Challenging

Meaningful Use (MU) Measures

for Eligible Professionals (EPs)

Beth Myers Policy and Outreach Lead, CMS eHealth Initiatives

July 28, 2014

Agenda

• Interoperability Overview

• Stage 2 Exchange Requirements

• Challenging Stage 2 Objectives

Summary of Care

Patient Electronic Access

• Resources

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Interoperability Overview

• What is interoperability? – The extent systems and devices can exchange and interpret

shared data

– For two systems to be interoperable, they must be able to exchange data and present that data in a understandable way

• Why is interoperability important? – Empowers patients to access, maintain, and exchange their

health information (i.e., patient electronic access)

– Streamlines communication through transitions of care

– Reduces duplication of effort

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Stage 2 Exchange Requirements

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The following Stage 2 of meaningful use objectives require

electronic health record (EHR) interoperability to exchange

health information

Examples • Provider-to-Provider (e.g.,

Transitions of Care [ToC])

• Provider-to-Patient (e.g., View,

Download, Transmit [VDT])

• e-Prescribing

• Public Health Reporting

Two challenging Stage 2 objectives that require exchange:

Challenging Stage 2 Objectives

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1. Summary of Care

2. Patient Electronic Access

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1. Summary of Care

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Why Summary of Care?

Purpose: Ensure eligible professional who transitions a patient

to another provider’s care sends most up-to-date

information available so that the next provider is able to make

more informed decisions

• When an EP transitions or

refers a patient to another

setting or provider of care,

the EP should send a

summary of care record

• Information generally

limited to what is available

in certified EHR

technology (CEHRT) at

time summary of care is

generated

Summary of Care Requirements

EPs must satisfy both Measure 1 and Measure 2:

• Measure 1 - Provide a summary of care record for more than 50% of

transitions of care and referrals

• Measure 2 - Provide a summary of care record for more than 10% of

transitions and referrals to a recipient either:

a) electronically transmitted using CEHRT, or

b) via exchange facilitated by an organization that is an eHealth

Exchange participant

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• For Measure 3, satisfy one of following criteria:

• Conduct one or more successful electronic exchanges of a summary of

care document, as part of which is counted in "measure 2" (with a

recipient who has EHR technology that was developed designed by a

different EHR technology developer than the sender's)

• Conduct one or more successful tests with the CMS designated test

EHR during the EHR reporting period

• Exclusion: Any EP who transfers a patient to another setting or refers a

patient to another provider less than 100 times during the EHR reporting

period is excluded from all three measures.

See the spec sheet for more information: http://www.cms.gov/Regulations-and-

Guidance/Legislation/EHRIncentivePrograms/downloads/Stage2_EPCore_15_Summary

Care.pdf

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Summary of Care Requirements, cont.

Measure Guidance

• EP must verify that info was entered into EHR for problem list, medication list, and medication allergy list prior to generating summary of care

• Problem list, medication list, and medication allergy list must either contain specific information or a notation that the patient has none of these items

• Leaving field blank would not allow provider to meet objective

- If other data elements from required list is not available in EHR at time summary of care is generated, that info does not have to be made available in summary of care

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Information Requirements

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Information Requirements for

Summary of Care Measure

Create Consolidated Clinical Document

Architecture (C-CDA)

Enter information into CEHRT

Provide summary of care record when

patient is transferred to another setting

of care or referred to another provider

Withhold any information provider

determines could cause possible harm

Verify presence of elements; Problem

List, Medication List, and Medication

Allergy List

• Patient name

• Referring or transitioning provider’s name and office contact

information

• Procedure

• Encounter diagnosis

• Immunizations

• Laboratory test results

• Vital signs (height, weight, blood pressure, body mass index

[BMI])

• Smoking Status

• Functional Status, including activities of daily living,

cognitive and disability status

• Demographic information (preferred language, sex, race,

ethnicity, date of birth)

• Care plan field, including goals and instructions

• Care team including the primary care provider of record and

any additional known care team members beyond the

referring or transitioning provider and the receiving provider

• Reason for referral

• Current problem list (EPs may also include historical

problems at their discretion)**

• Current medication list**

• Current medication allergy list**

**Required Fields

When reporting on the Summary of Care objective, which transitions would count toward the

numerator of the measures?

A transition of care is defined as the movement of a patient from one setting of care (hospital, ambulatory,

primary care practice, ambulatory specialty care practice, long-term care, home health, rehabilitation facility)

to another. To count toward the Summary of Care objective, the transition or referral must take place between

providers with different billing identities such as a different National Provider Identifier (NPI) or hospital CMS

Certification Number (CCN).

For Measure 1: include the transitions of care in which a summary of care document was provided to the

recipient of the transition or referral by any means.

For Measure 2: include the transitions of care in which a summary of care document was transmitted

electronically using a Certified EHR Technology (CEHRT) to the recipient, or via exchange facilitated by an

organization that is an eHealth Exchange participant.

If the receiving provider already has access to the CEHRT of the initiating provider of the transition or referral,

simply accessing the patient’s health information does not count toward meeting this objective. However, if the

initiating provider also sends a summary of care document, this transition can be included in the denominator

and the numerator as long as it is counted consistently across the organization and across both measures if:

– For Measure 1, a summary of care document is also provided by any means.

– For Measure 2, a summary of care document is provided using the same technical standards used if the receiving

provider did not have access to the CEHRT,

For Measure 3: a single summary of care document sent to a provider using a different EHR and EHR

Vendor or a test with the CMS and Office of the National Coordinator (ONC) Randomizer test system would

meet the measure.

See FAQ 9690: https://questions.cms.gov/faq.php?faqId=9690

Additional Guidance: Summary of Care Calculation

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National Institute of Standards and Technology (NIST) EHR Randomizer Tool

• Allows providers to test electronic exchange to meet Summary of Care Measure #3: http://ehr-randomizer.nist.gov

• The NIST-hosted software system matches a provider with a designated test EHR designed by a different EHR technology developer

• A new user guide is available on the Educational Resources page to help providers use the Randomizer

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2. Patient Electronic Access

Why Patient Electronic Access?

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Purpose: Allows patients access to health information

to help them make informed decisions about their

care and share most recent clinical information with

other health care providers and their caregivers

The patient electronic access measure requires EPs to provide patients the ability to view online, download, and transmit their health information within four (4) business days of information being available to provider

• Measure 1: Provide more than 50% of all unique patients seen by the EP

during the EHR reporting period are provided the ability to view online,

download, and transmit their health information within four (4) business days

of the information becoming available to the EP

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

representatives) view online, download, or transmit to a third party their

health information

• Exclusion: Any EP who:

1. Neither orders nor creates any of the information listed for inclusion as part of

both measures, except for "Patient name" and "Provider's name and office

contact information,” may exclude both measures.

2. Conducts 50% or more of his or her patient encounters in a county that does not

have 50% or more of its housing units with 3Mbps broadband availability

according to the latest information available from the FCC on the first day of the

EHR reporting period may exclude only the second measure.

See the spec sheet for more information: http://www.cms.gov/Regulations-and-

Guidance/Legislation/EHRIncentivePrograms/downloads/Stage2_EPCore_7_PatientElectr

onicAccess.pdf

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Patient Electronic Access Requirements

Measure Guidance

• Providing patient electronic access is an ongoing

requirement

• If a specific data field is not available to EP at time info

is sent to patient portal, that info does not have to be

made available online and EP can still meet objective

• As new info for specific items listed becomes available

to provider, that info must be updated and made

available to patient online within four (4) business days

• EP may withhold any info from online disclosure if he or

she believes providing such info may result in

significant harm

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Information Requirements

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Information Requirements for Patient

Electronic Access Measure*

• Patient name

• Provider’s name and office contact

information

• Current and past problem list

• Procedures

• Laboratory test results

• Current medication list and medication

history

• Current medication allergy list and

medication allergy history

• Vital signs (height, weight, blood pressure,

BMI growth charts)

• Smoking status

• Demographic Information (preferred

language, sex, race, ethnicity, date of birth)

• Care plan field(s), including goals and

instructions

• Any known care team members including

the primary care provider (PCP) of record

Enter information into certified EHR

technology as it becomes available

Withhold from online disclosure any

information provider determines could

cause possible harm

Make modified information available to

patient online within four (4) business

days

*Unless the information is not available in CEHRT is restricted from disclosure due to any federal, state, or

local law regarding the privacy of a person’s health information, including variations due to the age of the

patient, or the provider believes that substantial harm may arise from disclosing particular health

information in this manner.

Patient Access: Additional Guidance

If multiple EPs contribute information to a shared portal or to a patient's

online personal health record (PHR), how is it counted for meaningful use

when the patient accesses the information on the portal or PHR?

• If multiple EPs contribute information to an online portal or PHR during the

same EHR reporting period, all of the providers can count the patient to

meet the measure if the patient accesses any of the information in the portal

or PHR.

• A patient does not need to access the specific information an EP

contributed, in order for each of the EPs to count the patient to meet their

threshold.

See FAQ7735: https://questions.cms.gov/faq.php?faqId=7735

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Patient Access: Additional Guidance

In calculating the meaningful use objectives requiring patient action, if a

patient accesses his/her health information made available by their EP,

can the other EPs in the practice get credit for the patient’s action in

meeting the objectives?

• Yes. EPs in group practices are able to share credit to meet the patient

electronic access threshold if they each saw the patient during the EHR

reporting period and they are using the same certified EHR technology.

• The patient can only be counted in the numerator by all of these EPs if the

patient views, downloads, or transmits their health information online.

See FAQ 9686: https://questions.cms.gov/faq.php?faqId=9686

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Patient Access: Additional Guidance

Can an EP charge patients a fee to have access to their

health information?

CMS does not believe it would be appropriate for an EP to

charge patients fees to access certified EHR technology.

See FAQ 9112: https://questions.cms.gov/faq.php?id=5005&faqId=9112

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Related Tipsheets

• Data Sharing Tipsheet: Outlines the required data elements and provides additional guidance for Summary of Care, Clinical Summary, and Patient Electronic Access

• Patient Electronic Access Tipsheet: Outlines requirements for Patient Electronic Access in Stage 1 and Stage 2, as well as FAQs

Both available on Stage 2 and Educational Resources pages

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• CMS Program Website

www.cms.gov/EHRincentiveprograms

• CMS eHealth Website http://www.cms.gov/eHealth/

• ONC Program Website www.healthit.gov

• ONC JIRA Tool http://oncprojectracking.org/

• Is my EHR certified?

http://oncchpl.force.com/ehrcert?q=CHPL

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General Resources

Questions?

Contact Information

Beth Myers: elisabeth.myers@cms.hhs.gov

EHR Incentive Programs Information Center:

888-734-6433 (TTY 888-734-6563)

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