25)

Measure 1: More than 50 percent of all unique patients seen by the EP

during the EHR reporting period are provided timely (within 4 business days after the information is availableto the EP) online access to their health

information* subject to the EP's discretion to withhold certain information. Measure 2: At least one patient seen by the EP during the EHR reporting

period (or their authorized representatives) views,downloads, or transmits

his or her health information to a third party.

Alternate Exclusion Measure 2 (Stage 1): Provider may claim an exclusion for the

second measure

8.

Patient

Electronic

Access

Stage 2 Exclusions: Any EP who—(a) Neither orders nor creates any of the information listed for inclusion as part of the measures; or (b) Conducts 50 percent or more of his or her patient encounters in a county that does not have 50

(26)

• Current medication allergy list and medication

allergy history

• Vital signs (height, weight, blood pressure, BMI,

growth charts)

• Smoking status

• Demographic information (preferred language, sex,

race, ethnicity, date of birth)

• Care plan field(s), including goals and instructions;

and any known care team members including the

primary care provider of record.

Health

Information to be Provided

• Patient name

• Provider’s name and office contact info • Current problem list • PMH

• Procedures

• Laboratory test results • Current medication list

(27)

Measure:

During the EHR reporting period, the capability

for patients to send and receive a secure electronic

message with the provider was fully enabled.

Alternate Exclusion (Stage 1): An EP may claim an exclusion for the

measure

9.

Secure

Electronic

Messaging

(28)

Objective #10

Public Health Reporting

Stage 2

Measure Option 1 – Immunization Registry Reporting: The EP is in active

engagement with a public health agency to submit immunization data.

Exclusions: Any EP meeting one or more of the following criteria may be excluded

from the immunization registry reporting measure if the EP--

• Does not administer any immunizations to any of the populations for which data is collected by its jurisdiction's immunization registry or immunization

information system during the EHR reporting period;

• Operates in a jurisdiction for which no immunization registry or immunization information system is capable of accepting the specific standards required to meet the CEHRT definition at the start of the EHR reporting period; or

(29)

Objective #10

Public Health Reporting

Stage 2

Measure Option 2 – Syndromic Surveillance Reporting: The EP is in active

engagement with a public health agency to submit syndromic surveillance data.

Exclusion for EPs: Any EP meeting one or more of the following criteria may be

excluded from the syndromic surveillance reporting measure if the EP:

• Is not in a category of providers from which ambulatory syndromic surveillance data is collected by their jurisdiction's syndromic surveillance system;

• Operates in a jurisdiction for which no public health agency is capable of receiving electronic syndromic surveillance data from EPs in the specific

standards required to meet the CEHRT definition at the start of the EHR reporting period; or

(30)

Objective #10

Public Health Reporting

Stage 2

Measure Option 3 – Specialized Registry Reporting: The EP is in active engagement

to submit data to a specialized registry.

Exclusions: Any EP meeting at least one of the following criteria may be excluded

from the specialized registry reporting measure if the EP--

• Does not diagnose or treat any disease or condition associated with, or collect relevant data that is collected by, a specialized registry in their jurisdiction during the EHR reporting period;

• Operates in a jurisdiction for which no specialized registry is capable of accepting electronic registry transactions in the specific standards required to meet the CEHRT definition at the start of the EHR reporting period; or

• Operates in a jurisdiction where no specialized registry for which the EP is eligible has declared readiness to receive electronic registry transactions at the

(31)
(32)
(33)

Clinical Quality Measures (CQMs)

(34)

Hardship to 2015 MU

• If a provider is unable to meet the requirements of

meaningful use for an EHR reporting period in 2015 for

reasons related to the timing of the publication of the final

rule, a provider may apply for a hardship exception under

the "

extreme and uncontrollable

" circumstances category.

Each hardship exception application will be reviewed on a

case-by-case basis, as required by law.

• In the past, CMS has considered these applications

seriously and, in fact, has approved over 85% of hardship

exemptions. Hardship applications will be available in early

2016 on

https://www.cms.gov/EHRIncentivePrograms

(35)
(36)

References

Related documents

The AADA strongly supports CMS’ proposed change to the EHR reporting period in 2015, which would allow physicians to attest to an EHR reporting period of any continuous 90-day

• Successful ongoing submission of electronic syndromic surveillance data from CEHRT to a public health agency for the entire reporting period. • Successful ongoing

 In 2015, all providers would attest using an EHR reporting period of any continuous 90-day period within the calendar year. 

which data is collected by its jurisdiction's immunization registry or immunization information system during the EHR reporting period ̶ Operates in a jurisdiction for which

health agency is capable of receiving electronic syndromic surveillance data in the specific standards required for Certified EHR Technology at the start of their EHR

* Operates in a jurisdiction for which no public health agency is capable of receiving electronic syndromic surveillance data from EPs in the specific standards required to meet

Medicare – EPs who successfully demonstrate meaningful use of certified EHR technology during the rel- evant EHR reporting period may be eligible to receive an incentive

Medicare – EPs who successfully demonstrate meaningful use of certified EHR technology during the rel- evant EHR reporting period may be eligible to receive an incentive