florida’s medicaid ehr incentive program · florida’s medicaid ehr incentive program overview...
TRANSCRIPT
August 2, 2016
Kim Davis-Allen
Outreach Coordinator
Florida’s Medicaid EHR Incentive Program
Overview of Modified Stage 2
August 2, 2016
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August 2, 2016
Program Year (PY) 16 is the Last Year to Begin Program Participation
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Important Note
August 2, 2016
General Requirement #1• 50% of encounters during EHR/MU reporting period must be
at locations equipped with CEHRT
• Encounter numbers must be entered into the on-line application (MAPIR)
• If practicing at more than one location, complete #1 on the Additional Documentation form
• Prepayment verification will validate practicing at more than one location using claims data
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August 2, 2016
General Requirement #1 cont . . .• How do I know what to enter?
– Run an encounter report for the EHR reporting period
– If using individual volume from same reporting period and only work at one practice• Volume denominator = encounter numerator and denominator
– If practicing at multiple locations• Determine availability of CEHRT
• If yes, add to both numerator and denominator
• If no, add to denominator only
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August 2, 2016
General Requirement #2• 80% of unique patients seen at locations with CEHRT must
have their records in CEHRT– Prepayment verification compares to MU report for measures
with Unique Patients denominator e.g. Patient Electronic Access
• If audited, will have to provide a detailed report of all unique patients to verify
• Patients seen during the EHR reporting period but not in the CEHRT must be added to the denominator
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Practicing at More Than One Location• CMS Tip Sheet https://www.cms.gov/Regulations-and-
Guidance/Legislation/EHRIncentivePrograms/Downloads/EP_MultipleLocationsTipsheet.pdf
• Calculating 50% of encounters at locations with CEHRT– Patient encounter is any encounter where medical treatment and/or
evaluation and management services are provided. E&M are billing codes for office visits.
– Encounters at hospital inpatient and emergency department are excluded.
• Calculating Meaningful Use– Must get reports from locations with CEHRT and add numerators and
denominators– If unable to get a MU report, must include patients seen during the
reporting period in the denominator. FAQ 7815
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August 2, 2016
Overview of Modified Stage 2
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• Eligible Professionals (EPs) are required to attest to a single set of objectives and measures
• EPs must attest using 2014 Certified Electronic Health Record Technology (CEHRT)
• Modified Stage 2 Objectives– Protect Electronic Health Information – Clinical Decision Support – Computerized Provider Order Entry (CPOE) – E-Prescribing (eRx) – Health Information Exchange– Patient Specific Education – Medication Reconciliation – Patient Electronic Access – Secure Electronic Messaging – Public Health Reporting
August 2, 2016
Meaningful Use Participation Timeline
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• 2015: All Providers 90 days– Attest to modified version of Stage 2 with alternative
measures/exclusions for providers in their first or second reporting year
• 2016: 1st year 90 days; all other full year– Attest to modified version of Stage 2– Certain measures still have alternative measures/exclusions for
providers in their first or second reporting year
• 2017: 1st year 90 days; all other full year– Attest to modified version of Stage 2 or Stage 3
• 2018: 1st year 90 days; all other full year– Attest to Stage 3
August 2, 2016
Applying Modified Stage 2PY15 Reporting
• If PY15 is the first or second year of reporting MU
– aka Stage 1– Attest to alternate measures and
exclusions– 90 day reporting period
• If PY15 is the third or later year of reporting MU
– aka Stage 2– Select alternate measures and
exclusions– 90 day reporting period
PY16 Reporting
• If PY16 is the first year of reporting MU – aka Stage 1– Select alternate measures and
exclusions– 90 day reporting period
• If PY16 is the second year of reporting MU
– aka Stage 1– Select alternate measures and
exclusions– Full year reporting period
• If PY16 is the third or later year of reporting MU
– aka Stage 2– Select alternate measures and
exclusions– Full year reporting period
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Protect Patient Health Information• Measure: Conduct or review a security risk analysis in
accordance with the requirements 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
• Exclusion: None
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August 2, 2016
Protect Patient Health Information –Additional Information• Timing
– Can occur before, during or after the meaningful use reporting period (CMS FAQ# 13649) but must be performed before attestation
– Analysis must cover the full EHR reporting period
– An EP cannot use the same Security Risk Analysis (SRA) for more than one program year
– Documentation must include an asset inventory and the final report
– A copy must be uploaded with the application• Acceptance of the uploaded document does not guarantee it will be acceptable in an audit
– Asset inventory lists where Protected Health Information (PHI) comes in, is stored, and is transmitted out
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August 2, 2016
Clinical Decision Support• Measure 1: Implement five clinical decision support interventions
related to four or more clinical quality measures at a relevant point in patient care for the entire EHR reporting period. Absent four clinical quality measures related to an EP’s scope of practice or patient population, the clinical decision support interventions must be related to high priority health conditions
PY 15 Alternate Measure 1: For an EP scheduled to participate in Stage 1 in 2015, implement one clinical decision support rule
• Measure 2: The EP has enabled and implemented the functionality for drug-drug and drug allergy interaction checks for the entire EHR reporting period
• Exclusion: For Measure 2, any EP who writes fewer than 100 medication orders during the EHR reporting period
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August 2, 2016
Computerized Provider Order Entry - 1 of 3
• Measure 1: More than 60 percent of medication orders created by the EP during the EHR reporting period are recorded using computerized provider order entry (CPOE)
• PY 15 Alternate Measure 1: For Stage 1 providers in 2015, more than 30 percent of all unique patients with at least one medication in their medication list seen by the EP during the EHR reporting period have at least one medication order entered using CPOE; or more than 30 percent of medication orders created by the EP during the EHR reporting period are recorded using CPOE
• Exclusion: Any EP who writes fewer than 100 medication orders during the EHR reporting period
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August 2, 2016
CPOE- 2 of 3• Measure 2: More than 30 percent of laboratory orders created
by the EP during the EHR reporting period are recorded using CPOE
• PY 15 and 16 Alternate Exclusion: EPs scheduled for Stage 1 in 2015 or 2016 may claim an exclusion for measure 2 (lab orders) of the Stage 2 CPOE objective for an EHR reporting period in 2015 and 2016
• Exclusion 2: Any EP who writes fewer than 100 laboratory orders during the EHR reporting period
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August 2, 2016
CPOE- 3 of 3• Measure 3: More than 30 percent of radiology orders created
by the EP during the EHR reporting period are recorded using CPOE
• PY 15 and 16 Alternate Exclusion: EPs scheduled for Stage 1 in 2015 or 2016 may claim an exclusion for measure 3 (radiology orders) of the Stage 2 CPOE objective for an EHR reporting period in 2015 and 2016
• Exclusion: Any EP who writes fewer than 100 radiology orders during the EHR reporting period
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August 2, 2016
Electronic Prescribing (e-Rx)• Measure: More than 50 percent of permissible prescriptions
written by the EP are queried for a drug formulary and transmitted electronically using CEHRT
• PY 15 Alternate Measure: For Stage 1 providers in 2015, more than 40 percent of all permissible prescriptions written by the EP are transmitted electronically using CEHRT
• Exclusions: – EP who writes fewer than 100 permissible prescriptions during
the EHR reporting period; or– EP who 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 his or her EHR reporting period
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August 2, 2016
Health Information Exchange (HIE)• Measure: The 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 record; and (2) electronically transmit such summary to a receiving provider for more than 10 percent of transitions of care and referrals
• Exclusion: Any EP who transfers a patient to another setting or refers a patient to another provider less than 100 times during the EHR reporting period
• PY15 Alternate Exclusion: EP may claim an exclusion for the Stage 2 measure that requires the electronic transmission of a summary of care document if for an EHR reporting period in 2015, they were scheduled to demonstrate Stage 1, which does not have an equivalent measure
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August 2, 2016
HIE – Additional Information• In cases where providers share access to CEHRT, transition may still
count if referring provider creates the summary of care document in CEHRT and sends the summary of care document electronically
• No longer required that the Summary of Care document be transmitted using Direct Protocol
• The exchange must comply with the privacy and security protocols under ePHI under HIPAA
• The referring provider must have reasonable certainty of receipt by the receiving provider to count the action toward the measure
• The Florida Health Information Exchange’s Direct Messaging Service meets the security requirements
• The EHR may not calculate a transition into the numerator. EPs will have to provide documentation to support the numerator if different from their EHR report
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August 2, 2016
Health Information Exchange – Resources
• CMS FAQ #12817 – use of a third party
• CMS FAQ #9690 – sharing of CEHRT
• CMS Tip Sheet at https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/HIE_FactSheet.pdf
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August 2, 2016
Patient Specific Education• Measure: Patient specific education resources identified by
CEHRT are provided to patients for more than 10 percent of all unique patients with office visits seen by the EP during the EHR reporting period
• PY 15 Alternate Exclusion: EP may claim an exclusion for the measure of the Stage 2 Patient Specific Education objective if for an EHR reporting period in 2015 they were scheduled to demonstrate Stage 1 but did not intend to select the Stage 1 Patient Specific Education menu objective
• Exclusion: Any EP who has no office visits during the EHR reporting period
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August 2, 2016
Medication Reconciliation• Measure: The EP performs medication reconciliation for more
than 50 percent of transitions of care in which the patient is transitioned into the care of the EP
• PY 15 Alternate Exclusion: EP may claim an exclusion for the measure of the Stage 2 Medication Reconciliation objective if for an EHR reporting period in 2015 they were scheduled to demonstrate Stage 1 but did not intend to select the Stage 1 Medication Reconciliation menu objective
• Exclusion: Any EP who was not the recipient of any transitions of care during the EHR reporting period
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August 2, 2016
Patient Electronic Access – 1 of 2
• Measure 1: More than 50 percent of all unique patients seen by the EP during the EHR reporting period are provided timely access to view online, download, and transmit to a third party their health information subject to the EP's discretion to withhold certain information
• Exclusion for Measure 1 : An 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”
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August 2, 2016
Patient Electronic Access – 2 of 2• Measure 2: For an EHR reporting period in 2015, at least one patient seen
by the EP during the EHR reporting period (or patient-authorized representative) views, downloads or transmits to a third party his or her health information during the EHR reporting period
• PY 15 Alternate Exclusion for Measure 2: EP may claim an exclusion for the 2nd measure if for an EHR reporting period in 2015 they were scheduled to demonstrate Stage 1 which does not have an equivalent measure
• Exclusion for Measure 2: – An 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 contract information”; or
– An 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 EHR reporting period
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August 2, 2016
Secure Messaging• PY15 Measure: For an EHR reporting period in 2015, the
capability for patients to send and receive a secure electronic message with the EP was fully enabled during the EHR reporting period
• PY16 Measure: At least 1 patient seen by the EP during the EHR reporting period, a secure message was sent using the electronic messaging function of CEHRT to the patient (or the patient- authorized representative), or in response to a secure message sent by the patient (or the patient-authorized representative) during the EHR reporting period
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August 2, 2016
Secure Messaging - Exclusions• PY15 Alternate Exclusion: An EP may claim an exclusion for the
measure if for an EHR reporting period in 2015 they were scheduled to demonstrate Stage 1, which does not have an equivalent measure
• Any EP who has no office visits during the EHR reporting period, 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 EHR reporting period
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August 2, 2016
Public Health ReportingMeasures
• Measure Option 1 – Immunization Registry Reporting
– The EP is in active engagement with a public health agency to submit immunization data
• Measure Option 2 – Syndromic
Surveillance Reporting– The EP is in active engagement with a
public health agency to submit syndromic surveillance data
• Measure Option 3 – Specialized
Registry Reporting– The EP is in active engagement to
submit data to a specialized registry
PY15 Requirements
• If scheduled for Stage 1 in PY15– Must meet one measure or be
able to exclude from all
• If scheduled for Stage 2 in PY15– Must meet two measures or
meet fewer and exclude from the rest
PY16 Requirements
• All EPs in PY16 must meet two measures or meet fewer and exclude from the rest
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Note: EPs must register within 60 days of the start of their EHR reporting period unless they registered for a previous reporting period
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Active Engagement
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• Completed Registration to Submit Data– EP has registered to submit data. Registration was completed
within 60 days after the start of the EHR Reporting period and the provider is awaiting an invitation to begin testing and validation.
• Testing and Validation – EP is in the process of testing and validation of the electronic
submission of data. Providers must to respond to requests from the sponsor of the registry within 30 days; failure to respond twice within an EHR reporting period would result in the EP not meeting the measure.
• Production– EP has completed testing and validation of the electronic
submission and is electronically submitting production data.
August 2, 2016
Public Health Reporting - ExclusionsExclusions for Measure 1
• Does not administer any immunizations to any of the populations for which data is collected by its jurisdiction's immunization registry or immunization information system during the EHR reporting period;
• Operates in a jurisdiction for which no immunization registry or immunization information system is capable of accepting the specific standards required to meet the CEHRT definition at the start of the EHR reporting period; or
• Operates in a jurisdiction where no immunization registry or immunization information system has declared readiness to receive immunization data from the EP at the start of the EHR reporting period.
Exclusions for Measure 2
• Is not in a category of providers from which ambulatory syndromic surveillance data is collected by their jurisdiction's syndromic surveillance system;
• Operates in a jurisdiction for which no public health agency is capable of receiving electronic syndromic surveillance data from EPs in the specific standards required to meet the CEHRT definition at the start of the EHR reporting period; or
• Operates in a jurisdiction where no public health agency has declared readiness to receive syndromic surveillance data from EPs at the start of the EHR reporting period.
Exclusions for Measure 3
• Does not diagnose or treat any disease or condition associated with, or collect relevant data that is collected by, a specialized registry in their jurisdiction during the EHR reporting period;
• 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 EHR reporting period; or
• 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 EHR reporting period.
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August 2, 2016
Public Health Reporting – Alternate Exclusions• Stage 1 in 2015: must meet one measure or be able to exclude from all
⁻ May claim an Alternate Exclusion for Measure 1, Measure 2 or Measure 3
⁻ An Alternate Exclusion may be claimed for up to two measures, then the provider must either attest to or meet the exclusion requirements for the remaining measure
• Stage 2 in 2015: must meet two measures or meet fewer and exclude from the rest
⁻ May claim an Alternate Exclusion for Measure 2 or Measure 3 or both
• All EPs in 2016 must meet two or meet fewer and exclude from the rest
⁻ May claim an Alternate Exclusion for Measure 2 or Measure 3 or both
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August 2, 2016
Immunization Registry Reporting • CMS FAQ #11984 – when to claim an exclusion
• CMS FAQ #13409 – when scheduled to be in Stage 1
• CMS FAQ #12985 – alternate exclusions
• https://www.flshots.com/
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Specialized Registry Reporting • Identification
– Determine if the jurisdiction (state, territory, etc.) endorses or sponsors a registry; and
– Determine if a National Specialty Society or other specialty society with which the provider is affiliated endorses or sponsors a registry
– If neither has a registry the provider can report, an exclusion can be claimed
• Reporting
– Specialty societies with specialized registries can dictate the method in which they receive the data
– The data must be generated from the CEHRT
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August 2, 2016
Florida Registry Links
Cancer Registry
http://fcds.med.miami.edu/inc/welcome.shtml
E-FORCSE
http://www.floridahealth.gov/statistics-and-data/e-forcse
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E-FORCSE
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Source: E-FORCSE Florida Prescription Drug Monitoring Program
August 2, 2016
E-FORCSE
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Source: E-FORCSE Florida Prescription Drug Monitoring Program
August 2, 2016
Florida’s Specialized Registries• The Florida Cancer Registry can accept electronic reporting for
providers who diagnose or treat cancer
• Florida’s Prescription Drug Monitoring Program has a specialized registry, E-FORCSE
– Providers who dispense controlled substances to patients ages 17 and older are required to electronically report
– Providers who prescribe controlled substances to patients ages 17 and older can register and search the database prior to prescribing a controlled substance.
– CMS has approved the searching for a patient prior to prescribing as meeting the specialized registry measure
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August 2, 2016
Specialized Registry Exclusions• No documentation required for alternate exclusion
• If excluding for another reason need to document – Do not diagnose or treat cancer
– Do not prescribe controlled substances to patients 17 and older
– Or• Do not belong to a specialty society, or
• Belong to X specialty society but the society has no registry, or
• Belong to X specialty society which has a registry but it did not declare readiness by the first day of their EHR/MU reporting period, or
• Belong to X specialty society which has a registry that does not accept electronic reporting, or
• Belong to X specialty society which has a registry that accepts electronic reporting, but do not have any data that is reportable
• Recommend taking the alternate exclusion for Program Years 2015 and 2016.
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August 2, 2016
Clinical Quality Measures (CQMs)
• EPs - 9 out of 64
– Regardless of reporting year
• Cover at least three of the National Quality Strategy Domains
• Core Sets for Adult and Children
• No threshold that must be met
• CQMs reported through the online application (MAPIR)
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August 2, 2016
When Submitting Your Application
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• Remember to upload:– Documentation of 2014 CEHRT– Patient Volume Report– Encounter Report for EHR Reporting Period– Meaningful Use Report – including CQMs– Security Risk Analysis including Asset Inventory and Final Report– Additional Documentation Form– For Public Health Reporting
• Documentation of active engagement OR• Documentation supporting exclusions other than alternate exclusions
– Additional Documentation, as applicable:• PA-Led Attestation• Medical Record for ARNPs (if not billing Medicaid directly)
• Clearly Label Uploads
• Maintain Documentation
August 2, 2016
Additional Contacts and Resources
www.ahca.myflorida.com/medicaid/ehr
EHR Incentive Program Call Center: 855-231-5472
www.Florida-HIE.net
Florida HIE Help Desk: 850-412-3752
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