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Meaningful Use Modified Stage 2 Brett Paepke, OD

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Page 1: Meaningful Use Modified Stage 2 - RevolutionEHR · 2015-09-12 · Meaningful Use Modified Stage 2 Brett Paepke, OD • Notice of Proposed Rulemaking for MU 2015 - 2017 1. reduce reporting

Meaningful UseModified Stage 2

Brett Paepke, OD

Page 2: Meaningful Use Modified Stage 2 - RevolutionEHR · 2015-09-12 · Meaningful Use Modified Stage 2 Brett Paepke, OD • Notice of Proposed Rulemaking for MU 2015 - 2017 1. reduce reporting

• Notice of Proposed Rulemaking for MU 2015 - 20171. reduce reporting requirements2. align reporting periods with calendar year3. modify patient engagement measures

• Ideas discussed are not official yet.

Page 3: Meaningful Use Modified Stage 2 - RevolutionEHR · 2015-09-12 · Meaningful Use Modified Stage 2 Brett Paepke, OD • Notice of Proposed Rulemaking for MU 2015 - 2017 1. reduce reporting

Traditional Stages of MU

2011 2012 2013 2014 2015 2016 2017

2011 1 1 1 2 2 2 3

2012 1 1 2 2 2 3

2013 1 1 2 2 3

2014 1 1 2 2

2015 1 1 2

2016 1 1

2017 1

First Year of

MU

Page 4: Meaningful Use Modified Stage 2 - RevolutionEHR · 2015-09-12 · Meaningful Use Modified Stage 2 Brett Paepke, OD • Notice of Proposed Rulemaking for MU 2015 - 2017 1. reduce reporting

What is Modified Stage 2?

• Stage 1 and Stage 2 blended into one concept

• All EPs in 2015 and 2016 must demonstrate Modified Stage 2 success.

• 2017 would be the provider’s choice of Modified Stage 2 or Stage 3

• 10 total objectives + Clinical Quality Measure reporting• All objectives are required. No Core/Menu differentiation• Eliminates “topped out” objectives

• i.e., Patient Demographics• 25th percentile: 97%• 50th percentile: 99%• 75th percentile: 99.8%

Page 5: Meaningful Use Modified Stage 2 - RevolutionEHR · 2015-09-12 · Meaningful Use Modified Stage 2 Brett Paepke, OD • Notice of Proposed Rulemaking for MU 2015 - 2017 1. reduce reporting

First Year of Meaningful Use Stage of Meaningful Use

2015 2016 2017 2018

2011 Modified Stage 2 Modified Stage 2 Modified Stage 2 or Stage 3 Stage 3

2012 Modified Stage 2 Modified Stage 2 Modified Stage 2 or Stage 3 Stage 3

2013 Modified Stage 2 Modified Stage 2 Modified Stage 2 or Stage 3 Stage 3

2014 Modified Stage 2 Modified Stage 2 Modified Stage 2 or Stage 3 Stage 3

2015 Modified Stage 2 Modified Stage 2 Modified Stage 2 or Stage 3 Stage 3

2016 n/a Modified Stage 2 Modified Stage 2 or Stage 3 Stage 3

Page 6: Meaningful Use Modified Stage 2 - RevolutionEHR · 2015-09-12 · Meaningful Use Modified Stage 2 Brett Paepke, OD • Notice of Proposed Rulemaking for MU 2015 - 2017 1. reduce reporting

Reporting Periods

2015

• any 90 consecutive days for all EPs

• attestation cannot be completed until 2016 (1/1/16 - 2/29/16) 2016

• any 90 consecutive days for new EPs

• full calendar year for all others 2017+

• full calendar year for all Medicare EPs (including new EPs)

•Medicaid EPs will always have “any 90 consecutive day” 1st year

Page 7: Meaningful Use Modified Stage 2 - RevolutionEHR · 2015-09-12 · Meaningful Use Modified Stage 2 Brett Paepke, OD • Notice of Proposed Rulemaking for MU 2015 - 2017 1. reduce reporting

Modified Stage 2 ReorganizationCore 1 - CPOECore 2 - eRxCore 3 - DemographicsCore 4 - Vital SignsCore 5 - Smoking StatusCore 6 - Clinical Decision SupportCore 7 - Incorporate Clinical Lab-Test ResultsCore 8 - Patient Lists Core 9 - Preventative CareCore 10 - Patient Electronic AccessCore 11 - Clinical SummariesCore 12 - Patient Specific Educational ResourcesCore 13 - Medication ReconciliationCore 14 - Summary of CareCore 15 - Immunization Registries Data SubmissionCore 16 - Protect Electronic Health InformationCore 17 - Secure Electronic MessagingMenu 1 - Syndromic SurveillanceMenu 2 - Electronic NotesMenu 3 - Imaging ResultsMenu 4 - Family Health HistoryMenu 5 - Report Cancer CasesMenu 6 - Report Specific Cases

Page 8: Meaningful Use Modified Stage 2 - RevolutionEHR · 2015-09-12 · Meaningful Use Modified Stage 2 Brett Paepke, OD • Notice of Proposed Rulemaking for MU 2015 - 2017 1. reduce reporting

Modified Stage 2 Objectives

Protect Electronic Health Information

Proposed Objective Protect electronic health information created or maintained by the CEHRT through the implementation of appropriate technical capabilities.

Proposed Measure

Conduct or review a security risk analysis in accordance withthe requirements in 45 CFR 164.308(a)(1), including addressing the security (to include encryption) of data stored in Certified EHR Technology in accordance with requirements in 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

Exclusions None

Alternate Specifications for

EPs due for Stage 1 in 2015

None

Page 9: Meaningful Use Modified Stage 2 - RevolutionEHR · 2015-09-12 · Meaningful Use Modified Stage 2 Brett Paepke, OD • Notice of Proposed Rulemaking for MU 2015 - 2017 1. reduce reporting

Modified Stage 2 Objectives

• SRA can be performed anytime during the calendar year as long as it is completed by the day of attestation.

• 3rd party assistance not required, but a very good idea considering the evolution of audits• OIG• HIPAA• CMS

• Essentials of the Security Risk Analysis webinar with Marni Anderson

Page 10: Meaningful Use Modified Stage 2 - RevolutionEHR · 2015-09-12 · Meaningful Use Modified Stage 2 Brett Paepke, OD • Notice of Proposed Rulemaking for MU 2015 - 2017 1. reduce reporting

Modified Stage 2 Objectives

Clinical Decision Support

Proposed Objective Use clinical decision support to improve performance on high-priority health conditions

Proposed Measures

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

2. The EP has enabled and implemented the functionality for drug-drug and drug allergy interaction checks for the entire EHR reporting period

Exclusions Any EP who writes fewer than 100 medication orders during the EHR reporting period can exclude from measure 2

Alternate Specifications for

EPs due for Stage 1 in 2015

Proposed Objective: Implement one clinical decision support rule relevant to specialty

Proposed Measure: Implement one clinical decision support rule. It is also proposed that drug-drug and drug-allergy interaction checks in measure 2 above must be met since it’s the same as a Stage 1 objective

Page 11: Meaningful Use Modified Stage 2 - RevolutionEHR · 2015-09-12 · Meaningful Use Modified Stage 2 Brett Paepke, OD • Notice of Proposed Rulemaking for MU 2015 - 2017 1. reduce reporting

Modified Stage 2 Objectives

Computerized Provider Order Entry

Proposed ObjectiveUse computerized provider order entry (CPOE) for medication, laboratory, and diagnostic imaging orders directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local, and professional guidelines

Proposed Measures

1. More than 60 percent of medication orders created by the EP during the EHR reporting period are recorded using computerized provider order entry

2. More than 30 percent of laboratory orders created by the EP during the EHR reporting period are recorded using computerized provider order entry

3. More than 30 percent of diagnostic imaging orders created by the EP during the EHR reporting period are recorded using computerized provider order entry

Exclusions Any EP who writes fewer than 100 medication, laboratory, or diagnostic imaging orders during the EHR reporting period can exclude from that measure

Alternate Specifications for EPs due for Stage 1 in 2015

Proposed Measure: More than 30 percent of medication orders created by the EP during the EHR reporting period are recorded using computerized provider order entry

Providers due for Stage 1 in 2015 can exclude from measures 2 and 3 as they do not exist in Stage 1

Page 12: Meaningful Use Modified Stage 2 - RevolutionEHR · 2015-09-12 · Meaningful Use Modified Stage 2 Brett Paepke, OD • Notice of Proposed Rulemaking for MU 2015 - 2017 1. reduce reporting

Modified Stage 2 Objectives

Electronic Prescribing

Proposed Objective Generate and transmit permissible prescriptions electronically (eRx)

Proposed MeasureMore than 50 percent of all permissible prescriptions, or all prescriptions, written by the EP are queried for a drug formulary and transmitted electronically using Certified EHR Technology

Exclusions

1. Any EP who writes fewer than 100 permissible prescriptions during the EHR reporting period

2. An EP who does not have a pharmacy within his or her organization and does not have a pharmacy that accepts electronic prescriptions within 10 miles of the EP's practice location at the start of his or her EHR reporting period

Alternate Specifications for

EPs due for Stage 1 in 2015

Proposed Measure: More than 40 percent of all permissible prescriptions written by the EP are transmitted electronically using Certified EHR Technology

Page 13: Meaningful Use Modified Stage 2 - RevolutionEHR · 2015-09-12 · Meaningful Use Modified Stage 2 Brett Paepke, OD • Notice of Proposed Rulemaking for MU 2015 - 2017 1. reduce reporting

Modified Stage 2 Objectives

Summary of Care

Proposed ObjectiveThe EP who transitions their patient to another setting of care or refers their patient to another provider of care provides a summary care record for each transition of care or referral

Proposed Measure

The EP that transitions or refers their patient to another setting of care or provider of care:

1. uses CEHRT to create a summary of care record

2. electronically transmits the summary to a receiving provider for more than 10 percent of transitions of care and referrals

Exclusions Any EP who refers a patient to another provider less than 100 times during the EHR reporting period

Alternate Specifications for

EPs due for Stage 1 in 2015

EP may claim an exclusion for this objective since Stage 1 does not have an equivalent

Page 14: Meaningful Use Modified Stage 2 - RevolutionEHR · 2015-09-12 · Meaningful Use Modified Stage 2 Brett Paepke, OD • Notice of Proposed Rulemaking for MU 2015 - 2017 1. reduce reporting

Modified Stage 2 Objectives

Patient-Specific Education

Proposed ObjectiveUse clinically relevant information from Certified EHR Technology to identify patient-specific education resources and provide those resources to the patient

Proposed MeasurePatient-specific education resources identified by Certified EHR Technology are provided to more than 10 percent of all unique patients seen by the EP during the EHR reporting period

Exclusions Any EP who has no office visits during the EHR reporting period

Alternate Specifications for

EPs due for Stage 1 in 2015

EP may claim an exclusion for the measure if they did not intend to select the Stage 1 Patient Specific Education menu objective

Page 15: Meaningful Use Modified Stage 2 - RevolutionEHR · 2015-09-12 · Meaningful Use Modified Stage 2 Brett Paepke, OD • Notice of Proposed Rulemaking for MU 2015 - 2017 1. reduce reporting

Modified Stage 2 Objectives

Medication Reconciliation

Proposed ObjectiveThe EP who receives a patient from another setting of care or provider of care or believes an encounter is relevant should perform medication reconciliation

Proposed Measure The EP performs medication reconciliation for more than 50 percent of encounters with new patients and inbound transitions of care.

Exclusions Any EP who saw no new patients and was not the recipient of any transitions of care during the EHR reporting period

Alternate Specifications for

EPs due for Stage 1 in 2015

EP may claim an exclusion for the measure if they did not intend to select the Stage 1 Medication Reconciliation menu objective

Page 16: Meaningful Use Modified Stage 2 - RevolutionEHR · 2015-09-12 · Meaningful Use Modified Stage 2 Brett Paepke, OD • Notice of Proposed Rulemaking for MU 2015 - 2017 1. reduce reporting

Modified Stage 2 Objectives

Patient Electronic Access

Proposed Objective Provide patients the ability to view online, download, and transmit their health information within 4 business days of the information being available to the EP

Proposed Measures

An EP must meet both measures:

1. More than 50 percent of all unique patients seen by the EP during the EHR reporting period are provided timely (within 4 business days after the information is available to the EP) online access to their health information

2. At least one patient seen by the EP during the EHR reporting period (or their authorized representatives) views, downloads, or transmits his or her health information to a third party

Exclusions

Any EP who:

1. Neither orders nor creates any of the information listed for inclusion as part of the measures; or

2. 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 (www.broadbandmap.gov)

Alternate Specifications for EPs due for Stage 1 in 2015

EP may claim an exclusion for measure 2 since Stage 1 does not have an equivalent

Page 17: Meaningful Use Modified Stage 2 - RevolutionEHR · 2015-09-12 · Meaningful Use Modified Stage 2 Brett Paepke, OD • Notice of Proposed Rulemaking for MU 2015 - 2017 1. reduce reporting

Modified Stage 2 Objectives

Secure Electronic Messaging

Proposed Objective Use secure electronic messaging to communicate with patients on relevant health information

Proposed Measure During the EHR reporting period, the capability for patients to send and receive a secure electronic message with the provider was fully enabled

Exclusions

Any EP who:

1. has no office visits during the EHR reporting period, or

2. 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 (www.broadbandmap.gov)

Alternate Specifications for EPs

due for Stage 1 in 2015

EP may claim an exclusion since Stage 1 does not have an equivalent

Page 18: Meaningful Use Modified Stage 2 - RevolutionEHR · 2015-09-12 · Meaningful Use Modified Stage 2 Brett Paepke, OD • Notice of Proposed Rulemaking for MU 2015 - 2017 1. reduce reporting

Modified Stage 2 Objectives

Public Health and Clinical Data Registry Reporting

Proposed ObjectiveThe EP is in active engagement with a PHA or CDR to submit electronic public health data in a meaningful way using certified EHR technology, except where prohibited, and in accordance with applicable law and practice

Proposed MeasuresThere are a total of six possible measures for this objective. EPs would be required to choose from measures 1 through 5, and would be required to successfully attest to any combination of two measures

Exclusions 3 available for each measure

Alternate Specifications for EPs

due for Stage 1 in 2015

EP must report at least one measure unless they can exclude from all available measures

Page 19: Meaningful Use Modified Stage 2 - RevolutionEHR · 2015-09-12 · Meaningful Use Modified Stage 2 Brett Paepke, OD • Notice of Proposed Rulemaking for MU 2015 - 2017 1. reduce reporting

Public Health and Clinical Data Registry Reporting

What is “Active Engagement”?

The EP is moving toward the submission of real patient data. This can be demonstrated 1 of 3 ways:

1. Completed registration with a PHA or CDR within 60 days after the start of reporting period

2. Testing of data submission process initiated

3. Actively submitting patient data

Page 20: Meaningful Use Modified Stage 2 - RevolutionEHR · 2015-09-12 · Meaningful Use Modified Stage 2 Brett Paepke, OD • Notice of Proposed Rulemaking for MU 2015 - 2017 1. reduce reporting

Public Health and Clinical Data Registry Reporting

Exclusions:

• Do not count as satisfying a measure• i.e. EP cannot exclude from Immunization Registry Reporting on grounds

that they didn’t perform any immunizations during reporting period and have that count as 1 of the 2 measures they need to meet.

• In the event that 2 measures don’t apply, EP can report on whatever is applicable and claim an exclusion for the non-relevant measures

• Will introduction of AOA’s MORE affect your ability to exclude from a measure?

Page 21: Meaningful Use Modified Stage 2 - RevolutionEHR · 2015-09-12 · Meaningful Use Modified Stage 2 Brett Paepke, OD • Notice of Proposed Rulemaking for MU 2015 - 2017 1. reduce reporting

Summary• Proposed reporting periods

• 2015: any 90 consecutive days (1/1/15 - 12/31/15)• 2016: any 90 consecutive days for new EPs, full year for all others• 2017: full year for all EPs (including new EPs)

• MU in 2015 would involve 10 objectives based mainly on Stage 2 measures • Key Proposed Changes

• V/D/T Actual Use would change from >5% to “equal to or greater than 1”• Secure Messaging would change from >5% to “Yes/No” for having

functionality enabled• All public health reporting objectives consolidated into one objective with

multiple measures

• Providers due for Stage 1 in 2015 would have special exclusions and thresholds • All EPs held to same standards in 2016

• No attestation for 2015 reporting periods until 1/1/16 - 2/29/16

Page 22: Meaningful Use Modified Stage 2 - RevolutionEHR · 2015-09-12 · Meaningful Use Modified Stage 2 Brett Paepke, OD • Notice of Proposed Rulemaking for MU 2015 - 2017 1. reduce reporting

Next – 9:30 to 10:15 am• Meaningful Use - Stage 3 – Learn about and prepare for Meaningful Use

Stage 3 through a forward-looking discussion of the objectives and expectations.

Page 23: Meaningful Use Modified Stage 2 - RevolutionEHR · 2015-09-12 · Meaningful Use Modified Stage 2 Brett Paepke, OD • Notice of Proposed Rulemaking for MU 2015 - 2017 1. reduce reporting