Meaningful UseA Little Bit of Everything

WV HFMA January 23, 2014

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Objectives Understand Stage 1 changes starting in

2014 Understand Stage 2 Objectives & Quality

Measures – changes from Stage 1 and what you need to know about what’s new

Understand options for reporting Quality Measures and PQRS measures together starting in 2014

Learn what you need to do to pass a CMS Meaningful Use Audit

Stage 1 Changes in 2014

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Stage 1 Changes in 2014 – Objectives

CMS Ref Objective ChangeEPEH

Capability to exchange key clinical information electronically

Eliminated as Stage 1 Objective (2013)

EPEH

Provide patients with timely electronic access to their health information within four business days

Eliminated as Stage 1 Objective (2014)

EH

Provide patients with an electronic copy of their discharge instructions at time of discharge, upon request

Eliminated as Stage 1 Objective (2014)

EPEH

Option to be orders based for CPOE vs. patient based for denominator

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Stage 1 Changes in 2014 – Objectives

CMS Ref Objective ChangeEPEH

CPOE Denominator – Current : at least one medication order in the medications list (patient based)

Alternate : All medication orders created by the EP (orders based)

EP

ePrescribing Additional exclusion: if there is not a pharmacy at your organization or a pharmacy thataccepts electronic prescriptions within 10 miles of each of an EP’s practice locations

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Stage 1 Changes in 2014-Attestation

If 2014 is your first year to attest to Stage 1must attest within first 9 months of the attestation period to avoid penaltieso EHs – must meet MU for 90 days, but last 90 days will be

Apr-Juneo EPs – must meet MU for 90 days, but last 90 days will be

Jul-Septo CAHs - this does not apply

Batch submission for EPs o Separate batches for Medicare and Medicaido States not required to provide

Stage 2

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Stage 2 - ObjectivesEP 17 Core

Objectives 3 of 6 Menu

Objectives

28+ Core measures & sub measures

3 of 6 menu

EH 16 Core

Objectives 3 of 6 Menu

Objectives

26+ Core measures & sub measures

3 of 6 menu

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Stage 2 - CQMs CQMs selected must align with at least 3 of 6

National Quality Strategy Domains Any EP or EH in 2nd year of MU must submit

CQMs electronicallyEP Must choose 9 out of 64 available CQMs CMS priority CQMs (but not required to choose) Medicare EPs option to align MU CQMs with

PQRS, Medicare Shared Savings Program or Pioneer ACO

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Stage 2 - CQMs

EH Must choose 16 out of 29 available CQMs

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Stage 2 - Attestation

2014 “Special Dispensation”Regardless of what Stage you are, you only need to meet MU for 90 days. If 2014 is your second year, the 90 days is based on a quarter, not a rolling 90 days

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Stage 2 –Objectives: Eliminated

CMS Ref Objective ChangeEPEH

Implement drug-drug, drug-allergy check

Incorporated into Stage 2 Decision Support objective

EPEH

Maintain problem list of current and active diagnosis

Incorporated into Stage 2 Summary of Care document for TOC/Referrals

EPEH

Maintain Active Medication Allergy List

Incorporated into Stage 2 Summary of Care document for TOC/Referrals

EPEH

Report clinical qualitymeasures (CQMs) toCMS or the States

As of 2014, all CQMs must be submitted electronically

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Stage 2 – Objectives: Eliminated

CMS Ref Objective ChangeEPEH

Capability to exchangekey clinical informationelectronically

Eliminated in Stage 2

EPEH

Implement drug formularychecks

Incorporated into ePrescribing measure for Stage 2

EPEH

Provide patients with timely electronic access to their healthinformation

Eliminated in Stage 2

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Stage 2 – Objectives: Changes

CMS Ref

Objective Change

EPEH

Core

CPOE Meds: >60% (was 30%) Rad: >30% NewLab: >30% NewStandard: RxNorm for drugs & allergies

EP Core

Generate and transmit permissible prescriptions electronically (eRx)

>50% (was 40%) Must be compared to at least one drug formulary

EPEH

Core

Record demographics >80% (was 50%) Standard: ISO 639-2 for language

EPEH

Core

Record & chart changes in vital signs (BP, Height, Weight, BMI, growth charts)

>80% (was 50%) Age Requirement Changes: Ages 3 & over for blood pressure; height/weight all ages

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Stage 2 – Objectives: Changes

CMS Ref

Objective Change

EPEH

Core

Record Smoking Status for patients 13 yrs. & older

>80% (was > 50% )Standard: Must map to Snomed CT

EP Core Implement CDS

5 CDS Rules (was 1 rule)Additional Requirements: Must be tied to at least 4

CQMs Must have drug-drug and

drug-allergy interaction checks included

EPEH

Core

Incorporate Lab test results as structured data

>55% (was 40%)Moves from MenuCore

EPEH

Core

Submit date to immunization registries

Ongoing submission (was “test” of capability)Standard: CVX Moves from Menu Core

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Stage 2 – Objectives: Changes

CMS Ref

Objective Change

EH Core

Submit data on reportable lab results

Ongoing submission (was “test” of capability)Standard: LOINCMoves from MenuCore

EPEH

Core

Submit syndromic surveillance data

Ongoing submission (was “test” of capability)Moves from Menu Core for EH(remains as Menu for EP)

EP Core

Patient Reminders for follow up/preventative care

10% of all patients (was 20% of patients age 5 yrs & younger, and patients 65 yrs & older)Moves from Menu Core

EP Core

Provide clinical summary for patients for each office visit

>50% of office visits within 1 business day (was >50% of office visits within 3 business days)

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Stage 2 – Objectives: Changes

CMS Ref

Objective Change

EH Core

Provide patient specific education resources

>10% of all unique patients with office visits for the EP (was 10% of unique patients) Moves from Menu Core

EPEH

Core

Protect Electronic Health Information

Additional Focus: address the encryption/security of dataat rest (45 CFR 164.308 (a)(1))

EPEH

Core

Medication Reconciliation > 50% of transitions of care to the EPMoves from Menu Core

EP Core

Generate Patient List by specific condition

Generate at least onereport of patients with a specific conditionMoves from Menu Core

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Stage 2 – Objectives: Changes

CMS Ref

Objective Change

EPEH

Core

Provide Summary of Care Record (aka Transitions of Care or TOC)

> 50% of transitions of care or referrals (can be paper)

10% must be electronic directly from EHR to EHR or through an exchange (i.e. WVHIN)

Electronic transmission must be to a different EHR vendor or conduct a test with the CMS test designated EMR

(Was >50% of transitions of care must provide Summary of Care record)Moves from Menu Core

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Stage 2 – Objectives: NewCMS Ref

Objective Measure

EH Core Automatically track medications from order toadministration usingassistive technologies inconjunction with anelectronic medicationadministration record(eMAR)

>10% of medication orders created … during theEHR reporting period forwhich all doses aretracked are tracked usingeMAR

EPEH

Menu

Record electronic notes inpatient records

>30% - Enter at least oneelectronic progress notecreated, edited and signedby an EP … during the EHR reporting period

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Stage 2 – Objectives: NewCMS Ref

Objective Measure

EPEH

Menu

Imaging results consistingof the image itself and anyexplanation or otheraccompanying informationare accessible throughCEHRT.

>20% of all scans and tests whose result is an imageordered by the EP for patientsseen during the EHR reportingperiod are incorporated into oraccessible through CEHRT

EPEH

Menu

Record patient family health history as structured data

>20% of all unique patients… have structured data entry for one or more first-degreerelatives or an indication that family health history has been reviewed

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Stage 2 – Objectives: NewCMS Ref

Objective Measure

EH Menu

Generate and transmitpermissible dischargeprescriptions electronically(eRx)

>10% of hospital discharge medication orders for permissibleprescriptions (for new or changed prescriptions) are compared to at least one drug formulary andtransmitted electronically using Certified HER Technology

EH Menu

Provide structuredelectronic lab results toambulatory providers

>20% of lab results for orders received by hospital labs are sent as structured electronicclinical lab results back to theordering provider

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Stage 2 – Objectives: NewCMS Ref

Objective Measure

EP Core Use secure electronic messaging to communicate with patients on relevant health information

> 5% of unique patients securely message their provider during the reporting period

EP Menu

Capability to identify andreport cancer cases to aState cancer registry

Ongoing Submission of cancer case information to a cancer registry for the entire EHR reporting period

EP Menu

Capability to identify andreport specific cases to aspecialized registry (other than a cancer registry)

Ongoing Submission of specific case information to a pecialized registry for the entire EHR reporting period

CMS Meaningful Use Audits

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CMS MU Audits

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CMS MU Audits Desk audits Post payment audits for EPs and EHs Pre payment audits for EPs Candidate for audit after meeting MU for

full year In general, turnaround time is about 1

month.

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CMS MU Audits – Document Request

Part 1 General Information Proof of licensing of a certified EHR

“…provide a copy of your licensing agreement with the vendor or invoices. Please ensure that the licensing agreements or invoices identify the vendor, product name and product version number” Proof of method for calculating ED

admissions (i.e. an explanation of how the ED admissions were calculated and a summary of ED admissions)

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CMS MU Audits – Document Request

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CMS MU Audits – Document Request

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CMS MU Audits – Document Request

Part II Core Set Objectives/Measures Proof of Core Measures #1, 3, 4, 5, 6, 7, 8,

11, & 12o Report from the certified EHR used to complete

the attestationo Proof that the report used for attestation is

from the certified EHR• Vendor Logo Or• Step by step screen shots of how report is generated

from EHR

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CMS MU Audits – Document Request

Part II Core Set Objectives/Measures Proof that a security risk analysis was

performedo Must show that it was during the MU reporting

periodo Must include implementation plan to address

any deficiencies found, with completion dates

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CMS MU Audits – Document Request

Part III Menu Set Objectives/Measures Proof of Menu Measures #2, 3, 5, 6, or 7

o Report from the certified EHR used to complete the attestation

o Proof that the report used for attestation is from the certified EHR• Vendor Logo Or• Step by step screen shots of how report is generated from

HER Proof of Yes/No Menu Set Measures #4, 8, 9, or

10o Screen Shots

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CMS MU Audits – How to Pass!

Save EVERYTHING!o Reports from your EHR that you use to attesto The detail behind the numerator/denominatoro Screen shots from EHR for YES/NO measures from reporting

periodo Medicare and Medicaid attestation confirmationo Medicaid screen shots from every step of the attestationo Medicare summary of all of your input from the attestationo Security Risk Analysis (and every re-evaluation done)o Recommendation: create a share drive with tightly controlled

access to save off MU documents

Remember: You need to do this for every individual EP…much easier for EH!

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CMS MU Audits – How to Pass!

Contact your EHR Vendoro What can/will they do to assist you with an audit?o What limitations do you have in terms of what you

can submit without breaching proprietary property?

If Reporting MU from multiple EHRs…o Be sure that the reports used from each of the

EHRs have the same items for attestation o All reports have to be submitted for the audit

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CMS MU Audits – How to Pass!

Documentation Submissiono Be sure to follow the same order as requested in

the letter from Figliozzi (or CMS)o Cover letter – outline exactly what you are

submitting in response to each document requesto Create a single PDF of all of the documents in the

correct order along with a cover letter and submito Most importantly…

Don’t miss your submission deadline!

?? QUESTIONS ??

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