AAMC Contacts:Ivy Baer: Ibaer@aamc.orgLori Mihalich-Levin: Lmlevin@aamc.orgJennifer Faerberg: Jfaerberg@aamc.orgMary Wheatley: Mwheatley@aamc.orgScott Wetzel: Swetzel@aamc.org

Meaningful Use Stage 2 Proposed RuleProposed rule: http://www.gpo.gov/fdsys/pkg/FR-2012-03-07/pdf/2012-4443.pdf

AAMC comment letter: https://www.aamc.org/download/281814/data/aamccommentletteronmeaningfulusestage2proposedrule.pdf

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Are you an eligible professional (EP)?

YES

NO: $0; no penalty

Are you a non-hospital based EP? (CMS)

Are you using certified EHR technology (ONC)?

Have you attested to core & menu measures of meaningful use (CMS)?

YES

YES

YES

INCENTIVE! (CMS)!

Stage 2 Decision Tree: Medicare

Have you attested to EP quality measures (CMS)?

YES

NO

NO

NO

NO

2015: Unless are hospital-based or meet an exception, penalty begins

Stages of Meaningful Use By Payment Year

First Payment Year

Payment Year

2011 2012 2013 2014 2015 2016 2017

2011 Stage 1 Stage 1 Stage 1 Stage 2 Stage 2 Stage 3 Stage 3

2012 Stage 1 Stage 1 Stage 2 Stage 2 Stage 3 Stage 3

2013 Stage 1 Stage 1 Stage 2 Stage 2 Stage 3

2014 Stage 1 Stage 1 Stage 2 Stage 2Source: Federal Register, Table 2 (March 7, 2012 p. 13703)

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Stage 1 Stage 2

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EPs15 core5 or 10 menu20 total objectives

EPs17 core3 of 5 menu20 total objectives

Hospitals/CAHs14 core15 of 10 menu19 total objectives

Hospitals/CAHs16 core2 of 4 menu18 total objectives

Stage 1 Menu Moved to Proposed Stage 2 Core Implement drug-formulary checksRecord existence of advance directives (core for EH

only)Incorporate lab results as structured data (only where

results are available)Generate pt lists for specific conditionsSend pt remindersSummary of care recordSubmit reportable lab data (core for EH only)Submit syndromic surveillance data

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Measure EP EH

30% visits have at least 1 electronic EP note 30% of EH pt days have at least one e-note by MD, NP or PA 30% of EH med orders automatically tracked via electronic med admin recording

80% of pts offered ability to view and download via web-based portal w/in 36 hrs of discharge relevant info in the record

Online secure pt messaging in use Pt preferences for communication medium recorded for 20% of pts List of care team members (including PCP) available for 10% of pts in EHR

Record of longitudinal care plan for 20% of pts with high priority health conditions

New Measures – Proposed

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Through 2013 – • Report 3 core/alternate core + 3 measures (EPs)• Attest to results or EHR-PQRS pilot submission (EPs)• Continue to report 15 CQMs finalized in Stage 1 (Hospitals)

Changes in 2014 – • Criteria for CQM same for all stages (EPs)• 3 options for reporting, including group reporting (EPs)• Electronic submission (EPs)• Report 24 out of 49 (proposed) CQMs (Hospitals)• Must have at least one measure in each of the six quality domains

(Hospitals)• Ability to pick the measures most relevant to their patient population or

services offered (Hospitals)

Major Clinical Quality Measure (CQM) Changes (EPs and Hospitals)

2014 CQM - 3 Options for EPs

1a) 12 measures/6 domains

• At least one measure in each of the 6 domains

• 125 measures

1b) 11 “core” plus 1 measure

• 11 core measures listed

• One additional measure

2) PQRS-EHR

• Follows rules for PQRS-EHR submission

• Could change in future rule-making

Group Reporting

• >=2 NPI per Tax ID Number

• ACOs*• GPRO*

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OR

CMS will finalize either option 1a or 1b.

* Option only available for Medicare EHR Incentive

Group Reporting - CQM• Three possible methods

• 2 or more NPIs within single TIN• ACO• GPRO

• Group options available for:• CQM reporting only AND• All EPs in the group are beyond the first year

of Stage 1• Data must be reported from Certified EHR

Technology

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Penalties- EPsIn general, a penalty will be based on data from 2

years prior to the penalty. (Exception: EPs can apply up to Oct of the previous year if it is their first year of MU)

Determining 2015 penalty:• 1% percent reduction based on 2013 reporting

period (for most EPs)• Can report until Oct 2014 if first year

reporting• Additional 1% reduction if not an e-prescriber in

2014

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Existing Meaningful User:• MU for All of FY 2013• Attest by November 30, 2013

New Meaningful User:• MU for April 3, - June 2, 2014• Attest by July 1, 2014

Existing Meaningful User:• MU for All of FY 2014• Attest by November 30, 2014

Existing Meaningful User:• MU for April 3, - June 2, 2015• Attest by July 1, 2015

To avoid penalties, do what by when? (Hospitals)

2015

2016

To Avoid Penalties in FY:

• The requirements and timelines for achieving Meaningful Use Stage 2 are too aggressive.

• New attesters should have more time to meet the requirements for Meaningful Use Stage 1.

• The core measures in the proposed rule are new and untested and therefore greater flexibility should be provided to hospitals and EPs to report this information.

• The proposed CQMs are not market ready and would not lead to better outcomes in patient care. These quality measures should not be incorporated into the pay-for-performance programs without a supplemental process to ensure the validity of the EHR data capture.

• A group reporting option for CQMs and meaningful use measures should be implemented.

 

AAMC Concerns/Comments with the Proposed Rule

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