“modified stage 2” meaningful use in 2016 · meaningful use support security risk assessment...
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5/16/2016 1
“Modified Stage 2”Meaningful Use in 2016
Bruce Maki, MAM-CEITA / Altarum Institute
Regulatory & Incentive Program Analyst
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Agenda
1. Overview of M-CEITA
2. “Modified Stage 2”: Meaningful Use in 2016
3. PQRS Basics
4. Questions & Answers
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Who is M-CEITA?
▲ Michigan Center for Effective Information Technology Adoption (M-CEITA)
▲ One of 62 ONC Regional Extension Centers (REC) providing education & technical assistance to primary care providers across the country
▲ Founded as part of the HITECH Act to accelerate the adoption, implementation, and effective use of electronic health records (EHR), e.g. 90-days of MU
▲ Originally Funded by ARRA of 2009 (Stimulus Plan)
▲ Purpose: support the Triple Aim by achieving 5 overall performance goals
Meaningful Use
Improve
Quality, Safety &
Efficiency
Performance Measurement
Certified Technology Infrastructure
Engage
Patients &
Families
ImproveCare
Coordi-nation
ImprovePopulation
AndPublicHealth
EnsurePrivacy
AndSecurity
Protections
Improve patient experience
Improve population health
Reduce costs3THE TRIPLE AIM
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Meaningful Use Support
Security Risk Assessment
Targeted Process Optimization (Lean)
Audit Preparation
M-CEITA Services
Technical assistance, including workflow redesign, security risk assessment and MU compliance. (e.g. patient portal and clinical quality measures)
Support meeting the requirements of MU Measure: Protect Electronic Health Information, including an assessment using our exclusive tool.
A workflow analysis and redesign of core processes using Lean principles to increase efficiency and reduce duplication. (e.g. chart prep, doc. Management)
A review of Meaningful Use attestation documentation using our exclusive Audit File Checklist to correct any issues before completing the process.
PQRS SupportTechnical Assistance for the Physician Quality Reporting System including
measure selection as well as reporting method selection and assistance.
GLPTN - Great Lakes Practice Transformation NetworkNo cost Technical Assistance to eligible providers in support of quality
improvement initiatives, PQRS support, and preparing for upcoming advanced payment model changes under MACRA/MIPS
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“Modified Stage 2”
Summary of Objectives and Measures for
Eligible Professionals (EPs)
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MIPS: Merit-Based Incentive Payment System
Beginning in 2017, providers will be annually
measured in 4 performance categories:
• Meaningful Use (proposed rename: “Advancing
Care Information”)
• Value Based Modifier for Cost
• PQRS & Value Base Modifier for Quality
• Clinical Practice Improvement
These programs make up 85% of the MIPS score.
The best thing an organization can do to
prepare is improve on these programs NOW.
Meaningful Use IS expected to change again under MACRA/MIPS, but it is not
going away. Also, the pending changes will affect the Medicare MU program but
not necessarily the Medicaid MU program currently scheduled to end in 2021.
Meaningful Use is not dead!
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▲ Released: October 6, 2015
▲ Published: October 16, 2015
▲ Effective: December 15, 2015
▲ Medicare EPs could attest to a 2015 reporting period in the Federal RAS between 1/4/16 – 3/11/16
▲ Medicaid EPs could attest to a 2015 reporting period in CHAMPS/eMIPP between 2/14/16 – 4/30/16
▲ Medicaid EPs can begin attesting to a 2016 Meaningful Use reporting period as of 6/1/16
Medicare and Medicaid Programs; Electronic Health Record Incentive Program—Stage 3 and Modifications
to Meaningful Use in 2015 Through 2017 Final Rule with Comment Period
(aka Modified Stage 2 / Stage 3 Final Rule)
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Key changes in the Modified Stage 2 Rule
▲ Stage 1 and Stage 2 objectives and measures restructured to align with Stage 3
▲ Streamlined the program by removing redundant, duplicative, and topped out (RDT) measures
▲ One set of objectives and measures for all participants. No more menu set to choose from
▲ Patient engagement objectives that require “patient action” are modified
▲ Limited accommodations for Stage 1 EPs in 2016 (CPOE)
▲ Significant changes to the Public Health objective
▲ Optional “Alternate Exclusions” added to Public Health
– No proof of intent/documentation required to claim Alt Exclusions
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Meaningful Use Progression for EPs
2011 -2013
20142015 -2017
2018
Stage 1
15 Core
5 Menu
6 CQMs
Stage 1
13 Core
5 Menu
9 CQMs
Stage 2
17 Core
3 Menu
9 CQMs
Modified Stage 2
10 Objectives
9 CQMs
Stage 3
Optional: 2017
8 Objectives,
some with
lowered
thresholds
Stage 3
8 Objectives
CQM reporting
is required by
regulations;
Medicare PFS
rulemaking to
address
reporting
requirements
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Reporting Periods
▲ 2016– New Participants: Any continuous 90 days within the CY
– Returning Participants: Full Calendar Year (366 days)
▲ 2017– New Participants: Any continuous 90 days within the CY
– Providers electing Stage 3: Any continuous 90 days within the CY (requires EHR technology certified to the new 2015 standards)
– Returning Participants: Full Calendar Year (365 days)
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Measures removed under Modified Stage 2 (…but “Still Meaningful”)
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Gone…but “Still Meaningful” (cont’d)
▲ Many of these objectives and measures include actions that may be valuable to providers and patients, such as providing a clinical summary to a patient
▲ Conduct these activities as best suits the practice and the preferences of the patient population
▲ The removal is not intended as a withdrawal of an endorsement for these best practices or to discourage providers from conducting and tracking these activities for their own quality improvement goals
▲ No longer required to separately calculate and attest to the results of these measures for MU
▲ Some of the removed measures contain data elements that are still needed within other measures such as Patient Electronic Access (patient portal) and Health Information Exchange (Summary of Care) or are needed to calculate various Clinical Quality Measures
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2016 Requirements
▲ In addition to meeting the measures or exclusions for the remaining 10 objectives, as in previous years, all EPs have to report on Clinical Quality Measures.
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“Modified Stage 2” Meaningful Use Objectives:
1. Protect Patient Health Information (SRA)
2. Clinical Decision Support Interventions (CDS) (2 measures)
3. Computerized Provider Order Entry (CPOE) (3 measures)
4. Electronic Prescribing (eRx)
5. Health Information Exchange (formerly Summary of Care)
6. Patient Specific Education
7. Medication Reconciliation
8. Patient Electronic Access (VDT/Pt Portal) (2 measures)
9. Secure Electronic Messaging
10. Public Health Reporting (3 measures)
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Objective 1: Protect Patient Health Information (SRA – Security Risk Analysis)
Measure Threshold Exclusion
Conduct or review a security risk analysis in accordance with the requirements in 45 CFR 164.308(a)(1), including addressing the security (to include encryption) of ePHI created or maintained in CEHRT in accordance with requirements under 45 CFR 164.312(a)(2)(iv) and 45 CFR 164.306(d)(3), and implement security updates as necessary and correct identified security deficiencies as part of the EP’s risk management process
Y/N N/A
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Security Risk Analysis (cont’d)
▲ Not an "episodic" item related only to a snapshot in time; should cover the entirety of the year for which the SRA or review is conducted
▲ Acceptable for the SRA to be conducted outside the EHR reporting period if the reporting period is < CY
▲ Must be conducted within the same CY as the EHR reporting period; if the provider attests prior to the end of the CY, it must be conducted prior to the date of attestation
▲ Each EP is individually responsible for his/her own attestation and for independently meeting the objective. It is incumbent on each individual EP to ensure that any SRA or review conducted for the group is relevant to and fully inclusive of any unique implementation or use of CEHRT relevant to his/her individual practice
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Objective 2: Clinical Decision Support
Measure Threshold Exclusion
Measure 1: Implement 5 CDS interventions related to 4 or more CQMs at a relevant point in patient care for the entire reporting period (RP). Absent 4 CQMs related to an EPs scope of practice or patient population, the CDS interventions must be related to high-priority health conditions
Y/N N/A
Measure 2: The EP has enabled and implemented the functionality for drug/drug and drug/allergy interaction checks for the entire RP
Y/NEP who writes < 100 medication orders
during the RP
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Objective 3: Computerized Provider Order Entry (CPOE)
Measure Threshold Exclusion
Measure 1: > 60% of medication orders created by the EP during the RP are recorded using CPOE
> 60%EP who writes < 100 medication
orders during the RP
Measure 2: > 30% of laboratory orders created by the EP during the RP are recorded using CPOE
> 30%
EP who writes < 100 laboratory orders during the RP
Alternate Exclusion: 2016 S1 EPs may claim an exclusion
Measure 3: > 30% of radiology orders created by the EP during the RP are recorded using CPOE
> 30%
EP who writes < 100 radiology orders during the RP
Alternate Exclusion: 2016 S1 EPs may claim an exclusion
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Objective 4: Electronic Prescribing (eRX)
Measure Threshold Exclusion
> 50% of all permissible prescriptions written by the EP are queried for a drug formulary* & transmitted electronically using CEHRT
> 50%
EP who writes < than 100 medication orders during the RP or does not have a pharmacy within his or her organization and there are no pharmacies that accept electronic prescriptions within 10 miles of the EP's practice location at the start of the RP
* Note they must be queried against a drug formulary to count!
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Objective 5: Health Information Exchange (HIE)
Measure Threshold Exclusion
EP that transitions or refers their patient to another setting of care or provider of care must (1) use CEHRT to create a summary of care (SOC) record; and (2) electronically transmit such summary to a receiving provider for > 10% of transitions of care (TOC) and referrals
> 10%
EP who transfers a patient to another setting or refers a
patient to another provider < 100 times during the RP
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Objective 5: HIE (cont’d)
▲ Options for counting a transition in the numerator:
– EP must generate the Summary of Care (SoC) document from CEHRT and must electronically transmit it to the receiving EP via Direct
OR
– EP can now electronically transmit to a Health Information Exchange (HIE) who can then USE ANY MEANS available to route the SoC document to the receiving provider
HIE does not need to use CEHRT to deliver to receiving provider
HIE can use ANY available means to deliver the SoC document
Proof of receipt (“reasonable certainty”) is still required by the sending provider but this too can use non-tech methods. Onus is on HIE to provide this.
– The issue here is that transmitting the SoC document to an HIE will likely NOT trigger the EHR MU measure report; thus this change may necessitate manually tracking
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Objective 6: Patient Specific Education
Measure Threshold Exclusion
Patient specific education resources identified by CEHRT are provided to patients for > 10% of all unique patients with office visits seen by the EP during the RP
> 10%EP who has no office visits
during the RP
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Objective 7: Medication Reconciliation
Measure Threshold Exclusion
The EP performs medication reconciliation for > 50% of TOC in which the patient is transitioned into the care of the EP
> 50%EP who was not the recipient
of any transitions of care during the RP
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Objective 8: Patient Electronic Access (VDT)
Measure Threshold Exclusion
Measure 1: > 50% of all unique patients seen by the EP during the RP are provided timely access to view online, download, and transmit (VDT) to a third party their health information subject to the EP's discretion to withhold certain information
> 50%
EP who neither orders nor creates any of the information listed for inclusion as part of the measures except for Patient Name and Provider’s Name and office
contact information
Measure 2 (2016): At least one patient (or PAR) seen by the EP during the RP VDTs his or her health information during the RP
1 Patient
EP who (a) Neither orders nor creates any of the information listed for
inclusion as part of the measures; or (b) Conducts 50 percent or more of his or her patient encounters in a county that does not have 50 percent or more of its
housing units with 4Mbps broadband availability according to the latest
information available from the FCC on the first day of the reporting period
Measure 2 (2017): > 5% of unique patients (or PARs) seen by the EP during the reporting period VDTs their health information during the reporting period
> 5%
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Objective 9: Secure Electronic Messaging
Measure Threshold Exclusion
2016: At least 1 patient seen by the EP during the RP, a secure message was sent using the electronic messaging function of CEHRT to the patient (or PAR), or in response to a secure message sent by the patient (or PAR) during the RP
1 Patient
Any EP who has no office visits during the RP, or any EP who
conducts 50 percent or more of his or her patient encounters in a
county that does not have 50 percent or more of its housing units with 4Mbps broadband
availability according to the latest information available from the FCC on the first day of the RP
Alternate Exclusion: 2015 S1 EP may claim an exclusion
2017: For > 5% of unique patients seen by the EP during the RP, a secure message was sent using the electronic messaging function of CEHRT to the patient (or PAR), or in response to a secure message sent by the patient (or PAR) during the RP
> 5%
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Objective 10: Public Health Reporting
Measure Exclusion
Measure Option 1: Immunization Registry Reporting – The EP is in active engagement with a public health agency to submit immunization data
MI EPs: Does not administer any immunizations for which data is collected by the immunization registry
Measure Option 2: Syndromic Surveillance Reporting – The EP is in active engagement with a public health agency to submit syndromic surveillance data
MI EPs in Non-Urgent Care Settings: Is not in a category of providers from which ambulatory syndromic data is
collected by the PHA
Measure Option 3: Specialized Registry Reporting – The EP is in active engagement to submit data to a qualified specialized registry
EP (a) does not diagnose/treat any disease/condition associated with, or collect relevant data that is collected
by, a specialized registry in their jurisdiction during the RP; (b) operates in a jurisdiction for which no specialized
registry is capable of accepting electronic registry transactions in the specific standards required to meet the CEHRT definition at the start of the RP; or (c) operates in a jurisdiction where no specialized registry for which the EP
is eligible has declared readiness to receive electronic registry transactions at the beginning of the RP
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Public Health Reporting (cont’d)
▲Alternate Exclusions for 2016:
– EPs previously scheduled to be in Stage 1 or Stage 2
May claim an Alternate Exclusion for Measure 2 (Syndromic Surveillance) and Measure 3 (Specialized Registry)
An Alternate Exclusion may only be claimed for up to two measures, then the provider must either attest to or meet the exclusion requirements for the remaining measure described in 495.22 (e)(10)(i)(C)
▲Another Option for Syndromic Surveillance in 2016:
To accommodate EPs struggling to find and register with an alternate registry, MSSS has agreed to allow EPs who were Actively Engaged on 12/31/15 to maintain that status through 12/31/16 with no additional work/submissions/onboarding needed from the EP
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Public Health (cont’d)
▲Active Engagement =
Option 1 – Completed Registration to Submit Data
The EP, eligible hospital or CAH registered to submit data with the PHA or, where applicable, the organization to which the information is being submitted; registration was completed within 60 days after the start of the EHR reporting period; and the EP, eligible hospital, or CAH is awaiting an invitation to begin testing and validation.
Option 2 – Testing and Validation
The EP, eligible hospital, or CAH is in the process of testing and validation of the electronic submission of data.
Option 3 – Production
The EP, eligible hospital, or CAH has completed testing and validation of the electronic submission and is electronically submitting production data.
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Objective 10: Public Health Measure 3 Specialized Registry Reporting:
▲ To qualify as a “MU valid” specialized registry in 2016, the registry must do the following:
1. Publically declare readiness to accept electronic data (by 1st day of RP)
– Failure to declare by 1st day of EP reporting period does not mean EP cannot use registry to achieve MU in that program year. Instead, it creates an option.
2. Be able to accept electronic submissions – manual data entry into a website does not count, but an electronic file upload would
3. Be able to support the registration/onboarding and production processes
4. Be able to provide documentation to EP as evidence of active engagement
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What obligations do EPs have for finding a Specialized Registry for 2016?
▲ Determine if the specialized registries offered by a Public Health Agency (PHA) in MI are relevant to the provider’s scope of practice
Birth Defects Registry
Cancer Registry (must have EHR certified to Cancer reporting standards)
MiDR: Michigan’s Dental Registry (did not declare readiness by 1/1/16, thus consideration is optional until 2017)
▲ Determine if a Medical Society with which the provider is affiliated endorses or sponsors a MU valid specialized registry
▲ If no to both, EP can claim the “regular” exclusion in 2016
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Clinical Quality Measures (CQMs)
▲2016 and 2017
– New Participants
Any continuous 90 days w/in CY
Does not need to be same as MU 90 days
Attest through Medicare RAS or Medicaid eMIPP
Or attest using established methods for electronic reporting
– Returning Participants
Full Calendar Year
Attest through Medicare RAS or Medicaid eMIPP
Or attest using established methods for electronic reporting
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Resources
Final Rule: http://federalregister.gov/a/2015-25595
2016 Tipsheet: https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/2016_EPWhatYouNeedtoKnowfor2016.pdf
Modified Stage 2 Tipsheet: https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/Stage3Overview2015_2017.pdf
2016 Program Requirements and additional tools: https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/2016ProgramRequirements.html
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PQRS Basics
Physician Quality Reporting System
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What is PQRS?
▲ “The Physician Quality Reporting System (PQRS) is a quality reporting program that encourages individual eligible professionals (EPs) and group practices to report information on the quality of care to Medicare. PQRS gives participating EPs and group practices the opportunity to assess the quality of care they provide to their patients, helping to ensure that patients get the right care at the right time”
▲ PQRS uses payment adjustments to promote reporting of clinical quality information by EPs
▲ Program year 2014 was the last year to earn an incentive
▲ Beginning with the 2015 program year, there are no longer incentives for participation, only adjustments for non-compliance
▲ PQRS reporting period is a full calendar year of data
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Who is Eligible?
▲ If an EP bills Medicare Part B on a CMS 1500 form, or electronic equivalent for services on the Medicare Physician Fee Schedule (PFS), s/he is eligible to participate
▲ Only Traditional Medicare Part B & Railroad Medicare Part B Physician Fee Schedule charges are reported for the purposes of the program
Includes
Advanced
Practice
Registered
Nurse (APRN)
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▲ EPs who render services under Medicare Part B PFS via CMS-1500 or CMS-1450 claim are able to participate in PQRS regardless of the organization’s participation in other fee schedules or methodologies.
▲ For example, an EP who bills under an organization that is registered as a federally qualified health center (FQHC), yet (s)he renders services that are not covered by the FQHC methodology.
▲ Non-participating (Non-PAR) providers (meaning they do not accept assignment) can participate in PQRS.
▲ Professionals who reassign benefits to a Critical Access Hospital (CAH) that bills professional services at a facility level (Method II billing), can participate. To do so, the CAH must include the individual provider NPI on their Institutional (FI) claims.
Who is Eligible? (con’t)
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▲ 2016 PQRS List of Eligible Professionals
▲ If you need assistance determining whether or
not services are rendered under the Medicare
Part B Physician Fee Schedule via the 1500 or
1450 claim form, contact your Medicare
Administrative Contractor (MAC).
Who is Eligible? (con’t)
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PQRS Reporting Options
▲ Individual Reporting Option: Identified on claims by an individual NPI and TIN
– All providers participate as Individual Eligible Professionals
– Select measures separately for each provider
– No registration required
▲ Group reporting option (GPRO): A single TIN with 2 or more individual EPs who have reassigned their billing rights to the TIN (2 or more EPs billing under same TIN)
– Must have an EIDM account to register as GPRO
– Must indicate the reporting mechanism for 2016
– Register between April 1, 2016 and June 30, 2016 (11:59 pm EDT)
▲ NOTE: Even if not needed to register/report, you must have an EIDM account to access QRUR (Quality & Resource Use) reports
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Individual Provider Reporting Options
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*Note: CAHPS for PQRS survey is required for PQRS group practices of 100+ EPs
Group Reporting Options
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Why Should You Report PQRS?
▲ PQRS Payment Adjustments: Providers are already seeing negative payment adjustments in their Medicare Part B reimbursement as a result of not reporting. Reporting in 2016 affects payments in 2018. 2% penalty to Medicare Part B FFS reimbursement in 2018 for non-reporters
▲ Value Based Modifier (VBM): In addition to PQRS Adjustment. TBD for 2018, based on 2016 performance year
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Why Should You Report PQRS? (Con’t)
▲ Merit-Based Incentive Payment System (MIPS): The program is set to begin in performance year 2017, with subsequent positive or negative payment adjustments in payment year 2019
▲ Physician Compare Website: Results are publicly reported
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RESOURCES
▲ 2016 PQRS Claims Reporting Made Simple
▲ 2016 PQRS Measures List
▲ 2016 Cross-Cutting Measures List
▲ 2016 PQRS List of Face-To-Face Encounter Codes
▲ 2016 PQRS: Registry Reporting Made Simple
▲ 2016 PQRS Measures Groups Specifications Supporting Documents
