hfhs strategic review - report · 2018-03-01 · implementation was 25% more than vendor estimates....

Meaningful UseRegulations and Considerations –

Eligible Professionals

December 2, 2010

Questions/Comments we heard from you

1. Make the EHR 101 pretty simply and don't use a great deal of "terminology”

2. What are the advantages and drawbacks of hosted (MMC) or non hosted solutions?

3. What is the average time to install an EMR? What is my office’s involvement in terms of time commitment?

4. Is there an advantage to go with one package verses another based on a specialty (dentistry, plastic surgery, ortho, etc.)?

5. Want to hear about MCEITA and how they can help (especially with the independent, non EHR offices)

6. What are the Meaningful Use test scripts and how do we use them?

7. How much money do I get (for Meaningful Use)?

8. How do I apply?

9. How will I get paid?

10. Will this program (MU) go away? Will it change with changing political parties in power? How secure is the funding?

11. In Track 2, do not focus on eCW or Next Gen (we don't use either)

12. Which EHR's are currently certified as meeting MU criteria?

13. How will the 30% threshold for Medicaid be measured in Michigan? Does it have to met each year or only once?

14. When is the earliest these incentives funds may be actually dispersed to physicians?

15. What is a "clinical decision rule"?

16. How can a physician determine if they can "exclude" a measure?

17. Is this going to be as frustrating as participation in PQRI and eRx has been?

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Event Agenda and Presenters

Time Subject

8:00‐8:20 Introductions, Event Overview and Objectives

8:20‐11:30 Optional TracksTrack #1: EHRTrack #2: Meaningful Use

11:30‐12:00 M‐CEITA, Q&A, Wrap‐up

Presentation Team:

• Briggs Pille, HIMformatics

• Dr. Cook

• Randi Terry, MHC

• Crystal Larson, MHC

• Karen Moore, HIMformatics

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Optional Tracks

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#1 ‐ EHR Track #2 ‐Meaningful Use TrackThose interested in finding and

implementing an EHRThose already using an EHR, focused on how to reach Meaningful Use

• EHR 101• Costs, Benefits and Return on Investment

• Overview of Ambulatory EHR Market

• Meaningful Use Overview• Implementation Timeline

• Solution Status Update• Information Sources• Meaningful Use• Reimbursement and Penalties• Registration and Submission• Pursuit Timeline

There is a wide range of participants requiring different information, so we have structured two concurrent tracks

2010 Meaningful Use Assessment

TRACK #1 ‐ EHR

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Track #1 ‐ EHR

Time Topic Presenter (S)

8:20‐9:45 • EHR 101 ‐ The Basics of EHR and what you need to consider

• Costs, Benefits and Return on Investment – planning considerations and operational implications

• Meaningful Use Overview – Incentives, Penalties, and Requirements

• Implementation Timeline – practical timelines and important considerations

Karen Moore

9:45‐10:00 Break

10:00‐11:30 • Overview of Ambulatory EHR Market – who are the players and front runners; Demonstrations: NextGen, eClinicalWorks

Karen MooreCrystal Larson

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EHR 101

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EMR – Why Not?

• Practices are confused about the requirements for Meaningful Use and the incentives programs (who, what, when?)

• Practice administrators are distracted by RAC, PQRI, eRx, HIPAA and Revenue Cycle initiatives

• Practice physicians are worried about the drop in production that can happen when a practice launches an EMR

• Practices concerned about the significant capital outlay and increased on‐going expenses

• Practices have too many options in EMR solutions and no guidance on how to choose the best solution for their practice

• Practices may lack the in‐house expertise to implement an EMR

• Practice concerns about tying themselves to a particular hospital or to one hospital’s EMR package

• Practices have heard as many “horror” stories as “success” stories with EMRs

• Two practices can have absolutely opposite experiences with the same EMR, no one can find consistent recommendations for any single product. (Key: It’s not the product, it’s the implementation!)

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EMR – Why Should You?

There are external factors driving practices to implement EMR technology….

•Federal programs (HITECH, MIPPA, PQRI, etc.)

•Reimbursement challenges

•Healthcare reform changes (ACOs, Medical home, etc.)

•Physician and nurse shortage •Primary care shortage

•Sophisticated physicians•An aging population•Increase in ambulatory care visits

•Increase in competition for primary care

•Improved case management

•Consumer expectations9

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EMR – Why Should You?

Quotes from various clients on operational problems in the physician practice setting. Addressing these issues would result in substantial staff time savings for the practice.

Problem Statement Potential Impact of Technology Benefit

“Managing paper is the biggest problem here” High Save Time

“School and camp forms take a lot of time” High Save Time

“Information management takes up to 33% of all RN time” HighSave Time

Improve quality

“Authorizations take about 3 minutes each” Medium Save Time

“We spend about 20 hours per week looking for lost records” High Save Time

“20 lost charts per day at 15-20 minutes each” High Save Time

“10 to 20 charts faxed per day here- 15-20 pages each” Medium Eliminate paper cost

“It takes 3-5 minutes to process each order” High Save Time

“We spend significant time playing phone tag or writing notes” High

Save TimeImprove quality

EMR 101 – What is an EMR?

Software Package•Problem List, Medication List, Allergies

•Family/Social History

•Encounter Documentation Templates/Tools and Documents

•Order Entry and Results Reporting•Coding Analysis•Management Reporting

•Decision Support•Patient Education/Instruction•Display and Graphing

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Interfaces•Pharmacy

•Transcription•Laboratory•Disease Management

•PM System

•Document Management (scanning)

• Hospital Systems

Patient/Provider Portals•Select Access to Records•Request Appointments

•Receive Reminders

•Secure Messaging Interfaces

Devices•Desktop PC•Laptop•Tablet PC•Handheld

EMR 101 – What is an EMR?

• I have a PMS why do I need another system? Should you implement an EMR or an EHR? Is there a difference?

• In theory and by definition, there is a difference but the terms are frequently used interchangeably. The National Alliance for Health Information Technology (NAHIT) established definitions for electronic medical records (EMR), electronic health records (EHR), and personal health records (PHR).– Practice Management System (PMS) ‐ A PMS is software designed to deal with the day‐to‐day

operations of a medical practice such as patient demographics, appointment scheduling, maintaining lists of insurance payers, performing billing tasks, and generating reports.

– Electronic Medical Record – An electronic record of health‐related information on an individual that can be created, gathered, managed, and consulted by authorized clinicians and staff within one healthcare organization.

– Electronic Health Record – An electronic record of health‐related information on an individual that conforms to nationally recognized interoperability standards and that can be created, managed, and consulted by authorized clinicians and staff across more than one healthcare organization.

– Personal Health Record ‐ An electronic record of health‐related information on an individual that conforms to nationally recognized interoperability standards and can be drawn from multiple sources while being managed, shared, and controlled by the individual.

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General EHR Considerations

Operational Considerations

•Documentation – Are there templates and best practices guidelines available? Or are you starting from scratch in developing protocols, templates and cheat sheets for your practice, or does it have a storehouse of examples to choose from or tweak? Is documentationdone via “point and click”, voice recognition, or a combination?

•Built for the physician, or the billing office, or the nurses, but doesn’t really meet the needs of all three? Make sure the functionality is not too skewed to one user group, but if it is, it should be somewhat skewed to the provider.

•Flexibility – does it make the practice conform to it or can it conform to the practice? How?

•Access to the EMR – can charts be accessed from any workstation? By multiple users? Are changes in a chart reflected immediately?13

General EHR Considerations (cont.)

System Considerations

•ARRA Certification. Is the system certified by one of the recognized bodies (Drummond, CCHIT, InfoGard)?

•Interface and integration with your practice management system.Does the information flow both ways? Do you ever have to re‐enter information because one application doesn’t speak to the other?

•Built‐in Resources: annual upgrade of HCPCS and ICD codes, drug compendium (Epocrates, etc.), comparative effectiveness prompting, e‐prescribing, patient education materials?

•What’s the plan for ICD‐10?Will they provide practice support and education for the change or will they just change the number of characters in the diagnosis code field?

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Technical Considerations

•Data entry systems ‐ laptops, notebooks, tablets, iPads, smartphones, voice recognition?

•Hosting – in your office (Client/Server)? at the hospital (Hosted)? at the vendor’s data center (Hosted)? in the cloud of your choice (SaaS)?

•Downtime ‐ how often is the system down (unavailable) for upgrades, maintenance, or backups? Are there processes developed to deal with extended system downtime?

•Interface with other inside and outside systems ‐ Labs, imaging, hospital systems, ambulatory surgery center systems?

•Does the EMR include an e‐mail component?

•Mobile applications ‐ EMR on your providers’ phones?

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Financial & Contracting Considerations

•Price – should include annual maintenance and additional costs for training, implementation, on‐site support during go‐live, and additional licenses for providers or staff.

•Installed base ‐ How many practices is the EMR installed in today? Does the vendor have installations in a variety of different‐sized practices?

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Hosted vs. Non‐hosted?

• The decision on which EMR hosting model to choose comes down to researching each model and weighing this against your practice's operational needs, your comfort/risk level, interest in EMRs and internet technology, and your financial constraints.

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Hosted Model(SaaS* or ASP**)

Non‐Hosted(Client/Server)

Advantages • Shorter timeline for implementation• Lower initial expense• Built‐in disaster recovery• Reduced need for IT support• Software upgrades managed by the

vendor

• Elimination of leasing fees• Easier integration of existing

systems• Direct control of systems• Greater control over data

access• May be faster for data intensive

tasks.

Disadvantages • Multi‐year service contract• Continued expense for lease of

software• Reduced control over EMR system• Dependence on internet service• ***MMC hosting would provide

integration to a patient’s inpatient information.

• Greater initial expense for hardware and software costs

• Higher IT support costs• Extended implementation

period

* Software as a Service* * Application Service Provider


COSTS, BENEFITS AND ROI

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EMR ‐ Cost

• Cost is the biggest factor in the implementation of an EMR

• An entry level EMR can cost as little as $3,000, and advanced level EMRs can cost over $100,000 for a solo physician. Research suggests that the average cost is $33,000.

• Do in‐depth cost research before committing to any vendor – include all financial components (labor, software, support services, training costs, hardware, licenses, interface development, etc.)

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EMR – Cost Estimates

Source Implementation Cost Maintenance Cost Notes

Harvard $40‐60K/provider $5‐10K

AHRQ $32.6K $18K Smaller practices had the highest per physician cost at $37,204. Average cost for the implementation was 25% more than vendor estimates.

Perot Systems $25‐45K $3‐9K

EMR and HIPAA $33K $18K

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• Several sources researched had varying numbers for the cost per provider. The cost for implementation, range from $25,000 to $60,000 with a mean of $42,500. Maintenance costs range from $5,000 to $18,000 per provider per year.

• The details from several sources are listed below:

ROI Potential – Why?

Improved provider efficiency/revenue•Reduction in time spent in chart documentation (60% reduction in time)

•Increase in physician revenue (20% increase in revenue)•Increase in the number of patients seen per day (10–15% increase in volume)

•Reduction in time clinicians spend looking for charts (20–80% reduction in time)

•Reduced time to write a prescription

Enhanced revenue cycle•Reduced service‐to‐charge entry time (50% reduction in time)

•Improved revenue because of improved coding (3–15% of practice revenue)

•Reduction in lost charges ($2,000–$3,000 additional revenue per year, per provider, for each 1% reduction in lost charges)

•Improved patient throughput (20%)

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ROI Potential – Why?

Reduced medical records staffing and costs.•Reduction in number of chart pulls by 50–80%

•Reduction in number of chart pulls for medication refills by 80–100%

•Chart copying and courier costs reduced by 75%•Reduced supply cost per chart by 33%•Enhanced use of space and additional potential revenue (converted chart storage space to exam or procedure rooms)

Operational enhancements.•Decrease in the provider/support staff FTE ratio (10%)•Reduced transcription costs (13–50%)•Reduced time spent by staff on referral coordination (15% savings)

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Source: Michelle Holmes ECG Consultant, compilation of benefits from various literature sources. Source: Health Affairs: The Economics of HIT, 2005Source: Adapted from A Cost-Benefit Analysis of Electronic Medical Records in Primary Care, 2003

Evidence From the Literature

Factor Benchmark Value Notes

Spokane Internal Medicine Case Study – 9 Physician Practice Value: $68,600 +

FTE to Provider Ratio 4:1 to 2.6:1 $68,600 Case Study – 1.4 FTE per provider

Productivity 10% increase Not Valued Time saved may not equate to dollars

American Thoracic Society Physician Expenses Study – Activity Based Costing Value: $29,736

Medical Records Management $9,300 annual per provider cost $8,370 Estimated 90% reduction

Providing Information to Others $5,027 annual per provider $3,770 Estimated 75% reduction

Billing: Entering codes $14,709 annual per provider $13,238 Estimated 90% reduction

Billing Disputes: Resolve / Rebill $8,717 annual per provider $4,358 Estimated 50% reduction

ACP Observer Case Studies – Small to Medium Sized Practices Value: $74,975 +

Productivity 4 patients/hour improvement (6 providers) Not Valued Time saved may not equate to dollars

Coding Improvement Average E&M Code from 2.4-3.5 $74,975 Add $17.53 per visit

Malpractice Reduction 10% reduction in premiums Not Valued Size may make this vary

Virginia Mason – HFMA Study Value: $24,974

Reduction in manual data entry 50% staff reduction for these functions $2,393 Large group means dedicated staff

Charge Capture 2% improvement – multiple factors $22,401 Includes lost charges

Other Benefits Studies

These benefits have been documented in the literature, as noted. Values are per FTE Physician.

ROI – Why Should You Calculate?

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Start

Finish

On‐going Effort = On‐going Benefits

Adapted from: Arlotto & Oakes

Return on Investment

Definition of ROI

General Definition:

• Return on Investment is defined as “a profitability ratio that describes how much income is generated per dollar of investment”1

• Calculating a financial ROI is not difficult: Income from an investment divided by the value of the original investment– If you invest $100 and make $120 your ROI is 1.2 : 1

– Anything higher than 1 is a positive return

– This is a very simplistic generalization of the ROI measurement process.

Benefit

Cost= ROI

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Benefit

Cost= ROI

ROI Inputs ‐ Benefits

•Financial contribution – These are observable– Process improvements

– Revenue improvements

– Cost avoidance

•Non‐financial contribution– Some of these are not observable or quantifiable, but they are still very important. Examples include

• Improved quality of care

• Improved patient satisfaction

• Improved staff satisfaction


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ROI Inputs ‐ Costs•Financial contribution – These are observable

– Capital costs• Purchase

• Installation

• Productivity loss

– Operating costs – for a defined period of time• Direct, like maintenance fees paid to the vendor

• Indirect, like floor space for additional staff or interest paid to finance the investment

•Non‐financial contribution– Some of these are not observable or quantifiable, but they are still

very important. Examples include• Staff frustration from changes in process, workflow

• Distraction from other important tasks

• Negatively impacted patient satisfaction

Benefit

Cost= ROI

Development and UsageWe developed a baseline calculator, which computes estimated costs and benefits of implementing an ambulatory EHR solution, and adjusts those results based on how you change the parameters. The calculator is meant to provide a high‐level view of potential benefits and costs associated with implementation of an ambulatory EHR solution at a private physician practice, or at a community health center. It is designed for ease‐of‐use and understandability as a first step toward a more formal cost/benefit analysis.

• http://www.himformatics.com/himss/index.htm

• Changing the input parameters to reflect your organization will show possible financial outcomes based on those inputs

• If you would like to print the results, copy and paste the calculator into a word processing or presentation document

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The HIMSS Ambulatory ROI Calculator


Benefits Model

These benefits are included in the model:

•Increased coding due to elimination of lost charges and using appropriate coding levels based on services delivered

•Personnel savings from automated results documentation, reduced chart pulls, etc.

•Transcription savings due to charting as a by‐product of the visit•Paper supplies savings from elimination of the paper chart

•Increased capacity / throughput of patients due to effective patient management and improved information availability

•Improved resource utilization (for capitated patients only) through avoidance of redundant testing and substituting effective lower cost treatments

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Orientation•Input and results areas organized on the left and right•Only key input parameters included – others are assumed

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Key Input Parameters

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• Summary Panel– Initial costs– Steady state costs and

benefits– NPV over 5 years

• Contribution Panel– Source and weight of

benefits and costs– Float‐overs show

contribution by slice

• Cumulative Effect Panel– Shows cost, benefit

and net position of the investment over 5 years


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Conclusion

•Evidence supports the hypothesis that there is a materially positive Return On Investment (ROI) from properly implementing and using electronic health records in the ambulatory setting

•Any ROI will be negatively affected by failing to link desired benefits to the implementation plan

OR

•By failing to give the vendor incentive to assist you in achieving your desired benefits


EMR MARKET OVERVIEW

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Ambulatory EMR Functionality

• The NEJM defines AEMR functionality in two categories:– Basic System

– Fully Functional

• A Fully Functional AEMR is required to support Meaningful Use

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New England Journal of Medicine

Ambulatory EMR Functionality

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Source: Use of Electronic Medical Records by Ambulatory Care Providers: United States, 2006 by Esther Hing, M.P.H.; Margaret J. Hall, Ph.D.; and Jill J. Ashman, Ph.D. Division of Health Care Statistics

AEMR Market Overview

• 56% w/out an AEMR

• 17% “Partial”

• 21% “Basic”

• 6% “Fully Functional”

• A recent study of office‐based physicians by the Centers for Disease Control (CDC) estimates the extent of AEMR adoption break down within the U.S. as follows:

37

AEMR Market Overview

• Though there are more than 300+ AEMR vendors, the marketplace is dominated by a few large vendors. Studies vary based on how the market is measured (revenue, no. of physicians, type of install, etc.) however, consistently the five top vendors include:– EPIC*

– Allscripts

– eClinicalWorks

– NextGen

– GE Centricity

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* Typically large academic medical centers or medical groups

AEMR Market Resources

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• KLAS ‐ www.klasresearch.com

– Rankings of systems are available to providers at no cost. KLAS evaluates vendors in various markets

• Practice Specialty

• Practice size

– Ratings on post‐live sales experience, value, support

– Vendor trends, customer comments

– Vendor comparisons

http://www.klasresearch.com/


• Sample of a KLAS vendor comparison…

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EMR Consultant•EHR Scope ‐ www.ehrscope.com/emr‐comparison

– Vendor lists can be filtered based on various criteria:

• Practice specialty

• Practice size

• PM/EMR or EMR‐only

• Client Server or ASP

http://www.ehrscope.com/emr-comparison

http://www.ehrscope.com/emr-comparison

Pace of AEMR Deployment

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• Percentage of office-based physicians using electronic medical records/electronic health records (EMRs/EHRs)

• Based on a 2009 National Ambulatory Medical Care Survey of 2000+Physicians

• Note the increasing pace of adoption. This trend has been significantly amplified by the ARRA Incentives


• Studies indicate that adoption rates for EHRs are increasing at a rapid pace with the rates varying based on a number of factors. A recent strategic analysis of the U.S. Electronic Health Record market identified the following:

– The Ambulatory EHR market continues to accelerate, and is on pace to more than double the purchasing activity from 2009

– Interestingly, the study found the most important reason driving Ambulatory EMR purchases was the goal of physicians making their practice more efficient and not the ARRA / HITECH Act Stimulus funding.

– 50% of Groups in U.S. Plan to Purchase an Ambulatory EHR

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Source: 2010 U.S. Ambulatory EHR & Practice Management Study


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•Overall, U.S. medical office EHR adoption has grown from 36.1 to38.7%, since the beginning of 2010, or an increase of 2.6% in just nine months. By comparison, the overall rate for medical office adoption was reported to be 32.9% in February 2009.

•The fastest rates of adoption are occurring in practices owned by hospitals or health systems. In both of these models, adoption has jumped by about 11% since the start of 2010:

• 54.9 percent of hospital-owned medical practices• 61.2 percent of physician offices owned by large health systems

•While adoption has increased, that does not necessarily translate into “meaningful use”. Only 28% of respondents report keeping electronic patient notes, 27% with digitized lab values or X-rays and 26% writing electronic prescriptions, leaving significantly less than half of medical practices with fully functional EHR systems.


• With greater numbers adopting at a faster pace, there is concern that many practices may encounter difficulties finding qualified resources to assist with the selection, installation, implementation, and training required for an EMR system.

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MEANINGFUL USE OVERVIEW

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Who Qualifies?

Eligible ProfessionalsMedicare Medicaid

• Doctor of medicine or osteopathy

• Doctor of dental surgery or dental medicine

• Doctor of podiatric medicine• Doctor of optometry• Chiropractor

• Physicians• Dentists• Certified nurse midwives•Nurse practitioners• Physicians assistants (in rural health clinic or FQHC led by a physician assistant)

Requires minimum 30% Medicaid patient mix (20% for Pediatrics)

Medicare EPs may not be hospital-based

Medicare Incentives for EPs

• Maximum incentive amount is $44,000 over 5 years

• Must begin participation by 2012 to receive maximum incentive

• Incentives based on 75% of Medicare‐Allowed Charges for that year

• Starting in 2015 – Penalties (reduction in Medicare reimbursements) for EPs not demonstrating Meaningful Use

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Medicaid Incentives for EPs

• EPs may receive payments up to $63,750 over six years

• Incentive based on up to 85% of state‐calculated global average costs for EHR

• Start no later than 2016

• Achievement of MU not required in first year

• No payments made after 2021

• No Medicaid penalty for failure to demonstrate Meaningful Use

Stages of Meaningful Use

• Meaningful Use (MU) requires 3 main components:– Certified clinical system – Temporary program in place

– Health Information Exchange ‐ Relaxed for Stage 1

– Clinical quality reporting – Relaxed for Stage 1

• Three “stages” have been outlined and define increasing requirements to achieve and maintain Meaningful User status

Stage 1 Stage 2 Stage 32011-2012 2013-2014 2015 and beyond

Data Capture and SharingElectronically capture data in coded format as well as report health information for tracking key clinical conditions

Advanced Clinical ProcessesGuide and support care processes and coordination through the exchange of information

Improved Outcomes Achieve improved performance through the effective adoption and use of care processes as well as advance key health system outcomes

Stage 1 Overview

• Stage 1 MU regulations provide 2 sets of requirements:

– Core Objectives – 15 basic EHR functions that must be achieved by every EP

– Menu Activities – 10 additional functions from which providers can choose any 5 to implement in Stage1

– All Core and Menu activities will be required to achieve Stage 2 status

• Reporting mechanism in 2011 is “Attestation Methodology” with selected compliance reviews

• In 2012, CMS plans to have an electronic reporting mechanism

Stage 1 MU Requirements (CORE)

# ObjectiveEligible

Professionals

Eligible Hospitals and

CAHs Measurement

1 CPOE (computerized practitioner order entry)

✔ ✔ More than 30% of unique patients with at least one medication order entered using CPOE

2 Drug‐drug and drug‐allergy interaction checks

✔ ✔ Functionality is enabled for the entire EHR reporting period

3 E‐Rx ✔ N/A More than 40% of all permissible prescriptions written are transmitted electronically using certified EHR

4 Record demographics ✔ ✔ More than 50% of all unique patients have demographics recorded as structured data: Preferred language, Insurance type, Gender, Race, Ethnicity, Date of birth, Date and cause of death (Hospital Only)

5 Active problem and diagnosis list

✔ ✔ More than 80% of all unique patients have at least one entry or an indication that no problems are known recorded as structured data

6 Active medication list ✔ ✔ More than 80% of all unique patients have at least one entry (or an indication that the patient is not currently prescribed any medication) recorded as structured data

7 Active medication allergy list

✔ ✔ More than 80% of all unique patients have at least one entry (or an indication that the patient has no known medication allergies) recorded as structured data


# ObjectiveEligible

ProfessionalsEligible Hospitals

and CAHs Measurement

8 Record vital signs ✔ ✔ More than 50% of all unique patients age 2 and over have height, weight and blood pressure recorded as structured data: Height, Weight, Blood pressure, Calculate and display BMI, Plot and display growth charts for children 2‐20 years, including BMI

9 Smoking status ✔ ✔ More than 50% of all unique patients 13 years old or have smoking status recorded as structured data

10 Clinical decision support

✔ ✔ Implement one clinical decision support rule and ability to track compliance

11 Report CMS measures

6 measures from 44 (3 core, 3 selected)

15 measures from 44

2011: provide aggregate numerator, denominator, and exclusions through attestation2012: electronically submit clinical quality measures

12 Patient copy of health information

✔ ✔ More than 50% of all patients who request an electronic copy of their health information are provided it within 3 business days


# Objective Eligible ProfessionalsEligible Hospitals


13 Electronic copy of discharge instructions

N/A ✔ More than 50% of all patients who are discharged and who request an electronic copy of their discharge instructions are provided it

14 Clinical summaries ✔ N/A Clinical summaries provided to patients for more than 50% of all office visits within 3 business days

15 Exchange patient information

✔ ✔ Performed at least one test of certified EHR technology's capacity to electronically exchange key clinical information

16 Protect electronic health information

✔ ✔ Conduct or review a security risk analysis, implement security updates as necessary, and correct identified security deficiencies as part of risk management process

Stage 1 MU Requirements (MENU)

# ObjectiveEligible



1 Drug formulary checks

✔ ✔ Function is enabled for the entire EHR reporting period

2 Advance directives*

N/A ✔ More than 50% of all unique patients 65 years old or older admitted have an indication of an advance directive status recorded

3 Lab test results ✔ ✔ More than 40% of all clinical lab tests results ordered for patients admitted to its inpatient or emergency department 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

4 Patient listsi ✔ ✔ Generate at least one report listing patients of the EP, eligible hospital or CAH with a specific condition

5 Patient reminders ✔ N/A More than 20% of all unique patients 65 years or older or 5 years old or younger were sent an appropriate reminder during the EHR reporting period

6 Patient access to information

✔ N/A More than 10% of all unique patients are provided timely (available to the patient within 4 business days of being updated in the certified EHR technology) electronic access to their health information subject to the EP’s discretion to withhold certain information

* New in Final Rulei State has option to make required for Medicaid

Stage 1 MU Requirements (MENU)

# ObjectiveEligible



7 Patient education* ✔ ✔ More than 10% of all unique patients are provided patient‐specific education resources

8 Medication reconciliation

✔ ✔ Medication reconciliation is performed for more than 50% of transitions of care in which the patient is transitioned

9 Summary of care ✔ ✔ A summary of care record is provided for more than 50% of transitions of care and referrals

10 Immunization registries

✔ ✔ Performed at least one test of certified EHR technology's capacity to submit electronic data to immunization registries and follow up submission if the test is successful (unless none of the immunization registries have the capacity to receive the information electronically)

11 Public health data N/A ✔ Performed at least one test of certified EHR technology’s capacity to provide electronic submission of reportable lab results to public health agencies and follow‐up submission if the test is successful (unless none of the public health agencies do not have the capacity to receive information electronically)

12 Syndromic surveillance data

✔ ✔ Performed at least one test of certified EHR technology's capacity to provide electronic syndromic surveillance data to public health agencies and follow‐up submission if the test is successful (unless the public health agencies do not have the capacity to receive information electronically)

* New in Final Rulei State has option to make required for Medicaid

Stage 1 Timeline Considerations

October 1 (FY11)Medicare / Medicaidhospital incentive program begins

January 1Medicare / Medicaid incentive program for physicians begins & CMS program registration for EPs and EHs

July 1ONC accepts applications for ONC-ATCB status

2010

Jan 2012Permanent certification

2011

FallTemporary certified EHR software projected to be available & final rule on permanent process released

April 2011Initiate EP and EH Medicare attestation process

May 2011Medicare EHR incentives begin

SummerState Medicaid Programs launched

July 8Proposed HIPAA enforcement rule by OCR

June 30, 2012Many providers targeting 2012 to meet Stage 1 “Meaningful

Use”

Stage 1 requires 90 consecutive days of MU compliance. Therefore…

- EPs have until Sept. 30, 2011

… to meet and sustain MU and receive FY2011 incentive payments-

NOTE: EP incentives based on calendar years

Certification Update

• The ONC has designated several Authorized Testing and Certifcation Bodies (ATCBs)

• ONC’s list of Certified Health IT Product List– http://onc‐chpl.force.com/ehrcert

• Several prominent vendors have already received certification, including:– NextGen Complete Ambulatory EHR 5.6 SP1

– eClinicalWorks Complete Ambulatory EHR 8.0.48

– Allscripts (Professional 9.2/Peak Practice 5.5)

58

The basis for all MU is a certified EHR


IMPLEMENTATION STEPS

59

EHR Implementation Lifecycle

60

Ongoing Operations

Implementation….

• “It is no longer a question of if your organization will invest in electronic medical records and computerized physician order entry systems, but when. And then, of course, it becomes a question of how….and how well. Even if you’ve already made the initial investment, making sure your EMR systems bring your organization maximum benefit with minimum confusion is a task that will have no endpoint.”

‐ David Schwartz, National Health Information

61

Implementation Team

Selecting the Right Team•Implementation team is critical for success

– Identify one point of contact between your team and the EMR vendor

•Team should include (at least):

– Administrator/Practice Manager

– IT support personnel

– Medical Record Representative

– Clinical Operations Representative

– Registration/Billing Representative

– Ancillary Services (i.e. lab, pharmacy, radiology) Representative

– Physician “super user”

62

Implementation Team

Clinic Staff•Keep engaged in decisions made regarding EMR

•Involve staff in workflow teams

•Encourage input from staff regarding process changes/suggestions

•Appoint “super‐users”•Hold training in small sessions

•Cut back schedules during implementation

•Continue training and process development post implementation

63

Physician Champion

Physician Champion

•Picking the right physician leader for EMR implementation:

– A physician who has TIME to commit to EMR training/development

– A physician who communicates effectively with peers

– A physician who has good paper processes already in place

– A physician who knows his/her way around a computer

64

Implementation Steps

• Develop a budget– OVER estimate your labor expenses and hardware expenses (particularly if client/server and/or wireless)

• Establish your OWN project plan to compare to the vendor’s implementation plan– Implementation is very complex, your team needs to think of all angles and foresee realistic timelines

• Assign a project manager

• Decide what to do with existing paper record– Consult with the physician leader and legal

65

Implementation Steps

• Prepare yourself and your team for the countless hours of pre‐installation, installation and post‐installation tasks– Remember…the vendor is NOT going to do the work for you!

• Assign a physician leader…critical step

• Study Workflow, study workflow, study workflow (are you ready for Meaningful Use?)

• Evaluate hardware purchases carefully (tablets or PCs, wireless/not wireless) and purchase what will take you and your data safest and furthest into the future

• Electronic does NOT mean paperless!!

• BE PATIENT…BE REALISTIC…BE PREPARED

66

Implementation Timeline

67

You will need to start now, if you want to maximize the HITECH incentives


DEMONSTRATIONS

68

We will now conduct demonstrations of two market leading products currently in use in your market area. Our objective

is to help improve your understanding of EHRs not to promote any specific solution


TRACK #2 – MEANINGFUL USE

69

Track #2 – Meaningful Use

70

Time Topic Presenter (S)

8:20‐8:30 • Solution Status Update ‐ Quick update on NextGen and eCW solutions

Crystal Larson

8:30‐9:30 • Information Sources• Incentives, Reimbursement, and Penalties• Meaningful Use Part I – detailed discussion of core and menu requirements

Briggs PilleDr. Cook

9:45‐10:00 Break

10:00‐11:00 • Meaningful Use Part II – detailed discussion of core and menu requirements

Briggs PilleDr. Cook

11:00‐11:30 • Registration and Submission• MU Pursuit Timeline

Briggs Pille


INFORMATION SOURCES

71

Internet Home for Information

Centers for Medicare & Medicaid site http://www.cms.gov/EHRIncentivePrograms/

72

Office of the National Coordinator http://healthit.hhs.gov/portal/server.pt/community/healthit_hhs_gov__home/

http://www.cms.gov/EHRIncentivePrograms/

http://www.cms.gov/EHRIncentivePrograms/

http://healthit.hhs.gov/portal/server.pt/community/healthit_hhs_gov__home/



ONC Frequently Asked Questions (FAQs)

• Office of the National Coordinator (ONC) Provides FAQs to clarify and provide interpretation

• Questions are from all parties Providers (EPs and EHs) and EHR vendors

• Can be viewed or downloaded at http://healthit.hhs.gov/portal/server.pt/community/onc_regulations_faqs/3163

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

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

CMS FAQs on Registration and Submission

• Then Centers for Medicare & Medicaid Services also provide a list of FAQs

• They are stated as Registration and Submission FAQs, but seemed to be broader in scope and content

• The FAQs can be viewed at (much harder to downlaod)http://questions.cms.hhs.gov/app/answers/list/p/21,26,1058

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http://questions.cms.hhs.gov/app/answers/list/p/21,26,1058

http://questions.cms.hhs.gov/app/answers/list/p/21,26,1058


PROGRAMS AND ELIGIBILITY

75

Who Qualifies?

Eligible ProfessionalsMedicare Medicaid

• Doctor of medicine or osteopathy

• Doctor of dental surgery or dental medicine

• Doctor of podiatric medicine• Doctor of optometry• Chiropractor

• Physicians• Dentists• Certified nurse midwives•Nurse practitioners• Physicians assistants (in rural health clinic or FQHC led by a physician assistant)

Requires minimum 30% Medicaid patient mix (20% for Pediatrics)

Medicare EPs may not be hospital-based

Medicare Incentives for EPs

• Maximum incentive amount is $44,000 over 5 years

• Must begin participation by 2012 to receive maximum incentive

• Incentives based on 75% of Medicare‐Allowed Charges for that year

• Starting in 2015 – Penalties (reduction in Medicare reimbursements) for EPs not demonstrating Meaningful Use

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Medicaid Incentives for EPs

• EPs may receive payments up to $63,750 over six years

• Incentive based on up to 85% of state‐calculated global average costs for EHR

• Start no later than 2016

• Achievement of MU not required in first year

• No payments made after 2021

• No Medicaid penalty for failure to demonstrate Meaningful Use

Incentive Programs

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• Physician Quality Reporting System (PQRS) – Incentive payment for EPs who satisfactorily report data on quality measures for covered professional services furnished to Medicare beneficiaries. http://www.cms.gov/ PQRI/01_Overview.asp on the CMS website.

• Electronic Prescribing (eRx) Incentive Program or MIPAA – Separate incentive program for EPs who are successful electronic prescribershttp://www.cms.hhs.gov/ERxIncentive

• EHR – refers to the Medicare and Medicaid Incentives in the HITECH Program


INCENTIVES AND PENALTIES

80

Maximum Incentives

81

• In 2015, reduction in Medicare reimbursement begins for physicians who are not meaningful EHR users (1% per year, capped at a 3% reduction)

• Statue allows for exceptions for “significant hardship” as determined by the Secretary

Medicare Penalties

First Payment Year

Reduction in Medicare Fee Schedule for non‐adoption

of certified EHR

2011 $0

2012 $0

2013 $0

2014 $0

2015 ‐1%

2016 ‐2%

2017 and thereafter ‐3%

Timing of Incentive Payments

• CMS expects that Medicare incentive payments will begin in May 2011, payments will be held for EPs until the EP meets the $24,000 threshold in allowed charges

• Incentive payments for the Medicare EHR Incentive Program will be made approximately four to six weeks after an eligible professional (EP) successfully attests that they have demonstrated meaningful use of certified EHR technology

• Payments to Medicare providers will be made to the taxpayer identification number (TIN) selected at the time of registration, through the same channels their claims payments are made

• The form of payment (electronic funds transfer or check) will bethe same as claims payments

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CORE REQUIREMENTS

84

15 basic EHR functions that must be achieved by every EP

MU requirements – Key Phrases

85

Key Phrase Meaning / Interpretation

“Unique Patients” A unique patient means that even if a patient is seen multiple times during the EHR reporting period they are only counted once

“Structure Data” Discrete and codified (e.g., uses a standard nomenclature and is not entered as free text)

“… at least one entry …” Need one entry even if that entry is none or unknown (explicit negative)

“patients whose records are maintained using certified EHR technology”

This phraseology eliminates patients who might have an entry in your EHR, but you do not maintain their records in your EHR (referral lab work)

“Human Readable Format” Means a format that enables a human to read and easily comprehend the information presented to him or her regardless of the method of presentation (e.g., computer screen, handheld device, electronic document).”

MU Test Procedures

• National Institute Of Standards and Technology (NIST) –the federal technology agency that works with industry to develop and apply technology, measurements, and standards

• NIST has defined the Health IT Testing Infrastructure and the MU test methods and procedures

• Available at http://healthcare.nist.gov/

• This material is intended for vendors seeking product certification

• We must be meaningful users, but this information provides us insight into the requirements and often references standard

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http://healthcare.nist.gov/

MU Core #1 ‐ CPOE

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Stage 1 MeasuresAttestation

Type Numerator Denominator Threshold

More than 30% of unique patients with at least one medication in their medication list seen by the EP or admitted to the eligible hospital's or Critical Access Hospital (CAH)'s inpatient or emergency Dept (POS 21 or 23) have at least one medication order entered using CPOE

CalculationPatients w/ at least one med entered using CPOE

Based on counting actions for Patients whose records are maintained using certified EHR technology

30%

Enter of orders for medications - directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local and

professional guidelines

Understanding ‐MU Core #1

• Key points of discussion– Only applies to Medication orders

– Note the key phase “unique patients”

– “…any licensed healthcare professional…”

• Test Procedure for 170.304 (a) Computerized Provider Order Entry

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MU Core #2 – Drug Screening

89

Practice/ E Ps Stage 1 MeasuresAttestation


Implement drug-drug and drug-allergy interaction checks

The EP/ Eligible Hospital/ CAH has enabled this functionality for the entire EHR reporting period

Attestation Yes/No

Implement drug-drug and drug-allergy interaction checks

MU Drug #3 ‐ ePrescribing

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Generate and transmit permissible prescriptions electronically



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

Calculation

Prescriptions transmitted electronically by the EP


40%

Understanding – MU Core #3

• The term "permissible prescriptions" refers to the restrictions that were established by the Department of Justice (DOJ) on electronic prescribing (eRx) for controlled substances in Schedule II http://www.deadiversion.usdoj.gov/schedules/orangebook/e_cs_sched.pdf

• The determination of whether a prescription is a ''permissible prescription'' for purposes of the meaningful use objective should be made based on the guidelines for prescribing Schedule II controlled substances

• Any prescription not subject to these restrictions would be a permissible prescription

• Test Procedure for 170.304 (b) Electronic Prescribing– National Council for Prescription Drug Programs (NCPDP) SCRIPT 8.1 or 10.6 ‐ allows for

standard communication between the physician and pharmacist

– RxNorm, a standardized nomenclature for clinical drugs and drug delivery devices, is produced by the National Library of Medicine (NLM).

• Bottom Line: You certified EHR solution must use these standard and position you to be a meaningful user of them

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MU Core #4 – Record Demographics

92

Record Demographics including: Preferred Language, Gender, Race, Ethnicity, and Date of Birth



More than 50% 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) have demographics recorded as structured data

Calculation

Patients w/ language, gender, race, ethnicity, and DOB

# Unique Patients regardless of whether the patient's records are maintained using certified EHR technology

50%


• The primary consideration or additional requirement is the need to record both Race and Ethnicity (separately)

• We get additional direction from the Test Procedure for 170.304 (c) Record Demographics

• We are referred to an existing standard from the Office of Management and Budget (OMB) in the Federal Data on Race and Ethnicity, Statistical Policy Directive No. 15

• Bottom Line: The minimum designations are:Race:—American Indian or Alaskan Native —Asian or Pacific Islander—Black —White

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Ethnicity:—Hispanic origin —Not of Hispanic origin

MU Core #5 – Problem List

94

Maintain up-to-date problem list of current and active diagnoses



More than 80% of all unique patients seen by the EP or admitted to the eligible hospital's or CAHs inpatient or Emergency department (POS 21 or 23) have at least one entry or an indication that no problems are known for the patient recorded as structured data.

Calculation

Patients w/ at least one problem list entry or "none known"


80%


• “Unique patients” and “structure data” again

• Test Procedure for 170.302 (c) Maintain up‐to‐date problem list

• Problem list vocabulary guidance from 170.207

• Medical Data Code Sets 162.1002

• Bottom line: The certification criterion specifies that ICD‐9CM or SNOMED‐CT® are the code sets which must be included in Certified EHR Technology, and are therefore the code sets that would be used to record entries as structured data

95

MU Core #6 – Active Medication List

96

Maintain active medication list



More than 80% of all unique patients seen by the EP or admitted to the eligible hospital's or CAHs inpatient or Emergency department (POS 21 or 23) have at least one entry or an indication that the patient is not currently prescribed any medication) recorded as structured data

CalculationPatients w/ at least one medication entry or "no medication"


80%


• Test Procedure for 170.302 (d) Maintain Active Medication List

• Looking for longitudinal record of medications over multiple encounters

• Stage 1 requirement is for an individual provider not across a practice

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MU Core #7 – Active Medication Allergy List

98

Maintain active medication allergy list



More than 80% of all unique patients seen by the EP or admitted to the eligible hospital's or CAHs inpatient or Emergency department (POS 21 or 23) have at least one entry or an indication that the patient has no known medication allergies) recorded as structured data

Calculation

Patients w/ at least one medication allergy entry or "none known"


80%


• Test Procedure for 170.302 (e) Maintain active medication allergy list

• Again references longitudinal record, this time for medications allergies over multiple encounters

• Very similar to previous requirement in structure and metric

99

MU Core #8 – Record Vital Signs

100

Record and chart changes in vital signs including, Height, Weight, and Blood Pressure



For more than 50% of all unique patients age 2 and over seen by the EP or admitted to eligible hospital's or CAH's inpatient or emergency department (POS 21 or 23), height, weight and blood pressure are recorded as structured data.

Calculation

Patients ages 2 + w/ height, weight and blood pressure recorded

All patients ages 2+ 50%

The certified EHR must use this data to - Calculate and display BMI - Plot and display growth charts for children 2-20 years including BMI


• Basic requirements and information that must be collected as structured data

• Test Procedure for 170.302 (f) (1) Vital Signs

101

MU Core #9 – Smoking Status

102

Record smoking status for patients 13 years old or older



More than 50% of all unique patents 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

CalculationPatients ages 13+ w/ smoking status recorded

All patients age 13+ 50%

MU Core #10 – Clinical Decision Support

103

Implement one clinical decision support rule relevant to specialty or high clinical priority along with the ability to track

compliance to that rule



Implement one clinical decision support rule.

Attestation 1 Rule


• Test procedure for 170.304 (e) Clinical Decision Support

• Must implement one rule for Stage 1

• Rule must be triggered by problem list, medication list, allergy list, or other structured data

• System must provide notification, but does not supply method of notification (e.g., audio alarm, pop‐up window, red flag icon, etc.)

104

MU Core #11 – Quality Measures Reporting

105

Report ambulatory clinical quality measures to CMS or the States


Type Numerator Denominator ThresholdFor 2011, provide aggregate numerator, denominator, and exclusions through attestation as discussed in section II(A)(3) of this final rule.

For 2012, electronically submit the clinical quality measures as discussed in section II(A)(3) of this final rule.

Submission Submitted


• Test Procedure for 170.306 (i) Calculate and Submit Clinical Quality Measures

• Electronic submission specifications 170.205 (f)

• Eligible professionals must report from the table of 44 clinical quality measures which includes, 3 Core, 3 Alternate Core, and 38 additional CQMs.

• Core CQMs ‐ EPs must report on 3 required core CQMs, and if the denominatorof 1 or more of the required core measures is 0, then EPs are required to report results for up to 3 alternate core measures.

• EPs also must also select 3 additional CQMs from a set of 38 CQMs (excluding the core/alternate core measures). It is acceptable to have a '0' denominator provided the EP does not have an applicable population.

• In sum, EPs must report on 6 total measures: 3 required core measures (substituting alternate core measures where necessary) and 3 additional measures

• A maximum of 9 measures would be reported if the EP needed to attest to the 3 required core, the three alternate core, and the 3 additional measure.

106

MU Core #12 – Electronic Copy of PHI

107

Provide patients with an electronic copy of their health information (including diagnostic test results, problem list,

medication lists, medication allergies) upon request



More than 50% of all patients of the EP or the inpatient or emergency departments of the eligible hospital or CAH (POS 21 or 23) who request an electronic copy of their health information are provided it within 3 business days.

Calculation

Patients who receive an electronic copy of health info within 3 business days

Patients who request electronic copy of health information

50%


•Test Procedure for 170.304 (f) Electronic Copy of Health Information

•Electronic copy of a patient’s clinical information, including, at a minimum, diagnostic test results, problem list, medication list, and medication allergy list in:

1.Human readable format; and

2.On electronic media or through some other electronic means in accordance with:a.The standard (and applicable implementation specifications) specified in §170.205(a)(1) or §170.205(a)(2); and

b.For the following data elements the applicable standard must be used:i. Problems. The standard specified in §170.207(a)(1) or, at a minimum, the version of the standard specified in §170.207(a)(2);

ii. Laboratory test results. At a minimum, the version of the standard specified in §170.207(c); and

iii.Medications. The standard specified in §170.207(d).

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MU Core #14 – Provide Clinical Summary

109

Note MU Core #13 does not apply EPs

Provide clinical summaries for patents for each office visit



Clinical Summaries provided to patients for more than 50% of all office visits within 3 business days.

Calculation



• Test Procedure for 170.306 (d)(1) Electronic Copy of Health Information

110

MU Core #15 – Improve Care Coordination

111



Performed at least one test of certified EHR technology's capacity to electronically exchange key clinical information.

Attestation Yes/No

Capability to exchange key clinical information (for example, problem list, medication allergies, diagnostic test

results) among providers of care and patient authorized entities electronically


• Test Procedure for 170.306 (f) Exchange Clinical Information and Summary Record

112

MU Core #16 – Privacy and Security

113

Protect electronic health information created or maintained by the certified EHR technology through the

implementation of appropriate technical capabilities



Conduct or review a security risk analysis per 45 CFR 164.308 (a)(l) and implement security updates as necessary and correct identified security deficiencies as part of its risk management process.

Attestation Completed


• The privacy and security requirements refer to many previous requirements and standards including:– 45 CFR 164.308 (a)(l)

– 45 CFR 164.306 (a)

• Some general considerations include:– Password Requirements and Management

– Access Authorization

– Termination Procedures

– Disaster Recovery

– Security Awareness and Training

114


MENU REQUIREMENTS

115

10 additional EHR functions from which providers must choose 5 to implement in

Stage1

One Population or Public Health Requirement (10, 11, or 12) must be included

MU Menu #1 – Drug‐Drug Formulary Checks

116

Implement drug-formulary checks



The EP/ eligible hospital/ CAH has enabled this functionality and has access to at least one internal or external drug formulary for the entire EHR reporting period.

Attestation Enabled

Test Procedure for 170.302 (b) Drug-formulary checks

MU MENU #3 – Structured Lab Results

117

Incorporate clinical lab test results into certified EHR technology as structured data.



More than 40% of all clinical lab test results 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 or 23) during the EHR reporting period whose results are either in a positive/negative or numerical format are incorporated in a certified EHR technology as structured data.

Calculation

All lab results with + / - or numerical formatted results incorporated


40%

Note MU Menu #2 does not apply EPs

Test Procedure for 170.302 (h) Incorporate Laboratory Test Results

MU Menu #4 – Generate Patient List

118

Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities,

research or outreach



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

Attestation Yes/No

Test Procedure for 170.302 (i) Generate Patient Lists

MU Menu #5 – Appointment Reminder

119

Send reminders to patients per patient preference for preventative/ follow-up



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

Calculation


Test Procedure for 170.304 (d) Patient Reminders

MU Menu #6 – Patient Access to PHI

120

Provide patients with timely access to their health information including lab results, problem lists, medication lists, medication allergies within four business days of the

information being available to the EP



More than 10% of all unique patients seen by the EP are provided timely (available to the patient within four business days of being updated in the certified EHR technology) electronic access to their health information subject to the EP's discretion to withhold certain information

Calculation

Patients provided timely electronic access to their health information


10%

Test Procedure for 170.304 (g) Timely Access

MU Menu #7 – Specific Education Resources

121

Use certified EHR technology to identify patient-specific education resources and provide those

resources to the patient, if appropriate



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

Calculation

Patients provided patient-specific education resources


10%

Test Procedure for 170.302 (m) Patient-specific education resources

MU Menu #8 – Medication Reconciliation

122

The EP who receives a patent from another setting of care or provider of care or believes an

encounter is relevant should perform medication reconciliation



The EP, eligible hospital or CAH performs medication reconciliation for more than 50% of transitions of care in which the patient is transitioned into the care of the EP or admitted to the eligible hospital's or CAHs inpatient or emergency department (POS 21 or 23).

CalculationPatients w/ med reconciliation


50%

Test Procedure for 170.302 (j) Medication Reconciliation

MU Menu #9 – Summary of Care Records

123

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 of care record for each transition of care or referral



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

CalculationPatients w/ summary of care record


50%

Test Procedure for 170.304 (i) Exchange Clinical Information and Patient Summary Record

MU Menu #10 – Immunization Registries

124

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



Performed at least one test of certified EHR technology's capacity to submit electronic data to immunization registries and follow up submission if the test is successful (unless none of the immunization registries to which the EP, eligible hospital or CAH submits such information have the capability to receive the information electronically)

Attestation Yes/No

Test Procedure for 170.302 (k) Submission to Immunization Registries

Michigan Care Improvement Registries (MICR) Specifications and Standards

MU Menu #12 ‐ Syndromic Surveillance Data

125

Capability to submit electronic syndromic surveillance data to public health agencies and actual submission

in accordance with applicable law and practice.



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

Attestation Yes/No

Note MU Menu #11 does not apply EPs

Test Procedure for 170.302 (l) Public Health Surveillance


REGISTRATION AND SUBMISSION

126

Registration Plans

• The Medicare EHR Incentive Program will begin in early 2011

• Registration for the Medicare program will be available starting on January 3, 2011

• The Medicaid EHR Incentive Programs can also begin in 2011, but actual start dates will vary by State

• Providers will be able to access the registration system through http://www.cms.gov/EHRIncentivePrograms

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http://www.cms.gov/EHRIncentivePrograms

What can you do now?

• National Provider Identifier (NPI) ‐ All eligible professionals, eligible hospitals, and critical access hospitals (CAHs) must have a National Provider Identifier (NPI) in order to participate in the Medicare and Medicaid EHR Incentive Programs.

• National Plan and Provider Enumeration System (NPPES) ‐Most providers will need an active user account in the National Plan and Provider Enumeration System (NPPES).

• Provider Enrollment, Chain and Ownership System (PECOS) ‐ All eligible hospitals and Medicare eligible professionals must have an enrollment record in PECOS to participate in the EHR Incentive Programs. (Eligible professionals who are only participating in the Medicaid EHR Incentive Program are not required to be enrolled in PECOS.)

128

Make sure you have enrollment records in the appropriate systems

PECOS Enrollment

There are three ways to verify that you have an enrollment record in PECOS:

1. Check the Ordering Referring Report on the CMS website. If you are on that report, you have a current enrollment record in PECOS. Go to http://www.cms.gov/MedicareProviderSupEnroll/, click on "Ordering Referring Report" on the left

2. Use Internet‐based PECOS to look for your PECOS enrollment record. If no record is displayed, you do not have an enrollment record in PECOS. Go to http://www.cms.gov/MedicareProviderSupEnroll/, click on "Internet‐based PECOS" on the left

3. Contact your designated Medicare enrollment contractor and ask if you have an enrollment record in PECOS. Go to http://www.cms.gov/MedicareProviderSupEnroll/, click on "Medicare Fee‐For‐Service Contact Information" under "Downloads."��If you are not in PECOs, the best way to submit your application is through internet‐based PECOS. For more information go to: http://questions.cms.hhs.gov/app/answers/detail/a_id/10038/kw/pecos/session/L3NpZC9qeG1GdDliaw%3D%3D

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Pursuit Timeline

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Pursuit Process (GENERAL)

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Pursue Stage 2, as appropriate

• Availability of certified EMR version may drive timeline• Your focus should be how you use the system• Get solution in place and begin to monitor measures – Are

you a meaningful user?• Yr 1 reporting period 90 days; Yr 2 12 months

1-2 months 4-12 months 3-6 months