Modified Meaningful Use

Meaningful Use Program Update

History of Rulemaking and the Current State of MU

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

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

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2011 2012 2013 2014 2015 todate

Medicaid Eligible Professionals

Medicare Eligible Professionals

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.

Geographic Concentration of MU

Statewide MU AdoptionExample: CA

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

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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

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

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)

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27.59%

51.15%58.22%

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86.95% 88.14%93.29% 95.17% 99.27%

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Stage 2 Attestations Attrition % Attrition

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

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19,98018,600

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15,737

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Stage 1, 2013 Measures Stage 1, 2014 Measures Stage 2 Attestations

Attrition Attrition Rate

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

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Stage 2 Scheduled, Stage 1 2013 Measures Stage 2 Scheduled, Stage 1 2014 MeasuresStage 1 Scheduled, 2013 Measures

Modified Stage 2

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

MU Stages based on 1st Year

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

Medicare EHR Incentives

Medicaid EHR Incentives

Medicaid EHR Incentive Program

Modified Stage 2 and Stage 3 Objectives

Modified Stage 2 and Stage 3 Objectives

Objective #1 – Protect Health Information

Security Risk Analysis

• Security Risk Analysis must be completed for each reporting period

Security Risk Analysis

Security Risk Analysis

Security Risk Analysis

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

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

Objective #10 – Public Health Reporting

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)

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.

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.

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.

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

Specialty Registries Available Through NextGenShare

• Pricing based on what individual registry charges (most charge subscription, some charge installation/participation fee)

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

Alternate Exclusion 2016

Table: Measures and Exclusions for Modified Stage 2

2016 MU Reporting from NextGen® Health Quality Measures (HQM)

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

Payment Adjustments

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

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

Meaningful Use and the Medicare Access and CHIP Reauthorization Act of 2015

(MACRA)

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

MIPS: Merit-based Incentive Payment System

Positive/Negative adjustments based on benchmarked MIPS score…

Who Participates?

Years 1 and 2:

Physicians (MD/DO and DMD/DDS) PAs and NPs Clinical nurse specialists Certified registered nurse anesthetists

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

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

MU Resources for NextGen Healthcare Clients

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

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

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

Any Questions?