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Meaningful UseModified Stage 2
Brett Paepke, OD
• Notice of Proposed Rulemaking for MU 2015 - 20171. reduce reporting requirements2. align reporting periods with calendar year3. modify patient engagement measures
• Ideas discussed are not official yet.
Traditional Stages of MU
2011 2012 2013 2014 2015 2016 2017
2011 1 1 1 2 2 2 3
2012 1 1 2 2 2 3
2013 1 1 2 2 3
2014 1 1 2 2
2015 1 1 2
2016 1 1
2017 1
First Year of
MU
What is Modified Stage 2?
• Stage 1 and Stage 2 blended into one concept
• All EPs in 2015 and 2016 must demonstrate Modified Stage 2 success.
• 2017 would be the provider’s choice of Modified Stage 2 or Stage 3
• 10 total objectives + Clinical Quality Measure reporting• All objectives are required. No Core/Menu differentiation• Eliminates “topped out” objectives
• i.e., Patient Demographics• 25th percentile: 97%• 50th percentile: 99%• 75th percentile: 99.8%
First Year of Meaningful Use Stage of Meaningful Use
2015 2016 2017 2018
2011 Modified Stage 2 Modified Stage 2 Modified Stage 2 or Stage 3 Stage 3
2012 Modified Stage 2 Modified Stage 2 Modified Stage 2 or Stage 3 Stage 3
2013 Modified Stage 2 Modified Stage 2 Modified Stage 2 or Stage 3 Stage 3
2014 Modified Stage 2 Modified Stage 2 Modified Stage 2 or Stage 3 Stage 3
2015 Modified Stage 2 Modified Stage 2 Modified Stage 2 or Stage 3 Stage 3
2016 n/a Modified Stage 2 Modified Stage 2 or Stage 3 Stage 3
Reporting Periods
2015
• any 90 consecutive days for all EPs
• attestation cannot be completed until 2016 (1/1/16 - 2/29/16) 2016
• any 90 consecutive days for new EPs
• full calendar year for all others 2017+
• full calendar year for all Medicare EPs (including new EPs)
•Medicaid EPs will always have “any 90 consecutive day” 1st year
Modified Stage 2 ReorganizationCore 1 - CPOECore 2 - eRxCore 3 - DemographicsCore 4 - Vital SignsCore 5 - Smoking StatusCore 6 - Clinical Decision SupportCore 7 - Incorporate Clinical Lab-Test ResultsCore 8 - Patient Lists Core 9 - Preventative CareCore 10 - Patient Electronic AccessCore 11 - Clinical SummariesCore 12 - Patient Specific Educational ResourcesCore 13 - Medication ReconciliationCore 14 - Summary of CareCore 15 - Immunization Registries Data SubmissionCore 16 - Protect Electronic Health InformationCore 17 - Secure Electronic MessagingMenu 1 - Syndromic SurveillanceMenu 2 - Electronic NotesMenu 3 - Imaging ResultsMenu 4 - Family Health HistoryMenu 5 - Report Cancer CasesMenu 6 - Report Specific Cases
Modified Stage 2 Objectives
Protect Electronic Health Information
Proposed Objective Protect electronic health information created or maintained by the CEHRT through the implementation of appropriate technical capabilities.
Proposed Measure
Conduct or review a security risk analysis in accordance withthe requirements in 45 CFR 164.308(a)(1), including addressing the security (to include encryption) of data stored in Certified EHR Technology in accordance with requirements in 45 CFR 164.312(a)(2)(iv) and 45 CFR 164.306(d)(3), and implement security updates as necessary and correct identified security deficiencies as part of the EP’s risk management process
Exclusions None
Alternate Specifications for
EPs due for Stage 1 in 2015
None
Modified Stage 2 Objectives
• SRA can be performed anytime during the calendar year as long as it is completed by the day of attestation.
• 3rd party assistance not required, but a very good idea considering the evolution of audits• OIG• HIPAA• CMS
• Essentials of the Security Risk Analysis webinar with Marni Anderson
Modified Stage 2 Objectives
Clinical Decision Support
Proposed Objective Use clinical decision support to improve performance on high-priority health conditions
Proposed Measures
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
2. The EP has enabled and implemented the functionality for drug-drug and drug allergy interaction checks for the entire EHR reporting period
Exclusions Any EP who writes fewer than 100 medication orders during the EHR reporting period can exclude from measure 2
Alternate Specifications for
EPs due for Stage 1 in 2015
Proposed Objective: Implement one clinical decision support rule relevant to specialty
Proposed Measure: Implement one clinical decision support rule. It is also proposed that drug-drug and drug-allergy interaction checks in measure 2 above must be met since it’s the same as a Stage 1 objective
Modified Stage 2 Objectives
Computerized Provider Order Entry
Proposed ObjectiveUse computerized provider order entry (CPOE) for medication, laboratory, and diagnostic imaging orders directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local, and professional guidelines
Proposed Measures
1. More than 60 percent of medication orders created by the EP during the EHR reporting period are recorded using computerized provider order entry
2. More than 30 percent of laboratory orders created by the EP during the EHR reporting period are recorded using computerized provider order entry
3. More than 30 percent of diagnostic imaging orders created by the EP during the EHR reporting period are recorded using computerized provider order entry
Exclusions Any EP who writes fewer than 100 medication, laboratory, or diagnostic imaging orders during the EHR reporting period can exclude from that measure
Alternate Specifications for EPs due for Stage 1 in 2015
Proposed Measure: More than 30 percent of medication orders created by the EP during the EHR reporting period are recorded using computerized provider order entry
Providers due for Stage 1 in 2015 can exclude from measures 2 and 3 as they do not exist in Stage 1
Modified Stage 2 Objectives
Electronic Prescribing
Proposed Objective Generate and transmit permissible prescriptions electronically (eRx)
Proposed MeasureMore than 50 percent 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
1. Any EP who writes fewer than 100 permissible prescriptions during the EHR reporting period
2. An EP who does not have a pharmacy within his or her organization and does not have a pharmacy that accepts electronic prescriptions within 10 miles of the EP's practice location at the start of his or her EHR reporting period
Alternate Specifications for
EPs due for Stage 1 in 2015
Proposed Measure: More than 40 percent of all permissible prescriptions written by the EP are transmitted electronically using Certified EHR Technology
Modified Stage 2 Objectives
Summary of Care
Proposed ObjectiveThe EP who transitions their patient to another setting of care or refers their patient to another provider of care provides a summary care record for each transition of care or referral
Proposed Measure
The EP that transitions or refers their patient to another setting of care or provider of care:
1. uses CEHRT to create a summary of care record
2. electronically transmits the summary to a receiving provider for more than 10 percent of transitions of care and referrals
Exclusions Any EP who refers a patient to another provider less than 100 times during the EHR reporting period
Alternate Specifications for
EPs due for Stage 1 in 2015
EP may claim an exclusion for this objective since Stage 1 does not have an equivalent
Modified Stage 2 Objectives
Patient-Specific Education
Proposed ObjectiveUse clinically relevant information from Certified EHR Technology to identify patient-specific education resources and provide those resources to the patient
Proposed MeasurePatient-specific education resources identified by Certified EHR Technology are provided to more than 10 percent of all unique patients seen by the EP during the EHR reporting period
Exclusions Any EP who has no office visits during the EHR reporting period
Alternate Specifications for
EPs due for Stage 1 in 2015
EP may claim an exclusion for the measure if they did not intend to select the Stage 1 Patient Specific Education menu objective
Modified Stage 2 Objectives
Medication Reconciliation
Proposed ObjectiveThe EP who receives a patient from another setting of care or provider of care or believes an encounter is relevant should perform medication reconciliation
Proposed Measure The EP performs medication reconciliation for more than 50 percent of encounters with new patients and inbound transitions of care.
Exclusions Any EP who saw no new patients and was not the recipient of any transitions of care during the EHR reporting period
Alternate Specifications for
EPs due for Stage 1 in 2015
EP may claim an exclusion for the measure if they did not intend to select the Stage 1 Medication Reconciliation menu objective
Modified Stage 2 Objectives
Patient Electronic Access
Proposed Objective Provide patients the ability to view online, download, and transmit their health information within 4 business days of the information being available to the EP
Proposed Measures
An EP must meet both measures:
1. More than 50 percent 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
2. At least one patient seen by the EP during the EHR reporting period (or their authorized representatives) views, downloads, or transmits his or her health information to a third party
Exclusions
Any EP who:
1. Neither orders nor creates any of the information listed for inclusion as part of the measures; or
2. Conducts 50 percent or more of his or her patient encounters in a county that does not have 50 percent or more of its housing units with 4Mbps broadband availability according to the latest information available from the FCC on the first day of the EHR reporting period (www.broadbandmap.gov)
Alternate Specifications for EPs due for Stage 1 in 2015
EP may claim an exclusion for measure 2 since Stage 1 does not have an equivalent
Modified Stage 2 Objectives
Secure Electronic Messaging
Proposed Objective Use secure electronic messaging to communicate with patients on relevant health information
Proposed Measure During the EHR reporting period, the capability for patients to send and receive a secure electronic message with the provider was fully enabled
Exclusions
Any EP who:
1. has no office visits during the EHR reporting period, or
2. conducts 50 percent or more of his or her patient encounters in a county that does not have 50 percent or more of its housing units with 4Mbps broadband availability according to the latest information available from the FCC on the first day of the EHR reporting period (www.broadbandmap.gov)
Alternate Specifications for EPs
due for Stage 1 in 2015
EP may claim an exclusion since Stage 1 does not have an equivalent
Modified Stage 2 Objectives
Public Health and Clinical Data Registry Reporting
Proposed ObjectiveThe EP is in active engagement with a PHA or CDR to submit electronic public health data in a meaningful way using certified EHR technology, except where prohibited, and in accordance with applicable law and practice
Proposed MeasuresThere are a total of six possible measures for this objective. EPs would be required to choose from measures 1 through 5, and would be required to successfully attest to any combination of two measures
Exclusions 3 available for each measure
Alternate Specifications for EPs
due for Stage 1 in 2015
EP must report at least one measure unless they can exclude from all available measures
Public Health and Clinical Data Registry Reporting
What is “Active Engagement”?
The EP is moving toward the submission of real patient data. This can be demonstrated 1 of 3 ways:
1. Completed registration with a PHA or CDR within 60 days after the start of reporting period
2. Testing of data submission process initiated
3. Actively submitting patient data
Public Health and Clinical Data Registry Reporting
Exclusions:
• Do not count as satisfying a measure• i.e. EP cannot exclude from Immunization Registry Reporting on grounds
that they didn’t perform any immunizations during reporting period and have that count as 1 of the 2 measures they need to meet.
• In the event that 2 measures don’t apply, EP can report on whatever is applicable and claim an exclusion for the non-relevant measures
• Will introduction of AOA’s MORE affect your ability to exclude from a measure?
Summary• Proposed reporting periods
• 2015: any 90 consecutive days (1/1/15 - 12/31/15)• 2016: any 90 consecutive days for new EPs, full year for all others• 2017: full year for all EPs (including new EPs)
• MU in 2015 would involve 10 objectives based mainly on Stage 2 measures • Key Proposed Changes
• V/D/T Actual Use would change from >5% to “equal to or greater than 1”• Secure Messaging would change from >5% to “Yes/No” for having
functionality enabled• All public health reporting objectives consolidated into one objective with
multiple measures
• Providers due for Stage 1 in 2015 would have special exclusions and thresholds • All EPs held to same standards in 2016
• No attestation for 2015 reporting periods until 1/1/16 - 2/29/16
Next – 9:30 to 10:15 am• Meaningful Use - Stage 3 – Learn about and prepare for Meaningful Use
Stage 3 through a forward-looking discussion of the objectives and expectations.