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Meaningful Use Workgroup Paul Tang, Palo Alto Medical Foundation, Chair George Hripcsak, Columbia University, Co-Chair July 27, 2012

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Meaningful Use Workgroup . Paul Tang, Palo Alto Medical Foundation, Chair George Hripcsak, Columbia University, Co-Chair July 27, 2012. Workgroup Membership. Co-Chairs: Paul TangPalo Alto Medical Foundation George Hripcsak Columbia University Members: - PowerPoint PPT Presentation

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Page 1: Meaningful Use Workgroup

Meaningful Use Workgroup

Paul Tang, Palo Alto Medical Foundation, ChairGeorge Hripcsak, Columbia University, Co-Chair

July 27, 2012

Page 2: Meaningful Use Workgroup

MU Workgroup Recommended Response to Stage 3 NPRM 2

Workgroup Membership

Co-Chairs:Paul Tang Palo Alto Medical FoundationGeorge Hripcsak Columbia University

Members:• David Bates Brigham & Women’s Hospital• Michael Barr American College of Physicians• Christine Bechtel National Partnership/Women & Families• Neil Calman Institute for Family Health• Tim Cromwell Department of Veterans Affairs• Art Davidson Denver Public Health• Marty Fattig Nemaha County Hospital• James Figge NY State Dept. of Health• Joe FrancisVeterans Administration• Leslie Kelly Hall Healthwise• Yael Harris HRSA• David Lansky Pacific Business Group/Health• Deven McGraw Center/Democracy & Technology• Latanya Sweeney Carnegie Mellon University• Greg Pace Social Security Administration• Robert Tagalicod CMS/HHS• Karen Trudel CMS• Charlene Underwood Siemens• Amy Zimmerman Rhode Island Department of Health and Human Services

Page 3: Meaningful Use Workgroup

MU Workgroup Recommended Response to Stage 3 NPRM 3

Agenda

Updates from each subgroup*

Continue review of comments from previous meeting

*Slides do not reflect referrals from each subgroups

Page 4: Meaningful Use Workgroup

MU Workgroup Recommended Response to Stage 3 NPRM

Subgroup 1:Improve Quality Safety, Efficiency and

Reducing Health Disparities

• Is enough being done to reach domain goals, especially related to efficiencies? • There seems to be little in the rule around disparities.

4

Page 5: Meaningful Use Workgroup

MU Workgroup Recommended Response to Stage 3 NPRM

Improve Quality Safety, Efficiency and Reducing Health Disparities

5

Stage 1 Final Rule Stage 2 NPRM Stage 3 Recommendations

Medication only: More than 30% of unique patients seen during the reporting period with at least one medication in their medication list have at least one medication order entered using CPOE

Objective: Use computerized provider order entry (CPOE) for medication, laboratory and radiology orders directly entered by any licensed healthcare professional who can enter orders into the medical record per State, local and professional guidelines to create the first record of the order.

Measure: More than 60% of medication, laboratory, and radiology orders created by the EP or authorized providers of the eligible hospital's or CAH's inpatient or emergency department (POS 21 or 23) during the EHR reporting period are recorded using CPOE

Define % after Stage 2 final

Objective: Use computerized provider order entry (CPOE) for medication, laboratory and radiology orders directly entered by any licensed healthcare professional who can enter orders into the medical record per State, local and professional guidelines to create the first record of the order.

Measure: More than 60% of medication, laboratory, and radiology orders created by the EP or authorized providers of the eligible hospital's or CAH's inpatient or emergency department (POS 21 or 23) during the EHR reporting period are recorded using CPOE

New for stage 3 New for stage 3 Objective: Use computerized provider order entry for referrals/transition of care orders directly entered by any licensed healthcare professional who can enter orders into the medical record per State, local and professional guidelines to create the first record of the order.

Measure: More than 20% of referrals/transition of care orders created by the EP or authorized providers of the eligible hospital's or CAH's inpatient or emergency department (POS 21 or 23) during the EHR reporting period are recorded.

Page 6: Meaningful Use Workgroup

MU Workgroup Recommended Response to Stage 3 NPRM 6

Improve Quality Safety, Efficiency and Reducing Health DisparitiesStage 1 Final

Rule Stage 2 NPRM Stage 3 Recommendations

Implement drug-drug and drug-allergy interaction checks

Consolidated ConsolidatedCertification: EHRs need to be able to consume external lists of DDIs (e.g., “never” combinations).

Would need SNOMED-CT, Structured Product Labeling, and RxNorm (no current standards to represent DDIs).

EP only: Generate and transmit more than 40% of all permissible prescriptions electronically

EP Objective: Generate and transmit permissible prescriptions electronically (eRx)

EP Measure: More than 65 % of all permissible prescriptions written by the EP are compared to at least one drug formulary and transmitted electronically using Certified EHR Technology.

EH Objective: Generate and transmit permissible discharge prescriptions electronically (eRx)

EH Measure: More than 10% of hospital discharge medication orders for permissible prescriptions (for new or changed prescriptions) are compared to at least one drug formulary and transmitted electronically using Certified EHR Technology

EP Objective: Generate and transmit permissible prescriptions electronically (eRx)

EP Measure: More than 50% of all permissible prescriptions written by the EP are compared to at least one drug formulary (reviewed for generic substitutions) transmitted electronically using Certified EHR Technology.

EH Objective: Generate and transmit permissible discharge prescriptions electronically (eRx)

EH Measure: More than 30% of hospital discharge medication orders for permissible prescriptions (for new or changed prescriptions) are compared to at least one drug formulary and transmitted electronically using Certified EHR Technology

Page 7: Meaningful Use Workgroup

MU Workgroup Recommended Response to Stage 3 NPRM

Improve Quality Safety, Efficiency and Reducing Health Disparities

7

Stage 1 Final Rule Stage 2 NPRM Stage 3 Recommendations

Record demographics as structured data for more than 50% of all unique patients:• Preferred language• Gender• Race• Ethnicity• Date of birth

(Hospital Only) date and preliminary cause of death in the event of mortality in the eligible hospital or CAH

Objective: Record the following demographics:• Preferred language• Gender• Race• Ethnicity• Date of birth

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 department (POS 21 or 23) have demographics recorded as structured data• (Hospital Only) date and preliminary cause of death in the event of mortality in the eligible hospital or CAH

Objective: Record the following in structured data:Demographics:• Preferred language• Gender• Race• Ethnicity• Date of birthClinical:• SOGI• Disability status

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 department (POS 21 or 23) have demographics recorded as structured data• (Hospital Only) date and preliminary cause of death in the event of mortality in the eligible hospital or CAH

Referral from subgroup 2: Record 1) disability status, 2) sexual orientation and gender identity status, and 3) more granular race/ethnicity and language per IOM.Notes: Need to give thought to how EHRs display this, because often demographic data shows up at the top of every EHR screen, so SOGI data may not be part of “demographics” but should be a clinical field.

NOTE: In order to define disability status, subgroup 2 will use the 6 questions set forth in the American Community Survey (ACS). Subgroup 2 needs to see follow up work on the granular standards of race/ethnicity & language.

Page 8: Meaningful Use Workgroup

8

Improve Quality Safety, Efficiency and Reducing Health Disparities

8

Stage 1 Final Rule Stage 2 NPRM Stage 3 Recommendations

Maintain an up-to-date problem list of current and active diagnoses for more than 80% of all unique patients: have at least one entry or an indication that no problems are known for patient recorded as structured data

Consolidated with summary of care

ConsolidateDiscussion:• EHR systems need to be capable of computer assisted problems, meds, and med allergies. o Problem reconciliation? o Reconciliation from discharge, experience says that it is important for a human to review. • Select high priority conditions (such as HTN, under diagnosed and under treated). Assess whether properly identifying all patients with high blood pressure:o Have HTN on problem list?o Lab tests, drugs, vitals, diagnoses usedo David’s study identify diseases, DM, HTN, renal insufficiency (asthma and COPD are too hard).

• Functionality to make patient information reconciliation possible for problems - subgroup 3Defining high priority conditions.

Maintain active medication list: more than 80% of all unique patients have at least one entry recorded as structured data (or indication that the patient is on no meds)

Consolidated with summary of care

N/A

MU Workgroup Recommended Response to Stage 3 NPRM

Page 9: Meaningful Use Workgroup

9

Stage 1 Final Rule Stage 2 NPRM Stage 3 RecommendationsMaintain active medication allergy list: More than 80% of all unique patients seen during the reporting period have at least one entry (or indication that the patient has no known medication allergies) recorded as structured data

Consolidated with summary of care Consolidated

Discussion: Coding of med allergies to support better drug-allergy interactions. Algorithms to identify a strongly predictive interaction. What is the reaction? Has this person been on this and had no problem? Contraindication objective (meds or procedures).

HITSC: Are there mature standards for drug intolerance or allergic reaction value sets? Also standard value sets for overriding an allergy alert?

Record and chart changes in vital signs: more than 50% of all unique patients age 2 and over have vital signs recorded as structured data• Height• Weight• Blood pressure• Calculate and display BMI• Plot and display growth charts for children 2-20 years, including BMI

Objective: Record and chart changes in vital signs:• Height/Length• Weight• Blood pressure (age 3 and over)• Calculate and display BMI• Plot and display growth charts for patients 0-20 years, including BMI

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 department (POS 21 or 23), blood pressure (for patients age 3 and over only) and height/length and weight (for all ages) recoded as structured data

Maintain as is.Objective: Record and chart changes in vital signs:• Height/Length• Weight• Blood pressure (age 3 and over)• Calculate and display BMI• Plot and display growth charts for patients 0-20 years, including BMI

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 department (POS 21 or 23), blood pressure (for patients age 3 and over only) and height/length and weight (for all ages) recoded as structured data

Improve Quality Safety, Efficiency and Reducing Health Disparities

MU Workgroup Recommended Response to Stage 3 NPRM

Page 10: Meaningful Use Workgroup

MU Workgroup Recommended Response to Stage 3 NPRM 10

Stage 1 Final Rule Stage 2 NPRM Stage 3 Recommendations

Record smoking status for patients 13 years old and older: more than 50% of all unique patients seen during the reporting period 13 years or older have smoking status recorded as structured data

Objective: Record smoking status for patients13 years old or older

Measure: More than 80% of all unique patients 13 years old or older seen by the EP or admitted to the eligible hospital's or CAH's inpatient or emergency department (POS 21 or 23) have smoking status recorded as structured data

Consider retiring

HITSC: Is there a mature standard for coding smoking status? May consider retiring the objective because captured within CQMs.

MENU: Implement drug-formulary checks with access to at least one drug formulary

Consolidated - included within eRX core objective Consolidated - included within eRX core objective

Report ambulatory and hospital clinical quality measures to CMS or States

Removed Objective is incorporated directly into the definition of a meaningful EHR user and eliminated as an objective under 42 CFR 495.6

Removed

Improve Quality Safety, Efficiency and Reducing Health Disparities

Page 11: Meaningful Use Workgroup

MU Workgroup Recommended Response to Stage 3 NPRM 11

Stage 1 Final Rule Stage 2 NPRM Stage 3 Recommendations

EH MENU: Record advanced directives for more than 50% patients 65 years old or older

EP: N/A

EH Objective: Record whether a patient 65 years old or older has an advance directive

EH Menu Measure: More than 50% of all unique patients 65 years old or older admitted to the eligible hospital's or CAH's inpatient department (POS 21) during the EHR reporting period have an indication of an advance directive status recorded as structured data.

Raise the threshold for EPs and think about the standards in this area. Explicit statement about health care proxy. Add into Stage 3 if not added into Stage 2.

HITSC - Where does AD fit with CDA?

Referral from subgroup 2 - Advance directives: 1. Provide patients with the ability to document their AD online in a way that is retrievable by providers and able to be incorporated into EHR. Or, at a minimum, ensure AD document is scanned into EHR. This would accommodate state laws. May also need to provide exclusions for certain state laws.2. Require capability to document and integrate Physician Order for Life Sustaining Treatment (POLST) into the EHR.Notes: POLST is a Physician Order for Life Sustaining Treatment, includes proxy and standing orders for treatment (preferences re: nutrition, intubation, for example). So it fits well within an EHR. POLST is not replacement for advance directive, but the POLST can include an advance directive. Will need revision management strategy to make sure care team knows it is most up to date, similar to incorporating revisions to a care plan (S&I team can work on technical capabilities

Improve Quality Safety, Efficiency and Reducing Health Disparities

Page 12: Meaningful Use Workgroup

MU Workgroup Recommended Response to Stage 3 NPRM 12

Stage 1 Final Rule Stage 2 NPRM Stage 3 Recommendations

EP: Implement one clinical decision support rule relevant to specialty or high clinical priority along with ability to track compliance with that rule

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

Objective: Use clinical decision support toimprove performance on high priorityhealth conditions

Measure: 1. Implement five clinical decision support interventions related to five or more clinical quality measures, if applicable, at a relevant point in patient care for the entire EHR reporting period.2. The EP, eligible hospital, or CAH has enabled the functionality for drug-drug and drug-allergy interaction checks for the entire EHR reporting period.

Objective: Use clinical decision support toimprove performance on high priorityhealth conditions

Measure: 1. Implement 15 clinical decision support interventions related to five or more clinical quality measures, if applicable, at a relevant point in patient care for the entire EHR reporting period.2. The EP, eligible hospital, or CAH has enabled the functionality for drug-drug and drug-allergy interaction checks for the entire EHR reporting period.3. Ability to track CDS triggers and how the provider responded4. Ability to capture preferences and deliver recommendations for patients.5. Ability to track appropriate medications for diseases

Improve Quality Safety, Efficiency and Reducing Health Disparities

Page 13: Meaningful Use Workgroup

MU Workgroup Recommended Response to Stage 3 NPRM

Improve Quality Safety, Efficiency and Reducing Health Disparities

13

Stage 1 Final Rule Stage 2 NPRM Stage 3 Recommendations

MENU: Incorporate clinical lab test results into certified EHR technology as structured data for more than 40% of all clinical lab tests results ordered whose results are either in a positive/negative or numerical format

Objective: Incorporate clinical lab-test results into EHR as structured data

Measure: More than 55% of all clinical lab tests results ordered by the EP or by authorized providers 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 either in a positive/negative or numerical format are incorporated in Certified EHR Technology as structured data

Objective: Incorporate clinical lab-test results into EHR as structured data

Measure: More than 80% of all clinical lab tests results ordered by the EP or by authorized providers 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 either in a positive/negative or numerical format are incorporated in Certified EHR Technology as structured data

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

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

EP Measure: Generate at least one report listing patients of the EP, eligible hospital or CAH with a specific condition.

Discussion: Need to define dashboard.

Interest in incorporating lists into a dashboard (lists tend to be retrospective). Outreach: - Prioritizing where outreach is important- Should this be a separated from patient lists, but still be linked?

Need a process to manage the population.

Page 14: Meaningful Use Workgroup

MU Workgroup Recommended Response to Stage 3 NPRM 14

Stage 1 Final Rule Stage 2 NPRM Stage 3 Recommendations

EP MENU: Send preventive or follow-up reminders to more than 20% of all unique patients 65+ years old or 5 years old or younger

EP Objective: Use clinically relevant information to identify patients who should receive reminders for preventive/follow-up care

EP Measure: More than 10% of all unique patients who have had an office visit with the EP within the 24 months prior to the beginning of the EHR reporting period were sent a reminder, per patient preference

EP Objective: Use clinically relevant information to identify patients who should receive reminders for preventive/follow-up careEP Measure: More than 20% of all unique patients who have had an office visit with the EP within the 24 months prior to the beginning of the EHR reporting period were sent a reminder, per patient preference

Discussion: Reluctant to retire this. Prioritize outreach (with respective to CQMs

N/A EH Objective: Automatically track medications from order to administration using assistive technologies in conjunction with an electronic medication administration record (eMAR)

Measure: More than 10% of medication orders created by authorized providers of the eligible hospital's or CAH's inpatient or emergency department (POS 21 or 23) during the EHR reporting period are tracked using eMAR.

EH Objective: Automatically track medications from order to administration using assistive technologies in conjunction with an electronic medication administration record (eMAR)

Measure: 1) More than X% of medication orders created by authorized providers of the eligible hospital's or CAH's inpatient or emergency department (POS 21 or 23) during the EHR reporting period are tracked using eMAR.2)Mismatches are tracked and acted upon. (Do you know about it and design something to act upon it).

Improve Quality Safety, Efficiency and Reducing Health Disparities

Page 15: Meaningful Use Workgroup

MU Workgroup Recommended Response to Stage 3 NPRM 15

Stage 1 Final Rule Stage 2 NPRM Stage 3 Recommendations

N/A Objective: Incorporate imaging results and information into Certified EHR Technology

Menu Measure: More than 40% of all scans and tests whose result is an image ordered by the EP or by an authorized provider of the eligible hospital or CAH for patients admitted to its inpatient or emergency department (POS 21 and 23) during the EHR reporting period are incorporated into or accessible through Certified EHR Technology

Move to core, less prescription of how it is done. Will need to loop back based upon what ends up in Stage 2.

Objective: Incorporate imaging results and information into Certified EHR Technology

Menu Measure: More than 40% of all scans and tests whose result is an image ordered by the EP or by an authorized provider of the eligible hospital or CAH for patients admitted to its inpatient or emergency department (POS 21 and 23) during the EHR reporting period are incorporated into or accessible through Certified EHR Technology

N/A Objective: Record patient family health historyas structured data

Menu Measure: More than 20% of all unique patients seen by the EP or admitted to the eligible hospital or CAH's inpatient or emergency department (POS 21 or 23) during the EHR reporting period have a structured data entry for one or more first-degree relatives or an indication that family health history has been reviewed

HITSC: Is there a mature standard for family history? What about, HL7 Pedigree or SNOMED-CT?

Improve Quality Safety, Efficiency and Reducing Health Disparities

Page 16: Meaningful Use Workgroup

MU Workgroup Recommended Response to Stage 3 NPRM 16

Stage 1 Final Rule Stage 2 NPRM Stage 3 Recommendations

N/A Objective/Measure: Record electronic notes in patient records for more than 30 percent of office visits. While we believe that medical evaluation entries by providers are an important component of patient records that can provide information not otherwise captured within standardized fields, we believe there is evidence to suggest that electronic notes are already widely used by providers of Certified EHR Technology and therefore do not need to be included as a meaningful use objective.

Record electronic notes in patient records for more than _X_ percent of office visits within four calendar days.

Seeking comment.

N/A Hospital Objective: Provide structured electronic lab results to eligible professionals.

Hospital Measure: Hospital labs send (directly or indirectly) structured electronic clinical lab results to the ordering provider for more than 40 percent of electronic lab orders received.

Hospital Objective: Provide structured electronic lab results to eligible professionals. Hospital Measure: Hospital labs send (directly or indirectly) structured electronic clinical lab results to the ordering provider for more than 70 percent of electronic lab orders received.

Objective Not Included - Improve Quality Safety, Efficiency and Reducing Health Disparities

Page 17: Meaningful Use Workgroup

MU Workgroup Recommended Response to Stage 3 NPRM 17MU Workgroup Recommended Response to Stage 3 NPRM 17

Stage 1 Final Rule

Stage 2 NPRM Stage 3 Recommendations

New for Stage 3

New for stage 3 Timely transition document that is available electronically.

New for Stage 3

New for stage 3 Contraindications objective that could include: allergies, adverse reactions, procedural intolerance.

HITSC: Are there standards that currently exist?

Referral from Subgroup 2 to Subgroup 1

Referral from Subgroup 2 to Subgroup 1

Within the PHR, there should be an ability to compare self with other patients, see risk status, understand evidence based care for their own condition is (i.e. diabetic can see that HBA1C is higher than others, links to evidence based therapy). Stage 3 should provide access, future stages have the ability to compare. Provider attests that the PHR that is utilized and has these functionalities.

Health maintenance items that the patient is overdue for are shown to patients.

Referral from subgroup 2: Patient Decision Aids for preference-sensitive care: Under CDS Intervention category: Alert providers to highest value preference sensitive conditions (FIMDM has a list to draw a small number from). Also add measure of capturing and accommodating patient preferences in clinical decision making. Provider decides what clinical decisions this applies to, based on specialty, top conditions in patient populations. Notes: Goal is to ID what care is preference sensitive, what isn’t, and to consider patients values and preferences. An adaptable questionnaire platform could be used to collect patient preferences on a small number of specific conditions (highest value preference sensitive conditions).Should this also be reflected in a CQM? Would be consistent with MU2 approach, if the CQM around decision quality have evolved.

Improve Quality Safety, Efficiency and Reducing Health Disparities

Page 18: Meaningful Use Workgroup

MU Workgroup Recommended Response to Stage 3 NPRM 18MU Workgroup Recommended Response to Stage 3 NPRM 18

Stage 1 Final Rule Stage 2 NPRM Stage 3 Recommendations

New for stage 3 New for stage 3 CDS for appropriateness of lab/rad orders (avoid redundant and inappropriate orders).Tracking of all tests that have been done with the ability to flag important abnormal test results and ensure follow-up (i.e. abnormal PAP, mammogram, IPSA)

New for stage 3 New for stage 3 Medication dose monitoring.

Dose alerts for kidney function, age, and weight.

Duration of medication (i.e. ability to detect a long duration of typical short term medication).

Improve Quality Safety, Efficiency and Reducing Health Disparities

Page 19: Meaningful Use Workgroup

MU Workgroup Recommended Response to Stage 3 NPRM 19

Subgroup 2: Engage Patients and Families

Page 20: Meaningful Use Workgroup

MU Workgroup Recommended Response to Stage 3 NPRM 20

Stage 1 Final Rule Stage 2 NPRM Stage 3 Recommendations

Provide >50% with an electronic copy of their health information

Replaced N/A

Provide >50% with discharge instructions at the time of discharge upon request

Replaced N/A

>10% of unique patients timely electronic access to their health information subject to the EP’s discretion to withhold certain information

Replaced N/A

Engage Patients and Families

Page 21: Meaningful Use Workgroup

21

Stage 1 Final Rule Stage 2 NPRM Stage 3 Recommendations

N/A EP 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.EP Measure: 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 subject to the EP's discretion to withhold certain information2. More than 10 % of all unique patients seen by the EP during the EHR reporting period (or their authorized representatives) view, download , or transmit to a third party their health information

EH Objective: Provide patients the ability to view online and download information about a hospital admissionEH Measure: 1. More than 50 percent of all patients who are discharged from the inpatient or emergency department (POS 21 or 23) of an eligible hospital or CAH have their information available online within 36 hours of discharge 22. More than 10 percent of all patients who are discharged from the inpatient or emergency department (POS 21 or 23) of an eligible hospital or CAH view, download or transmit to a third party their information during the reporting period

Objective: View/Download/Transmit and Report: (including ability to upload or report data into primary place of choice by patient (PHR, Portal, care team member EHR, etc.)

Measure: Provider can choose one or two of these objectives to adopt according to what is most appropriate to their practice

• Provide patients with ability to self-report information such as:1. Family Health History [as per Surgeon General] 2. ODLs [as per standardized tool that is coming out]3. Caregiver status and role [as per DECAF]4. Functional status [as per PROMIS 10]5. Patient-created health goals (needs a standard, also in care summary & plan)6. Medical device: Glucose levels (IEEEE standards plus SNOMED/LOINC #2)7. Medical device: Blood Pressure monitoring (IEEEE standards plus SNOMED/LOINC #2)8. Medical device: Weight monitoring devices/tracking (IEEEE standards plus SNOMED/LOINC #2)NOTE TO Subgroup 1: Self-reporting of adherence to meds, diet, exercise or care plan (THIS IS USUALLY PART OF ODLs)

• Provide 50% of patients the ability to designate to whom and when (i.e. auto blue-button & on-demand) a summary of care document is sent to specific care team members (across settings/providers), and create ability of providers to review/accept updates. Note: Can set a high threshold because auto-blue button is already in existence and summary of care document is already defined and produced. This measure would simply add functionality to this specific piece of medical information. Identify questions for the RFC regarding the legal issues.

• Create capacity to accept pre-visit prep tools into the EHR (e.g., the ability to consent to treatment, fill out administrative forms) (and also could send to other EHRs)Note: Keep as an objective because it is a high priority for the patient. Simply about capacity for Stage 3, no use requirements. Do we refer this to the IE workgroup?

• Offer patients the ability to reconcile information -- correct errors, add addenda Note: Objective is about creating capacity in the EHR and for providers to offer this 10% of their patients. No threshold for percentage of patients that take action or use the capability, but 10% of patients need to be offered ability to reconcile, correct, and amend record.

MU Workgroup Recommended Response to Stage 3 NPRM

Engage Patients and Families

Page 22: Meaningful Use Workgroup

22

Stage 1 Final Rule Stage 2 NPRM Stage 3 Recommendations

Provide clinical summaries for >50% of all office visits within 3 business days

EP Objective: Provide clinical summaries for patients for each office visit

Measure: Clinical summaries provided to patients within 24 hours for more than 50 % of office visits.

The goal is concise and clear access to info about your most recent health and care, in terms patients can use and understand what they can do next, as well as when to call the doctor if certain symptoms/events arise. May need to adapt current requirement post final rule on Stage 2.

MENU: Use certified EHR to identify patient-specific educational resources for >10% of all patients

EP/EH Objective: Use Certified EHR Technology to identify patient-specific education resources and provide those resources to the patient

EP Measure: Patient-specific education resources identified by Certified EHR Technology are provided to patients for more than 10 percent of all office visits by the EP.

EH Measure: More than 10% of all unique patients admitted to the eligible hospital's or CAH's inpatient or emergency departments (POS 21 or 23) are provided patient- specific education resources identified by Certified EHR Technology

NEW: Provide patient specific education materials for 50% of patients. Of those patients who speak one of the top 5 nationally prevalent languages (other than English), 80% of materials must be provided in the language according to patient's preference.

We are seeking comment on 50% & definition of patient-specific education materials.

NOTE: Summary of care document includes patient specific instructions.

Engage Patients and Families

MU Workgroup Recommended Response to Stage 3 NPRM

Page 23: Meaningful Use Workgroup

MU Workgroup Recommended Response to Stage 3 NPRM 23

Stage 1 Final Rule

Stage 2 NPRM Stage 3 Recommendations

N/A Objective: Use secure electronic messaging to communicate with patients on relevant health information

Measure: A secure message was sent using the electronic messaging function of Certified EHR Technology by more than 10 % of unique patients seen during the EHR reporting period

More than 15% of patients use secure electronic messaging to communicate with EPs.

For Certification Rule Only (no use requirements): Create capacity for electronic episodes of care (telemetry devices, etc) and to do e-referrals and e-consults.

Notes: The measure will emphasize building infrastructure to support online consults/visits in Stage 3 and push for more in Stage 4. Not just about billing and consultation. Synchronous or a-synchronous. Make sure that other data needed to support encounter is available from the EHR, and that info generated from the encounter is digestible by the EHR. Make sure the communication is actionable for clinical and billing purposes.Secure messaging may be one of the primary methods, but what other capacities need to be developed?

New for Stage 3 New for Stage 3 Mechanism to identify patient preference for participating in patient-specific opportunities for enrollment in research/clinical trials

MENU: Make a menu item. EHR has capacity to query research enrollment systems using HL7 info-button standard. Certification rule only: No use requirements until Stage 4.

Notes: Create capacity to link patient with research community. If patient wants to identify themselves for enrollment purposes, enable the EHR to flag and report that patient to clinical trial offerings. Cleveland Clinic has done related work. Could ask patient if they want to be alerted to clinical trials relevant to them.

Engage Patients and Families

Page 24: Meaningful Use Workgroup

MU Workgroup Recommended Response to Stage 3 NPRM 24

Stage 1 Final Rule

Stage 2 NPRM Stage 3 Recommendations

N/A EP Objective/Measure: Record patient preferences for communication medium for more than 20 % of all unique patients seen during the EHR reporting period. We believe that this requirement is better incorporated with other objectives that require patient communication and is not necessary as a standalone objective.

Referral from subgroup 1 to discuss patient preference for communication.

More information needed here.

HITPC's intent was to capture a patient's preferred communication method in order for the system to use that media for future non-urgent communication. This respects the patient's wishes and is more efficient for the provider. We recommend that the preferred communication field support multiple message types (e.g., non-urgent clinical, administrative) and preferred media ( e.g., electronic, phone, SMS message).

Objective not included - Engage Patients and Families

Page 25: Meaningful Use Workgroup

MU Workgroup Recommended Response to Stage 3 NPRM 25

• This is the most important domain and is the weakest link when thinking about how to incorporate different vendor records, certification standards will be crucial.

Subgroup 3:Improve Care Coordination

Page 26: Meaningful Use Workgroup

MU Workgroup Recommended Response to Stage 3 NPRM26

Stage 1 Final Rule Stage 2 NPRM Stage 3 Recommendations

Perform at least one test of the capability to exchange key clinical information

Removed for an actual use case Eliminate for Stage 3 in favor of use cases.

MENU: Perform medication reconciliation for >50% of transitions of care in which the patient is transitioned into the care of the EP, eligible hospital, or CAH

EP Objective: The EP who receives a patient from another setting of care or provider of care or believes an encounter is relevant should perform medication reconciliation.

EP Measure: The EP, eligible hospital or CAH performs medication reconciliation for more than 65% of transitions of care in which the patient is transitioned into the care of the EP or admitted to the eligible hospital’s or CAH’s inpatient or emergency department (POS 21 or 23)

EH Objective: The 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

EH Measure: The EP, eligible hospital or CAH performs medication reconciliation for more than 65% of transitions of care in which the patient is transitioned into the care of the EP or admitted to the eligible hospital’s or CAH’s inpatient or emergency department (POS 21 or 23)

EP / EH / CAH Objective: The EP, 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 reconciliation for: - medications- medication allergies-problems

EP / EH / CAH Measure: The EP, EH, or CAH performs reconciliation for medications for more than 50% of transitions of care, and it performs reconciliation for medication, medication allergies, and problems for more than 10% of transitions of care in which the patient is transitioned into the care of the EP or admitted to the eligible hospital’s or CAH’s inpatient or emergency department (POS 21 or 23).

Input from Standards: No accepted standard for reconciling medication lists or contraindications other than existing allergy vocabularies. #3Contraindications objective that could include: allergies, adverse reactions, procedural intolerance

NOTE: There are less data standards surrounding contraindications and intolerances, so we recommend reconciliation for those item objectives in Stage 4. Our intention is to signal to vendors to prepare for incorporating contraindications and intolerances into the EHR.

Improve Care Coordination

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MU Workgroup Recommended Response to Stage 3 NPRM 27

Stage 1 Final Rule

Stage 2 NPRM Stage 3 Recommendations

MENU: Provide a summary of care record for >50% of all transitions and referrals of car

EP Objective: The EP 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.

EH Objective: The 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.

EP/EH /CAH Measure: 1. The EP, eligible hospital, or CAH that transitions or refers their patient to another setting of care or provider of care provides a summary of care record for more than 65 % of transitions of care and referrals.2. The EP, eligible hospital, or CAH that transitions or refers their patient to another setting of care or provider of care electronically transmits a summary of care record using certified EHR technology to a recipient with no organizational affiliation and using a different Certified

EHR Technology vendor than the sender for more than 10 % of transitions of care and referrals.Seeking Comment

EP/ EH / CAH Objective: EP/EH/CAH who transitions their patient to another setting of care or refers their patient to another provider of care - Provide a summary of care record for each transition of care or referral when transition or referral occurs with available information

Measure: The EP, eligible hospital, or CAH that transitions or refers their patient to another setting of care (including home) or provider of care provides a summary of care record for 65% of transitions of care and referrals (and at least 30% electronically).

Certification Criteria: EHR is able to set aside a concise narrative section in the summary of care document that allows the provider to prioritize clinically relevant information such as reason for transition and/or referral.

*Must include the following information for transition of care, and as clinically relevant for referrals: -Concise narrative in support of care transitions (free text that captures reason for referral and/or transition)- Setting-specific goals*- Instructions for care during transition and for 48 hours afterwards*- Care team members, including primary care provider and caregiver name, role and contact info (using DECAF)*

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MU Workgroup Recommended Response to Stage 3 NPRM 28MU Workgroup Recommended Response to Stage 3 NPRM 28

Stage 1 Final Rule

Stage 2 NPRM

Stage 3 Recommendations

New for Stage 3

New for Stage 3

EP/ EH / CAH Objective: EP/ EH/CAH who transitions their patient to another setting of care or refers their patient to another provider of care For each transition of care, provide a care plan with the following elements as applicable:• Medical diagnoses and stages • Functional capabilities, including ODLs*• Social and financial information, including caregiver name, role and contact information• Environmental factors impacting patient’s health• Most likely course of illness or condition, in broad terms (free text)• The care plan team, always including the patient or representative• The patient’s goal(s) for care, including time frame• A specific negotiated plan for achieving goals and meeting challenges, including any specific advance care plan (POLST) and the care setting in which it was executedFor each referral, provide a care plan if one exists

Measure: The EP, eligible hospital, or CAH that transitions or refers their patient to another setting of care or provider of care provides the electronic care plan information for 10% of transitions of care.

NOTE: Our intention was to allow the provider to use discretion in which fields of a care plan to complete.

* = aligned with PE View/Download/Transmit and Report objective

New for Stage 3

New for Stage 3

EP / EH / CAH Objective (new): Provider-to-provider acknowledgment of receipt of external information, as a result of automatic tracking of referral/order status. Must include (but not limited to): • Referral Order Status & Consult reports• Care Record Summary

Measure: For 10% of patients referred during an EHR reporting period, referral results, generated from the EHR, are returned to the requestor (e.g. via scan, via printout, via fax).

NOTE: Intended to use the capabilities of the EHRs to create a closed loop system for tracking of referrals and lab orders. Allows for flexibility of interacting with non-EHR specialists, labs.

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MU Workgroup Recommended Response to Stage 3 NPRM 29

Stage 1 Final Rule Stage 2 NPRM Stage 3 Recommendations

N/A Objective/Measure: Record health care team members (including at a minimum PCP, if available) for more than 10 percent of all patients seen during the reporting period; this information can be unstructured. We believe that this requirement is better incorporated with other objectives that require summary of care documents and is not necessary as a standalone objective.

Added into care summary

N/A Objective/Measure: Record care plan goals and patient instructions in the care plan for more than 10 percent of patients seen during the reporting period. We believe that this requirement is better incorporated with other objectives that require summary of care documents and is not necessary as a standalone objective.

Added into care summary

Objectives Not Included - Improve Care Coordination

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MU Workgroup Recommended Response to Stage 3 NPRM 30

Subgroup 4: Improve Population and Public Health

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MU Workgroup Recommended Response to Stage 3 NPRM 31

Stage 1 Final Rule Stage 2 NPRM Stage 3 Recommendations

MENU: Perform at least one test of the capability to submit electronic data to immunization registries

Objective: Capability to submit electronic data to immunization registries or immunization information systems except where prohibited, and in accordance with applicable law and practice

Measure: Successful ongoing submission of electronic immunization data from Certified EHR Technology to an immunization registry or immunization information system for the entire EHR reporting period

EP/EH Objective (Modify): Add submission of vaccine contraindication(s) and/or reason(s) for substance refusal to the current objective/measure of successful ongoing immunization data submission to registry/immunization information systems.

EP/ EH Objective (New): Capability to access and review a patient’s immunization history supplied by an immunization registry/immunization information system, and to enable healthcare professionals to use structured historical immunization events in the clinical workflow, except where prohibited, and in accordance with applicable law and practice.

Measure: Documentation of timely and successful electronic access and review by the Certified EHR Technology of vaccine history (including null results) from an immunization registry or immunization information system for 30% of patients who received immunizations from the EP/EH during the entire EHR reporting period.

Certification criteria: EHR is able to receive and present a standard set of structured, externally-generated, immunization history and capture the act and date of review within the EP/EH practice.

Exclusion: EPs and EHs that administer no immunizations or jurisdictions where immunization registries/immunization information systems cannot provide electronic immunization histories.

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MU Workgroup Recommended Response to Stage 3 NPRM 32

Improve Population and Public Health

Stage 1 Final Rule

Stage 2 NPRM Stage 3 Recommendations

New for Stage 3

New for Stage 3 EP/EH Objective (New): Capability to receive, generate or access appropriate age- gender- and immunization history-based recommendations (including immunization events from immunization registries/immunization information systems) as applicable by local or state policy.

Measure: Implement an immunization recommendation system that: 1) establishes baseline recommendation (e.g., Advisory Committee on Immunization Practices), 2) allows for local/state variations, and 3) accounts for contraindications and patient preferences (e.g., substance refusal). For 20% of patients receiving an immunization, the EP/EH practice reviews the recommendation before giving an immunization.

Certification criteria: EHR uses a standard (e.g., national, state and/or local) rule set, plus patient age, gender, and prior immunization history to recommend administration of immunizations; capture the act and date/time of recommendation review. Exclusion: EPs and EHs that administer no immunizations.

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MU Workgroup Recommended Response to Stage 3 NPRM 33

Stage 1 Final Rule Stage 2 NPRM Stage 3 Recommendations

Perform at least one test of the capability to submit electronic data on reportable lab results to public health agencies and actual submission in accordance with applicable law and practice

EH Objective: Capability to submit electronic reportable laboratory results to public health agencies, except where prohibited, and in accordance with applicable law and practice

Measure: Successful ongoing submission of electronic reportable laboratory results from Certified EHR Technology to public health agencies for the entire EHR reporting period as authorized, and in accordance with applicable State law and practice.

EH Objective (unchanged): No change from current requirement for electronic lab reporting which generally is sent from the laboratory information system

EH/EP Objective (new): Capability to access or receive and incorporate external data from the CDC/Council of State and Territorial Epidemiologists (CSTE) maintained Reportable Conditions Knowledge Management System (RCKMS) for appropriate criteria by which the Certified EHR is triggered to generate a standardized case report.

Measure: Documentation of successful electronic access or receipt and incorporation of jurisdiction specific knowledge into the Certified EHR Technology.

Certification criteria: EHR is able to access or receive and incorporate a standard set of external data specific to the jurisdiction(s) of interest.

Exclusion: where local or state health departments are incapable of receiving these standardized case reports

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MU Workgroup Recommended Response to Stage 3 NPRM 34

Improve Population and Public Health

Stage 1 Final Rule Stage 2 NPRM Stage 3 Recommendations

New for Stage 3 New for Stage 3 EP Objective (new): Capability to use externally accessed or received knowledge (e.g. reporting criteria) to determine when a case report should be reported and then submit the initial report to a public health agency, except where prohibited, and in accordance with applicable law and practice.

Measure: Attestation of submission of standardized initial case reports to public health agencies on 20% of all reportable disease or conditions during the entire EHR reporting period as authorized, and in accordance with applicable state/local law and practice.

Certification criteria: The EHR uses external data to prompt the end-user when criteria are met for case reporting. The date and time of prompt is available for audit. Standardized (e.g., consolidated CDA) case reports are submitted to the state/local jurisdiction and the data/time of submission is available for audit

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MU Workgroup Recommended Response to Stage 3 NPRM 35

Stage 1 Final Rule Stage 2 NPRM Stage 3 Recommendations

Perform at least one test of the capability to submit electronic syndromic surveillance data to public health agencies and actual submission in accordance with applicable law and practice

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

EP MENU Measure: Successful ongoing submission of electronic syndromic surveillance data from Certified EHR Technology to a public health agency for the entire EHR reporting period

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

EH CORE Measure: Successful ongoing submission of electronic syndromic surveillance data from Certified EHR Technology to a public health agency for the entire EHR reporting period

EH/EP Objective (New, pending Stage 2 Rule): Capability to electronically participate and send standardized, commonly formatted reports to a mandated jurisdictional registry (e.g., cancer, children with special needs, and/or early hearing detection and intervention) from Certified EHR to either local/state health departments, except where prohibited, and in accordance with applicable law and practice. This objective is in addition to prior requirements for submission to an immunization registry.

Measure: Documentation of ongoing successful electronic transmission of standardized reports from the Certified EHR Technology to the jurisdictional registry. Attestation of submission for at least 20% of all patients who meet registry inclusion criteria during the entire EHR reporting period as authorized, and in accordance with applicable State law and practice.

Certification criteria: EHR is able to build and then send a standardized report (e.g., standard message format) to an external mandated registry, maintain an audit of those reports, and track total number of reports sent.

Exclusion: Where local or state health departments have no mandated registries or are incapable of receiving these standardized reports

Improve Population and Public Health

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MU Workgroup Recommended Response to Stage 3 NPRM 36

Improve Population and Public Health

Stage 1 Final Rule Stage 2 NPRM Stage 3 Recommendations

N/A EP Objective: Capability to identify and report cancer cases to a State cancer registry, except where prohibited, and in accordance with applicable law and practice.

EP Menu Measure: Successful ongoing submission of cancer case information from Certified EHR Technology to a cancer registry for the entire EHR reporting period

EH/EP Objective (New, pending Stage 2 Rule): Capability to electronically participate and send standardized, commonly formatted reports to a mandated jurisdictional registry (e.g., cancer, children with special needs, and/or early hearing detection and intervention) from Certified EHR to either local/state health departments, except where prohibited, and in accordance with applicable law and practice. This objective is in addition to prior requirements for submission to an immunization registry.

Measure: Documentation of ongoing successful electronic transmission of standardized reports from the Certified EHR Technology to the jurisdictional registry. Attestation of submission for at least 20% of all patients who meet registry inclusion criteria during the entire EHR reporting period as authorized, and in accordance with applicable State law and practice.

Certification criteria: EHR is able to build and then send a standardized report (e.g., standard message format) to an external mandated registry, maintain an audit of those reports, and track total number of reports sent.

Exclusion: where local or state health departments have no mandated registries or are incapable of receiving these standardized reports

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MU Workgroup Recommended Response to Stage 3 NPRM 37

Stage 1 Final Rule

Stage 2 NPRM Stage 3 Recommendations

N/A EP Objective: Capability to identify and report specific cases to a specialized registry (other than a cancer registry), except where prohibited, and in accordance with applicable law and practice.

EP Menu Measure: Successful ongoing submission of specific case information from Certified EHR Technology to a specialized registry for the entire EHR reporting period

EP Objective (New, pending Stage 2 Rule): Capability to electronically submit standardized reports to an additional registry beyond any prior meaningful use requirements (e.g., immunizations, cancer, early hearing detection and intervention, and/or children with special needs). Registry examples include hypertension, diabetes, body mass index, devices, and/or other diagnoses/conditions) from the Certified EHR to a jurisdictional, professional or other aggregating resources (e.g., HIE, ACO), except where prohibited, and in accordance with applicable law and practice.

Measure: Documentation of successful ongoing electronic transmission of standardized (e.g., consolidated CDA) reports from the Certified EHR Technology to a jurisdictional, professional or other aggregating resource. Attestation of submission for at least 20% of all patients who meet registry inclusion criteria during the entire EHR reporting period as authorized, and in accordance with applicable state/local law and practice.

Certification criteria: EHR is able to build and send a standardized message report format to an external registry, maintain an audit of those reports, and track total number of reports sent.

Exclusion: where local or state health departments or other agencies are incapable of receiving these standard reports

New for Stage 3

New for Stage 3 • Referral to Subgroup 1: Data such as occupation and industry codes should be additional Stage 3 demographic data. These data have enormous public health significance and where appropriate or mandated should be shared with public health agencies regarding case reports (e.g., food-borne disease), syndromic surveillance, and specialized registries (e.g., respiratory diseases).

Certification criteria: The EHR should be able also to store the provenance (e.g., from the patient or caregiver) for patient-generated data.

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MU Workgroup Recommended Response to Stage 3 NPRM 38

Improve Population and Public HealthStage 1 Final Rule Stage 2 NPRM Stage 3 Recommendations

New for Stage 3

New for stage 3 EH Objective (new): Capability to electronically send standardized Healthcare Associated Infection (HAI) reports to the National Healthcare Safety Network (NHSN) using a common format from the Certified EHR, except where prohibited, and in accordance with applicable law and practice. (This might be a clinical quality measure).

Measure: Documentation of successful electronic transmission of standardized healthcare acquired infection reports to the NHSN from the Certified EHR Technology. Total numeric count of HAI in the hospital and attestation of Certified EHR electronic submission of at least 20% of all reports during the entire EHR reporting period as authorized, and in accordance with applicable State law and practice.

Certification criteria: EHR is able to sending a standard HAI message to NHSN, maintain an audit and track total number of reports sent.

Exclusion: None anticipated. Any healthcare facility accredited by JCAHO would need to report these measures.

New for Stage 3

New for stage 3 EH/EP Objective (new): Capability to electronically send adverse event reports (e.g., vaccines, devices, EHR, drugs or biologics) to the Federal Drug Administration (FDA) and/or Centers for Disease Control and Prevention (CDC) from the Certified EHR, except where prohibited, and in accordance with applicable law and practice.

Measure: Attestation of successful electronic transmission of standardized adverse event reports to the FDA/CDC from the Certified EHR Technology. Total numeric count (null is acceptable) of adverse event reports from the EH/EP submitted electronically during the entire EHR reporting period as authorized, and in accordance with applicable State law and practice.

Certification criteria: EHR is able to build and send a standardized adverse event report message to FDA/CDC and maintain an audit of those reports sent to track number of reports sent

Exclusion: None.

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Review of Subgroup Total Objectives

Subgroup 1: Improve Quality

• 27 Objectives

Subgroup 2: Engage Patients & Families

• 11 Objectives

Subgroup 3: Care Coordination

• 7 Objectives

Subgroup 4: Population Health

• 11 Objectives