modified meaningful use - starkmhar · • aligns with new macra law with respect to hitech...
TRANSCRIPT
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Modified Meaningful Use
Meaningful Use Program Update
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History of Rulemaking and the Current State of MU
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MU Rulemaking Recap
• 2009 – ARRA/HITECH sets the stage • 2010 – Final Rule for Stage 1 MU• 2011 – first year of MU reporting• 2012 – Final Rule for Stage 2 MU• 2012 – first set of Stage 1 changes• 2013 – second set of Stage 1 changes• 2014 – Flexibility Rule• 2015 – Modified Stage 2 (2015-2017 Changes) and
Stage 3 Rule
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MU Program Registration
• ~550,000 eligible providers have registered for EHR incentive program (~350,000 Medicare and ~185,000 Medicaid)
• About 85% of registered providers have received EHR incentive payments
• Lag since March 2015 reflects hold for 2015 modifications rule
Medicare Eligible
Professionals
Medicaid Eligible
Professionals TotalProfessionals Paid 305,335 146,514 451,849Total of Payments $8.16 Billion $3.94 Billion $12.1 BillionPercent of Registered Professionals Paid 86% 80% 84%Stage 2 PaymentsProfessionals Paid 51,115Total of Payments $330 Million
123,648113,658
54,062 48,623
14,621
49,051 61,098
34,77824,332
13,274
0
20,000
40,000
60,000
80,000
100,000
120,000
140,000
160,000
180,000
200,000
2011 2012 2013 2014 2015 todate
Medicaid Eligible Professionals
Medicare Eligible Professionals
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Ambulatory EHR Vendor Rankings• Vendors with the highest overall Medicare MU Market Share:
1. Epic Systems Corporation2. Allscripts3. eClinicalWorks LLC4. NextGen Healthcare 5. GE Healthcare6. Greenway Health, LLC7. athenahealth, Inc.8. Practice Fusion9. McKesson10. Community Computer Service Inc.
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Geographic Concentration of MU
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Statewide MU AdoptionExample: CA
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NextGen’s Position
• NextGen has maintained 4th for overall attestations (currently ~48,000) and has steadily grown market share of attestations year over year
• Approximately 30,000 unique providers have successfully attested for ~$870 million in MU incentives using certified solutions from NextGenHealthcare
0
20,000
40,000
60,000
80,000
100,000
120,000
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180,000
2011 2012 2013 2014 2015
Epic Systems Corporation Allscripts
eClinicalWorks LLC NextGen Healthcare
GE Healthcare Greenway Health LLC
athenahealth Inc Practice Fusion
McKesson Community Computer Service Inc
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MU Stage 2
• Stage 2 attestation numbers industry-wide have continued to be low
• Stage 2 attestations account for only 6% of overall attestations
Only 15% of previously successful Medicare Meaningful Users have attested to MU Stage 2
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MU Stage 2
• Vendors with the highest Medicare MU Stage 2 market share:1. Epic Systems Corporation2. eClinicalWorks LLC3. athenahealth, Inc.4. Allscripts5. Practice Fusion6. Community Computer Service Inc.7. Greenway Health8. NextGen Healthcare9. gMed Inc.10. Eyefinity/OfficeMate
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Stage 2 Attrition
• Stage 2 attrition refers to providers who were scheduled to attest to Stage 2, but did not attest as scheduled
• Many top ten vendors struggled to get providers to attest to Stage 2
• ¾ of vendors have attrition rates of 100% (i.e., did not have any providers attest to Stage 2 despite being scheduled)
0.00%
27.59%
51.15%58.22%
73.59%
86.95% 88.14%93.29% 95.17% 99.27%
0.00%
10.00%
20.00%
30.00%
40.00%
50.00%
60.00%
70.00%
80.00%
90.00%
100.00%
0
5,000
10,000
15,000
20,000
25,000
30,000
35,000
40,000
45,000
Stage 2 Attestations Attrition % Attrition
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Overall Attrition
• Attrition here (black line) = providers who did nothing in 2014
• Industry average for overall attrition is 67%
• All top ten vendors fare much better than industry average
• NextGen’s attrition rate has not grown, despite challenges of attesting in 2014
6,603
55,454
19,98018,600
11,585
3,321
15,737
6,960
27,509
7,721
0.00%
4.05%
18.31%
24.04%25.59%
28.88%30.94%
35.20% 35.95%
42.17%
0.00%
5.00%
10.00%
15.00%
20.00%
25.00%
30.00%
35.00%
40.00%
45.00%
0
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30,000
40,000
50,000
60,000
Stage 1, 2013 Measures Stage 1, 2014 Measures Stage 2 Attestations
Attrition Attrition Rate
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MU Flexibility
• Many vendors ranking high in Stage 2 attrition, but low in overall attrition, rank high in MU Flexibility attestations
• NextGen anticipated low Stage 2 attestations as we supported clients in their opting to take advantage of the flexibility rule
• Vendors who did not support their clients’ use of the flexibility rule had higher attrition rates
0
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6,000
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Stage 2 Scheduled, Stage 1 2013 Measures Stage 2 Scheduled, Stage 1 2014 MeasuresStage 1 Scheduled, 2013 Measures
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Modified Stage 2
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Summary of Final Rule for Modified Stage 2 and Stage 3
• CMS has released one final rule for both modified Stage 2 and Stage 3 – these combined rules:
• Simplify reporting by reducing number of objectives and eliminating core/menu structure
• Get all providers onto the same stage of MU• Focus MU on interoperability and advanced EHR usage in
Stage 3• Aligns with new MACRA law with respect to HITECH
penalties• EHR reporting based on a calendar year for all providers
(EPs and EHs)• Relieve burden on patient engagement rules temporarily
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MU Stages based on 1st Year
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MU Reporting Periods
• 90 Days all first-time attesters• Full year all returning attesters2016
• 90 Days first-time attesters• 90 Days providers exercising Stage 3 option • All others full year
2017
• Full year for all2018
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Medicare EHR Incentives
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Medicaid EHR Incentives
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Medicaid EHR Incentive Program
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Modified Stage 2 and Stage 3 Objectives
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Modified Stage 2 and Stage 3 Objectives
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Objective #1 – Protect Health Information
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Security Risk Analysis
• Security Risk Analysis must be completed for each reporting period
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Security Risk Analysis
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Security Risk Analysis
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Security Risk Analysis
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What is the SRA Requirement?
• Based in both HITECH (meaningful use) and HIPAA Security Rule [45 CFR 164.308(a) (1)]
• Requires accurate and thorough written assessment outlining potential risks and vulnerabilities, security policies and procedures, and corrective actions
• Practice must update SRA each year, documenting the completion of previous corrective actions, along with any new risks and related actions
• The SRA answers some basic questions concerning electronic protected health information (ePHI):
• Where is ePHI stored and used?• How is it currently protected? • Is protection adequate? (Risks)
• P - Physical safeguards• A - Administrative safeguards• T - Technical safeguards
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A Simplified SRA Solution for MU and HIPAA
Next Gen Healthcare has partnered with HIPAA One to offer hands-on assistance and online tools to help you meet your Security Risk Assessment (SRA) obligations and reduce risk to your practice:
• HIPAA One® license and training • Network vulnerability scan• Education on security rules under MU and HIPAA• Review of existing SRA• Service packages to support client’s specific SRA needs:
– Silver – self-directed; remote training on HIPAA One tool– Gold – Guided SRA (remote)– Platinum – Comprehensive onsite SRA w/ physical walk-through
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Objective #10 – Public Health Reporting
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Public Health Reporting
One objective, 3 measures:• Measure Option 1 – Immunization Registry Reporting: The EP is
in active engagement with a public health agency to submit immunization data. (May be counted 1 time)
• Measure Option 2 – Syndromic Surveillance Reporting: The EP is in active engagement with a public health agency to submit syndromic surveillance data. (May be counted 1 time)
• Measure Option 3 – Specialized Registry Reporting: The EP is in active engagement to submit data to a specialized registry. (May be counted two times)
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Achieving ‘Active Engagement’
• Modified Stage 2 rules require “active engagement” with public health or specialized registry (as opposed to “ongoing submission” per the old rule)
• Option 1: The EP is registered to submit data with the agency, registration was completed within 60 days after the start of the EHR reporting period; and the EP is awaiting invitation to begin testing and validation.
• Option 2: The EP is in the process of testing and validation of the electronic submission of data. Providers must respond to requests from the agency within 30 days; failure to respond twice within an EHR reporting period would result in that provider not meeting the measure.
• Option 3: The EP has completed testing and validation and is submitting production data.
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Public Health Reporting
One objective, 3 measures:• 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.
An EP previously scheduled to be in Stage 2 in 2015 must meet 2 measures
An EP previously scheduled to be in Stage 1 in 2015 must meet 1 measureAll EPs must meet 2 measures in 2016 and 2017.
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Public Health Reporting
One objective, 3 measures:• 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.
All EPs must meet 2 measures in 2016 and 2017.
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Public Health Reporting
NextGen® Clinical Registry Service• Choose from several available specialty registries• Utilizes one connection from NextGen® Share to all
available registries• Simplified implementation process (self-installed through
NextGen® Share)
Note: This is a not replacement for syndromic or immunization interfaces at this time
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Specialty Registries Available Through NextGenShare
• Pricing based on what individual registry charges (most charge subscription, some charge installation/participation fee)
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Additional Specialty Registries
• These registries are available to clients outside of NextGen Share• Clients will work directly with the registries to submit data
• American Urological Association / AQUA• American Academy of Neurology / Axon• American College of Emergency Physicians / CEDR• American Board of Family Medicine / PRIME• American College of Rheumatology / RISE• American Society of Nuclear Cardiology / ImageGuide• Academy of Dermatology / DataDerm• Diabetes Collaborative Registry• American College of Cardiology / PINNACLE• American Academy of Ophthalmology / IRIS
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Alternate Exclusion 2016
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Table: Measures and Exclusions for Modified Stage 2
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2016 MU Reporting from NextGen® Health Quality Measures (HQM)
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HQM for 2016
• All clients auto-enrolled in 2016 MU Program• Released on April 8th, 2016• All providers pre-configured for full year reporting
• If in first year will need to change reporting period to 90 days
• Redundant, Duplicative, Topped Out measures:• Remain in HQM for monitoring purposes• Numbering in place for ‘reportable’ objectives
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Payment Adjustments
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Based on performance in 2016….
• New participants who successfully demonstrate meaningful use for 90 days will avoid the payment adjustment in CY 2017 if the EP successfully attests by October 1, 2016, and will avoid the payment adjustment in CY 2018 if the EP successfully attests by February 28, 2017
• Returning participants who successfully demonstrate meaningful use will avoid the payment adjustment in CY 2018 if the EP successfully attests by February 28, 2017
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Based on performance in 2017….
• New participants who successfully demonstrate meaningful use for 90 days will avoid the payment adjustment in CY 2018 if the EP successfully attests by October 1, 2017
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Meaningful Use and the Medicare Access and CHIP Reauthorization Act of 2015
(MACRA)
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MIPS and MU
• Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), signed into law in April, includes new Medicare Merit-Based Incentive Payment System (MIPS)
• Taken together with final MU rules, MIPS does the following:• Sunsets meaningful use, PQRS, and VBM penalties after 2018 • Consolidates programs and associated penalties into a new
payment system that will assess physicians in four categories• Quality measures (30%)• Resource use/cost (30%)• Clinical practice improvement activities (15%)• Meaningful use of a certified EHR (25%)
MIPS Scores (0-100) will be compared to benchmarks and used to determine positive/negative payment adjustments
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MIPS: Merit-based Incentive Payment System
Positive/Negative adjustments based on benchmarked MIPS score…
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Who Participates?
Years 1 and 2:
Physicians (MD/DO and DMD/DDS) PAs and NPs Clinical nurse specialists Certified registered nurse anesthetists
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Who Participates?
Years 3 and beyond: (may expand to include)
Physical therapists Occupational therapists Speech-language pathologists Audiologists Nurse midwives Clinical social workers Clinical psychologists Dietitians/Nutritional professionals
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Still Relevant?
MU remains relevant…
As a percentage of your MIPS score As a means of participating in quality improvement
programs and reporting quality metrics As a set of behaviors to support clinical improvement,
patient engagement/consumerism, care coordination
…even after the incentives and penalties are gone
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MU Resources for NextGen Healthcare Clients
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Complimentary Webinars
• Meaningful Use: Modified Stage 2 (Complimentary)• Meaningful Use: Question and Answer Session
(Complimentary)• New webinars coming soon!• Meaningful Use page in Success Community
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For More Information
• 2016 CMS Program Requirements• CMS Educational Resources• CMS FAQs • CMS Fact sheet on MACRA• CMS presentation MACRA/MIPS• CMS presentation on MIPS/Advancing Care
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Hardship Exceptions
• Providers may apply for hardship exceptions to avoid the payment adjustments
• Hardship exceptions are granted on a case-by-case basis
• Information on how to apply for a hardship exception is posted on the CMS EHR Incentive Programs website
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Any Questions?