New MU Exemptions for 2015 Reporting Periods

gavel and law-1063249_1920New Legislation This Week Intended to Offer Eligible Healthcare Providers Relief from Medicare Payment Adjustment Penalties

President Obama signed the “Patient Access and Medicare Protection Act” into law on Monday, December 28, 2015. Congress passed the bill the prior week as one of their final legislative acts before adjourning for the year.

This new legislation aims to alleviate stress placed on Eligible Providers (EPs) after the Modified Stage 2 Rule — which requires 90 consecutive days of EHR data reporting for 2015 — was released in mid-October. With the late release of the modifications, there wasn’t a full 90-day reporting period remaining in the 2015 calendar year and some healthcare providers didn’t have enough time to comply with the updates.

The statute makes it easier for Eligible Providers (EPs) to obtain hardship exemptions to the Modified Stage 2 Meaningful Use requirements for 2015. Under prior legislation, EPs could apply to the Center for Medicare and Medicaid Services (CMS) for a hardship exemption on a “case-by-case” basis.  This new legislation enables CMS to grant hardships to affected healthcare providers for 2015 impacting 2017 payment adjustments.

This new law extends the opportunity for EPs who’re unable to meet Meaningful Use for 2015 to apply for an exemption. To protect themselves from Medicare Part B Penalties that would be applied in 2017, EPs should apply for exemption by March 15, 2016.  CMS will continue to accept hardship applications after the mid-March deadline, but such applications will revert back to the original case-by-case review process.  More information regarding what the exemption process will entail is forthcoming from the Center for Medicare and Medicaid Services.

Meaningful Use or Meaningful Confusion? Part 3 of 3

medical-moneyThis is Part 3 of our Three-part Blog Series, “Introduction of Stage 3,” which outlines the objectives finalized for Stage 3 under the October 16, 2015 Final Rule.

Meaningful Use was introduced as part of the HITECH Act as a means to encourage healthcare providers to adopt electronic health records, and also begin to shift to additional quality care metrics. Yet, since Meaningful Use began in 2011, there have been many critics who assert that the program does not achieve the meaning in Meaningful Use.  As such, there have been multiple iterations of the rule and the various stages.  We will present to you the latest changes that you need to know in this three part blog post series.

Part three of the series, “Introduction of Stage 3” outlines the objectives finalized for Stage 3 under the October 16th Final Rule.  You can view Part One of our series, “Changes for 2015” here.  Part Two of our the series, “Changes for 2016-2017” can be viewed here.

 

Optional 2017 Reporting and Required 2018 Reporting

Stage 3 will be available for attestation in 2017, although it won’t be required as previously thought. Eligible Providers will be given the option of attesting to Stage 3 in 2017 for a 90 day reporting period.  In 2018, all Providers, regardless of what stage they were scheduled to be on, are to attest to Stage 3 Objectives for a calendar year reporting period.  The optional year in 2017 will allow providers to “test the waters” with a shorter reporting period and begin preparing for Stage 3 before they are required to implement it.

 

Eight Objectives

Unlike previous iterations of Meaningful Use, there are no Core and Menu Objective Sets, only required Objectives. Modified Stage 2 set the tone by absorbing previous measures into one set of measures, a precedent that Stage 3 will follow. Stage 3 features many measures from previous of versions of Meaningful Use, often with higher thresholds and less exclusions.

 

Stage 3 Objectives Summary

Objective 1 Protect Patient Health Information Conduct a Security Risk Analysis within the Reporting Period (RP)
Objective 2 Electronic Prescribing More than 60% of permissible prescriptions written by the Eligible Provider (EP) in the RP are queried for a drug formulary and transmitted electronically
Objective 3 Clinical Decision Support 1 – Implement five Clinical Decision Support Rules related to four or more Clinical Quality Measures
2 – Enable Drug-Drug and Drug-Allergy interaction checks for the entire RP
Objective 4 Computerized Provider Order Entry (CPOE) 1 – More than 60% of Medication orders during the RP are created through CPOE
2 – More than 60% of lab orders during the RP are created through CPOE
3 – More than 60% of radiology orders during the RP are created through CPOE
Objective 5 Patient Electronic Access 1 – More than 80% of unique patients seen by the EP during the RP are provided timely access to view online, download, or transmit their health records and can be accessed using the application of the patient’s choice
2 – More than 35% of patients seen by the EP in the RP receive patient specific education resources that were identified by the CEHRT and receive electronic access to those materials
Objective 6 Coordination of Care through Patient Engagement 1 – More than 10% of unique patients seen by the EP during the RP views online, downloads, or electronically transmits their health information or accessing their health information from an application of their choice
2 – More than 25% of unique patients seen by the EP during the RP are sent an electronic message using the secure messaging feature of CEHRT
3 – For more than 5% of unique patients seen in the RP by the EP, patient-generated health data or data from a non-clinical setting is incorporated into the CEHRT
Objective 7 Health Information Exchange 1 – For more than 50% of transitions of care and referrals, the EP that refers the patient should create and electronically exchange the summary of care record using CEHRT
2 – For more than 40% of transitions of care or referrals received by the EP where the EP has never encountered the patient, the EP receives and incorporates into the patient’s record an electronic summary of care document
3 – For more than 80% of transitions of care or referrals received by the EP where the EP has never encountered the patient, the EP performs clinical information reconciliation
Objective 8 Public Health and Clinical Data Registry Reporting 1 – Immunization Registry Reporting
2 – Syndromic Surveillance Reporting
3 – Electronic Case Reporting
4 – Public Health Registry Reporting
5 – Clinical Data Registry Reporting

 

Still confused? Do you need one-on-one guidance regarding your organization? We can help!  Please contact our Meaningful Use Expert, Kathryn Ayers Wickenhauser (Kathryn.Wickenhauser@DataFileTechnologies.com) for guidance about how these changes impact you.

Meaningful Use or Meaningful Confusion? Part 2 of 3

medical-moneyThis is Part 2 of our Three-part Blog Series, “Changes for 2016 and 2017” which describes the realignment of Stage 1 and Stage 2 objectives into a single measure set for 2016 and 2017. 

Meaningful Use was introduced as part of the HITECH Act as a means to encourage healthcare providers to adopt electronic health records, and also begin to shift to additional quality care metrics. Yet, since Meaningful Use began in 2011, there have been many critics who assert that the program does not achieve the “meaning” in Meaningful Use.  As a result, there have been multiple iterations of the rule and the various stages.  We will present to you the latest changes that you need to know in this Three-part blog post series.

Part two of the series, “Changes for 2016-2017” describes the realignment of Stage 1 and Stage 2 objectives into a single measure set for 2016 and 2017.  You can view Part One of our series, “Changes for 2015” here.

 

Realignment of Stage 1 and Stage 2, or “Modified Stage 2”

As an effort to realign and prepare providers for Stage 3 of Meaningful Use, CMS has created a “Modified Stage 2.” All Providers on track to attest to Stage 1 or Stage 2 in 2016 and 2017 will attest to this combined set of ten objectives.

 

2016 and 2017 for “Modified Stage 2” are Full Year Reporting Periods

See the detailed chart below for a summary for the “Modified Stage 2” Objectives.  CMS is continuing complete year reporting periods (for providers beyond their first year of attestation) for 2016 and 2017, despite offering a 90-day reporting period for 2015.   The thought behind the longer reporting period is that CMS has adjusted many of the Meaningful Use measures to make them more attainable for many providers.  With more exclusions and the updates to some existing measures, CMS believes that the updated objective set is achievable for providers over a calendar year.

 

Optional Stage 3 in 2017

In 2014, CMS allowed providers who were slated to attest to Stage 2 a flexible year where they could attest to Stage 1 again if they wished. Similarly, CMS is doing the same thing for Stage 3 Meaningful Use by allowing providers the option of attesting to Stage 3 in 2017.  A huge benefit of participating in Stage 3 in 2017 is the provision that it will only be a 90 day reporting period for those participating providers.  When Stage 3 is required for all provides in 2018 (see Part Three in our Blog Post series next week about this topic!), a calendar year reporting period will be required.  The optional year in 2017 will allow providers to “test the waters” with a shorter reporting period and begin preparing for Stage 3 before they are required to implement it.

 

“Modified Stage 2” Objectives Summary

Objective 1 Protect Patient Health Information Conduct a Security Risk Analysis within the Reporting Period (RP)
Objective 2 Clinical Decision Support 1 – Implement five Clinical Decision Support Rules related to four or more Clinical Quality Measures
2 – Enable Drug-Drug and Drug-Allergy interaction checks for the entire RP

Exclusion: Eligible Providers (EP) who write less than 100 prescriptions during the RP

Objective 3 Computerized Provider Order Entry 1 – More than 60% of Medication orders during the RP are created through CPOE

Exclusion: Any EP who writes fewer than 100 prescriptions during the RP

2 – More than 30% of lab orders during the RP are created through CPOE

Exclusion: Any EP who orders fewer than 100 lab orders during the RP or scheduled to be in Stage 1 during the 2016 RP

3 – More than 30% of radiology orders during the RP are created through CPOE

Exclusion: Any EP who orders fewer than 100 radiology orders during the RP or scheduled to be in Stage 1 during the 2016 RP

Objective 4 Electronic Prescribing More than 50% of permissible prescriptions are queried for a drug formulary and transmitted electronically

Exclusions: Any EP who writes fewer than 100 prescriptions within the RP or does not have a pharmacy that accepts electronic prescriptions within 10 miles of the organization

Objective 5 Health Information Exchange An EP who transitions their patient to another setting of care must use Certified Electronic Health Record Technology (CEHRT) to create a summary of care record and electronically transmit the summary to the receiving provider for more than 10% of transitions of care

Exclusion: Any EP who transitions a patient to another setting of care less than 100 times in the RP

Objective 6 Patient Specific Education More than 10% of patients seen by the EP in the RP receive patient specific education resources that were identified by the CEHRT

Exclusion: Any EP who has no office visits in the RP

Objective 7 Medication Reconciliation The EP performs medication reconciliation for more than 50% of transitions of care in which the patient is transitioned into the care of EP

Exclusion: Any EP who was not the recipient of any transitions of care during the RP

Objective 8 Patient Electronic Access (V/D/T) 1 – More than 50% of unique patients seen by the EP during the RP are provided timely access to view online, download, or transmit their health records

Exclusions: Any EP who neither orders nor created any of the information listed for inclusion of the measures or conducts more than 50% of their encounters in a county that does not have 50% or more of its housing units with 4Mbps broadband availability on the first day of the RP

2 – 2016: At least one patient seen by EP in the RP views online, downloads, or electronically transmits their health information.

2017: More than 5% of unique patients seen by the EP during the RP views online, downloads, or electronically transmits their health information.

Exclusions: Any EP who neither orders nor created any of the information listed for inclusion of the measures or conducts more than 50% of their encounters in a county that does not have 50% or more of its housing units with 4Mbps broadband availability on the first day of the RP

Objective 9 Secure Messaging 2016: At least one patient seen by the EP during the RP sent an electronic message using the secure messaging feature of CEHRT

2017: More than 5% of unique patients seen by the EP during the RP sent an electronic message using the secure messaging feature of CEHRT

Objective 10 Public Health Reporting Must meet two of the three measures in 2016 and 2017
1 – Immunization Registry

Exclusions: An EP who does not administer immunizations in the RP, operates in a jurisdiction where no immunization registry has declared readiness or is capable of accepting immunizations aligned with the CEHRT definition

2 – Syndromic Surveillance Registry

Exclusions: An EP who is not in a category of providers from which ambulatory syndromic surveillance data is collected or operates in a jurisdiction that is not capable or ready to collect syndromic surveillance data

3 – Specialized Registry

Exclusions: An EP who does not diagnose or treat any condition associated with a specialized registry

 

See us back here next Friday for Part Three of this Blog Series which will focus specifically on Stage 3.

Still confused? Do you need one-on-one guidance regarding your organization? We can help!  Please contact our Meaningful Use Expert, Kathryn Ayers Wickenhauser (Kathryn.Wickenhauser@DataFileTechnologies.com) for guidance about how these changes impact you.