Modified Stage 2 Final Rule

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Illinois Health Information Technology

Regional Extension Center (ILHITREC)

SUPPORT PROVIDED BY ILHITREC:

The Illinois Health Information Technology Regional Extension Center

(ILHITREC), under contract with the Illinois Department of Health and Family

Services (HFS), is providing education, outreach and support to Medicaid

providers for the Electronic Health Record (EHR) Provider Incentive Payment

(PIP) Program. Northern Illinois University serves as the Illinois Health

Information Technology Regional Extension Center providing EHR and

meaningful use services to providers in Illinois. For more information, e-mail

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Speaker Biography

Brenda Simms, RN, BSN, CHTS-CP

Brenda is a Clinical Informatics Specialist at ILHITREC. She works with physicians, practice managers, clinical staff, billing representatives, physicians and EHR vendors to successfully plan, coordinate, and implement an electronic health record (EHR) system, as well as assist practices with workflow redesign and assists with development of required quality

reporting. Brenda also worked for a time with the Central Illinois Health Information Exchange (CIHIE) to facilitate the implementation and effective adoption of HIE.

Patty Tobin, MBA

Patty is a Clinical Informatics Specialist at ILHITREC, where she assists practices in quality improvement, achievement of Meaningful Use, an optimization of EHR systems. She has over 15 years dedicated to healthcare informatics. Prior to joining ILHITREC, Patty

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Disclaimer



The target audience of this presentation is Eligible Providers, but some references will be made related to Eligible Hospitals.

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This webinar is based on official guidance provided by the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator (ONC),

experiences from ILHITREC, and other Regional Extension Centers.



This presentation was prepared as a tool to assist providers enrolled in the EHR Incentive Program administered by CMS. The ultimate responsibility for compliance, submission and response to any remittance from CMS rests with the provider. Medicare policy changes frequently. It is highly recommended that providers and their designee review rules and regulations frequently.

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Modified Final Rule 2015 - 2017

The Modification Rule responds to provider concerns about software implementation and information exchange readiness:



Restructures Stage 1 and Stage 2 Objective measures to align with Stage 3:



EP: 10 Objectives, including 1 consolidated public health objective

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EH/CAH: 9 Objectives, including 1 consolidated public health objective

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Streamlines program by removing redundant, duplicative and topped out measures

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Modifies patient action measures in Stage 2 objectives related to patient engagement that requires “patient action”

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Starting in 2015, aligns reporting period with the calendar year for all providers

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Changes EHR reporting period in 2015 to 90-day period to accommodate modifications

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All providers attest to Modified Stage 2 Objectives unless this is the first year of participation

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“Blending” of Objective Measures

 Beginning in 2015, Stage 1 and Stage 2 objectives and measures are “Blended” into a single set of objectives

 Replaces previous structure of Core and Menu measures  Accommodations are made for Stage 1 providers

 Stage objectives are based on 1st _{payment year (excluding AIU)}

First Payment Year 2015 2016 2017 2018 Modified Stage 2 Or Stage 3 Modified Stage 2 Or Stage 3 Modified Stage 2 Or Stage 3 Modified Stage 2 Or Stage 3 Modified Stage 2 Or Stage 3 Modified Stage 2 Or Stage 3

Stage of Meaningful Use

2011 Modified Stage 2 Modified Stage 2 Stage 3

2016 - NA - Modified Stage 2 Stage 3

2014 Modified Stage 2* Modified Stage 2 Stage 3

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Participation Timeline

Attest to Modified Stage 2

(with accommodations for Stage 1 providers)

2015

Attest to Modified Stage 2

(Some alternate exclusions remain for Stage 1 providers)

2016

Attest to either Modified Stage 2

or full version of Stage 3

2017

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Reporting Periods

- All providers attest to EHR reporting period of any

continuous 90-day period within calendar year.

2015

2016

2017

2018

- First-time participants may use any 90-day period

- Returning participants must report the full calendar year

- First-time participants may use any 90-day period

- Returning participants must report the full calendar year - Stage 3 participants may use any 90-day period

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Previous EP Stage 1 Objectives

 13 Core Objectives

 5 of 9 Menu Objectives

EP Objectives for 2015-2017 (Modified Stage 2)

 10 Objectives (including one consolidated public health reporting objective with 3 measure options)

Previous EH/CAH Stage 1 Objectives

 11 Core Objectives

EH/CAH Objectives for 2015-2017 (Modified Stage 2)

EP

EH/CAH

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Previous EP Stage 1 Objectives

 17 Core Objectives (including public health objectives)

EP Objectives for 2015-2017 (Modified Stage 2)

Previous EH/CAH Stage 1 Objectives

 16 Core Objectives (including public health objectives)

EH/CAH Objectives for 2015-2017 (Modified Stage 2)

EP

EH/CAH

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EHR Certification

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2015 – No changes to the 2014 CEHRT currently in use

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2018 – Required to update CEHRT to 2015 standards

Note: Providers may upgrade early to technology certified to the 2015 Edition for EHR reporting period prior to 2018 as outlined in the rule

Reporting Year Certified EHR Technology Edition

2015 2014 CEHRT

2016 - 2017 2014 or 2015 CEHRT

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Major Changes to Objectives Beginning in 2015

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Changing threshold from Stage 2 objective for Patient Electronic Access measure #2, from 5%, to equal to or greater than 1 patient seen by provider or discharged from hospital

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Changing threshold from Stage 2 objective Secure Electronic Messaging from percent to functionality fully enabled (yes/no)

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Consolidating all public health reporting objectives into one objective with measure options following structure of Stage 3 Public Health Reporting objective

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Alternate Exclusions and Specifications

for Stage 1 Providers for Meaningful Use in 2015



Any provider scheduled to demonstrate Stage 1 who was not

intending to attest to the Stage 1 Patient Specific Education menu

objective, may claim an exclusion to the measure.



Please note that beginning in 2016, all providers must attest to

the objective and measure, and meet the Modified Stage 2

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Core Problem List

Core Record Demographics

Core Record Vital Signs*

Core Record Smoking Status*

Core Clinical Summaries

Menu Structured Lab Results

Menu Patient Lists

Menu Patient Reminders

Menu Summary of Care (Measures 1 & 3)

Scheduled for Stage 2 Beginning in 2015 Electronic Notes Scheduled for Stage 2 Beginning in 2015 Image Results

Scheduled for Stage 2 Beginning in 2015 Family Health History

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Modified Stage 2 Objectives for Eligible Providers

Modified Stage 2 Minimum Required for Providers

Scheduled for Stage 1

Data in Certified EHR only Data in Certified EHR only

5 rules, 4 related to CQMs 1 CDS Rule

Objective 3: CPOE Meds/Labs/Radiology 60% / 30% / 30% 30% / Exclusion / Exclusion

Objective 4: Electronic Prescribing 50% 40%

Objective 5: Health Information Exchange

Part 2: Electronically submit summary 10% May claim an exclusion

Objective 6: Patient Specific Education 10% May claim an exclusion if EP did not intend

to select this Stage 1 Menu Objective

50% May claim an exclusion if EP did not intend

to select this Stage 1 Menu Objective Objective 8: Patient Electronic Access

Part 1: Timely Access 50% 50%

Part 2: Patient VDT 1 patient VDT May claim an exclusion

Objective 9: Secure Electronic Messaging Function Enabled May claim an exclusion

Objective 10: Public Health Reporting Report on 2 Options Report on 1 Option

Objective

Objective 7: Medication Reconciliation

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Payment Adjustment and Hardship Exceptions

Reporting 2015 Penalty Year Reporting 2016 Penalty Year New Participant Any 90-day Period CY 2016 - 2017

Any 90-day Period*

(1/1/16 - 10/1/16) CY 2018

Returning Participant Any 90-day Period CY 2016 Full Calendar Year CY 2018

The EHR reporting periods for the payment adjustment will begin and end prior to the year of the payment adjustment

Providers may apply for a hardship exception to avoid the payment adjustments. Hardship exceptions are granted on a case-by-case basis.

Information on how to apply is posted on the CMS EHR Incentive Program Website

https://www.cms.gov/Regulations-and-guidance/Legislation/EHRIncentivePrograms/PaymentAdj_Hardship.html

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Attestation Deadline for CY:

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Preparing for participation in 2015

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Confirm your Stage

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Check registration information:

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NPPES Login Information

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Make sure email address is correct

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Make sure payment information is correct

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Identify and Access Management (I&A) and/or Surrogate

Users Info up to date

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Illinois Medicaid EHR Incentive Program Participants:

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Register and Link surrogates to providers in Medi

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Impact Registrations (Must register in both systems)

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Complete Attestations EARLY, do not wait until the last minute

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Modified Stage 2 Objectives for EPs

Objective 1: Protect Patient Health Info/Security Risk Assessment Objective 2: Clinical Decision Support + Drug Interactions

Objective 3: CPOE for Medication, Laboratory, and Radiology Orders Objective 4: Electronic Prescribing (eRx)

Objective 5: Health Information Exchange (Summary of Care) Objective 6: Patient Specific Education

Objective 8: Patient Electronic Access (VDT)

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Progression of Stages for Eligible Providers

Retired Stage 1 Retired Stage 2 Modified Stage 2

Core 1: CPOE for Medication Orders Core 1: CPOE for Medication, Laboratory, Radiology Objective 3: CPOE for Medication, Laboratory, Radiology Core 2: Drug Interaction Checks No longer a separate objective (incorporated into CDS) No longer a separate or required objective

Core 3: Maintain Problem List No longer a separate objective (incorporated into SOC) No longer a separate or required objective Core 4: Electronic Prescribing (eRx) Core 2: Electronic Prescribing (eRx) Objective 4: Electronic Prescribing (eRx) Core 5: Active Med List No longer a separate objective (incorporated into SOC) No longer a separate or required objective Core 6: Active Med Allergy List No longer a separate objective (incorporated into SOC) No longer a separate or required objective Core 7: Record Demographics Core 3: Record Demographics No longer a separate or required objective Core 8: Record Vital Signs Core 4: Record Vital Signs No longer a separate or required objective Core 9: Record Smoking Status Core 5: Record Smoking Status No longer a separate or required objective

Core 10: Clinical Decision Support Core 6: Clinical Decision Support + Drug Interactions Objective 2: Clinical Decision Support + Drug Interactions Core 11: Patient Electronic Access Core 10: Patient Electronic Access Objective 8: Patient Electronic Access

Core 12: Clinical Summaries Core 11: Clinical Summaries No longer a separate or required objective Core 13: Protect Electronic Health Info/SRA Core 17: Protect Electronic Health Info/SRA Objective 1: Protect Electronic Health Info/SRA

Menu 1: Drug Formulary Checks No longer a separate objective (incorporated into eRx) No longer a separate or required objective Menu 2: Clinical Lab-test Results Core 7: Clinical Lab-test Results No longer a separate or required objective Menu 3: Patient Lists Core 8: Patient Lists No longer a separate or required objective Menu 4: Patient Reminders Core 9: Patient Reminders No longer a separate or required objective Menu 5: Patient-specific Education Core 12: Patient-specific Education Objective 6: Patient-specific Education Menu 6: Medication Reconciliation Core 14: Medication Reconciliation Objective 7: Medication Reconciliation Menu 7: Summary Care Record Core 15: Summary of Care Objective 5: Health Information Exchange Menu 8: Immunization Registry Core 16: Immunization Registry Objective 10: Public Health Option Menu 9: Syndromic Surveillance Menu 3: Syndromic Surveillance Objective 10: Public Health Option

Core 13: Secure Electronic Messaging Objective 9: Secure Electronic Messaging

Menu 1: Imaging Results No longer a separate or required objective Menu 2: Family History No longer a separate or required objective Menu 4: Cancer Registry No longer a separate or required objective

(May count towards the Specialized Registry Reporting) Menu 5: Specialized Registry Objective 10: Public Health Option

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Modified Stage 2 Objectives for EPs

Objective 1: Protect Patient Health Info/Security Risk Assessment

Objective 2: Clinical Decision Support + Drug Interactions

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Objective 1: Protect Patient Health Information/SRA

Conduct or review a security risk analysis including addressing the encryption/security of data stored in Certified EHR Technology, and implement security updates as necessary and correct identified security deficiencies as part of the EPs risk management process. Note: This measure should be in accordance with the Code of Federal

Regulations: 45CFR164.308(a)(1); 45CFR164.312(a)(2)(iv); 45CFR164.306(d)(3), and organizations must follow the risk analysis guidance in accordance with the HIPAA Security Rule (issued by the Office for Civil Rights).

Measure:

Alternate Exclusions and Specifications for Stage 1 Providers in 2015

Objective Modified Stage 2 Requirements Alternate Stage 1 Requirements

Protect Patient Health Info Conduct or review

security risk analysis None

Note: Free Security Risk Assessment (SRA) Tool developed by ONC and OCR:

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Modified Stage 2 Objectives for EPs

Objective 1: Protect Patient Health Info/Security Risk Assessment

Objective 2: Clinical Decision Support + Drug Interactions

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Objective 2: Clinical Decision Support + Drug Interactions

Measure 1: 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.

Measure 2: The EP has enabled and implemented the functionality for drug-drug and drug allergy interaction checks for the entire reporting period.

Exclusion: Any EP who writes fewer than 100 medication orders during the reporting period.

Measure Modified Stage 2 Requirements Alternate Stage 1 Requirements

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Modified Stage 2 Objectives for EPs

Objective 3: CPOE for Medication, Laboratory, and Radiology Orders

Objective 4: Electronic Prescribing (eRx)

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Objective 3: Computerized Provider Order Entry

Measure 1: Medication Orders - More than 60% of medication orders created by the

EP during the reporting period are recorded using CPOE.

Exclusion: Any EP who writes fewer than 100 medication orders during the reporting period.

Measure 2: Laboratory Orders - More than 30% of laboratory orders created by the

EP during the reporting period are recorded using CPOE.

Exclusion: Any EP who writes fewer than 100 laboratory orders during the reporting period.

Measure 3: Radiology Orders - More than 30% of radiology orders created by the EP

during the reporting period are recorded using CPOE.

Exclusion: Any EP who writes fewer than 100 radiology orders during the reporting period.

Alternate Exclusions and Specifications for Stage 1 Providers

Measure Modified Stage 2 Requirements Alternate Stage 1 Requirements 1. Medication Orders 60% 2015: 30%

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Modified Stage 2 Objectives for EPs

Objective 3: CPOE for Medication, Laboratory, and Radiology Orders

Objective 4: Electronic Prescribing (eRx)

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Objective 4: Electronic Prescribing (eRx)

Measure: More than 50% of all permissible prescriptions, or all prescriptions, written by the EP are queried for a drug formulary and transmitted electronically using Certified EHR Technology.

Exclusions: Any EP who writes fewer than 100 permissible prescriptions during the reporting period. Or any EP who does not have a pharmacy within his or her organization and there are no pharmacies that accept electronic prescriptions within 10 miles of the EP's practice location at the start of the reporting period.

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Modified Stage 2 Objectives for EPs

Objective 5: Health Information Exchange (Summary of Care)

Objective 6: Patient Specific Education Objective 7: Medication Reconciliation

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Objective 5: Health Information Exchange

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

Exclusion: Any EP who transfers a patient to another setting or refers a patient to another provider less than 100 times during the reporting period.

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

(2) electronically transmits such summary to a receiving provider for more than 10% of transitions of care and referrals.

Part 2: Electronically Transmit

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Modified Stage 2 Objectives for EPs

Objective 5: Health Information Exchange (Summary of Care)

Objective 6: Patient Specific Education

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Objective 6: Patient Specific Education

Measure: Patient specific education resources identified by Certified EHR Technology are provided to patients for more than 10 percent of all unique patients with office visits seen by the EP during the EHR reporting period.

Exclusion: Any EP who has no office visits during the reporting period.

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Modified Stage 2 Objectives for EPs

Objective 7: Medication Reconciliation

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Objective 7: Medication Reconciliation

Measure: 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.

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

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Modified Stage 2 Objectives for EPs

Objective 8: Patient Electronic Access (VDT)

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Objective 8: Patient Electronic Access

Measure 1: More than 50% of all unique patients seen by the EP during the EHR reporting period are provided timely (within 4 business days after the

information is available to the EP) online access to their health information. Measure 2: In 2015 or 2016 reporting period, at least one patient seen by the EP

during the reporting period views, downloads, or transmits his or her health information to a third party.

In 2017 reporting period, more than 5% of unique patients seen by the

EP during the reporting period view, download, or transmit their health information to a third party.

Exclusions: Any EP who neither orders nor creates any of the info listed for

inclusion as part of the measures; or the EP practices in a county with less than 4 Mbps broadband.

Measure 1: Timely Access 50% 50% Measure 2: Patient View,

Download, or Transmit (VDT)

2015: 1 patient 2016: 1 patient 2017: 5%

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Modified Stage 2 Objectives for EPs

Objective 8: Patient Electronic Access (VDT)

Objective 9: Secure Electronic Messaging (EPs Only)

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Objective 9: Secure Electronic Messaging

Measure: In 2015, the capability for patients to send and receive a secure electronic

message with the EP was fully enabled during the reporting period.

In 2016, for at least 1 patient seen by the EP during the reporting period, a

secure message was sent using the electronic messaging function to the patient, or in response to a secure message sent by the patient during the reporting period.

In 2017, for more than 5% of unique patients seen by the EP during the

reporting period, a secure message was sent using the electronic

messaging function to the patient, or in response to a secure message sent by the patient during the reporting period.

Exclusions: An EP has no office visits during the reporting period, or the EP practices in a county with less than 4 Mbps broadband.

Secure Electronic Messaging

2015: Fully Enabled 2016: 1 Patient 2017: 5%

May claim an exclusion in 2015 if EP did not intend to select this

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Modified Stage 2 Objectives for EPs

Objective 8: Patient Electronic Access (VDT) Objective 9: Secure Electronic Messaging

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Objective 10: Public Health Reporting

Measure:

The EP is in active engagement with a Public Health Agency (PHA) to submit electronic public health data in a meaningful way. The EP is required to

successfully attest to any combination of 2 of the possible 3 measures: Measure 1: Immunization Registry Reporting

Measure 2: Syndromic Surveillance Reporting Measure 3: Specialized Registry Reporting

Exclusions:

Measure 1: EP does not administer any immunizations during the reporting period. Measure 2: EP does not treat or diagnose any disease or condition associated with syndromic surveillance.

Measure 3: EP does not diagnose or treat any disease or condition associated with or collect relevant data that is required by a specialized registry.

Applies to all 3 measures: The registry cannot accept electronic information, or the registry has not announced readiness to accept information.

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Clinical Quality Measures

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No changes to CQM selection or reporting scheme (EPs must report on 9 of the 64 approved CQMs)

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For EHR reporting period in 2015 (and for providers participating for first time in 2016), providers attest to any continuous 90-day period of CQM data

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Registration and Attestation site – Providers also have option to electronically report CQM data using established methods for electronic reporting

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For 2016 and subsequent years, providers beyond first year of

meaningful use may attest to one full calendar year of CQM data or electronically report CQM data using established methods for

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Stage 3 Objectives for Eligible Providers

Objective 1: Protect Patient Health Information

Objective 2: Electronic Prescribing

Objective 3: Clinical Decision Support

Objective 4: Computerized Provider Order Entry

Objective 5: Patient Electronic Access to Health Information

Objective 6: Coordination of Care through Patient Engagement

Objective 7: Health Information Exchange

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2015 2016 2017 2018

First Year in MU

Any 90-day Period (1/1/15 – 12/31/15)

Any 90-day Period (By October 1, 2016)

Any 90-day Period

(By October 1, 2017) One Year

Returning Participant Any 90-day Period One Year

Stage 2 – One Year

Stage 3 – 90-days One Year

2015 2016 2017 2018

Penalty Year

Modified Stage 2

(With Alternate Exclusions and Specifications for Stage 1 Providers)

Modified Stage 2 (With Alternate Exclusions and Specifications for Stage 1 Providers) Modified Stage 2

(Or Stage 3) Stage 3

2015 2016 2017 2018

Objectives and CQMs

9 Objectives 2 Public Health Objectives 9 CQMs Minimum of 3/6 Domains

(Alternative for Stage 1 Providers)

Modified Stage 2 (Some alternate exclusions remain for

Stage 1 providers)

Modified Stage 2

(Or Stage 3) Stage 3

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Additional References



Final Rule – Modification 2015 -2017

https://s3.amazonaws.com/public-inspection.federalregister.gov/2015-25595.pdf



CMS EHR Incentive Program

https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/index.html



CMS FAQs

https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/FAQ.html



2015 Requirements

https://www.cms.gov/Regulations-and-guidance/Legislation/EHRIncentivePrograms/2015ProgramRequirements.html