DisclaimerThis webinar may be recorded. This webinar presents a sampling of best practices and overviews, generalities, and some laws. This should not be used as legal advice. Itentive recognizes that there is not a “one size fits

all” solution for the ideas expressed in this webinar; we invite you to follow up directly with us for more personalized information as it pertains

to your specific practice and issues.

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About UsOur passion is to provide solutions for our healthcare provider partners which help them improve patient care, enhance the patient experience and maintain a financially healthy practice.

Since 2003 we have specialized in NextGen Healthcare services including:

• Consulting

• Hosting

• Customization

• And productivity tools such as ChartGuard® and RefundManager®

Upcoming Webinars:

• Using NextGen Share in the Real World Wednesday, February 24, 2016

• The Steps to a Patients Centered Medical Home Wednesday, March 16, 2016

• Quality Care Program Reporting: So Many Choices, So Little Time Wednesday, April 13, 2016

Meaningful Use Objectives and

Hardship Exception Clarification

Introductions

Cindi KincadeVice President,

Consulting Solutions

Lindsey LanningHealthcare Informatics

Coordinator

Meaningful Use Objectives and

Hardship ExceptionClarification

Today’s Webinar

• Public Health Objective and Measures

• Registry Basics

• How to Achieve Public Health Reporting through Registries

• Public Health Reporting Exclusions

• Meaningful Use Hardship Exception

• Other Miscellaneous MU Updates

• The Future of Meaningful Use

Meaningful Use Public Health Reporting

Public Health Objective

The EP is actively engaged with a Public Health Agency or Clinical Data Registry to submit electronic public health data in a meaningful way using CEHRT, except where prohibited, and in accordance with applicable law and practice.

Public Health Measure

The EP is required to successfully attest to any combination of 2 measures from 3 available:

What This Means• This means you can have any combination of the following

measures:

Immunization registry reporting + syndromic surveillance reporting

Immunization registry reporting + specialized registry reporting

Syndromic surveillance reporting + specialized registry reporting

Specialized registry reporting + different specialized registry reporting

• An EP who is scheduled to be in Stage 1 in 2015 must report at least one measure unless they can exclude from all available measures. Stage 2 EPs must meet at least 2 measures in 2015, and all EPs must meet at least 2 measures in 2016 and 2017.

Active Engagement

In order to successfully meet the public health reporting objective a provider must be in active engagement with a public health agency or a clinical data registry.

Originally, the objective used the verbiage “ongoing submission”, but changed it in order to better capture a physician’s actions.

Active Engagement Option 1To be considered in active engagement a provider has three options:

• Option 1: Completed registration to submit data:

Registration was completed within 60 days after the start of the EHR reporting period and the EP is awaiting an invitation from the PHA or CDR to begin testing.

Registration to two public health agencies or specialized registries needs to be completed by February 29, 2016 in order to meet the deadline to achieve active engagement in 2016.

*** Once you have registered your intent with two registries before Feb. 29, 2016 you are successfully meeting this objective. Just make sure to respond to any requests for information throughout the year.

Active Engagement Option 2 & 3

• Option 2: Testing and Validation: EP is in the process of testing and validation

of the electronic submission of data. EPs must respond to requests from the PHA within 30 days; failure to respond twice within a reporting period would result in failure to meet this objective.

• Option 3: Production: EP has completed testing and validation and

is electronically submitting production data to a PHA or CDR.

Active Engagement

Under the active engagement requirement, providers would only need to register once with a public health agency or a clinical data registry and could register before the reporting period begins.

In addition, previous registrations with a public health agency or clinical data registry that occurred in a previous stage of meaningful use could count toward active engagement option 1 for any of the EHR reporting periods in 2015, 2016, or 2017.

What are Registries?

What is a Registry

As defined by the NCVHS,• A registry is an organized system for

the collection, storage, retrieval, analysis, and dissemination of information on individual persons.

• Registries are operated by Federal, state and local governments, universities, non-profits, private groups, hospitals, etc.

Registry Characteristics

These are some of the characteristics that distinguish them from other technologies:

• The use of a Registry is distinct from an EHR

• The EHR collects data directly from providers

• The Registry audits, validates, analyzes and reports data

• Registries are focused on measuring and improving outcomes over time

Registry Trends

Reporting data to a public health registry has been moving… • From paper to electronic media and

transmission of data

• From periodic batch uploads to real time updates

• From one-way transfer to bi-directional exchange

Registries We Will Talk About Today

• Clinical Data Registry

• Public Health Registry

• Specialized Registry

Clinical Data Registry

• Collect clinical data to track care and outcomes of a specific patient population.

• It has many purposes:

Focuses on health problems (incidence and prevalence)

Benchmarks performance and feedback to providers

Identifies care gaps

• Overall: to provide more information in order to improve care outcomes and care coordination

Public Health Registry

• Sponsored by a state/local/regional/national public health agency

• Immunization registries fall into this category Every state should have an

immunization registry

Specialized Registry

“A variety of registries may be considered specialized registries, which allows providers the flexibility to report using a registry that is most

helpful to their patients. We will continue to allow these registries to be considered

specialized registries for purposes of reporting for the EHR Reporting periods in 2015, 2016, and

2017.”

Specialized Registry

• Under the MU rules, a Specialty or Specialized Registry could be one created by any of the specialty societies or other quality stakeholder groups.

• This is what CMS describes:

“In the Stage 2 final rule, we were purposefully general in our use of the term "specialized registry" (other than a cancer registry)…to encompass both registry reporting to public health agencies and clinical data registries in order to prevent inadvertent exclusion of certain registries through an attempt to be more specific.”

How to Achieve Registry Reporting

NextGen Clinical RegistryNextGen Clinical Registry Service utilizes NextGen Share to allow access to the following registries:

While there is no cost to use NextGen Share, subscription and/or participation fees apply (costs vary depending on the individual registry). The first step is to register your intent with the registries of your choice and satisfy any applicable registry fees.

NextGen FAQ

According to a NextGen published FAQ, NextGen Clinical Registry Service provides the capability to connect to specialized registries and meet measure #3 of the public health objective, but cannot be used for immunization or syndromic registry reporting at this time.

How Does It Work?Per NextGen, Interfaces to the individual registries will be self-installable and configurable from the NextGen Share portal.

The NextGen EHR will export a C-CDA for each patient upon encounter lock and send to NextGen Share for registry submission.

The C-CDA’s will be evaluated for measure compliance with each registry your providers are signed up for.

Providers will also have the ability to log into a portal and track their progress for quality submissions with each registry.

Interfaces

If the registry is not available in NextGen Share and the registry does not accept data extraction upload then an interface may be required. These registries require data to be submitted on a regular basis through an HL7 interface.

• Immunization and syndromic have NextGen HL7 interfaces

• There will be a cost associated with building an interface

Data Extraction

There are registries available that do not utilize NextGen Share and therefore do not have a direct relationship with NextGen, and also do not require a commercial interface. Instead, these registries enable data extraction by working directly with the practice and are available to clients outside of NextGen Share.

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

Other Specialty Registry OptionsIf you are a specialty practice struggling to find a specialized registry, here are some other options available to meet the specialized registry reporting measure:

• DartNet

Patient Safety Registry

• National Health Care Surveys

National Ambulatory Medical Care

In the white paper for objective 10 public health reporting, NextGen lists registries separated by type that are available in each state.

2015 Specialty Registry Reporting Options

• Prescription Drug Monitoring Program

CMS states, “We continue to allow registries such as Prescription Drug Monitoring Program reporting and electronic case reporting registries to be considered specialized registries for purposes of reporting the EHR Reporting period in 2015.”

• Cancer Registry

EPs who were previously planning to attest to the cancer case reporting objective, may count that action toward the Specialized Registry reporting measure. (2015-2017)

BUT for Stage 3 (optional in 2017, mandatory in 2018)- A specialized registry cannot be duplicative of any of the other registries or reporting included in other meaningful use requirements.

Public Health Reporting Exclusions

What Do They Mean?

• An exclusion allows a provider to be excused from attesting to a specific measure based on certain criteria laid out by CMS they must meet.

• An exclusion for a public health reporting measure does not count toward the total of two measures needed to successfully attest. Instead, in order to meet this objective an EP would need to meet two of the total number of measures available to them.

For 2015, if the EP qualifies for multiple exclusions and the remaining number of measures available to the EP is less than two, the EP can meet the objective by meeting the one remaining measure available to them and claiming the applicable exclusions.

Immunization Reporting ExclusionThe EP is excluded from immunization registry reporting if the EP:

• Does not administer any immunizations to any of the populations for which data is collected by its jurisdiction's immunization registry during the EHR reporting period;

• Operates in a jurisdiction for which no immunization registry is capable of accepting the specific standards required to meet the CEHRT definition at the start of the EHR reporting period; or

• Operates in a jurisdiction where no immunization registry has declared readiness to receive immunization data from the EP at the start of the EHR reporting period.

Syndromic Surveillance ExclusionThe EP is excluded from syndromic surveillance reporting if the EP:

• Is not in a category of providers from which ambulatory syndromic surveillance data is collected by their jurisdiction's syndromic surveillance system;

• Operates in a jurisdiction for which no public health agency is capable of receiving electronic syndromic surveillance data from EPs in the specific standards required to meet the CEHRT definition at the start of the EHR reporting period; or

• Operates in a jurisdiction where no public health agency has declared readiness to receive syndromic surveillance data from EPs at the start of the EHR reporting period.

Specialized Registry ExclusionThe EP is excluded from specialized registry reporting if the EP:

• Does not diagnose or treat any disease or condition associated with, or collect relevant data that is collected by, a specialized registry in their jurisdiction during the EHR reporting period;

• Operates in a jurisdiction for which no specialized registry is capable of accepting electronic registry transactions in the specific standards required to meet the CEHRT definition at the start of the EHR reporting period; or

• Operates in a jurisdiction where no specialized registry for which the EP is eligible has declared readiness to receive electronic registry transactions at the beginning of the EHR reporting period.

Alternate Exclusions (2015 ONLY)• EPs scheduled to be in Stage 1: Must attest to at least 1

measure from the Public Health Reporting Objective Measures 1-3.

May claim an Alternate Exclusion for Measure 1, Measure 2, or Measure 3.

An Alternate Exclusion may only be claimed for up to two measures, then the provider must either attest to or meet the standard exclusion requirements for the remaining measure.

• EPs scheduled to be in Stage 2: Must attest to at least 2 measures from the Public Health Reporting Objective Measures 1-3.

May claim an Alternate Exclusion for Measure 2 or Measure 3 (Syndromic Surveillance Measure or Specialized Registry Reporting Measure) or both (updated in November).

Alternate Exclusions (2016 ONLY)EPs, eligible hospitals and CAHs that were scheduled to be in Stage 1 in 2016 may claim an alternate exclusion for an EHR reporting period in 2016 for Objective 3: Computerized Provider Order Entry, Measures 2 and 3 (lab and radiology orders), or choose the modified Stage 2 objective and measures.

How to Attest Using Alternate Exclusions

The Medicare and Medicaid EHR Incentive Programs registration and attestation system will automatically identify those providers who are eligible for alternate exclusions.

Upon attestation, these providers will be offered the option to attest to the Modified Stage 2 objective and measure, and the option to attest to the alternate exclusion, if applicable.

The provider may independently select the option available to them for each measure for which an alternate exclusion may apply.

Meaningful Use Hardship Exception

What Is It?• Eligible professionals who can participate in either

the Medicare or Medicaid EHR Incentive Programs will be subject to payment adjustments unless they are meaningful users under one of the EHR Incentive Programs.

• Eligible professionals may apply for hardship exceptions to avoid these payment adjustments.

Provides relief from MU penalties, however it does not replace any incentive payment that an EP forfeits

• Hardship exceptions will be granted only under specific circumstances and only if CMS determines that providers have demonstrated that those circumstances pose a significant barrier to their achieving meaningful use.

2016 Penalties

• The Centers for Medicare & Medicaid Services (CMS) announced that there will be 209,000 EPs subject to a 2016 penalty under Medicare for failing to demonstrate Meaningful Use in 2014.

• CMS projects that, based on the estimated Medicare claims volume, the majority of EPs will be subject to a penaltay that is less than $1,000. CMS published the following breakdown of EPs and their expected penalties:

13,900 EPs will receive a penalty of less than $100

103,000 EPs will receive a penalty of $100- $1,000

30,400 EPs will receive a penalty of $1,000 - $5,000

56,000 EPs will receive a penalty of $5,000 - $10,000

Hardship Exception Reasons• Insufficient Internet Connectivity

In order to be approved for this hardship exception, the provider(s) must attest to practicing in an area without sufficient internet access or facing insurmountable barriers to obtaining infrastructure (e.g. lack of broadband).

• Lack of Control over CEHRT Availability

In order to be approved for this hardship exception, the EP(s) must attest to a lack of control over the availability of certified EHR technology in 1 or more practice locations where more than 50 percent of the patient encounters occurred.

• Lack of Face-To-Face Patient Interaction

In order to be approved for this hardship exception, the EP(s) must attest to a complete lack of face-to-face patient interaction and follow-up or that the cases of face-to-face interaction and follow-up were extremely rare and not part of the normal scope of business.

Hardship Exception Reasons

Extreme and Uncontrollable Circumstances• In order to be approved for this hardship

exception, the provider(s) must attest to facing Extreme and Uncontrollable Circumstances as listed below that prevented the provider(s) from demonstrating meaningful use.

Disaster

Practice or Hospital Closure

Severe Financial Distress

EHR Certification/Vendor Issues

Extreme and Uncontrollable Circumstances

Streamlined Hardship Exception

• In previous years, providers had to apply individually for a hardship exception valid for one payment year, and each application was reviewed on a case-by-case basis.

• Under this new streamlined hardship exception providers would not have to meet such stringent criteria and qualifications and their applications would not be reviewed on a case-by-case basis.

Failed Attempts

• Two acts that were unsuccessful in enacting a blanket hardship exception were: Meaningful Use

Hardship Relief Act Electronic Health

Fairness Act

• But there was one that was successful…

Patient Access and Medicare Protection Act

This act expands the authority of CMS to grant hardship exceptions to Meaningful Use participants for the 2015 program year.

They would allow eligible hospitals and eligible physicians who find it impossible to comply with the modified Stage 2 rule released into the final 90-day reporting period of 2015 to apply under the "Extreme and Uncontrollable Circumstances" category.

The legislation enables CMS to grant hardships not just on a case-by-case basis, but also to "categories" with the deadline of March 15, 2016 for EPs after which time CMS would still have the case-by-case authority to grant hardship exceptions until July 1, 2016.

CMS Updated FAQ• CMS does not require an EP, eligible hospital, or CAH – or any

group of providers – to submit documentation for the hardship category selected and CMS will not be reviewing documentation supporting the application on a case-by-case basis. CMS will review the application to record the category selected and use the identifying information to approve the hardship exception for each provider listed on the application. Providers should retain documentation of their circumstances for their own records, but no such documentation is required for review by CMS.

• Providers who experienced an issue with their CEHRT related to the rule timing – and any other provider for whom the timing of the rule caused a significant hardship – should select sub-category 2.2d on the 2017 hardship exception application. No additional documentation is required for this selection.

Hardship Exception Application

• Is now available on CMS’ website with instructions.

• NextGen has said that there will be no need to provide hardship letters.

• This application will allow groups of healthcare providers to apply for a hardship exception together instead of each doctor applying individually.

Meaningful Use Objective Updates 2016

Patient Engagement Clarification

“If the provider fails to provide access to a patient upon an initial visit during the EHR reporting period, but provides access on a

subsequent visit, the patient cannot be counted in the numerator because the

patient did not have timely online access to health information related to the first visit.”

Update to Patient Engagement• Historically, Meaningful Use

objectives requiring patients to take specific actions have been proven very challenging for EPs to meet. However, a recently published FAQ outlines a new calculation for these type of measures.

• When a patient of any one of the group’s EPs sends a secure message, receives educational materials electronically, or accesses via a portal their health information, any EP in the group can now count that patient towards their own numerator for patient action measures.

Updates to Secure Message

• For 2015 reporting period, the threshold that a secure message must be sent using electronic messaging of CEHRT by more than 5% of patients changed to just having secure messaging fully enabled.

• Now, for 2016 reporting period a secure message must be sent using CEHRT for at least 1 patient .

Attestation Update

• CMS has updated its meaningful use batch upload page for the 2015 program year. Groups may upload all of its meaningful use attestation materials in one batch file rather than in separate files. When using this method, eligible providers will still need to independently register for the program, or have someone else do that for them on their behalf.

• Additionally, each provider type, stage number, and measure category also require separate submissions.

• CMS will accept submissions for the 2015 program year between January 4, 2016 and February 29, 2016.

The attestation website is up and running

NextGen as a Top Performing Vendor in Meaningful Use

According to data from the ONC, NextGen had the fourth highest number of total EP attestations at 19,461.

So…Will Meaningful Use Even Be Around in

2016??

Meaningful Use to End in 2016?• Earlier this month, CMS and the AMA convened at the 34th Annual JP

Morgan Healthcare Conference to discuss the future of the healthcare industry and the direction meaningful use is likely to take moving forward.

• CMS’s acting administrator Andy Slavitt explained that the meaningful use program in its current nature will essentially end. Slavitt was quoted saying,

“The meaningful use program as it has existed will now effectively be over, and replaced with something better.”

• Slavitt did not offer many details, but did say that more news would be coming in the next few months. He offered some insight into what this next phase would look like with a shift toward provider-oriented EHR use

• As the meaningful use program progresses and evolves in these next few months Slavitt points out the purpose behind these major changes saying

“We have to get the hearts and minds of physicians back. I think we’ve lost them.”

What We Need to Remember• Nothing can happen without legislation!

• They already had their chance to get rid of Meaningful Use with MACRA and choose not to.

• MACRA regulations are intended to be released in 2016, which will change the program as we know it but as of now MU is still a part of a provider’s MIPS composite score.

• CMS released a blog in response to the industry’s reaction to the announcement saying, “The current law requires that we continue to measure the meaningful use of CEHRT under the existing set of standards. It [MACRA] does not eliminate it, nor will it instantly eliminate all the tensions of the current system. We encourage you to look for the MACRA regulations this year; in the meantime, our existing regulations – including meaningful use Stage 3 – are still in effect.”

Reminders

• HQM reports for 2016 are in development and are not available yet.

There is a flexible date range report that is available if clients open a ticket with NG that will allow them to monitor 2016 but they are not the official 2016 reports.

• CMS 2016 reporting requirements have been posted on CMS’ website as of last week.

• Providers need to register their intent with TWO registries by February 29th, 2016.

• All returning attesters are reporting for a FULL calendar year in 2016.

Uncertain Where Your Practice Stands?

Let Itentive help:• By assessing your current readiness

• Providing recommendations

• Implementation of new processes and procedures

Next Steps

• Visit us Itentive.com

• Sign-up for our informative webinars and blog

• Consider our 3-day, fixed price on-site consultations:

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• Test Drive our Products

Questions• Lindsey Lanning

Healthcare Informatics Coordinator llanning@Itentive.com 224-220-5621

• Kathy Thompson

Managing Consultant kthompson@Itentive.com 224-220-5531

• Cindi Kincade

Vice President, Client Solutions ckincade@Itentive.com 224-220-5575

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