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How to Play by the (Final) Rules:
An Overview of Meaningful Use Stage 2 and the
Standards and Certification Criteria Final Rules
Presented by:
- Travis Broome, MBA, MPH – Policy Analyst, Office of eHealth Standards and
Services, CMS
- Steve Posnack, MHS, MS, CISSP - Director of the Federal Policy Division, ONC
Moderated by:
- Kate Berry, CEO, NeHC
August 30, 2012
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Presentation slides are now available!
http://www.nationalehealth.org/FinalRules
Recorded webinar will be on our website by 5:00PM ET.
Full transcript will be available in approximately 7 to 10 days.
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Medicare & Medicaid
EHR Incentive Programs
Stage 2 Final Rule
Travis Broome, Centers for Medicare & Medicaid Services
NeHC
8-30-12
What is in the Rule
q Changes to Stage 1 of meaningful use
q Stage 2 of meaningful use
q New clinical quality measures
q New clinical quality measure reporting mechanisms
q Payment adjustments and hardships
q Medicare Advantage program changes
q Medicaid program changes
10
What Stage 2 Means to You
q New Criteria – Starting in 2014, providers participating
in the EHR Incentive Programs who have met Stage 1
for two or three years will need to meet meaningful use
Stage 2 criteria.
q Improving Patient Care – Stage 2 includes new
objectives to improve patient care through better
clinical decision support, care coordination and patient
engagement.
q Saving Money, Time, Lives – With this next stage,
EHRs will further save our health care system money,
save time for doctors and hospitals, and save lives.
11
Stage 2 Eligibility
12
EHR Incentive Program Eligibility
1. In general, eligibility is determined by the HITECH
Act.
2. There have been no changes to the HITECH Act.
3. Therefore the only eligibility changes are those
within our regulatory purview under the Medicaid
EHR Incentive Program.
13
Stage 2 Change: Hospital-Based EP
Definition
EPs can demonstrate that they fund the acquisition,
implementation, and maintenance of CEHRT, including
supporting hardware and interfaces needed for meaningful
use without reimbursement from an eligible hospital or
CAH — in lieu of using the hospital’s CEHRT — can be
determined non-hospital-based and potentially receive an
incentive payment.
Determination will be made through an
application process.
14
Stage 2 Meaningful Use
15
Stages of Meaningful Use
Improved
outcomes
Advanced
clinical
processes
Data
capturing
and sharing
Stage 3
Stage 2
Stage 1
16
What is Your Meaningful Use Path?
For Medicare EPs:
17
What is Your Meaningful Use Path?
For Medicare Hospitals:
18
Meaningful Use:
Changes from Stage 1 to Stage 2
Stage 1
Stage 2
Eligible Professionals
Eligible Professionals
15 core objectives
17 core objectives
5 of 10 menu objectives
3 of 6 menu objectives
20 total objectives
20 total objectives
Eligible Hospitals &
CAHs
Eligible Hospitals &
CAHs
14 core objectives
16 core objectives
5 of 10 menu objectives
3 of 6 menu objectives
19 total objectives
19 total objectives
19
Changes to Meaningful Use
Changes
No Changes
q Menu Objective Exclusion–
While you can continue to
claim exclusions if applicable
for menu objectives, starting in
2014 these exclusions will no
longer count towards the
number of menu objectives
needed.
q Half of Outpatient
Encounters– at least 50% of EP
outpatient encounters must
occur at locations equipped
with certified EHR technology.
q Measure compliance =
objective compliance
q Denominators based on
outpatient locations equipped
with CEHRT and include all
such encounters or only those
for patients whose records are
in CEHRT depending on the
measure.
20
2014 Changes
1. EHRs Meeting ONC 2014 Standards – starting in 2014,
all EHR Incentive Programs participants will have to
adopt certified EHR technology that meets ONC’s
Standards & Certification Criteria 2014 Final Rule
2. Reporting Period Reduced to Three Months – to allow
providers time to adopt 2014 certified EHR technology
and prepare for Stage 2, all participants will have a threemonth reporting period in 2014.
21
Stage 2: Batch Reporting
Stage 2 rule allows for batch reporting.
What does that mean?
Starting in 2014, groups will be allowed to submit
attestation information for all of their individual EPs
in one file for upload to the Attestation System,
rather than having each EP individually enter data.
22
Stage 2 EP Core Objectives
EPs must meet all 17 core objectives:
Core Objective
Measure
1. CPOE
Use CPOE for more than 60% of medication, 30% of
laboratory, and 30% of radiology
2. E-Rx
E-Rx for more than 50%
3. Demographics
Record demographics for more than 80%
4. Vital Signs
Record vital signs for more than 80%
5. Smoking Status
Record smoking status for more than 80%
6. Interventions
Implement 5 clinical decision support interventions +
drug/drug and drug/allergy
7. Labs
Incorporate lab results for more than 55%
8. Patient List
Generate patient list by specific condition
9. Preventive Reminders
Use EHR to identify and provide reminders for
preventive/follow-up care for more than 10% of patients
with two or more office visits in the last 2 years
23
Stage 2 EP Core Objectives
EPs must meet all 17 core objectives:
Core Objective
Measure
10. Patient Access
Provide online access to health information for more than
50% with more than 5% actually accessing
11. Visit Summaries
Provide office visit summaries for more than 50% of office
visits
12. Education Resources
Use EHR to identify and provide education resources more
than 10%
13. Secure Messages
More than 5% of patients send secure messages to their EP
14. Rx Reconciliation
15. Summary of Care
Medication reconciliation at more than 50% of transitions of
care
Provide summary of care document for more than 50% of
transitions of care and referrals with 10% sent
electronically and at least one sent to a recipient with a
different EHR vendor or successfully testing with CMS
test EHR
16. Immunizations
Successful ongoing transmission of immunization data
17. Security Analysis
Conduct or review security analysis and incorporate in risk
management process
24
Stage 2 EP Menu Objectives
EPs must select 3 out of the 6:
Menu Objective
Measure
1. Imaging Results
More than 10% of imaging results are accessible through
Certified EHR Technology
2. Family History
Record family health history for more than 20%
3. Syndromic Surveillance
Successful ongoing transmission of syndromic
surveillance data
4. Cancer
Successful ongoing transmission of cancer case
information
5. Specialized Registry
Successful ongoing transmission of data to a specialized
registry
6. Progress Notes
Enter an electronic progress note for more than 30% of
unique patients
25
Stage 2 Hospital Core Objectives
Eligible hospitals must meet all 16 core objectives:
Core Objective
Measure
1. CPOE
Use CPOE for more than 60% of medication, 30% of
laboratory, and 30% of radiology
2. Demographics
Record demographics for more than 80%
3. Vital Signs
Record vital signs for more than 80%
4. Smoking Status
Record smoking status for more than 80%
5. Interventions
Implement 5 clinical decision support interventions +
drug/drug and drug/allergy
6. Labs
Incorporate lab results for more than 55%
7. Patient List
Generate patient list by specific condition
8. eMAR
eMAR is implemented and used for more than 10% of
medication orders
26
Stage 2 Hospital Core Objectives
Eligible hospitals must meet all 16 core objectives:
Core Objective
Measure
9. Patient Access
Provide online access to health information for more than
50% with more than 5% actually accessing
10. Education Resources
Use EHR to identify and provide education resources
more than 10%
11. Rx Reconciliation
Medication reconciliation at more than 50% of transitions
of care
12. Summary of Care
Provide summary of care document for more than 50% of
transitions of care and referrals with 10% sent
electronically and at least one sent to a recipient with a
different EHR vendor or successfully testing with CMS
test EHR
13. Immunizations
Successful ongoing transmission of immunization data
14. Labs
Successful ongoing submission of reportable laboratory
results
15. Syndromic Surveillance
Successful ongoing submission of electronic syndromic
surveillance data
16. Security Analysis
Conduct or review security analysis and incorporate in
risk management process
27
Stage 2 Hospital Menu Objectives
Eligible Hospitals must select 3 out of the 6:
Menu Objective
Measure
1. Progress Notes
Enter an electronic progress note for more than 30% of
unique patients
2. E-Rx
More than 10% electronic prescribing (eRx) of discharge
medication orders
3. Imaging Results
More than 10% of imaging results are accessible through
Certified EHR Technology
4. Family History
Record family health history for more than 20%
5. Advanced Directives
Record advanced directives for more than 50% of patients
65 years or older
6. Labs
Provide structured electronic lab results to EPs for more
than 20%
28
Closer Look at Stage 2:
Patient Engagement
• Patient engagement – engagement is an important focus of
Stage 2.
Requirements for Patient Action:
• More than 5% of patients must send secure messages to their EP
• More than 5% of patients must access their health information
online
• EXCULSIONS – CMS is introducing exclusions based on
broadband availability in the provider’s county.
29
Closer Look at Stage 2:
Electronic Exchange
Stage 2 focuses on actual use cases of electronic
information exchange:
• Stage 2 requires that a provider send a summary of care record for more
than 50% of transitions of care and referrals.
• The rule also requires that a provider electronically transmit a summary
of care for more than 10% of transitions of care and referrals.
• At least one summary of care document sent electronically to recipient
with different EHR vendor or to CMS test EHR.
30
Changes to Stage 1: CPOE
Current Stage 1 Measure
Denominator=
New Stage 1 Option
Unique patient
with at least one
medication in
their medication
list
Denominator=
Number of
orders during
the EHR
Reporting Period
This optional CPOE denominator is available in 2013 and beyond for
Stage 1
31
Changes to Stage 1: Vital Signs
New Stage 1 Measure
Current Stage 1 Measure
Age Limits=
Age 2 for Blood
Pressure &
Height/ Weight
Exclusion=
All three
elements not
relevant to scope
of practice
Age Limits=
Age 3 for Blood
Pressure, No age
limit for Height/
Weight
Exclusion=
Blood pressure
to be separated
from height
/weight
The vital signs changes are optional in 2013, but required starting in
2014
30
Changes to Stage 1:
Testing of HIE
Current Stage 1 Measure
Stage 1 Measure Removed
One test of
electronic
transmission of key
clinical information
Requirement
removed effective
2013
The removal of this measure is effective starting in 2013
33
Changes to Stage 1:
E-Copy & Online Access
New Stage 1 Objective
Current Stage 1 Objective
Objective=
Provide patients
with e-copy of
health information
upon request
Objective=
Provide electronic
access to health
information
Provide patients
the ability to
view online,
download and
transmit their
health
information
• The measure of the new objective is 50% of patients have accessed their
information; there is no requirement that 5% of patients do access their
information for Stage 1.
• The change in objective takes effect in 2014 to coincide with the 2014
certification and standards criteria
34
34
Changes to Stage 1:
Public Health Objectives
Current Stage 1 Objectives
New Stage 1 Addition
Immunizations
Addition of
“except where
prohibited” to
all three
objectives
Reportable
Labs
Syndromic
Surveillance
This addition is for clarity purposes and does not change the Stage 1
measure for these objectives.
35
Clinical Quality
Measures
36
CQM Reporting in 2013
• CQM reporting will remain the same through 2013.
•
44 EP CQMs
•
•
•
3 core or alternate core (if reporting zeroes in the core) plus 3 additional CQMs
Report minimum of 6 CQMs (up to 9 CQMs if any core CQMs were zeroes)
15 Eligible Hospital and CAH CQMs
•
Report all 15 CQMs
• In 2012 and continued in 2013, there are two reporting
methods available for reporting the Stage 1 measures:
•
•
Attestation
eReporting pilots
•
Physician Quality Reporting System EHR Incentive Program Pilot for EPs
•
eReporting Pilot for eligible hospitals and CAHs
• Medicaid providers submit CQMs according to their
state-based submission requirements.
37
CQM Specifications in 2013
• Electronic specifications for the CQMs for reporting in 2013
will not be updated.
• Flexibility in implementing CEHRT certified to the 2014
Edition certification criteria in 2013
•
Providers could report via attestation CQMs finalized in both Stage 1 and
Stage 2 final rules
•
For EPs, this includes 41 of the 44 CQMs finalized in the Stage 1 final rule
•
•
Excludes: NQF 0013, NQF 0027, NQF 0084
•
Since NQF 0013 is a core CQM in the Stage 1 final rule, an alternate core CQM must be
reported instead since it will not be certified based on 2014 Edition certification criteria.
For Eligible Hospitals and CAHs, this includes all 15 of the CQMs
finalized in the Stage 1 final rule
38
How do CQMs relate to the
CMS EHR Incentive Programs?
• CQMs are no longer a core objective of the EHR
Incentive Programs beginning in 2014, but all
providers are required to report on CQMs in order
to demonstrate meaningful use.
39
CQM Selection and HHS Priorities
All providers must select CQMs from at least 3 of the 6
HHS National Quality Strategy domains:
q Patient and Family Engagement
q Patient Safety
q Care Coordination
q Population and Public Health
q Efficient Use of Healthcare Resources
q Clinical Processes/Effectiveness
40
Aligning CQMs Across Programs
• CMS’s commitment to alignment includes finalizing
the same CQMs used in multiple quality reporting
programs for reporting beginning in 2014
• Other programs include Hospital IQR Program,
PQRS, CHIPRA, and Medicare SSP and Pioneer ACOs
Hospital
Inpatient
Quality
Reporting
Program
Children’s
Health
Insurance
Program
Reauthorization
Act
Physician
Quality
Reporting
System
41
Medicare
Shared
Savings
Program and
Pioneer
ACOs
Aligning Reporting Mechanisms
• Identifying ways to minimize multiple submission
requirements and mechanisms
Provider
Requirements
Mechanisms
EPs
CY 2013 Medicare Physician
Fee Schedule (MPFS) NPRM
includes proposals for aligning
reporting requirements
•Option to submit once and get credit for the
CQM requirement in two programs
• Individual EPs
•PQRS EHR reporting option
•Group Practices
•PQRS GPRO options
•Medicare SSP or Pioneer ACOs
Eligible
Hospitals and
CAHs
FY 2012 and FY 2013 Inpatient
Prospective Payment Schedule
(IPPS) final rules include target
for electronic reporting in
Hospital IQR Program
eReporting pilot will be the possible basis for
the electronic reporting mechanism in
hospital reporting programs, beginning
with the Hospital IQR Program
42
Electronic Submission of CQMs
Beginning in 2014
• Beginning in 2014, all
Medicare-eligible providers
in their second year and
beyond of demonstrating
meaningful use must
electronically report their
CQM data to CMS.
• Medicaid providers will
report their CQM data to
their state, which may
include electronic
reporting.
43
CQMs Beginning in 2014
• A complete list of CQMs required for
reporting beginning in 2014 and their
associated National Quality Strategy
domains will be posted on the CMS EHR
Incentive Programs website
(www.cms.gov/EHRIncentivePrograms)
in the future.
• CMS will include a recommended core
set of CQMs for EPs that focus on highpriority health conditions and bestpractices for care delivery.
• 9 for adult populations
• 9 for pediatric populations
44
Recommended Core CQMs for EPs
CMS selected the recommended core CQMs based on
analysis of several factors:
•
Conditions that contribute to the morbidity
and mortality of the most Medicare and
Medicaid beneficiaries
•
Conditions that represent national public/
population health priorities
•
Conditions that are common to health disparities
45
Recommended Core CQMs for
EPs(cont’d)
• Conditions that disproportionately drive
healthcare costs and could improve with better
quality measurement
• Measures that would enable CMS, States, and
the provider community to measure quality of
care in new dimensions, with a stronger focus
on parsimonious measurement
• Measures that include patient and/or caregiver engagement
46
Changes to CQMs Reporting
Beginning in 2014
Prior to 2014
EPs
Eligible
Hospitals
and CAHs
Report 6 out of
44 CQMs
• 3 core or alt.
core
• 3 menu
Report 15 out of
15 CQMs
EPs
Report 9 out of 64 CQMs
Selected CQMs must cover at
least 3 of the 6 NQS domains
Recommended core CQMs:
9 for adult populations
9 for pediatric populations
Eligible
Hospitals
and CAHs
Report 16 out of 29 CQMs
Selected CQMs must cover at
least 3 of the 6 NQS domains
47
EP CQM Reporting Beginning in 2014
Eligible Professionals reporting for the Medicare EHR Incentive Program
Category
EPs in 1st Year of
Demonstrating
MU*
Data Level
Aggregate
Payer Level
All payer
Submission Type
Attestation
Reporting Schema
Submit 9 CQMs from EP measures table (includes adult
and pediatric recommended core CQMs), covering at least
3 domains
EPs Beyond the 1st Year of Demonstrating Meaningful Use
Option 1
Aggregate
All payer
Electronic
Submit 9 CQMs from EP measures table (includes adult
and pediatric recommended core CQMs), covering at least
3 domains
Option 2
Patient
Medicare
Electronic
Satisfy requirements of PQRS EHR Reporting Option using
CEHRT
Group Reporting (only EPs Beyond the 1st Year of Demonstrating Meaningful Use)**
EPs in an ACO
(Medicare Shared
Savings Program
or Pioneer ACOs)
Patient
Medicare
Electronic
Satisfy requirements of Medicare Shared Savings Program
of Pioneer ACOs using CEHRT
EPs satisfactorily
reporting via
PQRS group
reporting options
Patient
Medicare
Electronic
Satisfy requirements of PQRS group reporting options using
CEHRT
*Attestation is required for EPs in their 1st year of demonstrating MU because it is the only reporting method that
would allow them to meet the submission deadline of October 1 to avoid a payment adjustment.
**Groups with EPs in their 1st year of demonstrating MU can report as a group, however the individual EP(s) who
are in their 1st year must attest to their CQM results by October 1 to avoid a payment adjustment.
48
Hospital CQM Reporting Beginning in
2014
Eligible Hospitals reporting for the Medicare EHR Incentive Program
Category
Eligible Hospitals
in 1st Year of
Demonstrating
MU*
Data Level
Aggregate
Payer Level
Submission Type
All payer
Attestation
Reporting Schema
Submit 16 CQMs from Eligible Hospital/CAH
measures table, covering at least 3 domains
Eligible Hospitals/CAHs Beyond the 1st Year of Demonstrating Meaningful Use
Option 1
Aggregate
All payer
Electronic
Submit 16 CQMs from Eligible Hospital/CAH
measures table, covering at least 3 domains
Option 2
Patient
All payer
(sample)
Electronic
Submit 16 CQMs from Eligible Hospital/CAH
measures table, covering at least 3 domains
Ø
Manner similar to the 2012 Medicare EHR
Incentive Program Electronic Reporting Pilot
*Attestation is required for Eligible Hospitals in their 1st year of demonstrating MU because it is the only reporting
method that would allow them to meet the submission deadline of July 1 to avoid a payment adjustment.
49
CQM – Timing
Time periods for reporting CQMs – NO CHANGE from
Stage 1 to Stage 2
Provider
Type
Reporting
Period for 1st
year of MU
Submission Period for
1st year of MU
Reporting Period
for Subsequent
years of MU (2nd
year and beyond)
Submission Period
for Subsequent
years of MU (2nd
year and beyond)
EP
90
consecutive
days within
the calendar
year
Anytime immediately
following the end of the
90-day reporting period,
but no later than
February 28 of the
following calendar year*
1 calendar year
(January 1 –
December 31)
2 months following
the end of the EHR
reporting period
(January 1 –
February 28)
Eligible
Hospital/
CAH
90
consecutive
days within
the fiscal
year
Anytime immediately
following the end of the
90-day reporting period,
but no later than
November 30 of the
following fiscal year*
1 fiscal year
(October 1 –
September 30)
2 months following
the end of the EHR
reporting period
(October 1 –
November 30)
*In order to avoid payment adjustments, EPs must submit CQMs no later than October 1 and
Eligible Hospitals must submit CQMs no later than July 1.
50
2014 CQM Quarterly Reporting
For Medicare providers, the 2014 3-month reporting period is fixed to the quarter of either
the fiscal (for eligible hospitals and CAHs) or calendar (for EPs) year in order to align with
existing CMS quality reporting programs.
In subsequent years, the reporting period for CQMs would be the entire calendar year (for
EPs) or fiscal year (for eligible hospitals and CAHs) for providers beyond the 1st year of MU.
Provider
Type
Optional Reporting Period
in 2014*
EP
Calendar year quarter:
January 1 – March 31
April 1 – June 30
July 1 – September 30
October 1 – December 31
Fiscal year quarter:
Eligible
Hospital/CAH October 1 – December 31
January 1 – March 31
April 1 – June 30
July 1 – September 30
Reporting Period for
Subsequent Years of
Meaningful Use
Submission Period for
Subsequent Years of
Meaningful Use
1 calendar year
(January 1 - December
31)
2 months following the
end of the reporting
period
(January 1 - February
28)
1 fiscal year
(October 1 - September
30)
2 months following the
end of the reporting
period
(October 1 - November
30)
*In order to avoid payment adjustments, EPs must submit CQMs no later than October 1 and
Eligible Hospitals must submit CQMs no later than July 1.
51
Payment Adjustments
& Hardship Exceptions
Medicare Only
EPs, Subsection (d) Hospitals and CAHs
52
Payment Adjustments
• The HITECH Act stipulates that for Medicare EP, subsection
(d) hospitals and CAHs a payment adjustment applies if
they are not a meaningful EHR user.
• An EP, subsection (d) hospital or CAH becomes a meaningful
EHR user when they successfully attest to meaningful use
under either the Medicare or Medicaid EHR Incentive
Program
Adopt, implement and upgrade ≠ meaningful use
A provider receiving a Medicaid incentive for AIU would still be
subject to the Medicare payment adjustment.
53
EP Payment Adjustments
% Adjustment shown below assumes less than 75% of EPs are meaningful users
for CY 2018 and subsequent years
2015
2016
2017
2018
2019
2020+
EP is not subject to the payment
adjustment for e-Rx in 2014
99%
98%
97%
96%
95%
95%
EP is subject to the payment adjustment
for e-Rx in 2014
98%
98%
97%
96%
95%
95%
% Adjustment shown below assumes more than 75% of EPs are meaningful users
for CY 2018 and subsequent years
2015
2016
2017
2018
2019
2020+
EP is not subject to the payment
adjustment for e-Rx in 2014
99%
98%
97%
97%
97%
97%
EP is subject to the payment adjustment
for e-Rx in 2014
98%
98%
97%
97%
97%
97%
54
EP EHR Reporting Period
Payment adjustments are based on prior years’ reporting periods. The
length of the reporting period depends upon the first year of
participation.
For an EP who has demonstrated meaningful use in 2011 or 2012:
Payment Adjustment Year
2015
2016
2017
2018
2019
2020
Based on Full Year EHR Reporting
Period
2013
2014*
2015
2016
2017
2018
* Special 3 month EHR reporting period
To Avoid Payment Adjustments:
EPs must continue to demonstrate meaningful use every year to avoid
payment adjustments in subsequent years.
55
EP EHR Reporting Period
For an EP who demonstrates meaningful use in 2013 for the first time:
Payment Adjustment Year
2015
Based on 90 day EHR Reporting Period
2013
Based on Full Year EHR Reporting Period
2016
2017
2018
2019
2020
2014*
2015
2016
2017
2018
* Special 3 month EHR reporting period
To Avoid Payment Adjustments:
EPs must continue to demonstrate meaningful use every year to avoid
payment adjustments in subsequent years.
56
EP EHR Reporting Period
EP who demonstrates meaningful use in 2014 for the first time:
Payment Adjustment Year
2015
Based on 90 day EHR Reporting Period
2014*
Based on Full Year EHR Reporting Period
2016
2017
2018
2019
2020
2015
2016
2017
2018
2014
*In order to avoid the 2015 payment adjustment the EP must attest no later
than October 1, 2014, which means they must begin their 90 day EHR
reporting period no later than July 1, 2014.
57
Payment Adjustments for Providers
Eligible for Both Programs
Eligible for both programs?
If you are eligible to participate in both the Medicare and Medicaid EHR
Incentive Programs, you MUST demonstrate meaningful use according
to the timelines in the previous slides to avoid the payment
adjustments. You may demonstrate meaningful use under either
Medicare or Medicaid.
Note: Congress mandated that an EP must be a meaningful user in order to avoid
the payment adjustment; therefore receiving a Medicaid EHR incentive payment
for adopting, implementing, or upgrading your certified EHR Technology would
not exempt you from the payment adjustments.
58
Subsection (d) Hospital
Payment Adjustments
% Decrease in the Percentage Increase to the IPPS* Payment Rate that the hospital
would otherwise receive for that year:
% Decrease
2015
2016
2017
2018
2019
2020+
25%
50%
75%
75%
75%
75%
Example:
If the increase to IPPS for 2015 was 2%, than a hospital subject to the payment
adjustment would only receive a 1.5% increase
2% increase X 25% = .5% payment adjustment
*Inpatient Prospective Payment System (IPPS)
59
OR
1.5% increase total
Subsection (d) Hospital EHR
Reporting Period
Payment adjustments are based on prior years’ reporting periods. The length of
the reporting period depends upon the first year of participation.
For a hospital that has demonstrated meaningful use in 2011 or 2012 (fiscal years):
Payment Adjustment Year
2015
2016
2017
2018
2019
2020
Based on Full Year EHR Reporting Period
2013
2014*
2015
2016
2017
2018
For a hospital that demonstrates meaningful use in 2013 for the first time:
Payment Adjustment Year
2015
Based on 90 day EHR Reporting Period
2013
Based on Full Year EHR Reporting Period
2016
2017
2018
2019
2020
2014*
2015
2016
2017
2018
*Special 3 month EHR reporting period
To Avoid Payment Adjustments:
Eligible hospitals must continue to demonstrate meaningful use every year to avoid
payment adjustments in subsequent years.
60
Subsection (d) Hospital EHR
Reporting Period
For a hospital that demonstrates meaningful use in 2014 for the first time:
Payment Adjustment Year
2015
2016
Based on 90 day EHR Reporting Period
2014*
2014
Based on Full Year EHR Reporting Period
2017
2018
2019
2020
2015
2016
2017
2018
*In order to avoid the 2015 payment adjustment the hospital must attest no
later than July 1, 2014 which means they must begin their 90 day EHR
reporting period no later than April 1, 2014
61
Critical Access Hospital (CAH)
Payment Adjustments
Applicable % of reasonable costs reimbursement which absent payment
adjustments is 101%:
% of reasonable costs
2015
2016
2017
2018
2019
2020+
100.66%
100.33%
100%
100%
100%
100%
Example:
If a CAH has not demonstrated meaningful use for an applicable reporting period,
then for a cost reporting period that begins in FY 2015, its reimbursement would
be reduced from 101 percent of its reasonable costs to 100.66 percent.
62
CAH EHR Reporting Period
Payment adjustments for CAHs are also based on prior years’ reporting
periods. The length of the reporting period depends upon the first year
of participation.
For a CAH who has demonstrated meaningful use prior to 2015 (fiscal years):
Payment Adjustment Year
2015
2016
2017
2018
2019
2020
Based on Full Year EHR Reporting Period
2015
2016
2017
2018
2019
2020
For a CAH who demonstrates meaningful use in 2015 for the first time:
Payment Adjustment Year
2015
Based on 90 day EHR Reporting Period
2015
Based on Full Year EHR Reporting Period
2016
2017
2018
2019
2020
2016
2017
2018
2019
2020
To Avoid Payment Adjustments:
CAHs must continue to demonstrate meaningful use every year to avoid payment
adjustments in subsequent years.
63
EP Hardship Exceptions
EPs can apply for hardship exceptions in the following categories:
1. Infrastructure
EPs must demonstrate that they are in
an area without sufficient internet
access or face insurmountable barriers
to obtaining infrastructure (e.g., lack of
broadband).
4. EPs must demonstrate that they meet
the following criteria:
•
•
Lack of face-to-face or telemedicine
interaction with patients
Lack of follow-up need with patients
5. EPs who practice at multiple locations
must demonstrate that they:
• Lack of control over availability of
CEHRT for more than 50% of patient
encounters
2. New EPs
Newly practicing EPs who would not
have had time to become meaningful
users can apply for a 2-year limited
exception to payment adjustments.
3. Unforeseen Circumstances
Examples may include a natural
disaster or other unforeseeable barrier.
64
EP Hardship Exceptions
EPs whose primary specialties are anesthesiology, radiology
or pathology:
As of July 1st of the year preceding the payment adjustment
year, EPs in these specialties will receive a hardship exception
based on the 4th criteria for EPs
EPs must demonstrate that they meet the following criteria:
o Lack of face-to-face or telemedicine interaction with patients
o Lack of follow-up need with patients
65
Eligible Hospital and
CAH Hardship Exceptions
Eligible hospitals and CAHs can apply for hardship exceptions
in the following categories
1. Infrastructure
Eligible hospitals and CAHs must
demonstrate that they are in an area
without sufficient internet access or face
insurmountable barriers to obtaining
infrastructure
(e.g., lack of broadband).
limited to one full year after the
CAH accepts its first Medicare
patient.
•
For eligible hospitals the hardship
exception is limited to one full-year
cost reporting period after it accepts
its first Medicare patient.
3. Unforeseen Circumstances
2. New Eligible Hospitals or CAHs
Examples may include a natural disaster
New eligible hospitals and CAHs with
or other unforeseeable barrier.
new CMS Certification Numbers (CCNs)
that would not have had time to become
meaningful users can apply for a limited
exception to payment adjustments.
•
For CAHs the hardship exception is
66
Applying for Hardship Exceptions
q Applying: EPs, eligible hospitals, and CAHs must apply for hardship
exceptions to avoid the payment adjustments.
q Granting Exceptions: Hardship exceptions will be granted only if CMS
determines that providers have demonstrated that those circumstances pose
a significant barrier to their achieving meaningful use.
q Deadlines: Applications need to be submitted no later than April 1 for
hospitals, and July 1 for EPs of the year before the payment adjustment year;
however, CMS encourages earlier submission
For More Info: Details on how to apply for a hardship exception will be posted
on the CMS EHR Incentive Programs website in the future:
www.cms.gov/EHRIncentivePrograms
67
Medicaid-Specific
Changes
68
Medicaid Eligibility Expansion
Patient Encounters:
The definition of what constitutes a Medicaid patient encounter has
changed. The rule includes encounters for anyone enrolled in a
Medicaid program, including Medicaid expansion encounters (except
stand-alone Title 21), and those with zero-pay claims.
Ø The rule adds flexibility in the look-back period for overall patient
volume.
69
Provider Eligibility: Patient
Volume Calculation
Medicaid Encounters:
• Previously under Stage 1 rule:
o Service rendered on any one day where Medicaid paid
for all or part of the service or Medicaid paid the copays, cost-sharing, or premiums
• Changed in Stage 2 rule (applicable to all stages):
o Service rendered on any one day to a Medicaid-enrolled
individual, regardless of payment liability
o Includes zero-pay claims and encounters with patients
in Title 21-funded Medicaid expansions (but not
separate CHIPs)
70
Provider Eligibility: Patient
Volume Calculation
Zero-pay claims include:
• Claim denied because the Medicaid beneficiary has maxed
out the service limit
• Claim denied because the service wasn’t covered under the
State’s Medicaid program
• Claim paid at $0 because another payer’s payment
exceeded the Medicaid payment
• Claim denied because claim wasn’t submitted timely
• Such services can be included in provider’s Medicaid patient
volume calculation as long as the services were provided to a
beneficiary who is enrolled in Medicaid
71
Provider Eligibility: Patient
Volume Calculation
CHIP encounters to include in patient volume
calculation:
• Previously under Stage 1 rule:
o Only CHIP encounters for patients in Title 19 Medicaid
expansion programs
• Under Stage 2 rule (applicable to all stages):
o CHIP encounters for patients in Title 19 and Title 21
Medicaid expansion programs
• As before, encounters with patients in stand-alone CHIP
programs cannot be included in Medicaid patient volume
calculation
72
Provider Eligibility: Patient
Volume Calculation
90-day period for Medicaid patient volume
calculation:
• Under Stage 1 rule, Medicaid patient volume for providers
calculated across 90-day period in last calendar year (for
EPs) or Federal fiscal year (for hospitals)
• Under Stage 2 rule (applicable to all stages), States also
have option to allow providers to calculate Medicaid
patient volume across 90-day period in last 12 months
preceding provider’s attestation
• Also applies to needy individual patient volume
• Applies to patient panel methodology, too
o With at least one Medicaid encounter taking place in
the 24 months prior to 90-day period (expanded from
12 months prior)
73
Children’s Hospitals
Medicaid made approximately 12 additional children’s
hospitals eligible that have not been able to participate to date,
despite meeting all other eligibility criteria, because they do
not have a CMS Certification Number since they do not bill
Medicare.
74
Children’s Hospitals
Children’s hospital:
• Not children’s wings of larger hospital
• Previously under Stage 1 rule:
o Separately certified hospital that has CMS Certification
Number (CCN) with last 4 digits in the series 3300-3399
• Under Stage 2 rule (applicable to all stages):
o Now also includes children’s hospital that does not
have CCN because they do not serve Medicare
beneficiaries, but has received alternate number from
CMS for Incentive Program participation
75
Hospital Incentive Calculation
Changes under Stage 2 rule for determining
discharge-related amount:
• Hospitals that begin participating in FFY 2013 or later use
discharge data from most recent continuous 12-month
period for which data are available prior to payment year
• Hospitals that began participating before FFY 2013 use
discharge data from hospital fiscal year that ends during
FFY prior to hospital fiscal year that services as the first
payment year
76
Stage 2 Resources
CMS Stage 2 Webpage:
• http://www.cms.gov/Regulations-andGuidance/Legislation/EHRIncentivePrograms/Stage_2.html
Links to the Federal Register
Tipsheets:
•
Stage 2 Overview
•
2014 Clinical Quality Measures
•
Payment Adjustments & Hardship Exceptions (EPs & Hospitals)
•
Stage 1 Changes
•
Stage 1 vs. Stage 2 Tables (EPs & Hospitals)
77
2014 Edition
Standards & Certification Criteria
Final Rule
Steve Posnack, MHS, MS, CISSP
Director, Federal Policy Division
S&CC 2014 Edition Final Rule
Major Themes
• Enhancing standards-based exchange
• Promoting EHR technology safety and security
• Enabling greater patient engagement
• Introducing greater transparency
• Reducing regulatory burden
79
S&CC and Meaningful Use
Complementary but Different Scopes
• S&CC scope = “technical”
– Specifies the capabilities EHR technology must
include and how they need to perform in order to
be certified
– It does not specify how the EHR technology needs
to be used
• Meaningful use scope = “behavioral”
– Specifies how eligible providers need to use
Certified EHR Technology in order to receive
incentives
80
NPRM versus Final Rule
S&CC February ‘12
S&CC August ‘12
§ 170.314
§ 170.314
(a)
(b)
(c)
(d)
(e)
(f)
(g)
Clinical (n=18)
Care Coordination (n=6)
CQMs (n=3)
Privacy and Security (n=9*)
Patient Engagement (n=3)
Public Health (n=8)
Utilization (n=4)
(a)
(b)
(c)
(d)
(e)
(f)
(g)
Clinical (n=17)
Care Coordination (n=7)
CQMs (n=3)
Privacy and Security (n=9*)
Patient Engagement (n=3)
Public Health (n=6*)
Utilization (n=4)
* = includes optional
certification criteria 81
“New” Certification Criteria
Ambulatory & Inpatient
Inpatient Only
Ambulatory Only
Electronic Notes
Electronic medication
administration record
Secure messaging
Image results
eRx (for discharge)
Cancer case
information
Family Health History
Transmission of electronic
lab tests and values/results
to ambulatory providers
Transmission to
cancer registries
Amendments
View, Download, &
Transmit to 3rd party
Auto numerator recording
Non-%-based measure use
report
Safety-enhanced design
Quality management
system
Data Portability
82
“Revised” Certification Criteria
Ambulatory & Inpatient
Ambulatory Only
Drug-drug, drug-allergy
interaction checks
Vital signs, body mass
index, and growth charts
eRx
Demographics
CQMs (3 criteria)
Clinical summaries
Clinical information
reconciliation
Incorporate lab tests and
values/results
Problem list
End-user device encryption
Clinical decision support
Auditable events and
tamper-resistance
Drug-formulary checks
Audit report(s)
TOC – receive, display, and
incorporate toc/referral
summaries
TOC – create and transmit
toc/referral summaries
Patient list creation
Patient-specific education
resources
Smoking status
Automated measure
calculation
Transmission to
Immunization Registries
Transmission to public
health agencies –
syndromic surveillance
Inpatient Only
Transmission of
reportable lab tests and
values/results
83
“Unchanged” Certification Criteria
Ambulatory & Inpatient
CPOE
Advance directives
Medication list
Immunization information
Medication allergy list
Automatic log-off
Authentication, access control, &
authorization
Emergency access
Integrity
Accounting of disclosures
Incorporate lab test results
(inpatient only)
Smoking status
Vital signs, body mass index, and
growth charts
Drug-formulary checks
Patient lists
Patient reminders
Public health surveillance
Reportable laboratory tests and
values/results
• These certification criteria would be “eligible” for “gap certification”
84
Revised Certified EHR Technology
(CEHRT) Definition
July 2010 Final Rule Policy
Static Definition
Driven by Certification Criteria
Still available option and
effective through 2013 in
addition to other flexibilities
August 2012 Final Rule Policy
Dynamic Definition
Driven by Meaningful Use
Would be available as soon as final rule
is effective and once EHR technology
certified to the 2014 Edition EHR
certification criteria is available
85
2014 Edition CEHRT
Easy as 1, 2, 3 + C*
What varies is the quantity of EHR technology
certified to the 2014 Edition EHR certification
criteria that would be necessary to be used to
meet MU
EP/EH/CAH would only need to have
EHR technology with capabilities
certified for the MU menu set
objectives & measures for the stage of
MU they seek to achieve.
EP/EH/CAH would need to have EHR
technology with capabilities certified
for the MU core set objectives &
measures for the stage of MU they
seek to achieve unless the EP/EH/CAH
can meet an exclusion.
Base EHR
1
EP/EH/CAH must have EHR technology
with capabilities certified to meet the
Base EHR definition.
*C = CQMs
86
Revised CEHRT Definition
• Most important point: Quantity…
Quantity…
Quantity…
• It is all about the quantity of EHR technology
certified to the 2014 Edition EHR certification
criteria for MU stage you seek to meet.
• EHR technology developers have the opportunity
to rethink EHR software package(s) to offer “right
size certifications” to their customers.
87
So what? Why should I be excited?
Now 3 ways to meet CEHRT definition
• Complete EHR (ultimate assurance)
• EHR Module(s):
– Combination of EHR Modules
– Single EHR Module
• In the case of EHR Modules, it is now possible for
an eligible provider to have just enough EHR
technology certified to the 2014 Edition EHR
certification criteria to meet the CEHRT
definition.
88
Two Types of Certifications Issued
“Complete EHR” or “EHR Module”
1 Universe of EHR technology capabilities
(e.g., all of what XYZ’s EHR technology includes)
2014Ed Complete EHR definition
2 Supports MUS1 or MUS2 achievement
Certified to all 2014Ed cert. criteria for setting
EHR Module certified to quantity of 2014Ed
3 necessary to support MUS1
4
MUS2
MUS1
Inner square = EHR Module certified to
quantity of 2014Ed less than MUS1 (or MUS2)
Outer square = EHR Module certified to
quantity of 2014Ed necessary to support MUS2
5 Base EHR definition = certified EHR Module
6 EHR Module certified to less than
Base EHR definition
Point to remember:
Certification’s scope does NOT address all
capabilities included in EHR technology
2014 Edition Scope Stops Here
89
A Different Look: Understanding the
CEHRT Definition Quantity Spectrum
2014 Edition Complete EHR
2014 Edition EHR Module Approaches
Base
EHR
Stage 1
EP/EH
Stage 2
EP/EH
Base
EHR
Stage 1
EP/EH
MU1
Menu
MU1
Core
Base
EHR
Vendor X
Vendor B
MU1
Core
Vendor A
Base
EHR
MU1
Menu
Vendor B
MU1
Core
MU1
Core
MU2
Menu
Vendor A
Base EHR
MU1
Menu
Vendor B
Vendor A
MU1
MU2
Menu
MU1
Core
Base
EHR
Stage 1
EP/EH
Stage 2
EP/EH
4
5
w/exclusions
1
2
3
Vendor A Vendor B
MU2
Menu
Vendor C
MU2
MU2
Menu
MU1
Core
Base
EHR
Stage 2
EP/EH
w/exclusions
906
Certification Criteria Assigned to
Final Base EHR Definition
• It is a definition. It is meant to be used like a checklist to meet the CEHRT definition.
• It is not “a Base EHR” or a singular type of EHR technology that has these capabilities.
• The Base EHR definition includes CQM requirements not specified in this table.
2014 Edition EHR Certification Criteria Required to Satisfy the Base EHR Definition
EHR technology that:
Certification Criteria
Demographics § 170.314(a)(3)
Vital Signs § 170.314(a)(4)
Includes patient demographic and
clinical health information, such as
Problem List § 170.314(a)(5)
medical history and problem lists
Medication List § 170.314(a)(6)
Medication Allergy List § 170.314(a)(7)
Has the capacity to provide clinical
decision support
Has the capacity to support physician
order entry
Has the capacity to capture and query
information relevant to health care
quality
Has the capacity to exchange electronic
health information with, and integrate
such information from other sources
Has the capacity to protect the
confidentiality, integrity, and availability
of health information stored and
exchanged
Drug-Drug and Drug-Allergy Interaction Checks § 170.314(a)(2)
Clinical Decision Support § 170.314(a)(8)
þ
N/A
þ
þ
þ
N/A
þ
Computerized Provider Order Entry § 170.314(a)(1)
þ
Clinical Quality Measures § 170.314(c)(1) through (3)
þ
Transitions of Care § 170.314(b)(1) and (2)
Data Portability § 170.314(b)(7)
View, Download, and Transmit to 3rd Party § 170.314(e)(1)
Privacy and Security § 170.314(d)(1) through (8)
þ
þ
N/A
þ
91
Revised Definition of CEHRT Effective Dates
EHR Reporting Period
FY/CY 2011
FY/CY 2012
FY/CY 2013
FY/CY2014
MU Stage 1
MU Stage 1
MU Stage 1
MU Stage 1 or MU Stage 2
All EPs, EHs, and CAHs must have:
1) EHR technology that has been certified
to all applicable 2011 Edition EHR
certification criteria or equivalent 2014
Edition EHR certification criteria adopted
by the Secretary; or
2) EHR technology that has been certified
to the 2014 Edition EHR certification
criteria that meets the Base EHR definition
and would support the objectives,
measures, and their ability to successfully
report CQMs, for MU Stage 1.
All EPs, EHs, and CAHs must have
EHR technology certified to the 2014
Edition EHR certification criteria
that meets the Base EHR definition
and would support the objectives,
measures, and their ability to
successfully report the CQMs, for
the MU stage that they seek to
achieve.
There is no such thing as being “Stage 1 Certified” or “Stage 2 Certified” – 2014 Edition EHR
technology would be able to support the achievement of either meaningful use Stage. 92
2014 Certification Criteria associated with
a Base EHR:
2014 Certification Criteria
associated with MU Core Stage 2:
MU Menu
• Demographics (170.314(a)(3))
• Problem list (170.314(a)(5))
• Drug-drug, drug-allergy interaction
checks (170.314(a)(2))
MU Core
• Vital signs, BMI, & growth charts
(170.314(a)(4))
• Medication list (170.314(a)(6))
• Medication allergy list (170.314(a)(7))
• Clinical decision support (170.314(a)(8))
• Smoking status (170.314(a)(11))
Base EHR
• Patient list creation (170.314(a)(14))
• Patient-specific education resources
• Transitions of care (170.314(b)(1) & (2))
• Data portability (170.314(b)(7))
• Clinical quality measures (170.314(c)(1) - (3))
(170.314(a)(15))
• Privacy and Security CC:
• eMAR (170.314(a)(16))
Authentication, access control,
& authorization (170.314(d)(1))
o Auditable events & tamper resistance
o
• Clinical information reconciliation
(170.314(b)(4))
• Incorporate lab tests &
values/results (170.314(b)(5))
• View, download, & transmit to
Party (170.314(e)(1))
• CPOE (170.314(a)(1))
(170.314(d)(2))
o
3rd
o
o
• Immunization information
o
(170.314(f)(1))
o
• Transmission to immunization
registries (170.314(f)(2))
o
o
• Transmission to PH agencies –
syndromic surveillance (170.314(f)(3))
Audit report(s) (170.314(d)(3))
Amendments (170.314(d)(4))
Automatic log-off (170.314(d)(5))
Emergency access (170.314(d)(6))
End-user device encryption (170.314(d)(7))
Integrity (170.314(d)(8))
Accounting of disclosures* (170.314(d)(9))
2014 Certification Criteria associated
with MU Menu Stage 2:
• Transmission of reportable lab tests
& values/results (170.314(f)(4))
• Electronic notes (170.314(a)(9))
• Drug-formulary checks (170.314(a)(10))
2014 ed. certification criteria for which
certification may be required:
•
•
•
•
*= optional
Automated numerator recording (170.314(g)(1))
Automated measure calculation (170.314(g)(2))
Safety-enhanced design (170.314(g)(3))
Quality management system (170.314(g)(4))
• Image results (170.314(a)(12))
• Family health history (170.314(a)(13))
• Advance directives (170.314(a)(17))
• eRx (170.314(b)(3))
• Transmission of e-lab tests &
values/results to providers (170.314(b)(6))
Do you have EHR Technology that meets the new Certified EHR
Technology definition for Meaningful Use Stage 1?
START HERE
Do you have a 2014
Edition Complete EHR for the
Ambulatory (EPs) or Inpatient
(EHs/CAHs) Setting?
Yes
Yes
No
Do you have EHR technology
that has been:
Yes
ü Certified to ≥ 9 CQMs
§ ≥ 6 from CMS’ recommended
core set
§ Address ≥ 3 domains from the
set selected by CMS for EPs?
Yes
Is your EHR technology certified to the
following certification criteria required to
meet the Base EHR definition? § 170.314:
ü(a)(1),(3)&(5-8) –
CPOE/Demogfrx/ProbList/
MedList/MedAllergyList/CDS
ü(b)(1),(2)&(7) – TOC/Data Port
ü(c)(1)-(3) – CQMS
ü(d)(1)-(8) – P&S
Is your EHR technology certified to the
following certification criteria to support
the MU1 EP Core Objectives you seek to
achieve and for which you cannot meet a
MU exclusion? § 170.314:
Yes
Is your EHR technology certified to the
following certification criteria to support
the MU1 EP Menu Objectives you seek to
meet? § 170.314:
ü(a)(10) – RxFormulary
ü(a)(14) – Pt List
ü(a)(15) – Pt Edu
ü(b)(4) – ClinInfoRec
ü(a)(2) – DD/DA
ü(b)(3) – eRx
ü(a)(4) – Vitals
ü(e)(1) – VDTx3
ü(a)(11) – Smoking ü(e)(2) – Clinical Sum
Yes
ü(b)(5) – Incorp Lab
ü(f)(1) – Immz Info
ü(f)(2) – Immz Tx
ü(f)(3) – Syn Surv
No
No
No
No
No
No
EP
No
Yes
Do you have EHR technology
that has been:
ü Certified to ≥ 16 CQMs from
CMS’ selected set for EH/CAHs
§ Address ≥ 3 domains from the
set selected by CMS for
EH/CAHs?
Is your EHR technology certified to the
following certification criteria to support
the MU1 EH/CAH Menu Objectives you
seek to meet? § 170.314:
Is your EHR technology certified to the
following certification criteria to support
the MU1 EH/CAH Core Objectives you seek
to achieve and for which you cannot meet
a MU exclusion? § 170.314:
Yes
ü (a)(2) – DD/DA
ü (a)(4) – Vitals
Note: To meet the CEHRT definition, EHR technology will need to have been certified to:
§ Automated numerator recording (170.314(g)(1)) or Automated measure calculation (170.314(g)(2));
§ Safety-enhanced design (170.314(g)(3)); and
§ Quality management system (170.314(g)(4))
ü(a)(11) – Smoking
ü(e)(1) – VDTx3
Yes
ü(a)(10) – RxFormulary
ü(a)(14) – Pt List
ü(a)(15) – Pt Edu
ü(a)(17) – AD
ü(b)(4) – ClinInfoRec
ü(b)(5) – Incorp Lab
ü(f)(1) – Immz Info
ü(f)(2) – Immz Tx
ü(f)(3) – Syn Surv
ü(f)(4) – ELR
Yes
EPs: Do you have EHR Technology that meets the new Certified
EHR Technology definition for Meaningful Use Stage 1?
START HERE
Do you have a 2014
Edition Complete EHR for the
Ambulatory Setting?
Yes
Yes
No
Is your EHR technology certified to the
following certification criteria required to
meet the Base EHR definition? § 170.314:
ü(a)(1),(3)&(5-8) –
CPOE/Demogfrx/ProbList/
MedList/MedAllergyList/CDS
ü(b)(1),(2)&(7) – TOC/Data Port
ü(c)(1)-(3) – CQMS
ü(d)(1)-(8) – P&S
Yes
No
No
Do you have EHR technology
that has been:
ü Certified to ≥ 9 CQMs
§ ≥ 6 from CMS’ recommended
core set
§ Address ≥ 3 domains from the
set selected by CMS for EPs?
No
Yes
Is your EHR technology certified to the
following certification criteria to support the
MU1 EP Core Objectives you seek to achieve
and for which you cannot meet a MU
exclusion? § 170.314:
ü(a)(2) – DD/DA
ü(b)(3) – eRx
ü(a)(4) – Vitals
ü(e)(1) – VDTx3
ü(a)(11) – Smoking ü(e)(2) – Clinical Sum
Note: To meet the CEHRT definition, EHR technology will need to have been certified to:
§ Automated numerator recording (170.314(g)(1)) or Automated measure calculation (170.314(g)(2));
§ Safety-enhanced design (170.314(g)(3)); and
§ Quality management system (170.314(g)(4))
No
Yes
Is your EHR technology certified to the
following certification criteria to support
the MU1 EP Menu Objectives you seek to
meet? § 170.314:
ü(a)(10) – RxFormulary
ü(a)(14) – Pt List
ü(a)(15) – Pt Edu
ü(b)(4) – ClinInfoRec
ü(b)(5) – Incorp Lab
ü(f)(1) – Immz Info
ü(f)(2) – Immz Tx
ü(f)(3) – Syn Surv
Yes
ONC HIT Certification Program
Final Changes
• Temporary Certification Program Sunsets
– Upon 2014 Edition final rule effective date
• Program Name Change
– “ONC HIT Certification Program”
• Revisions to EHR Module Certification
Requirements
– Privacy and Security Certification Policy
• Will not require upfront certification to P&S for the 2014
Edition CC
• Policy outcome now reflected in Base EHR definition (which
includes all P&S CC)
– Other tweaks to make certification more efficient
96
ONC HIT Certification Program
Final Changes (cont.)
• Application of certain new certification criteria to EHR technology
– § 170.314(g)(1): Automated numerator recording
– § 170.314(g)(3): Safety-enhanced design
• 8 Medication related certification criteria: CPOE; Drug-drug, drug-allergy
interaction checks; Medication list; Medication allergy list; Clinical decision
support; eMAR; e-prescribing; and Clinical information reconciliation.
– § 170.314(g)(4): Quality management system
• Price Transparency: ONC-ACBs are required to ensure that EHR
technology developers notify eligible providers about additional
types of costs (i.e., one-time, ongoing, or both) that affect a
certified Complete EHR or certified EHR Module’s total cost of
ownership for the purposes of achieving meaningful use.
• Test Result Transparency: The final rule requires that ONC-ACBs
submit a hyperlink of the test results used to issue a certification to
a Complete EHR or EHR Module.
97
Standards Applicability
Purpose
Vocabulary &
Code Sets
Demographics
OMB Race/Ethnicity
ISO 639-2 (constrained)
Problems
SNOMED CT + US ext
CDS
Transport
HL7 Infobutton + IGs
Smoking Status
SNOMED CT + US ext
Family Health
History
SNOMED CT + US ext
HL7 Pedigree
Patient Ed Resources
ToC – receive, display,
& incorporate
Content Exchange
/ Utilization
HL7 Infobutton + IGs
SNOMED CT + US ext
RxNorm
CCD/C32
Applicability
Statement for Secure
Health Transport
CCR
AppState + XDR/XDM
Consolidated CDA
SOAP RTM +
XDR/XDM
98
Standards Applicability (cont.)
Purpose
Vocabulary &
Code Sets
Content Exchange
/ Utilization
[Common MU
Data Set]
ICD-10-CM
CVX
Consolidated CDA
e-Rx
RxNorm
NCPDP SCRIPT 10.6
Incorporate Labs
(ambulatory)
LOINC
HL7 S&I LRI Spec
Data Portability
[Common MU
Data Set]
ICD-10-CM
CVX
Consolidated CDA
ToC – Create &
Transmit
Transport
Applicability
Statement for Secure
Health Transport
AppState + XDR/XDM
SOAP RTM +
XDR/XDM
99
Standards Applicability (cont.)
Purpose
Vocabulary &
Code Sets
Content Exchange
/ Utilization
CQM Export
QRDA Category I
CQM Import
QRDA Category I
CQM e-Submit
QRDA Category
I & III
Consolidated CDA
View, download,
transmit to 3rd party
[Common MU
Data Set]
Clinical Summary
[Common MU
Data Set]
Consolidated CDA
Immz Reporting
CVX
HL7 2.5.1 + IGs
Syndromic
Surveillance
WCAG Level A
Transport
Applicability
Statement for Secure
Health Transport
HL7 2.5.1
+IG (inpatient only)
ELR
SNOMED CT + US ext
LOINC
HL7 2.5.1 + IG
Cancer Registry
SNOMED CT + US ext
LOINC
CDA R2 + IG
100
What’s Next?
A Brief Timeline
• Aug 2012
– Final rule issued
• Sept 2012 – Dec 2012:
– Waves of Test Procedures published
– Test Procedures available for comment
– Final rule effective date reached TCP sunsets
101
But wait, there’s more!
• Check back to:
http://www.healthit.gov/policy-researchers-implementers/meaningful-use-stage-2-0
Now:
– CEHRT Infographic flows and Bull’s eye diagrams
Coming soon:
– Grids comparing MU1 and MU2 w/ 2014 Ed.
– Standards resource page where all the adopted standards as part of
the 2014 Edition EHR Certification Criteria will be listed with URLs to
where you can find/access them.
102
Questions
103
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