modified stage 2 final rule 2015-2017 - il-hitrec modified stage 2 final rule... · for stage 1...

Modified Stage 2 Final Rule

2015-2017

Illinois Health Information TechnologyRegional Extension Center (ILHITREC)

SUPPORT PROVIDED BY ILHITREC:The Illinois Health Information Technology Regional Extension Center (ILHITREC), under contract with the Illinois Department of Health and Family Services (HFS), is providing education, outreach and support to Medicaid providers for the Electronic Health Record (EHR) Provider Incentive Payment (PIP) Program. Northern Illinois University serves as the Illinois Health Information Technology Regional Extension Center providing EHR and meaningful use services to providers in Illinois. For more information, e-mail [email protected]

mailto:[email protected]

Speaker Biography

Brenda Simms, RN, BSN, CHTS-CPBrenda is a Clinical Informatics Specialist at ILHITREC. She works with physicians, practice managers, clinical staff, billing representatives, physicians and EHR vendors to successfully plan, coordinate, and implement an electronic health record (EHR) system, as well as assist practices with workflow redesign and assists with development of required quality reporting. Brenda also worked for a time with the Central Illinois Health Information Exchange (CIHIE) to facilitate the implementation and effective adoption of HIE.

Patty Tobin, MBAPatty is a Clinical Informatics Specialist at ILHITREC, where she assists practices in quality improvement, achievement of Meaningful Use, an optimization of EHR systems. She has over 15 years dedicated to healthcare informatics. Prior to joining ILHITREC, Patty previously worked as a Healthcare IT Consultant, where she delivered a broad range of consulting engagements focused on implementing and managing healthcare data and information projects.

INTRODUCTION

Disclaimer

The target audience of this presentation is Eligible Providers, but some

references will be made related to Eligible Hospitals.

This webinar is based on official guidance provided by the Centers for Medicare and

Medicaid Services (CMS) and the Office of the National Coordinator (ONC),

experiences from ILHITREC, and other Regional Extension Centers.

This presentation was prepared as a tool to assist providers enrolled in the EHR

Incentive Program administered by CMS. The ultimate responsibility for compliance,

submission and response to any remittance from CMS rests with the provider. Medicare

policy changes frequently. It is highly recommended that providers and their designee

review rules and regulations frequently.

The focus of this presentation is an introduction to the Modified Rule for 2015- 2017.

The contents apply to both the Medicare and Medicaid EHR Incentive Programs through

CMS and the ONC.

Modified Final Rule 2015 - 2017

The Modification Rule responds to provider concerns about software implementation and information exchange readiness:

Restructures Stage 1 and Stage 2 Objective measures to align with Stage 3:

EP: 10 Objectives, including 1 consolidated public health objective

EH/CAH: 9 Objectives, including 1 consolidated public health objective

Streamlines program by removing redundant, duplicative and topped out measures

Modifies patient action measures in Stage 2 objectives related to patient engagement that requires “patient action”

Starting in 2015, aligns reporting period with the calendar year for all providers

Changes EHR reporting period in 2015 to 90-day period to accommodate modifications

All providers attest to Modified Stage 2 Objectives unless this is the first year of participation

CQM reporting for all remains as previously finalized

“Blending” of Objective Measures

Beginning in 2015, Stage 1 and Stage 2 objectives and measures are “Blended” into a single set of objectives

Replaces previous structure of Core and Menu measures Accommodations are made for Stage 1 providers Stage objectives are based on 1st payment year (excluding AIU)

First Payment

Year 2015 2016 2017 2018

Modified Stage 2

Or Stage 3

Modified Stage 2

Or Stage 3

Modified Stage 2

Or Stage 3

Modified Stage 2

Or Stage 3

Modified Stage 2

Or Stage 3

Modified Stage 2

Or Stage 3

Stage of Meaningful Use

2011 Modified Stage 2 Modified Stage 2 Stage 3



2016 - NA - Modified Stage 2 Stage 3

2014 Modified Stage 2* Modified Stage 2 Stage 3

2015 Modified Stage 2* Modified Stage 2 Stage 3

Participation Timeline

Attest to Modified Stage 2 (with accommodations for Stage 1 providers)2015

Attest to Modified Stage 2

(Some alternate exclusions remain for Stage 1 providers)2016

Attest to either Modified Stage 2

or full version of Stage 32017

2018 Attest to full version of Stage 3

Reporting Periods

- All providers attest to EHR reporting period of any continuous 90-day period within calendar year.2015

2016

2017

2018

- First-time participants may use any 90-day period

- Returning participants must report the full calendar year

- First-time participants may use any 90-day period


- Stage 3 participants may use any 90-day period

- First-time Medicaid participants may use any 90-day period


Previous EP Stage 1 Objectives

13 Core Objectives

5 of 9 Menu Objectives

EP Objectives for 2015-2017 (Modified Stage 2)

10 Objectives (including one consolidated public health reporting

objective with 3 measure options)

Previous EH/CAH Stage 1 Objectives

11 Core Objectives


EH/CAH Objectives for 2015-2017 (Modified Stage 2)



EP

EH/CAH

Changes from Stage 1

Previous EP Stage 1 Objectives

17 Core Objectives (including public health objectives)


EP Objectives for 2015-2017 (Modified Stage 2)



Previous EH/CAH Stage 1 Objectives

16 Core Objectives (including public health objectives)


EH/CAH Objectives for 2015-2017 (Modified Stage 2)



EP

EH/CAH

Changes from Stage 2

EHR Certification

2015 – No changes to the 2014 CEHRT currently in use

2018 – Required to update CEHRT to 2015 standards

Note: Providers may upgrade early to technology certified to the 2015 Edition

for EHR reporting period prior to 2018 as outlined in the rule

Reporting Year Certified EHR Technology Edition

2015 2014 CEHRT

2016 - 2017 2014 or 2015 CEHRT

2018 2015 CEHRT

Major Changes to Objectives Beginning in 2015

Changing threshold from Stage 2 objective for Patient Electronic Access

measure #2, from 5%, to equal to or greater than 1 patient seen by provider

or discharged from hospital

Changing threshold from Stage 2 objective Secure Electronic Messaging

from percent to functionality fully enabled (yes/no)

Consolidating all public health reporting objectives into one objective with

measure options following structure of Stage 3 Public Health Reporting

objective

Changing eligible hospital electronic prescribing objective from “menu” to

“core” with an exclusion available for certain eligible hospitals/CAHs

Alternate Exclusions and Specifications for Stage 1 Providers for Meaningful Use in 2015

Any provider scheduled to demonstrate Stage 1 who was not intending to attest to the Stage 1 Patient Specific Education menu objective, may claim an exclusion to the measure.

Please note that beginning in 2016, all providers must attest to the objective and measure, and meet the Modified Stage 2 specifications and threshold, in order to successfully demonstrate meaningful use, except for CPOE.

Core Problem List

Core Record Demographics

Core Record Vital Signs*

Core Record Smoking Status*

Core Clinical Summaries

Menu Structured Lab Results

Menu Patient Lists

Menu Patient Reminders

Menu Summary of Care (Measures 1 & 3)

Scheduled for Stage 2 Beginning in 2015 Electronic Notes

Scheduled for Stage 2 Beginning in 2015 Image Results

Scheduled for Stage 2 Beginning in 2015 Family Health History

Topped Out Measures – No Longer Required to Report

*Modified Stage 2

Modified Stage 2 Objectives for Eligible Providers

Modified Stage 2Minimum Required for Providers

Scheduled for Stage 1Data in Certified EHR only Data in Certified EHR only

5 rules, 4 related to CQMs 1 CDS Rule

Objective 3: CPOE Meds/Labs/Radiology 60% / 30% / 30% 30% / Exclusion / Exclusion

Objective 4: Electronic Prescribing 50% 40%

Objective 5: Health Information Exchange

Part 2: Electronically submit summary 10% May claim an exclusion

Objective 6: Patient Specific Education 10%May claim an exclusion if EP did not intend

to select this Stage 1 Menu Objective

50%May claim an exclusion if EP did not intend


Objective 8: Patient Electronic Access

Part 1: Timely Access 50% 50%

Part 2: Patient VDT 1 patient VDT May claim an exclusion

Objective 9: Secure Electronic Messaging Function Enabled May claim an exclusion

Objective 10: Public Health Reporting Report on 2 Options Report on 1 Option

Objective

Objective 7: Medication Reconciliation

Objective 1: Protect Patient Health Information

Objective 2: Clinical Decision Support

Payment Adjustment and Hardship Exceptions

Reporting 2015 Penalty Year Reporting 2016 Penalty Year

New ParticipantAny 90-day Period CY 2016 - 2017

Any 90-day Period* (1/1/16 - 10/1/16)

CY 2018

Returning Participant Any 90-day Period CY 2016 Full Calendar Year CY 2018

The EHR reporting periods for the payment adjustment will begin and end prior to the year of the payment adjustment

Providers may apply for a hardship exception to avoid the payment adjustments.Hardship exceptions are granted on a case-by-case basis.Information on how to apply is posted on the CMS EHR Incentive Program Websitehttps://www.cms.gov/Regulations-and-guidance/Legislation/EHRIncentivePrograms/PaymentAdj_Hardship.html

Attestation Deadline for CY:

Medicare = February 29, 2016 (Website available January 4, 2016)

Medicaid = March 31, 2016 (To Be Announced)

https://www.cms.gov/Regulations-and-guidance/Legislation/EHRIncentivePrograms/PaymentAdj_Hardship.html

Preparing for participation in 2015

Confirm your Stage Check registration information: NPPES Login Information Make sure email address is correct Make sure payment information is correct Identify and Access Management (I&A) and/or Surrogate

Users Info up to date Illinois Medicaid EHR Incentive Program Participants:

Register and Link surrogates to providers in Medi Impact Registrations (Must register in both systems)

Complete Attestations EARLY, do not wait until the last minute ILHITREC is available to provide assistance and answer questions.

OBJECTIVE OVERVIEW

Modified Stage 2 Objectives for EPsObjective 1: Protect Patient Health Info/Security Risk Assessment

Objective 2: Clinical Decision Support + Drug Interactions

Objective 3: CPOE for Medication, Laboratory, and Radiology Orders

Objective 4: Electronic Prescribing (eRx)

Objective 5: Health Information Exchange (Summary of Care)

Objective 6: Patient Specific Education


Objective 8: Patient Electronic Access (VDT)

Objective 9: Secure Electronic Messaging (EPs Only)

Objective 10: Public Health Reporting

Progression of Stages for Eligible ProvidersRetired Stage 1 Retired Stage 2 Modified Stage 2

Core 1: CPOE for Medication Orders Core 1: CPOE for Medication, Laboratory, Radiology Objective 3: CPOE for Medication, Laboratory, Radiology

Core 2: Drug Interaction Checks No longer a separate objective (incorporated into CDS) No longer a separate or required objective

Core 3: Maintain Problem List No longer a separate objective (incorporated into SOC) No longer a separate or required objective

Core 4: Electronic Prescribing (eRx) Core 2: Electronic Prescribing (eRx) Objective 4: Electronic Prescribing (eRx)

Core 5: Active Med List No longer a separate objective (incorporated into SOC) No longer a separate or required objective

Core 6: Active Med Allergy List No longer a separate objective (incorporated into SOC) No longer a separate or required objective

Core 7: Record Demographics Core 3: Record Demographics No longer a separate or required objective

Core 8: Record Vital Signs Core 4: Record Vital Signs No longer a separate or required objective

Core 9: Record Smoking Status Core 5: Record Smoking Status No longer a separate or required objective

Core 10: Clinical Decision Support Core 6: Clinical Decision Support + Drug Interactions Objective 2: Clinical Decision Support + Drug Interactions

Core 11: Patient Electronic Access Core 10: Patient Electronic Access Objective 8: Patient Electronic Access

Core 12: Clinical Summaries Core 11: Clinical Summaries No longer a separate or required objective

Core 13: Protect Electronic Health Info/SRA Core 17: Protect Electronic Health Info/SRA Objective 1: Protect Electronic Health Info/SRA

Menu 1: Drug Formulary Checks No longer a separate objective (incorporated into eRx) No longer a separate or required objective

Menu 2: Clinical Lab-test Results Core 7: Clinical Lab-test Results No longer a separate or required objective

Menu 3: Patient Lists Core 8: Patient Lists No longer a separate or required objective

Menu 4: Patient Reminders Core 9: Patient Reminders No longer a separate or required objective

Menu 5: Patient-specific Education Core 12: Patient-specific Education Objective 6: Patient-specific Education

Menu 6: Medication Reconciliation Core 14: Medication Reconciliation Objective 7: Medication Reconciliation

Menu 7: Summary Care Record Core 15: Summary of Care Objective 5: Health Information Exchange

Menu 8: Immunization Registry Core 16: Immunization Registry Objective 10: Public Health Option

Menu 9: Syndromic Surveillance Menu 3: Syndromic Surveillance Objective 10: Public Health Option

Core 13: Secure Electronic Messaging Objective 9: Secure Electronic Messaging

Menu 1: Imaging Results No longer a separate or required objective

Menu 2: Family History No longer a separate or required objective

Menu 4: Cancer RegistryNo longer a separate or required objective

(May count towards the Specialized Registry Reporting)

Menu 5: Specialized Registry Objective 10: Public Health Option

Menu 6: eProgress Notes No longer a separate or required objective









Objective 9: Secure Electronic Messaging


Objective 1: Protect Patient Health Information/SRA

Conduct or review a security risk analysis including addressing the encryption/security of data stored in Certified EHR Technology, and implement security updates as necessary and correct identified security deficiencies as part of the EPs risk management process.

Note: This measure should be in accordance with the Code of Federal Regulations: 45CFR164.308(a)(1); 45CFR164.312(a)(2)(iv); 45CFR164.306(d)(3), and organizations must follow the risk analysis guidance in accordance with the HIPAA Security Rule (issued by the Office for Civil Rights).

Measure:

Alternate Exclusions and Specifications for Stage 1 Providers in 2015

Objective Modified Stage 2 Requirements Alternate Stage 1 Requirements

Protect Patient Health InfoConduct or review

security risk analysisNone

Note: Free Security Risk Assessment (SRA) Tool developed by ONC and OCR: https://www.healthit.gov/providers-professionals/security-risk-assessment-tool

https://www.healthit.gov/providers-professionals/security-risk-assessment-tool

https://www.healthit.gov/providers-professionals/security-risk-assessment-tool


Measure 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.

Measure 2: The EP has enabled and implemented the functionality for drug-drug and drug allergy interaction checks for the entire reporting period.Exclusion: Any EP who writes fewer than 100 medication orders during the reporting period.


Measure Modified Stage 2 Requirements Alternate Stage 1 Requirements

1. Clinical Decision Support 5 rules, 4 related to CQMs 1 CDS Rule

2. Drug Interactions Functionality Enabled None

Objective 3: Computerized Provider Order Entry

Measure 1: Medication Orders - More than 60% of medication orders created by the EP during the reporting period are recorded using CPOE.Exclusion: Any EP who writes fewer than 100 medication orders during the reporting period.

Measure 2: Laboratory Orders - More than 30% of laboratory orders created by the EP during the reporting period are recorded using CPOE.Exclusion: Any EP who writes fewer than 100 laboratory orders during the reporting period.

Measure 3: Radiology Orders - More than 30% of radiology orders created by the EP during the reporting period are recorded using CPOE.Exclusion: Any EP who writes fewer than 100 radiology orders during the reporting period.

Alternate Exclusions and Specifications for Stage 1 Providers


1. Medication Orders 60% 2015: 30%

2. Laboratory Orders 30% 2015 and 2016: Exclusion

3. Radiology Orders 30% 2015 and 2016: Exclusion


Measure: More than 50% 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: Any EP who writes fewer than 100 permissible prescriptions during the reporting period. Or any EP who does not have a pharmacy within his or her organization and there are no pharmacies that accept electronic prescriptions within 10 miles of the EP's practice location at the start of the reporting period.



Electronic Prescribing 50% 40%


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

Exclusion: Any EP who transfers a patient to another setting or refers a patient to another provider less than 100 times during the reporting period.

(1) uses CEHRT to create a summary of care record, and

(2) electronically transmits such summary to a receiving provider for more than 10% of transitions of care and referrals.



Part 2: Electronically Transmit

Summary of Care10% May claim an exclusion in 2015


Measure: Patient specific education resources identified by Certified EHR Technology are provided to patients for more than 10 percent of all unique patients with office visits seen by the EP during the EHR reporting period.

Exclusion: Any EP who has no office visits during the reporting period.



Patient Specific Education 10%May claim an exclusion if EP did not intend



Measure: The EP performs medication reconciliation for more than 50% of transitions of care in which the patient is transitioned into the care of the EP.

Exclusion: Any EP who was not the recipient of any transitions of care during the EHR reporting period.



Medication Reconciliation 50%May claim an exclusion if EP did not intend


Objective 8: Patient Electronic Access

Measure 1: More than 50% 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.

Measure 2: In 2015 or 2016 reporting period, at least one patient seen by the EP during the reporting period views, downloads, or transmits his or her health information to a third party.

In 2017 reporting period, more than 5% of unique patients seen by the EP during the reporting period view, download, or transmit their health information to a third party.

Exclusions: Any EP who neither orders nor creates any of the info listed for inclusion as part of the measures; or the EP practices in a county with less than 4 Mbps broadband.



Measure 1: Timely Access 50% 50%

Measure 2: Patient View,

Download, or Transmit (VDT)

2015: 1 patient

2016: 1 patient

2017: 5%

May claim an exclusion in 2015









Objective 9: Secure Electronic Messaging (EPs Only)



Measure: In 2015, the capability for patients to send and receive a secure electronic message with the EP was fully enabled during the reporting period.

In 2016, for at least 1 patient seen by the EP during the reporting period, a secure message was sent using the electronic messaging function to the patient, or in response to a secure message sent by the patient during the reporting period.

In 2017, for more than 5% of unique patients seen by the EP during the reporting period, a secure message was sent using the electronic messaging function to the patient, or in response to a secure message sent by the patient during the reporting period.

Exclusions: An EP has no office visits during the reporting period, or the EP practices in a county with less than 4 Mbps broadband.



Secure Electronic Messaging

2015: Fully Enabled

2016: 1 Patient

2017: 5%

May claim an exclusion in 2015

if EP did not intend to select this

Stage 1 Menu Objective


Measure:


The EP is in active engagement with a Public Health Agency (PHA) to submit electronic public health data in a meaningful way. The EP is required to successfully attest to any combination of 2 of the possible 3 measures:

Measure 1: Immunization Registry ReportingMeasure 2: Syndromic Surveillance ReportingMeasure 3: Specialized Registry Reporting

Exclusions: Measure 1: EP does not administer any immunizations during the reporting period.Measure 2: EP does not treat or diagnose any disease or condition associated with syndromic surveillance. Measure 3: EP does not diagnose or treat any disease or condition associated with or collect relevant data that is required by a specialized registry.Applies to all 3 measures: The registry cannot accept electronic information, or the registry has not announced readiness to accept information.


Public Health Reporting Report on 2 Options Report on 1 Option

Clinical Quality Measures

No changes to CQM selection or reporting scheme (EPs must report on 9 of the 64 approved CQMs)

For EHR reporting period in 2015 (and for providers participating for first time in 2016), providers attest to any continuous 90-day period of CQM data

Registration and Attestation site – Providers also have option to electronically report CQM data using established methods for electronic reporting

For 2016 and subsequent years, providers beyond first year of meaningful use may attest to one full calendar year of CQM data or electronically report CQM data using established methods for electronic reporting outlined

Stage 3 Objectives for Eligible Providers

Objective 1: Protect Patient Health Information

Objective 2: Electronic Prescribing

Objective 3: Clinical Decision Support

Objective 4: Computerized Provider Order Entry

Objective 5: Patient Electronic Access to Health Information

Objective 6: Coordination of Care through Patient Engagement


Objective 8: Public Health and Clinical Data Registry

2015 2016 2017 2018

First Year in MUAny 90-day Period

(1/1/15 – 12/31/15)Any 90-day Period

(By October 1, 2016)Any 90-day Period

(By October 1, 2017)One Year

Returning Participant Any 90-day Period One YearStage 2 – One YearStage 3 – 90-days

One Year

2015 2016 2017 2018

Penalty YearModified Stage 2

(With Alternate Exclusions and Specifications for Stage 1 Providers)

Modified Stage 2(With Alternate Exclusions and

Specifications for Stage 1 Providers)

Modified Stage 2(Or Stage 3)

Stage 3

2015 2016 2017 2018

Objectives and CQMs

9 Objectives2 Public Health Objectives

9 CQMs Minimum of 3/6 Domains(Alternative for Stage 1 Providers)

Modified Stage 2(Some alternate

exclusions remain for Stage 1 providers)

Modified Stage 2(Or Stage 3)

Stage 3

Summary

Additional References

Final Rule – Modification 2015 -2017https://s3.amazonaws.com/public-inspection.federalregister.gov/2015-25595.pdf

CMS EHR Incentive Programhttps://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/index.html

CMS FAQshttps://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/FAQ.html

2015 Requirementshttps://www.cms.gov/Regulations-and-guidance/Legislation/EHRIncentivePrograms/2015ProgramRequirements.html

IDPH Public Health Objectives (MURS)https://murs.illinois.gov/

IMPACThttp://www.illinois.gov/hfs/impact/Pages/default.aspx

https://s3.amazonaws.com/public-inspection.federalregister.gov/2015-25595.pdf

https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/index.html

https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/FAQ.html

https://www.cms.gov/Regulations-and-guidance/Legislation/EHRIncentivePrograms/2015ProgramRequirements.html

https://murs.illinois.gov/

http://www.illinois.gov/hfs/impact/Pages/default.aspx

Questions?

Contact Information:

Brenda [email protected]

Patty [email protected]

http://www.ilhitrec.org

[email protected]

(815) 753-5900



http://www.ilhitrec.org/


modified stage 2 final rule 2015-2017 - il-hitrec modified stage 2 final rule... · for stage 1...

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