Meaningful Use Stage 2

Meaningful Use Stage 2

Shannon Vogel

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ARRA passed on Feb. 13, 2009.

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Health Information Technology for Economic

and Clinical Health (HITECH) Act has HIT provisions.

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Significant physician incentives!

Medicare Physician Incentives

_{2011 2012 2013 2014 2015 2016 Total}

Paid 2011 $18,000 $12,000 $8,000 $4,000 $2,000 - $44,000

2012 $18,000 $12,000 $8,000 $4,000 $2,000 $44,000

2013 $15,000 $12,000 $8,000 $4,000 $39,000

2014 $12,000 $8,000 $4,000 $24,000

2015 - - - -

Last year to begin is 2014. Last payment year is 2016.

*Health professional shortage area (HPSA) physicians eligible for additional 10 percent Y ea r of el ig ib ility

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Incentives based on the individual, not the practice

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Payments based on 75 percent of Medicare allowable

charges

Medicare Incentives

Year 1 Year 2 Year 3 Year 4 Year 5

$24,000 $16,000 $10,667 $5,334 $2,667

X 75% X 75% X 75% X 75% X 75%

Medicaid Incentives

• Eligible physicians with at least 30-percent Medicaid volume could receive up to $63,750 over a six-year period.

Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Adopting, implementing, and upgrading an EHR $21,250 Meaningfully operating and maintaining an EHR

$8,500 $8,500 $8,500 $8,500 $8,500

Total possible Medicaid incentive is $63,750.

Medicaid incentives available through 2021

Medicaid Incentives

• Eligible pediatricians with at least 20-percent Medicaid

volume could receive up to $42,500 over a six-year period.

Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Adopting,

implementing, and upgrading an EHR

$14,167

Meaningfully operating and maintaining an EHR

$5,667 $5,667 $5,667 $5,667 $5,665

Total possible Medicaid incentive is $42,500.

Medicaid incentives available through 2021

Stages of Meaningful Use

Stage I Data capture and sharing Stage II Advanced clinical processes Stage III Improved outcomes (no rules yet)

2011 2014 2015 2013 2017 2016

First Year

Payment Year

2011 2012 2013 2014 2015 2016 2011 Stage I Stage I Stage 1 Stage 2 Stage 2 Stage 2 2012 Stage I Stage I Stage 2 Stage 2 Stage 2 2013 Stage I Stage 1 Stage 2 Stage 2

2014 Stage I Stage 1 Stage 2

2015+ Stage 1

Stage 1

Requirements by Payment Year

90-days meaningful use allowed in 2014.

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Starting in 2014, ALL practices must use the 2014

edition of their certified EHR, regardless of

meaningful use stage.

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Check the Certified Health IT Product List (CHPL):

http://oncchpl.force.com/ehrcert/

• 2014 edition

• Ambulatory

• Click on product to see CQM list

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Because of the EHR upgrade, the 2014 reporting period is reduced to three months.

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The reporting periods for those beyond year one*

must choose reporting periods by quarter.

• Jan.1 to March 31

• April 1 to June 30

• July 1 to Sept. 30

• Oct. 1 to Dec. 31

* Year one still gets any 90-day reporting period.

Medicare EHR Program (as of Aug. 2014)

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29,292 participants

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$1.1 billion

Medicaid EHR program (as of Aug. 2014)

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11,187 participants

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$6.8 million

Meaningful Use — Exclusions

Stage 1: Exclusions allowed for 13 of the 24 criteria

www.cms.gov/EHRIncentivePrograms/Downloads/EP-MU-TOC.pdf

Stage 2: Exclusions allowed for 19 of the 23 criteria

www.cms.gov/Regulations-andguidance/Legislation/EHRIncentivePrograms/Downloads/ Stage2_MeaningfulUseSpecSheet_TableContents_EPs.pdf

Must choose three menu criteria where exclusions are not applicable.

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There is a delicate balance between how much physicians are pushed and industry readiness.

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Criteria are primary-care focused. Not all specialties

find value in all requirements.

Use computerized physician order entry (CPOE) for more than 60 percent of medication, 30 percent of laboratory, and 30 percent of radiology orders.

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Exclusion: Any eligible provider (EP) who writes

few than 100 medication, 100 radiology, or 100 laboratory orders.

Generate, compare with at least one drug formulary,

and transmit more than 50 percent of all permissible

prescriptions.

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Exclusion: 1) any EP who writers few than 100

permissible prescriptions during the EHR reporting period. 2) Does not have a pharmacy within their organization or 10-mile radius accepting

e-prescriptions.

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Record demographics as structured data for more

than 80 percent of all unique patients seen by the EP.

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No exclusion

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Must record the following:

• Preferred language

• Sex

• Race

• Ethnicity

• Date of birth

Record blood pressure (over age 3), height, and weight as structured data for more than 80 percent of all unique

patients seen by the EP.

• Exclusion 1: No patients 3 years or older excluded from BP

• Exclusion 2: Believes all vital signs of height, weight, and

BP have no clinical relevance.

• Exclusion 3: Believes height and weight are relevant, but

BP is not, is excluded from recording BP.

• Exclusion 4: Believes BP is relevant, but not height and

weight are excluded from recording height/weight.

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Record smoking status of unique patients 13 and older.

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Just status – smoking cessation counseling is for

PQRS.

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Exclusion if no patients 13 or older.

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Measure 1: Implement five clinical decision support interventions related to four or more clinical quality measures related to scope of practice.

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Measure 2: Enable drug-drug and drug-allergy

interactions for entire reporting period.

• Exclusion: Writes few than 100 medication orders during reporting period.

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Consult with vendor to determine clinical decision

support rules capable within your EHR.

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Measure 1: More than 50% of all unique patients are provided timely (within 4 business days) online

access to their health information.

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Measure 2: More than 5% of all unique patients (or

their representative) must view, download, or

transmit to a 3rd part their health information.

• Exclusion: Conducts 50% or more of visits in a county that does not have 50% or more of its housing with 3Mbps

broadband.

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Clinical summaries provided to patient or authorized representatives within one business day for more than 50% of all office visits.

• Exclusion: No office visit during the reporting period.

• Can be provided through PHR, portal, secure email, USB, CD, or even printed copy.

• Cannot charge patients for this access.

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More than 50% of all unique patients are provided timely (within 4 business days) online access to their health information. Gather email addresses!!

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More than 5% of all unique patients (or their

representative) must view, download, or transmit to a

3rd part their health information.

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An electronic secure message was sent to the

physician through the EHR or patient portal by more than 5% of unique patients seen during the EHR

reporting period.

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Clinical summaries provided to patient or authorized representatives within one business day for more than 50% of all office visits.

• Exclusion: No office visit during the reporting period.

• Can be provided through PHR, portal, secure email, USB, CD, or even printed copy.

• Cannot charge patients for this access.

Patient Access/4 business days Visit Summary/1 business day

Patient name Patient name

Physician’s name/office contact Physician’s name/office contact

Date, location, and reason for office visit

Current and past problem list Current problem list Procedures Procedures during visit Current medication list and history Current medication list

Medication allergies and history Current medication allergies Laboratory test results Laboratory test results

Vital signs (height, weight, BP, BMI, growth charts)

Vital signs during visit (height, weight, BP, BMI, growth charts)

Patient Access/4 business days Visit Summary/1 business day

Smoking status Smoking status

Demographic information (sex, race, ethnicity, date of birth, preferred

language)

Demographic information (sex, race, ethnicity, date of birth, preferred

language)

Care plan (goals and instructions) Care plan (goals and instructions) Known care team members (such as

PCP of record)

Immunizations during visit Diagnostic tests pending Clinical instructions Future appointments

Referrals to other providers Future scheduled tests

Recommended patient decision aids

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Conduct a security risk analysis (SRA)

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SRA must occur during the reporting period.

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ONC did create a SRA tool to use in your practice:

http://www.healthit.gov/providers-professionals/security-risk-assessment-tool

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More than 55% of all clinical lab tests results are incorporated into the EHR as structured data.

• Only for lab tests reported in positive/negative or numeric format.

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Exclusion: No lab tests or ordered or results are not

in positive/negative or numeric format.

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Generate at least one report listing patients with a specific condition.

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Be sure to retain the report in the event of an audit.

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Run a different report each EHR reporting period.

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More than 10% of all unique patients who have had 2 or more office visits within the 24 months before the reporting period were sent a reminder, per patient

preference.

• Exclusion: No office visits in the 24 months before the EHR reporting period.

• Must be a reminder for care the patient was not already scheduled to receive.

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Patient-specific education resources identified by the EHR are provided for more than 10% of unique

patients.

• Exclusion: No office visits during EHR reporting period.

• Education resources do not have to be stored in your EHR.

• Must use EHR for suggested resources based on patient information in the EHR. You make final determination to its relevancy.

• Information can be provided in printed format, through portal, or PHR.

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Perform medication reconciliation for more than 50 percent of patients transitioned to your care.

• Exclusion: You were not the recipient of any transitions of care during the reporting period.

• Measure 1: Must provide a patient summary of care record when you transition your patient to another care provider for more than 50% of all transitions.

• Measure 2: Submit the summary of care record via health information exchange (HIE) for 10% of all transitions and referrals.

• Measure 3: Conducts one or more successful exchange of a summary of care document or conducts one or more successful tests with CMS.

• Exclusion: Excluded from all three measures if referring a patient less than 100 times during reporting period.

• Exchanges are in various stages throughout Texas.

• Texas received $28 million from the Office of the National Coordinator for HIT to work.

• Texas Health Services Authority (THSA) overseeing grant dissemination for regional HIEs in Texas.

• Details about Texas HIEs available at

http://hietexas.org/

• October 2012 issue of Texas Medicine article “Vital Connections” provides detailed information.

www.texmed.org/HIE.

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Successful ongoing submission of electronic

immunization data from EHR to immunization registry (ImmTrac in Texas).

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Exclusion 1: Do not administer immunizations

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Exclusion 2: No immunization registry in the state.

ImmTrac website:

http://www.dshs.state.tx.us/Immunize/ImmTrac/

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An electronic secure message was sent to the

physician through the EHR or patient portal by more than 5% of unique patients seen during the EHR

reporting period.

• Exclusion: No office visits or conducts 50% or more of visits in a county that does not have 50% or more of its housing with 3Mbps broadband.

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Successful ongoing submission of syndromic

surveillance data from EHR to a public health agency for reporting period.

• Exclusion 1: Not in a category that collects ambulatory syndromic surveillance data on patients.

• Exclusion 2: Operates in a jurisdiction where agency cannot receive the data electronically.

• Exclusion 3: Operates in a jurisdiction where agency does not provide information timely on how to receive data.

• Exclusion 4: Operates in a jurisdiction where agency cannot accept EHR technology standards.

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Record electronic notes in patient record for more than 30% of all unique patients.

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No exclusion.

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Text of the notes must be text searchable.

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More than 10% of all tests whose result is one or more images ordered during reporting period.

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Exclusion: orders less than 100 tests whose result is

an image during the reporting period.

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More than 20% of all unique patients have structured data entry for one or more first-degree relatives.

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Exclusion: No office visits

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Acceptable to record “unknown” as structured data if

patient is asked and does not know family history.

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Must attest to ongoing submission of cancer case information from EHR to central cancer registry.

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Exclusion 1: Does not diagnose or treat cancer

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Exclusion 2: In jurisdiction with no cancer registry

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Exclusion 3: Agency does not provide submission

information in a timely manner

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Exclusion 4: Agency cannot receive information at

beginning of reporting period

Texas cancer registry: https://www.dshs.state.tx.us/tcr/

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Successful ongoing submission of specific case information from EHR to specialized registry.

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Exclusions: similar to previous registry exclusions.

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CQMs are no longer a core objective, but all physicians are required to report on CQMs to demonstrate meaningful use.

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CQMs are integrated with PQRS reporting.

• PQRS requires full-year reporting, which does not align with EHR 2014 reporting.

• Single submission of PQRS and EHR for 2014 payment year would have to take place between Jan. 1 and Feb. 28, 2015.

• Must submit electronically to CMS (EXCEPT for year one MU physicians)

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Must select CQMs from at least three of the six National Quality Strategy domains:

• Patient and family engagement (PFE)

• Patient safety (PS)

• Care coordination (CC)

• Population and public health (PPH)

• Efficient use of health care resources (HCR)

• Clinical processes/effectiveness (CPE)

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Must report on nine of 64 CQMs

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Adult recommended core set:

Clinical Quality Measures

Controlling high blood pressure

Use of high-risk medications in the elderly

Preventive care and screening: Tobacco use screening and

cessation Use of imaging studies

for low back pain

Preventive care and screening: Screening for clinical depression

Documentation of

current medications in the medical record Preventive care and

screening: Body mass index screening

Closing the referral loop: Receipt of specialist report

Functional status assessment for complex chronic conditions

Submission to CMS:

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Check to see which CQMs your EHR vendor is able

to e-submit: http://oncchpl.force.com/ehrcert/

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Whoever submits to CMS must register with IACS.

• If practice submits — register with IACS

• If vendor submits — practice does not need to register with IACS

Clinical Quality Measures

Check the Certified Health IT Product List (CHPL):

http://oncchpl.force.com/ehrcert/

Medicare Physician Penalties

Penalties Percentage

2015 1 %

2016 2 %

2017 and beyond 3 %

The U.S. Department of Health and Human Services may decrease payments 1 percent per year to a

maximum of 5 percent if 75 percent of office-based

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Must take action each year to prevent the penalty for next payment year.

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Too late to prevent penalty in 2015 (2 exceptions)

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If claiming exemptions, must be claimed by July 1

each year.

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Exemptions include:

• Infrastructure

• New physician

• Unforeseen circumstances/closing practice

• Patient interaction

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Exemption portal reopened for these exceptions:

• Unable to implement 2014 certified technology

• Unable to attest by Oct. 1 using flexibility options.

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Must submit by Nov. 30, 2014 to prevent 2015 penalty.

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Application found here:

http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/PaymentA dj_Hardship.html

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CMS provided some relief to practices if their EHR vendor did not come through with 2014 technology upgrades.

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This may include using an earlier software version to

attest, and may allow for an earlier stage.

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Only applies to practices that could not get 2014

software from the vendor in time to attest.

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Details here:

http://www.texmed.org/Template.aspx?id=31847

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CMS is conducting audits.

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Some are random. Some are based on complex

algorithms.

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Participants should document everything!

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Keep all documentation for six years.

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Once physicians meet meaningful use, attestation is

required for every year of program participation.

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Separate attestation page for each meaningful use

measure

Direct technical questions about the registration and attestation pages to the EHR Information Center:

(888) 734-6433

Mon-Fri; 7:30 am to 6:30 pm (CT)

North Texas

1,498 physicians DFW Hospital Council (469) 648-5140

www.ntrec.org/

(

CentrEast

1,000 physicians Texas A&M HSC (979) 862-5001

www.centreastrec.org/

Gulf Coast

2,928 physicians UT HSC Houston (713) 500-3479

www.uthouston.edu/gcrec/

West Texas

1,022 physicians Texas Tech HSC (806) 743-7960 www.wtxhitrec.org/

We do not plan to implement

an EHR., 20%

We want to or plan to implement

an EHR., 12% We currently

use an EHR., 68%

EHR Status

Use of Scribes

Hired new staff, 19%

Retrained existing staff, 47%

Both, 33%

Practice Use of Scribes

20 percent of practices now use scribes for data entry.

Medicare:

www.cms.gov/EHRIncentivePrograms/

Medicaid:

www.tmhp.com/Pages/HealthIT/HIT_Home.aspx

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Physicians are now permitted through DEA (2010) and Texas DPS (2014) rules to electronically transmit controlled substance prescriptions.

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Prescriptions requiring a DEA number are considered

controlled substances. These include:

• All schedule II

• Many III

• Some IV

• Some V

E-Prescribing Controlled

Substances (EPCS)

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Check with EHR vendor for EPCS module. Can also check Surescripts’ website:

http://surescripts.com/network-connections/mns/prescriber-software#

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It is important for the eRx network to know the vendor is certified and has flipped the switch to prevent blocking the prescription.

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Surescripts largest network.

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There are a handful of other private networks through

vendors.

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Software vendor will handle DEA-required certification.

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There is an identity-proofing process.

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EPCS software requires 2-factor authentication.

Must be:

• Something you know (PIN)

• Something you are (biometrics, such as thumb print)

• Something you have (FOB – frequency operated button, app, magnetic strip)

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Check with local pharmacies to see if they are accepting EPCS.

• Not all of them are.

• Chain pharmacies will most likely be early adopters.

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Pharmacy software may vary in capability to “hold” prescriptions for issuance at later date.

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Pharmacy may not be able to forward prescription if

Schedule II prescription is not in stock.

TMA Resources — EHRs

Resource Access

EHR Implementation Guide (105 pages) www.texmed.org/HIT

EHR Readiness Assessment www.texmed.org/EHRAssess

EHR Comparison Tool www.texmed.org/EHRTool TMA Members Only

EHR Price Guides

• Solo physician • Two-physician • 10-physician

www.texmed.org/EHRTool TMA Members Only

EHR Buyer Beware: Issues to Consider

When Contracting with EHR Vendors www.texmed.org/BuyerBeware

HIT homepage www.texmed.org/HIT

Email: [email protected] Call: (800) 880-5720

TMA Resources – EHR Incentives

Resource Access

Federal stimulus information

• EHR incentive timelines • Program comparisons • Meaningful use information

www.texmed.org/Stimulus

Medicare EHR Incentive Guide

• Step-by-step registration instructions www.texmed.org/MedicareEHR

Medicaid EHR Incentive Guide

• Step-by-step registration instructions _{www.texmed.org/MedicaidEHR}

REC Resource Center

• REC locator tool

• Service and eligibility information

www.texmed.org/REC

Email: [email protected] Call: (800) 880-5720

Questions?

CONTACT INFORMATION Shannon Vogel

Director, Health Information Technology

401 W. 15th St.

Austin, Texas 78701-1680 (800) 880-1300, ext. 1411 [email protected] www.texmed.org