meaningful use monitoring methodology © 1 meaningful use monitor (mum) initial gap assessment (iga)...

Meaningful Use Monitoring Methodology © 1

Meaningful Use Monitor (MUM)

Initial Gap Assessment (IGA) Phase Kit

4/6/2010

Meaningful Use MonitorIndiana Radiology Business Management Association

Medical Staff EducationNovember, 2010


Who Am I?Jay R. Fisher

• Education as a CPA– Undergraduate: University of Wisconsin – Psychology– Masters Program: Georgia State University -

Accountancy• 13 Years at Major Consultancies

– Arthur Andersen– Deloitte & Touche

• 10 Years Boutique Consulting – $5 mm annual sales– IT Executive and project consulting, predominantly

health care• A couple years working for someone else’s consulting

firm– Lesson: Strategy (verbalized or not) starts at the top

and does not change• C3 Partners Meaningful Use Monitor

– Lesson: a few committed people with a vision can create organizational and market excitement

I think and hope that consulting success has small parts of ideas,

brains, secret sauce … all overbalanced by your network,

your reputation and your sincere desire to make things better for

your clients.


What have I done that is relevant?

General Health Care:• Program Manager over IT for an all-digital hospital, built from scratch• EHR Implementation PMO for very large health system• Two years experience with physician practice management systems • Various cost reporting, certificate of need, and SSO project work • Core team member in the creation of a Network Model HMO • Core team member in the creation of a hospital-based HMO• Multiple EHR selection projects for ambulatory groups

Meaningful Use:• Created a company, and a product to minimize the administrative

overhead associated with getting to Meaningful Use• Our toolset currently in place for 20 hospitals and around 700 physicians• Call center for Meaningful Use Hot Line starting December 1


Today’s Discussion Topics

ARRA HITECH Foundation

Step 1:Eligible Professional

Step 2:Eligible IT

Step 3:Eligible Processes

Step 4:Program Monitoring

Step 5:Strategies

Step 6:Getting HelpMeaningful Use of Certified EHR

What it is, does it effect me, and what can I do about it?

In “presentation mode”, click the steps to navigate


Law, Regulations and Grounding



Step 2:Eligible IT



Step 5:Strategies

Step 6:Getting Help



ARRA HITECH FoundationRegulatory Content

The Language of HITECH

EP = Eligible Professional (you folks) Unique requirements Unique eligibility Unique payment and penalty Time tables

Eligible Hospital and CAH

Certification = something an EHR vendor must do to their software

Meaningful Use = something you must do with Certified Software


ARRA FoundationScope and Discussion Threads for Today

• How are Radiologists impacted in their practices?– Within Imaging Centers– On Hospital Premises– As a contracted Employee

• How are Radiologists impacted in the context of inpatient work? – Hospitals are impacted too, and much of the change falls on the

shoulders of clinicians practicing there whether those clinicians are financially involved or not

– Hospitals may expect you to do new tasks, or to do some current tasks differently


ARRA HITECH FoundationRegulatory Content

• CMS issued MU Final Ruling on 07/28/10

– Defines activities clinicians must follow, and data clinicians must populate into Certified EHR for Provider to qualify for funding

– Hospital must meet 19 of 24 Meaningful Use Requirements, and populate the data for 15 Quality Measures into a Certified EHR

– EP’s must meet 15 of 25 Meaningful Use Requirements, and populate the data for 6 of 41 Quality Measures

• CMS in the early stages of Certifying EHR Software

– Providers can move forward with Usage within existing EHR in anticipation of Certification, with some caveats

– Certification is generally in the hands of the EHR vendors, but providers can choose to “self-certify” EHR modules


• Interesting, but not directly relevant to us:– Beacon Communities – Regional Extension Centers– State Health Information Exchanges – IT Educational support– Strategic Health Advanced IT Research Projects (SHARP)

• Directly Relevant to US:– Meaningful Use of the EHR (Electronic Health Record Incentive

Program)

ARRA-HITECH FoundationWhat does the law cover?


ARRA-HITECH Foundation Timelines for achieving Meaningful Use

January 2011

Registration for the EHR Incentive Programs begins

April 2011 Attestation for the Medicare EHR Incentive Program begins

May 2011 EHR incentive payments begin

November 30, 2011

Last day for eligible hospitals and CAHs to register and attest to receive an incentive payment for FFY 2011

February 29, 2012

Last day for EPs to register and attest to receive an incentive payment for CY 2011

2015 Medicare payment adjustments begin for EPs and eligible hospitals that are not meaningful users of EHR technology

2016 Last year to receive a Medicare EHR incentive payment; Last year to initiate participation in Medicaid EHR Incentive Program

2021 Last year to receive Medicaid EHR incentive payment


ARRA-HITECH Foundation How much is at stake for your practice?


ARRA-HITECH FoundationWhat Penalties Apply?

Hospital Penalty – Portion of Market Basket Reduced to Zero2015 - 33.3% of three-quarters2016 - 66.7% of three-quarters2017+ - 100% of three-quarters

Physician Penalty• 2015 - 1% of Medicare fee schedule• 2016 - 2% of Medicare fee schedule• 2017+ - 3% of Medicare fee schedule

Observations• Penalties begin against Medicare Stimulus Payments regardless of EP’s choice to

participate in Medicaid, or to “join” the Reimbursement program• 2016 is the first Penalty Year – and no Medicare Stimulus Payments will be made in

2016 or later• Requirements to qualify become more rigorous over time• CMS / DHS budget constraints, and Final Rules explicitly cite Audit Process (currently

in development)• If CMS finds that adoption levels are less than 75% of EP’s by 2018, penalties can

increase another 1% per year, up to maximum of 5%


Summary PointIt is not just about eligibility

• If you fall within the rules:– Over 5 or 6 years you will be eligible to receive $44k or $63k in

Stimulus funding– After 2015, if you are not considered a Meaningful User, you

will start to lose Medicare Reimbursement– Your practice will be listed on a CMS website as a Meaningful

User, if you qualify. Some organizations will use this to competitive advantage (or disadvantage!)

Alt

http://c3partners.biz/MrData.swf


What rules define who must participate?



Step 2:Eligible IT



Step 5:Strategies

Step 6:Getting Help



Step 1: Eligible ProfessionalProvider Type

Hospitals• As a practical matter, you

should assume all hospitals will be eligible

• Your interaction with a hospital’s MU program will be limited to a few specific requirements

EP - Medicare• Starting point is

“physician”, or: Doctor of Medicine or

Osteopathy, Doctor of Dental Surgery or

Dental Medicine Doctor of Podiatric

Medicine Doctor of Optometry Chiropractor

• Hospital Based Providers not Eligible (we’ll come back to this later)

EP – Medicaid• Physicians, dentists,

certified nurse-midwives, nurse practitioners, and physician assistants practicing in an FQHC or RHC that is so led by a physician assistant.

• Hospital Based restrictions same as Medicare, except Medicaid EPs practicing predominantly in an FQHC or RHC are not subject to the hospital-based exclusion


Step 1: Eligible ProfessionalPlace of Service

Hospital-Based Providers

• Not eligible to receive payments• 90% of work done in hospital

environment = hospital-based• Hospital based determined by POS codes

on HCFA 1500’s – 21—Inpatient Hospital– 23 – Emergency Room

• CMS will pre-determine Hospital-based status from prior year claims experience

• Radiology billing based on where the interpretation is done

The appropriate POS code is the place where the service takes place. If the interpretation is performed in the hospital setting, the POS code is hospital outpatient (22). If the interpretation is performed at a location other than the location of the physician’s office and the location meets the definition of office, the POS code is office (11). If the physician performs the interpretation from home, the POS code is either office (11) if it meets the definition of office or other (99).


What rules define if my environment qualifies?



Step 2:Eligible IT



Step 5:Strategies

Step 6:Getting Help



Step 2: Eligible ITHow do I know if my EHR is Certified?

http://onc-chpl.force.com/ehrcert


Step 2: Eligible ITHow do I know if my EHR is Certified?

What does it mean to have a Certified

EHR?


What must I do with my IT to qualify?



Step 2:Eligible IT



Step 5:Strategies

Step 6:Getting Help



Step 3: Eligible Processes Our Vendor’s Role and Our Role

alt

http://c3partners.biz/AirGuitar.swf


MU Hospital Eligible Provider

Core Meaningful Use –must meet all core requirements

14 15

Menu Meaningful Use –select from list of 10

5 5

Core - Quality measures – must meet all core requirements

15 3

Alternate Core – quality measures used only if EP has no patients for Core

n/a 3

Menu – quality measures – select from list of 38

n/a 3

Step 3: Eligible Processes Requirements Overview


Step 3: Eligible ProcessesWhy such a high degree of diligence?

• We must hit:– every single metric, – for every single requirement, – in every single department – by every single clinician

• When was the last time any organization made zero mistakes?

• Prudent management suggests powerful control mechanisms

» CMS audits are likely at some point; failure to prove that you actually did what you said is Medicare fraud

No room for these. .


Step 3: Eligible Processes Pragmatic Considerations – All or Each?

Hospitals• Each objective must be met across all

clinicians in the hospital • As a result, hospitals are likely to

engage in significant measurement and education activities, to which you may be asked to be a party

EP Rules• Each EP qualifies individually• No relationships between EP’s

ability to qualify• Each EP has individual penalties,

too

Qualifying in your practice has no impact on whether / how your hospital

clients will qualify (and vice-versa)


Step 3: Eligible ProcessesPragmatic Considerations - Objectives not relevant to my practice

After consideration of the public comments received, we have identified, for each meaningful use objective, whether the EP, eligible hospital, or CAH may attest that they did not have any patients or insufficient actions on which to base a measurement of a meaningful use for the EHR reporting period.

For objectives in the core set, such an attestation would remove the objective from consideration when determining whether an EP, eligible hospital, or CAH is a meaningful EHR user. In other words, the EP, eligible hospital, or CAH could satisfy the core set objectives by satisfying all remaining objectives included in the core set.

For objectives in the menu set, such an attestation would also remove the objective from consideration when determining whether an EP, eligible hospital, or CAH is a meaningful EHR user. For example, if for one objective included in the menu set an EP attests that he or she did not have any patients or insufficient actions during the EHR reporting period on which to base a measurement of a meaningful use objective, rather than satisfy 5 of the 10 meaningful use objectives included in the menu set for EPs, the EP need only satisfy 4 of the 9 remaining meaningful use objectives included in the menu set for EP’s.

CMS-0033-F Page 61

Bottom Line:

You need not comply with objectives corresponding

to circumstances that don’t exist in your

practice.

In reporting to CMS, you must attest that the

measure is irrelevant to your practice, and why


1. Computerized physician order entry (CPOE)2. E-Prescribing (eRx)3. Report ambulatory clinical quality measures to CMS/States4. Implement one clinical decision support rule5. Provide patients with an electronic copy of their health information, upon request6. Provide clinical summaries for patients for each office visit7. Drug-drug and drug-allergy interaction checks8. Record demographics9. Maintain an up-to-date problem list of current and active diagnoses10. Maintain active medication list11. Maintain active medication allergy list12. Record and chart changes in vital signs13. Record smoking status for patients 13 years or older14. Capability to exchange key clinical information among providers of care and

patient-authorized entities electronically15. Protect electronic health information

Step 3: Eligible Processes EP Core Objectives

Candidates to consider as exclusions for RadiologistsProbable applicable to Radiologists


Step 3: Eligible Processes CPOE

OBJECTIVE: Use CPOE for medication orders directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local and professional guidelines. METHOD OF MEASURE CALCULATION: Denominator is based on counting actions for patients whose records are maintained using certified EHR technology

NUMERATOR: The number of patients in the denominator that have at least one medication order entered using CPOE.

DENOMINATOR: Number of unique patients with at least one medication in their medication list seen by the EP or admitted to an eligible hospital’s or CAH’s inpatient or emergency department (POS 21 or 23) during the EHR reporting period. The only patients that are included in the denominator are those patients whose records are maintained using certified EHR technology.

THRESHOLD: The resulting percentage must be more than 30 percent in order for eligible hospital or CAH to meet this measure.

EXCLUSIONS: EP - If an EP’s writes fewer than one hundred prescriptions during the EHR reporting period they would be excluded from this requirement.

Radiologist Action:

Candidate for “no patients or

Insufficient actions”


Step 3: Eligible Processese-Prescribing

OBJECTIVE: Generate and transmit permissible prescriptions electronically (eRx).

ASSOCIATED MEASURE: More than 40% of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technology.

METHOD OF MEASURE CALCULATION: Denominator is based on counting actions for patients whose records are maintained using certified EHR technology.

NUMERATOR: The number of prescriptions in the denominator generated and transmitted electronically.

DENOMINATOR: Number of prescriptions written for drugs requiring a prescription in order to be dispensed other than controlled substances during the EHR reporting period.

THRESHOLD: The resulting percentage must be more than 40 percent in order for an EP to meet this measure.

EXCLUSIONS: This objective and associated measure do not apply to any EP who writes fewer than one hundred prescriptions during the EHR reporting period.

Radiologist Action:




Step 3: Eligible ProcessesReport Clinical Quality measures

OBJECTIVE: Report hospital \ ambulatory clinical quality measures to CMS (or, for eligible hospitals seeking the Medicaid incentive payment, the States)

ASSOCIATED MEASURE: For 2011, an EP or eligible hospital or CAH would provide the aggregate level data for the numerator, denominator, and exclusions through attestation as discussed in section II.A.3 of this final rule. For 2012, an EP or eligible hospital or CAH would electronically submit the measures as discussed in section II.A.3. of this final rule.

METHOD OF MEASURE CALCULATION: Measure requires only a Yes/No attestation.

THRESHOLD: Requires attestation to ability to report the 6 EP or 15 hospital quality measures

EXCLUSIONS: None

Note:This requirement decomposes into 6 unique quality reporting requirements, chosen from a field of 44

Radiologist Action:

Review quality measures list,

select those for which your

practice is most likely to be able to populate data

elements


Step 3: Eligible ProcessesClinical Decision Support

OBJECTIVE: Implement one clinical decision support rule related to a high priority hospital condition along with the ability to track compliance with that rule.

ASSOCIATED MEASURE: Implement one clinical decision support rule.

METHOD OF MEASURE CALCUALTION: Measure requires only a Yes/No attestation.

THRESHOLD: Implement at least one clinical decision support rule

EXCLUSIONS: None

Radiologist Action:

Identify one relevant clinical

decision support rule, turn it on

in your EHR, and Attest YES


Step 3: Eligible ProcessesProvide Electronic Information to Patients

OBJECTIVE: Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, medication allergies, discharge summary, procedures), upon request.

ASSOCIATED MEASURE: More than 50 percent of all patients of the EP or of the inpatient or emergency departments of the eligible hospital or CAH (POS 21 or 23) who request an electronic copy of their health information are provided it within 3 business days (Monday through Friday - excluding federal and state holidays where administrative staff is unavailable).

METHOD OF MEASURE CALCULATION - Denominator is based on counting actions for patients whose records are maintained using certified EHR technology.

NUMERATOR: The number of patients in the denominator who receive an electronic copy of their electronic health information within three business days.

DENOMINATOR: The number of patients of the EP or eligible hospital’s or CAH’s inpatient or emergency departments (POS 21 or 23) who request an electronic copy of their electronic health information four business days prior to the end of the EHR reporting period. The only patients that are included in the denominator are those patients whose records are maintained using certified EHR technology.

THRESHOLD: The resulting percentage must be more than 50 percent in order for an EP, eligible hospital, or CAH to meet this measure

EXCLUSIONS: If the EP, eligible hospital, or CAH has no requests from patients or their agents for an electronic copy of patient health information during the EHR reporting period they would be excluded from this requirement.

Radiologist Action:

1. Monitor patients

who request

electronic copies of

their imaging and/or

interpretations

2. Track the occurrences of

when you provided this information

electronically


Step 3: Eligible ProcessesProvide Clinical Summaries

OBJECTIVE: Provide clinical summaries for patients for each office visit

ASSOCIATED MEASURE: Clinical summaries provided to patients for more than 50 percent of all office visits within 3 business days.


NUMERATOR: Number of patients in the denominator who are provided a clinical summary of their visit within three business days.

DENOMINATOR: Number of unique patients seen by the EP for an office visit during the EHR reporting period. The only patients that are included in the denominator are those patients whose records are maintained using certified EHR technology.

THRESHOLD: The resulting percentage must be more than 50 percent in order for an EP to meet this measure.

EXCLUSIONS: EP's who have no office visits during the EHR reporting period would be excluded from this requirement.

Radiologist Action:




Step 3: Eligible ProcessesDrug-Drug and Drug-Allergy

OBJECTIVE: Implement drug-drug and drug-allergy checks.

ASSOCIATED MEASURE: The EP has enabled this functionality for the entire EHR reporting period.

METHOD OF MEASURE CALCULATION: Measure requires only a Yes/No Attestation.

THRESHOLD: Not applicable

EXCLUSIONS: None

Radiologist Action:Turn on

Functionality in EHR and Attest

YES

- OR -

Radiologist Action:




Step 3: Eligible ProcessesRecord Demographics

OBJECTIVE: Record demographics o preferred language o gender o race o ethnicity o date of birth

ASSOCIATED MEASURE: More than 50 percent of all unique patients seen by the EP have demographics recorded as structured data.

METHOD OF MEASURE CALCULATION: Denominator is unique patients regardless of whether the patient's records are maintained using certified EHR technology.

NUMERATOR: The number of patients in the denominator who have all the elements of demographics (or a specific exclusion if the patient declined to provide one or more elements or if recording an element is contrary to state law) recorded as structured data.

DENOMINATOR: Number of unique patients seen by the EP during the EHR reporting period.

THRESHOLD: The resulting percentage must be more than 50% in order for an EP to meet this measure.

EXCLUSIONS: None

Radiologist Action:




Step 3: Eligible ProcessesProblem Lists

OBJECTIVE: Maintain an up-to-date problem list of current and active diagnoses.

ASSOCIATED MEASURE: More than 80 percent of all unique patients admitted to the eligible hospital’s or CAH’s inpatient or emergency departments (POS 21 or 23) have at least one entry or an indication that no problems are known for the patient recorded as structured data.

METHOD OF MEASURE CALCULATION - Denominator is unique patients regardless of whether the patient's records are maintained using certified EHR technology.

NUMERATOR: The number of patients in the denominator who have at least one entry or an indication that no problems are known for the patient recorded as structured data in their problem list.

DENOMINATOR: Number of unique patients admitted to an eligible hospital’s or CAH’s inpatient or emergency department (POS 21 or 23) during the EHR reporting period. (Total Number of Unique Patients - Regardless of Whether the Patient’s Records Are Maintained Using Certified EHR Technology).

THRESHOLD: The resulting percentage must be more than 80 percent in order for an EP, eligible hospital, or CAH to meet this measure.

EXCLUSIONS: None

Radiologist Action:

Capture as part of normal

interpretations


Step 3: Eligible ProcessesActive Meds List

OBJECTIVE: Maintain active medication list

ASSOCIATED MEASURE: More than 80 percent of all unique patients seen by the EP or admitted to the eligible hospital’s or CAH’s inpatient or emergency departments (POS 21 or 23) have at least one entry (or an indication that the patient is not currently prescribed any medication) recorded as structured data.


NUMERATOR: The number of patients in the denominator who have a medication (or an indication that the patient is not currently prescribed any medication) recorded as structured data.

DENOMINATOR: Number of unique patients admitted to an eligible hospital’s or CAH’s inpatient or emergency departments (POS 21 or 23) during the EHR reporting period. A definition of unique patient is discussed under the objective of CPOE. (Total Number of Unique Patients - Regardless of Whether the Patient’s Records Are Maintained Using Certified EHR Technology).


EXCLUSIONS: None Additional Note in Regulations: We are only concerned with medications that are known to the provider through querying the patient, their own records and the transfer of records from other providers. Meaningful use cannot address situations where the information is withheld from the EP, eligible hospital, or CAH by the patient or by other providers.

Radiologist Action:




Step 3: Eligible ProcessesActive Med Allergies

OBJECTIVE: Maintain active medication allergy list

ASSOCIATED MEASURE: More than 80 percent of all unique patients admitted seen by the EP or admitted to the eligible hospital’s or CAH’s inpatient or emergency departments (POS 21 or 23) have at least one entry (or an indication that the patient has no known medication allergies) recorded as structured data.


NUMERATOR: The number of unique patients in the denominator who have at least one entry (or an indication that the patient has no known medication allergies) recorded as structured data in their medication allergy list.

DENOMINATOR: Number of unique patients admitted to an eligible hospital’s or CAH’s inpatient or emergency departments (POS 21 or 23) during the EHR reporting period. The definition of “a unique patient” is provided under the objective of CPOE. (Total Number of Unique Patients - Regardless of Whether the Patient’s Records Are Maintained Using Certified EHR Technology).


EXCLUSIONS: None

Radiologist Action:




Step 3: Eligible ProcessesRecord and chart changes in vital signs

OBJECTIVE: Record and chart changes in vital signs: o height o weight o blood pressure o Calculate and display: BMI o Plot and display growth charts for children 2-20 years, including BMI.

ASSOCIATED MEASURE: For more than 50 percent of all unique patients age 2 and over admitted to eligible hospital’s or CAH’s inpatient or emergency department (POS 21 or 23), height, weight and blood pressure are recorded as structured data.

METHOD OF MEASURE CALCULATION - Denominator is based on counting actions for patients whose records are maintained using certified EHR technology

NUMERATOR: The number of patients in the denominator who have at least one entry of their height, weight and blood pressure are recorded as structure data.

DENOMINATOR: Number of unique patients age 2 or over admitted to an eligible hospital’s or CAH’s inpatient or emergency department (POS 21 or 23) during the EHR reporting period. A unique patient is discussed under the objective of CPOE. The only patients that are included in the denominator are those patients whose records are maintained using certified EHR technology.


EXCLUSIONS: None

Radiologist Action:




Step 3: Eligible ProcessesSmoking Status

OBJECTIVE: Record smoking status for patients 13 years old or older

ASSOCIATED MEASURE: More than 50 percent of all unique patients 13 years old or older admitted to the eligible hospital’s or CAH’s inpatient or emergency departments (POS 21 or 23) have smoking status recorded as structured data.

METHOD OF MEASURE CALCULATION: Denominator is based on counting actions for patients whose records are maintained using certified EHR technology

NUMERATOR: The number of patients in the denominator with smoking status recorded as structured data.

DENOMINATOR: Number of unique patients age 13 or older admitted to an eligible hospital’s or CAH’s inpatient or emergency departments (POS 21 or 23) during the EHR reporting period. A unique patient is discussed under the objective of maintaining an up-to-date problem list.

THRESHOLD: Threshold: The resulting percentage must be more than 50 percent in order for an EP, eligible hospital, or CAH to meet this measure.

EXCLUSIONS: None

Radiologist Action:




Step 3: Eligible ProcessesExchange Key Clinical Information

OBJECTIVE: Capability to exchange key clinical information (for example, discharge summary, procedures, problem list, medication list, medication allergies, diagnostic test results), among providers of care and patient authorized entities electronically.

ASSOCIATED MEASURE: Performed at least one test of certified EHR technology's capacity to electronically exchange key clinical information. Measure requires only a Yes/No Attestation.


THRESHOLD: To be considered an ‘‘exchange’’ for this objective and measure the clinical information must be sent between different legal entities with distinct certified EHR technology or other system that can accept the information

EXCLUSIONS: None

Radiologist Action:

Develop EHR integration with

one or more referring

physicians, or one hospital


Step 3: Eligible ProcessesProtect Electronic Health Information

OBJECTIVE: Protect electronic health information created or maintained by the certified EHR technology through the implementation of appropriate technical capabilities

ASSOCIATED MEASURE: Conduct or review a security risk analysis per 45 CFR 164.308(a)(1) of the certified EHR technology, and implement security updates and correct identified security deficiencies as part of its risk management process.

METHOD OF MEASURE CALCULATION: Measure requires only a Yes/No attestation

THRESHOLD: Conduct one security risk assessment.

EXCLUSIONS: None

Radiologist Action:

Conduct HIPAA Security

Assessment, and monitor your

progress on any shortcomings


Step 3: Eligible Processes EP: Menu Set Objectives*

Eligible Professionals – select 5 from list*1. Drug-formulary checks2. Incorporate clinical lab test results as structured

data3. Generate lists of patients by specific conditions4. Send reminders to patients per patient preference

for preventive/follow up care5. Provide patients with timely electronic access to

their health information6. Use certified EHR technology to identify patient-

specific education resources and provide to patient, if appropriate

7. Medication reconciliation8. Summary of care record for each transition of

care/referrals9. Capability to submit electronic data to

immunization registries/systems*10.Capability to provide electronic syndromic

surveillance data to public health agencies*

*At least 1 public health objective must be selected 25

Candidates to consider as exclusions for RadiologistsProbable applicable to Radiologists


Step 3: Eligible Processes Drug-Formulary checking

OBJECTIVE: Implement drug formulary checks

ASSOCIATED MEASURE: Drug formulary check system is implemented and has access to at least one internal or external drug formulary for the entire reporting period.

METHOD OF MEASURE CALCULATION: Measure requires only a Yes/No Attestation.

THRESHOLD: Capability must be enabled for entire reporting period

EXCLUSIONS: None

Radiologist Action:

Create or enable access to drug

formulary (payer or hospital)And turn on

checking capability

Selection RecommendationDo not select this

rule


Step 3: Eligible Processes Incorporate Clinical Lab Test Results

OBJECTIVE: Incorporate clinical lab test results into EHR as structured data

ASSOCIATED MEASURE: More than 40 percent of all clinical lab tests results ordered by authorized provider of the eligible hospital or CAH for patients admitted to its inpatient or emergency department (POS 21 or 23) during the EHR reporting period whose results are in either in a positive/negative or numerical format are incorporated in certified EHR technology as structured data


NUMERATOR: The number of lab test results whose results are expressed in a positive or negative affirmation or as a number which are incorporated as structured data.

DENOMINATOR: Number of lab tests ordered during the EHR reporting period by the authorized providers of the eligible hospital or CAH for patients admitted to an eligible hospital’s or CAH’s inpatient or emergency department (POS 21 & 23) whose results are expressed in a positive or negative affirmation or as a number. The only patients whose lab test orders are included in the denominator are those patients whose records are maintained using certified EHR technology.


EXCLUSIONS: If an EP orders no lab tests whose results are either in a positive/negative or numeric format during the EHR reporting period they would be excluded from this requirement as described previously in this section under our discussion of whether certain EP, eligible hospital or CAH can meet all Stage 1 meaningful use objectives given established scopes of practices.

Selection RecommendationDo not select this

rule

Radiologist Action:




Step 3: Eligible Processes Generate Lists by Specific Conditions

OBJECTIVE: Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research, or outreach

ASSOCIATED MEASURE: Generate at least one report listing patients of the EP or eligible hospital with a specific condition. (Note: report only needs to contain patients whose records are maintained in the certified EHR)


THRESHOLD: Only one report in required for any given EHR reporting period.

EXCLUSIONS: None

Radiologist Action:

Generate reporting based

on selected condition

Selection Recommendation

Select this Rule


Step 3: Eligible Processes Send Reminders per Patient Preference

OBJECTIVE: Send reminders to patients per patient preference for preventive/ follow up care.

ASSOCIATED MEASURE: More than 20 percent of all patients 65 years or older or 5 years old or younger were sent an appropriate reminder during the EHR reporting period.


NUMERATOR: The number of patients in the denominator who were sent the appropriate reminder.

DENOMINATOR: Number of unique patients 65 years old or older or 5 years old or younger. The denominator is based on patients whose records are maintained using certified EHR technology.

THRESHOLD: The resulting percentage must be more than 20% in order for an EP to meet this measure.

EXCLUSION: If an EP has no patients 65 yeras or older or 5 years or younger with records maintained using certified EHR technology that EP is excluded from this requirement

Selection RecommendationDo Not Select this

Rule

Radiologist Action:




Step 3: Eligible Processes Provide patients electronic access

OBJECTIVE: Provide patients with timely electronic access to their health information (including lab results, problem list, medication lists, medication allergies) within four business days of the information being available to the EP.

ASSOCIATED MEASURE: At least 10 percent of all unique patients seen by the EP are provided timely (available to the patient within four business days of being updated in the certified EHR technology) electronic access to their health information subject to the EP’s discretion to withhold certain information.

METHOD OF MEASURE CALCULATION: Denominator is unique patients regardless of whether the patient's records are maintained using certified EHR technology.

NUMERATOR: The number of patients in the denominator who have timely (available to the patient within four business days of being updated in the certified EHR technology) electronic access to their health information online.

DENOMINATOR: Number of unique patients seen by the EP during the EHR reporting period.

THRESHOLD: The resulting percentage must be at least 10 percent in order for the EP to meet this measure.

EXCLUSION: If an EP neither orders nor creates any of the information listed in the ONC final rule 45 CFR 170.304(g) and therefore included in the minimum data for this objective during the EHR reporting period they would be excluded from this requirement.

Radiologist Action:Provide

interpretations and images

electronically as requested


Select this Rule


Step 3: Eligible Processes Provide patient-specific education resource to patient

OBJECTIVE: Use certified EHR technology to identify patient-specific education resources and provide those resources to the patient if appropriate.

ASSOCIATED MEASURE: More than 10% of all unique patients seen by the EP or admitted to eligible hospital's or CAH's inpatient or emergency department (POS 21 or 23) are provided patient-specific educational resources.


NUMERATOR: Number of patients in the denominator who are provided patient education specific resources.

DENOMINATOR: Number of unique patients seen by the EP during the EHR reporting period. (Total Number of Unique Patients - Regardless of Whether the Patient’s Records Are Maintained Using Certified EHR Technology).


EXCLUSIONS: None

Radiologist Action:

Incorporate educational

resources, and issue to patient

(or referring physician) as

requested


Select this Rule


Step 3: Eligible Processes Medication Reconciliation at Transition of Care

OBJECTIVE: The EP or eligible hospital or CAH who receives a patient from another setting of care or provider of care or believes an encounter is relevant should perform medication reconciliation

ASSOCIATED MEASURE: The EP or eligible hospital or CAH performs medication reconciliation for more than 50 percent of transitions of care in which the patient is admitted to the eligible hospital’s or CAH’s inpatient or emergency department (POS 21 or 23).


NUMERATOR: The number of transitions of care in the denominator where medication reconciliation was performed.

DENOMINATOR: Number of transitions of care during the EHR reporting period for which the EP was the receiving party of the transition. The only patients whose medication reconciliations are included in the denominator are those patients whose records are maintained using certified EHR technology.


EXCLUSIONS: None


Rule

Radiologist Action:




Step 3: Eligible Processes Provide Summary of Care Record

OBJECTIVE: The EP, eligible hospital or CAH who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care should provide summary care record for each transition of care or referral.

ASSOCIATED MEASURE: The EP or eligible hospital or CAH who transitions or refers their patient to another setting of care or provider of care provides a summary of care record for more than 50 percent of transitions of care and referrals.


NUMERATOR: The number of transitions of care and referrals in the denominator where a summary of care record was provided

DENOMINATOR: Number of transitions of care and referrals during the EHR reporting period for which the EP or eligible hospital’s or CAH’s inpatient or emergency department (POS 21 to 23) was the transferring or referring provider. The only patients whose transitions of care and referrals are included in the denominator are those patients whose records are maintained using certified EHR technology.

THRESHOLD: The percentage must be more than 50 percent in order for an EP,eligible hospital, or CAH to meet this measure.

EXCLUSIONS: None


Rule

Radiologist Action:




Step 3: Eligible Processes Submit Electronic data to Immunization Registries

OBJECTIVE: Capability to submit electronic data to immunization registries or Immunization Information Systems and actual submission in accordance with to applicable law and practice

ASSOCIATED MEASURE: Performed at least one test of certified EHR technology's capacity to submit electronic data to immunization registries (unless none of the immunization registries to which the EP, eligible hospital, or CAH submits such information have the capacity to receive the information electronically). Test does not have to be successful.

METHOD OF MEASURE CALCULATION: Measure requires only a Yes/No attestation

THRESHOLD: Perform at least one test of certified EHR technology’s capacity to submit electronic data to immunization registries and follow up submission if the test is successful. A failed attempt would meet the measure.

EXCLUSIONS: Eligible hospitals and CAH's that have not given any immunizations during the EHR reporting period are excluded from this measure


Rule

Radiologist Action:




Step 3: Eligible Processes Submit Electronic Syndromic Surveillance Data

OBJECTIVE: Capability to submit electronic syndromic surveillance data to public health agencies and actual submission in accordance with applicable law and practice

ASSOCIATED MEASURE: Performed at least one test of certified EHR technology's capacity to provide electronic syndromic surveillance data to public health agencies and follow-up submission if the test is successful (unless none of the public health agencies to which an EP, eligible hospital, or CAH submits such information have the capacity to receive the information electronically).


THRESHOLD: Perform at least one test of certified EHR technology’s capacity to submit electronic data to public health agency and follow up submission if the test is successful. This test must include the transfer of either actual or ‘‘dummy’’ data to the chosen public health agency. A failed attempt would meet the measure.

EXCLUSIONS: None.

Radiologist Action:Provide

appropriate data as

requested, and attest “Yes”


Select this Rule


Step 3: Eligible Processes Meeting Quality Measures

• The good news is: – Quality measures do not have thresholds – For 2011, it is not necessary to submit electronically to CMS, but may be

required in 2012• The bad news is:

– All data to support quality measures must be maintained in our certified EHR’s, which is not currently the case

• Must submit six quality measures three of which must be core or alternate core measures. Can attest to the fact that the EP had no patients for the quality measure


Planning for compliance and staying on track



Step 2:Eligible IT



Step 5:Strategies

Step 6:Getting Help



Meaningful Use Requirements How Many?

Core Meaningful Use –must meet all core requirements

15

Menu Meaningful Use –select from list of 10

5

Core - Quality measures – must meet six of 44

6

Step 4: Program Monitoring Compliance Tracking Summary

For Each

Requirement

What interpretation do we provide our clinicians ?

What report(s) do we run and store long term to

prove we were compliant for each reporting year ?

What is the operational process flow ?

For Each Quality Report

Where in our EHR is the supporting

data stored?

In what system is the data currently originated, and how are we getting it into

the EHR?

What reports do we create and execute, to prove that

we have the data in our EHR?

What data sets must our clinicians use ?

MUM is the framework for all this, and more


Step 4: Program Monitoring Compliance Tracking Summary

• The basis for Incentives is predicated on Meaningful Use (MU) of EHRs …

However, it’s not just about the technology – there has to be significant changes in clinical processes and procedures

• Clinical involvement is imperative for achieving Meaningful Use … if it looks complex it probably is - over 100 FAQ’s have been issued by CMS and ONC!

Remember:

• EHR Vendors can get you from Red to Yellow

• Only process, training, adoption, and data will get you to Green

• It is initially adequate to Attest, but you must retain Proof of Green for up to 6 years


Role of Formalized Compliance Tools

Real-time visibility to all key stakeholders Repository for all requirements, assigned to appropriate individuals, with any relevant interpretations The place where your clinical attestation coordinator tracks EHR compliance status Organize and communicate work accountabilities and status Provide a pathway to auditable proof of compliance we can save for statutory 6 year audit time

frame

Program MonitoringFormal Compliance Tools


Program MonitoringFormal Compliance Milestones



X – You are here

X

Status Reporting works best within a visual context. Sample statements might be …

So Far we have:• Assembled and educated our

Leadership Team• Prepared our tracking tools• Defined a timeline

What we are about to do is: • Complete education for

Executives, Clinicians and Clinical Attestation Coordinators

• Kick off our detailed Gap Analysis

• Work on shortfall remediations, identified as EHR Vendor, Clinical Process, and Documentation of Proof


High level timelines should tie your milestones to CMS program



Strategies and Tactics to optimize my goals



Step 2:Eligible IT



Step 5:Strategies

Step 6:Getting Help



Step 5: StrategiesWhat Strategies might we need?

• ARRA Participation Strategies• “Scheduling” Strategies to help manage

individual provider eligibility• Program Management Strategies • EHR Product Strategies• Regulatory Intervention and Influencing

Strategies (Manage the CMS Relationship)


Step 5: Strategies ARRA Participation Strategies

• Cost Benefit of entering program now vs paying penalties later

• Can / should some providers quallify for Medicaid (it is a choice)? – Higher payments ($63,750 vs $44,000 Medicare)– $63,750 is predicated on allowable costs of EHR (per EP) being at least

$75,000– First Year can be for Adopting, Implementing or Upgrading EHR and

need not be meaningful Use– Six year payout, vs Five year for Medicare– EP must have at least 30% of encounters as Medicaid


Step 5: Strategies Scheduling Strategies

Remember that rewards and penalties are attributable to the Individual EP, not the practice. So …

• To Maximize Stimulus Funding:

– If most work is within eligible POS’s, make sure each individual conducts more than 10% in non-hospital settings

– If most work is within non-eligible POS’s, try concentrating workload to a small number of professionals who can qualify, and then spread the resulting payments across the practice

• If you are not planning on being part of ARRA HITECH:– Analyze all encounters across the entire staff– Minimize future penalties by scheduling work so that the minimum number of

individuals “qualify”, in order to minimize future penalties. • Where possible, conduct interpretations within relevant POS to fit your

goals


Step 5: Strategies Program Management Strategies

• Achieving Meaningful Use– Some of this you will be doing for other purposes – May not be all that much in incremental cost

• Federal Program Compliance is not free– CMS predicts you will spend little or no effort in “compliance” activities– Small hospitals are estimating at least one full time equivalent, and many

estimate more just for tracking (not achieving)

• Putting someone in Charge– Project management– Clinical coordination– IT Coordination (get from Red to Yellow as fast as you can. Yellow to Green

takes longer)


Step 5: Strategies EHR Product Strategies

• Develop points of view on your current (or new) EHR’s capabilities • Will your vendor certify the product you currently own, or require an

upgrade? – You must own all the functionality even if you don’t use it all – Self-certification may be a viable option for larger groups, but will require

some software development as well• Reports to calculate metrics • Some functionality you may not have

• Build an Interoperability Strategy, based on the Menu Options you select – Interactions with referring physicians or hospitals– Interactions with public health organizations


Step 5: Strategies CMS Relationship Strategies

• Participate in professional societies– Meaningful Use will continue to evolve, and you need your position known– Current regulations likely to contain problems and unintended consequences,

for / against which you should lobby – especially for your specialty

• Stay informed in the current regulations via FAQ and other CMS pronouncements


Additional Federal Funding, Commercial Sources, Links



Step 2:Eligible IT



Step 5:Strategies

Step 6:Getting Help



Step 6: Getting HelpC3 Partners Sites and Tools

Information Overload on the Web. The Final Rule for Meaningful Use is over 800 pages long. Our firm has organized much content, and commits to researching and answering your questions on:• http://EverythingHITECH.com – content

regarding the rules around eligibility, payments and many other administrative issues

• http://MUMrequirements.com – the details of what you need to do with your EHR, in a discussion board format

• http://MeaningfulUseMonitor.com – a quick overview of our ARRA HITECH program management software designed to organize your compliance efforts.

http://www.everythinghitech.com/everything-hitech/2010/08/trouble-navigating-the-800-page-final-rule-.html

http://everythinghitech.com/

http://mumrequirements.com/

http://meaningfulusemonitor.com/





Step 6: Getting HelpRegulatory and Professional Sources

Information Overload on the Web. The Final Rule for Meaningful Use is over 800 pages long. We try to stick to “primary” sources. Here are a couple that matter:• http://www.RadiologyMU.org – I’ve not spent a lot of time here, but this

site seems to speak to specialty-specific issues• http://onc-chpl.force.com/ehrcert - The definitive listing of what EHR

vendors and modules are currently certified.• http://healthit.hhs.gov/portal/server.pt/community/onc_regulations_faqs

/3163 - This site is as big and ugly as the URL itself. But it is the place where CMS responds to questions and maintains changes in policy (so far)

http://www.radiologymu.org/

http://onc-chpl.force.com/ehrcert

http://healthit.hhs.gov/portal/server.pt/community/onc_regulations_faqs/3163

http://healthit.hhs.gov/portal/server.pt/community/onc_regulations_faqs/3163


Step 6: Getting HelpRegional Extension Centers

• Regional Extension Centers– Focus of small primary care practices

(under 10)– But … they need physicians to sign up

with them to get and retain government funding, and sign ups have been slow

– REC has federal funding available to help with consulting services (up to $5k per physician), and may charge you for services beyond that rate

– Startup organizations in process of building out Meaningful Use assistance capabilities

• Indiana RECs:– HealthBridge

http://www.healthbridge.org/index.php– Indiana Health Information Technology

Extension Center (Purdue University) http://www.ihitec.purdue.edu/

http://www.healthbridge.org/index.php

http://www.ihitec.purdue.edu/


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