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CMS Meaningful Use Final Rule

Two weeks ago CMS released the final rule that simplifies requirements and adds new flexibility for providers including:

  • Any consecutive 90-day reporting period in 2015
  • 10 objectives for eligible professionals including one public health reporting objective, down from 18 total objectives in prior stages and replaces the core and menu measures for all stages.
  • Stage 3 requirements are optional in 2017, required in 2018
  • Medicare Attestations for 2015 begins on January 4, 2016
  • Additional exclusions and flexibility for providers attesting for the first time this year

 

Final Rule Meaningful Use Requirements

These tables summarize the impact on the Stage 2 measures per the CMS 2015 – 2017 Modification final rulemaking (released 10/06/15, published in Federal Register 10/16/15) compared to Stage 2.  Please note the “Scheduled for Stage 1” in 2015 column as well.  Updated October 9, 2015

 Stage 2 Core (report all 17)

Stage 2 (Final Rule 2012) Description

2015 – 2017 Modification MU

Stage 2 Exclusion

Altnerate Options If 2015 Scheduled for Stage 1

1. CPOE [%]

>60% of medication, 30% of lab, AND 30% of radiology orders

Modified Objective 3

No change from Stage 2

Fewer than 100 for each medication, radiology, laboratory orders, see Specification Sheet

Stage 1 EPs may use “Alternate Measure”

  • > 30% medications

2. e-Prescribing (eRx) [%]

>50% of permissible Rx’s compared to one formulary & transmitted electronically using CEHRT

Modified Objective 4

No change from Stage 2

fewer than 100 Rxs or no ePharm within 10 miles

Stage 1 EPs may use “Alternate Measure”

  • >40% ePrescribed

3. Demographics

80% of unique patients

Removed *

None

Stage 1 was 50%

4. Vital Signs

80% of unique patients
  ≥ age 3 - blood pressure
  all ages - height & weight are recorded as structured data

Removed *

Yes – 4 exclusions, see Specification Sheet for details

Stage 1 was 50% of unique patients ≥ age 3 - height, weight & blood pressure

5. Smoking Status

>80% of unique patients ≥ 13 years old

Removed *

Has no patients  ≥ age 13

Stage 1 was 50%

6. Clinical Decision Support [5 Yes/No]

M1) 5 CDS interventions tied to ≥ 4 CQMs

M2) Drug-drug & drug-allergy interaction checks enabled for entire EHR reporting period

Modified Objective 2

No change;

M2 only EP writes fewer than 100 medication orders

Stage 1 EPs may use “Alternate Measure”

  • 1 CDS Rule
  • Drug interations not applicable to Alt Msr

7. Patient Electronic Access to Health Information (VDT) [%]

M1) 50% of unique patients seen are provided online access within 4 business days (VDT)

M2) >5% actually access (view, download, or transmit)

Modified Objective 8

M1 (50%) no change

M2 reduced from 5% to “at least 1 patient”

Yes – 2 exclusions, see Specification Sheet for details

Measure 2 Only

Stage 1 EPs may use “Alternate Exclusion”

  • Stage 1 did not have an equivalent Core Msr

8. Clinical Summary

>50% of office visits, within 1 business day

Removed

Any EP who has no office visits

Stage 1 was 50% within 3 business days

9. Priv & Sec [Yes]

Conduct SRA w/ encryption of data at rest

Modified Objective 1

No change

None

No atlernate

10. Lab Results

>55% of lab tests in EHR as structured data

Removed *

No lab tests where results are either in a positive/ negative affirmation or numeric format

Stage 1 was

  • >40%
  • Menu measure

11. Patient List

Generate one list by condition

Removed

None.  (Yes attestation rqd)

Stage 1 was Menu measure

12. Patient Reminders

>10% of patients seen ≥ 2 times in past 24 months were identified and had reminders provided

Removed

Has had no office visits in the 24 months before the EHR reporting period

  • >20% ≥ age 65 or ≤ age 5
  • Menu measure

13. Patient Education [%] **

>10% of unique patients seen by EP

Educational resources identified by CEHRT

Modified Objective 6

No change

No office visits during the EHR reporting period

Stage 1 EPs may use “Alternate Exclusion”

  • Did not intend to select Stage 1 Menu choice **

14. Medication Reconciliation [%]

>50% of patients transitioned into care of provider has medication reconciliation performed

Modified Objective 7

No change

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

Stage 1 EPs may use “Alternate Exclusion”

  • Did not intend to select Stage 1 Menu choice***

15. Summary of Care Record [%]

New Name: Health Information Exchange

M1) >50% of transitions and/or referrals to another provider or setting

M2) 10% sent electronically

M3) At least one sent to provider using different vendor’s EHR or to CMS-designated test EHR

Modified Objective 5

M1 and M3 are removed

M2 “simplified” but still 10%;  created in CEHRT and transmitted electronically

Fewer than 100 transfers or referrals

Stage 1 EPs may use “Alternate Specification”

  • Stage 1 did not have an equivalent Core measure

16. Immunization Registries

Successful ongoing electronic transmission of immunization data

Moved into Public Health Measure.  See page 4.

Yes – 4 exclusions, see Specification Sheet for details

  • Perform at least 1 test
  • Menu measure

16. Public Health [Yes]  No exact correlation to one specific Stage 2 Measure

Active engagement with a Public Health Agency or clinical data registry to submit electronic PH data using CEHRT (abbreviated)

Modified Objective 10

Meet 2 of 3 Options Stage See Page 4 for details

Various, however exclusiond do not count towards “meeting”

Stage 1 EPs may use “Alternate Exclusion”

  • May meet 1 PH option

17. Secure Messaging [Yes]

5% of unique patients send electronic message that contains health information

Modified Objective 9

Capability Yes

Yes – 2 exclusions, see Specification Sheet for details

Stage 1 EPs may use “Alternate Exclusion”

Stage 1 did not have an equivalent Core measure

 

S2 Menu Set Measures (Rpt on 3 of 6)

Stage 2

2015 – 2017 Modification NPRM

Stage 2 Exclusion

Altnerate Options If 2015 scheduled for Stage 1

1. Syndromic Surveillance

Successful ongoing electronic transmission of syndromic surveillance data to public health agency

Moved into Public Health Measure.  See Page 4.

Yes – See Spec Sheet

Perform at least 1 test

2. Electronic Note

>30% of patients seen have an electronic progress note created, edited, signed by EP

Removed

No

New S2 measure

3. Imaging Results

>10% of all scans and tests are incorporated into or accessible through CEHRT

Removed *

Fewer than 100 or no access

New S2 measure

4. Family History

>20% of patients seen have a structured data entry for family health history or note that family history was reviewed

Removed

Any EP who has no office visits

New S2 measure

5. Cancer Registries

Successful ongoing electronic submission of cancer case information to cancer registry

Indirectly moved into Public Health Measure

Yes – See Spec Sheet

New S2 measure

6. Specialized Registries

Successful ongoing electronic submission of specific case information to specialized registry

Moved into Public Health Measure

Yes – See Spec Sheet

New S2 measure

* Removed as standalone measures but are required data elements to meet either Patient Electronic Access or the Summary of Care measures

** Regarding the Alternate Exclusions, “did not intend to select the Stage 1 Patient Education menu objective”, reference Page 200 (of 752 page Final Rule pdf) wherein the rule states, “we acknowledge that it may be difficult for a provider to document intent and will not require such documentation”

 

 

Public Health

2015 – 2017 Modification NPRM Scheduled for Stage 2

Exclusions

2015 scheduled for Stage 2

2015 scheduled for Stage 1

1. Immunization Registry Reporting

The EP, eligible hospital, or CAH is in active engagement with a public health agency to submit immunization data.

Yes, See CMS EHR Incentive Programs 2015 through 2017 (Modified Stage 2) Overview

Must meet 2 measures to meet the threshold (Iz, SynSurv, Spec.)

May meet one measure to meet the threshold

2. Syndromic Surveillance Reporting

The EP, eligible hospital or CAH is in active engagement with a public health agency to submit syndromic surveillance data.

Yes, above link

Must meet 2 measures to meet the threshold

(Iz, SynSurv, Spec.)

May meet one measure to meet the threshold

3. Specialized Registry Reporting ***

The EP, eligible hospital, or CAH is in active engagement with a public health agency to submit data to a specialized registry.

Yes, above link

Must meet 2 measures to meet the threshold

(Iz, SynSurv, Spec.)

May meet one measure to meet the threshold

 

*** Reference Page 261+ of the final rule, “We are not finalizing our proposal to split specialized registry reporting into two distinct measures; We include cancer case reporting asan option for EPs only under the adopted specialized registry reporting measure.”

 

Public Health

Definition of Active Engagment (as Proposed) 

Active Engagement Option 1

Completed Registration to Submit Data: The EP, eligible hospital, or CAH registered to submit data with the PHA or, where applicable, the CDR to which the information is being submitted; registration was completed within 60 days after the start of the EHR reporting period; and the EP, eligible hospital, or CAH is awaiting an invitation from the PHA or CDR to begin testing and validation. This option allows providers to meet the measure when the PHA or the CDR has limited resources to initiate the testing and validation process. Providers that have registered in previous years do not need to submit an additional registration to meet this requirement for each EHR reporting period.

Active Engagement Option 2

Testing and Validation: The EP, eligible hospital, or CAH is in the process of testing and validation of the electronic submission of data.  Providers must respond to requests from the PHA or, where applicable, the CDR within 30 days; failure to respond twice within an EHR reporting period would result in that provider not meeting the measure.

Active Engagement Option 3

Production: The EP, eligible hospital, or CAH has completed testing and validation of the electronic submission and is electronically submitting production data to the PHA or CDR.

 

 

CQMS:  2015 – 2017 Modification, no changes from Stage 2.  Must report on 9 (of 64) CQMs from 3 (of 6) Nat’l Domains

Patient Portal (View, download Transmit)

  • Provide access to 50% of patients
  • Even if one patients does VDT, you achieve this measure
  • In addition a provider sends at least one secure message as a response to a patient’s request on Patient Portal, you will meet the Secure Messaging Requirement

 

HIE Requirement (Previously referred to as Transition of Care, Summary of Care Records)

  • Ability to export out a CCD
  • Send 10% of your referrals (CCD) electronically if a provider does more than 100 referrals in 90 days
  • Exclusion: If a provider does less than 100 referrals they can claim an exclusion.

 

Public Health Reporting

  • Require 2 out of 3 measures:  Immunization, Syndromic Surveillance and a Specialized Registry:
  • For 2015, there is a possibility that organizations can just submit to one requirement.
  • For 2016, providers are required to submit to 2 out of 3 public health organizations.

Meaningful Use Audits

  • CMS has been performing Meaningful Use Audits since 2012.
  • Medi-Cal has started their Meaningful Use for the first time in 2015.
  • Meaningful Use audits can ask for documentation back to 2011
  • Most common reason for failing an audit is failing to conduct a HIPAA Security Risk Analysis

MediCal SLR Website Update

  • Till December 14th SLR Website will be accepting MU Attestations based on the previous requirements.
  • After December 14th, the SLR Website will be closed indefinitely for Meaningful Use Attestations
  • So providers who would prefer to complete their attestations now are encouraged to do so
  • Only AIU Attestations will be accepted after 12/14/15

PQRS Submission for Medi-Cal Attestors

  • If you do not submit your PQRS requirements prior to December 31st, you may be eligible for a Payment Reduction of 1% on your MediCare payments in 2016.
  • You can comply with this requirement either by attesting to Meaningful Use or submitting your PQRS measures through a registry.
  • Because SLR is unavailable for an indefinite period, providers can attest on CMS website for Meaningful Use (Medicare attestation) to qualify for PQRS.

 

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