Proposed Changes to Meaningful Use 1 and 2 Paul Kleeberg, MD, FAAFP, FHIMSS Burning Issues Webinar June 1, 2015
Objectives • Provide an overview of the proposed changes to stages 1 and 2 of the Meaningful Use program starting this year • Provide a framework for collecting feedback for the Proposed Rule • Enable you to provide your feedback to CMS 1
Lake Superior Quality Innovation Network • Three quality improvement organizations: • MPRO in Michigan • Stratis Health in Minnesota • MetaStar in Wisconsin • Collaboration to improve health care for Medicare consumers, share best practices and maximize efficiencies 2
Bending the Curve Towards Transformed Health Improved outcomes Advanced clinical processes “Phased -in series of improved clinical data capture supporting more Data capture and rigorous and robust quality sharing measurement and improvement.” Stage 1 Stage 2 Stage 3 Source: Connecting for Health, Markle Foundation “Achieving the Health IT Objectives of the American Recovery and Reinvestment Act” April 2009 3 3
Meaningful Use Overview: Statutory Framework • In HITECH, Congress established three fundamental criteria of requirements for meaningful use: – Use of certified EHR technology in a meaningful manner – The exchange of health information – Submission of clinical quality data Adapted from: Brian Wagner, Senior Director of Policy and Public Affairs, eHealth Initiative (eHI) presentation to the MN Exchange and Meaningful Use Workgroup January 15, 2010 4
The Proposed Rule • Meaningful Use Changes to Stage 1 and 2 – Released: April 15, 2015 and available in html at: • https://www.federalregister.gov/articles/2015/04/15/20 15-08514/medicare-and-medicaid-programs- electronic-health-record-incentive-program- modifications-to – Comments Due: June 15, 2015 at: • http://www.regulations.gov/#!submitComment;D=CM S-2015-0045-0001 5
Proposed Timeline Changes for MU 1-2 • 90 Day reporting for all in 2015 • Providers scheduled to do MU1 – In 2015 will do MU2 with additional exemptions – In 2016 and 2017 will do MU 2 without additional exemptions • Starting in 2017, Medicare first timers must do a full year (Medicaid only may do any 90 days) 90 days 90 days X 2 X X 2 X X * Still considered doing stage 2 even if they did stage 1 6
Reporting Periods • 2015: – Hospitals: • Starting in 2015 and continuing on have a calendar reporting year • 15 reporting months in the 2015 year but only need to attest for 90 continuous days) – Professionals • Any 90 days in calendar year 2015 • 2016 – Any 90 days for first time attesters – Full year for those beyond their first year • 2017 – Full year reporting for all except Medicaid only first year 7
Attestation • No changes to the method • All Medicare: – No 2015 Medicare attestations before January 2016 • Deadlines – Last day of February for all • Medicaid – Providers who fall below the 30% (or 20%) threshold, can attest under Medicare to avoid the penalty without it constituting a switch in payment programs. 8
Incentives • Unchanged but winding down • Medicare – If just starting: • 2014 was the last year for EP to receive incentives • 2015 is the last year for CAH or PPS Hospitals to receive incentives – Last incentive year is 2015 for CAHs and 2016 for EPs and PPS hospitals. • Medicaid – If just starting: • 2016 is the last year for EPs, CAH or PPS Hospitals to receive incentives – EPs: • 2021 is the last payment year for EPs • Max of 6 payments – Hospitals: • Last payment date depends on the State – can be 3-6 years after 1st payment • Any payment skipped after 2016 ends the program 9
Penalties and Exceptions • Unchanged Except – All who attest for the first time anytime in 2015 will not be penalized in either 2016 or 2017 • Reason it is anytime: the attestation system will not be available before January 2016 – All who attest for first time in 2016 will not be penalized in 2017 and 2018 if they attest before Oct 1 – 2017 on requires full year reporting 10
Miscellaneous Changes • State Flexibility – Unchanged • Paper-based documents – No longer count in numerators starting in 2015 except for patient education materials 11
Proposed Program Goals and Objectives • Protect Patient Health Information • Electronic Prescribing • Clinical Decision Support • Computerized Provider Order Entry • Patient Electronic Access to Health Information • Health Information Exchange • Public Health and Clinical Data Registry Reporting 12
Protect Personal Health Information Stage 1 (Core) Stage 2 (Core) Proposed Measure Unchanged except: Measure • Conduct or review a • • Implies that it is Conduct or review a security risk analysis, security risk expanded to include including the encryption/security all instances of analysis, implement of data stored in electronically stored security updates as CEHRT , implement necessary and PHI not just on security updates as necessary and CEHRT correct identified correct identified security deficiencies security deficiencies Denominator Denominator • Yes/No Attest • Yes/No Attest Exclusion Exclusion • None • None 13 13
Drug Formulary Check Stage 1 (Menu) Stage 2 (Core/Menu) Proposed 2015 Measure Measure • • • Implement drug Incorporated into EP: Incorporated formulary checks with into the eRx core the Stage 2 eRx at least one internal item for EPs & EHs item or external formulary • EH: Incorporated Denominator into the eRx menu • Yes/No Attest item Exclusion • EP: writes <100 medication orders during the EHR reporting period • EH: None 14 14
ePrescribing (EP) Stage 1 (Core) Stage 2 (Core) Proposed Measure Measure Stage 1 • • >50 percent of permissible >40% of permissible • or all prescriptions written Unchanged for 2015 scripts are generated are queried for a drug and transmitted only formulary and transmitted electronically electronically • Stage 2 requirement Denominator Denominator • in 2016 & 2017 Number of permissible • Number of permissible or (non-controlled all scripts written by the Stage 2 substance) scripts EP written by the EP Exclusion • Unchanged Exclusion • Any EP who writes <100 • Any EP who writes <100 permissible prescriptions prescriptions during the during the EHR reporting EHR reporting period. period. • • No pharmacies that No pharmacies that accept e-prescriptions accept e-prescriptions within 10 miles within 10 miles 15 15
Discharge ePrescribing (EH) Stage 1 Stage 2 (Menu) Proposed Measure Stage 1 None • >10 percent of hospital • discharge medication Not required in 2015 orders for permissible only prescriptions are queried for a drug formulary and • Stage 2 requirement transmitted electronically. in 2016 & 2017 Denominator • Number of new, changed, Stage 2 and refilled prescriptions Exclusion • Required element • No internal pharmacy that otherwise can accept electronic prescriptions unchanged • Not located within 10 miles of any pharmacy that accepts electronic prescriptions 16 16
Clinical Decision Support (CDS) Stage 1 (Core) Stage 2 (Core) Proposed Measures (were Stage 1 Measures separate) • • Unchanged for 2015 5 CDS • 1 CDS rule relevant interventions only to the specialty relevant to 4 quality • Stage 2 requirement specific quality metrics or high in 2016 & 2017 metric or high priority condition priority condition Stage 2 Denominator with the ability to • Unchanged track compliance • Yes/No Attest Denominator Exclusion • Yes/No Attest • None Exclusion • None 17 17
Drug-Drug and Drug-Allergy Interaction Checks Stage 1 (Core) Stage 2 (Core) Proposed Stage 1&2 Measure Measure • • • Unchanged This functionality is This functionality is enabled for the enabled for the entire EHR reporting entire EHR reporting period period Denominator Denominator • • Yes/No Attest Yes/No Attest Exclusion Exclusion • • None EP: if writes <100 medication orders 18 18
Computerized Provider Order Entry (CPOE) Stage 1 (Core) Stage 2 (Core) Proposed Measure Measures Stage 1 • • >60% of all medication >30% of patients on • Unchanged for 2015 orders, >30% of all any meds with ≥ one laboratory and >30% only CPOE med order or radiology orders must may use >30% all • be entered using CPOE Stage 2 requirement orders Denominators: in 2016 & 2017 Denominator • Unique orders • Stage 2 Unique patients or Exclusions: unique orders ) • • Any EP who writes <100 Unchanged Exclusion: medication, <100 radiology, or <100 • Any EP who writes laboratory orders during <100 medication the EHR reporting orders during the period. EHR reporting period. Any licensed healthcare professionals and credentialed medical assistants , can enter orders into the medical record for purposes of including the order in the numerator for the objective of CPOE if they can originate the order per state, local and professional guidelines. 19 19
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