Stage 2 Meaningful Use - Transforming into a Superhero (Alabama MGMA)
 

Stage 2 Meaningful Use - Transforming into a Superhero (Alabama MGMA)

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Stage 2 Meaningful Use - Transforming into a Superhero (Alabama MGMA) Stage 2 Meaningful Use - Transforming into a Superhero (Alabama MGMA) Presentation Transcript

  • Stage 2 Meaningful Use – Transforming into a Superhero Adele Allison National Director of Government Affairs March 2, 2012 Less Risk, More Results. That’s Success
  • Future of Meaningful Use – Stage 2
    • Quick Overview Final Rule – Stage 1
    • MU - By the Numbers
    • Stage 2 – Infrastructure Wave
    • Stage 2 Proposed Measures
    • Practice Redesign Considerations
    • Questions
  • U.S. Government 101 – Ten Questions
    • Who’s the Prez?
    • Who’s the Vice-Prez?
    • What is law-making?
    • When a Bill is signed, it becomes an “Act.” What does that mean?
    • What is policy-making?
    • How many cabinet positions are there?
    • Which cabinet position is over U.S. Health Care?
    • How many agencies are under Secretary of HHS?
    • Who can influence policy-making?
    • Can you become involved?
  • The Hill
    • The Hill is like an ER
    • Congress receives 18M Postal and 313M Internet Contacts/Month
    • Average Congressman – 6,000 Communications/Month
    • Average Member – 13 Meetings/Day and 70 Hours/Week
    • Average Staffer is 27 years old
    • Biggest Impact “Squeaking:”
    • 97% In Person Visit
    • 96% Constituent Rep Contact
    • 90% Letters
    • 88% Email
    • 86% Phone
  • Legislation and Health IT
    • ↑ Freshmen than in 60 years ( 96 House; 6 Senate)
    • Priorities:
      • #1 – Economy and Jobs
      • #2 – Fiscal Budget ( $3.73 Trillion in Spending!)
      • #3 – Deficit – Super-Committee
      • #4 – Health Care Reform (‘Care, ‘Caid, CHIP)
    • Basics of legislative Process – An “Act” is a Statute
    • Legislative Rulemaking Process
      • Health Care Policy Making
      • NPRM and IFR
    • EHR Vendor Rules come from ONC
    • Provider / Hospital Rules come from CMS
  • The HIPAAMIPPACHIPRAARRAPPACA Era!
    • HIPAA – Electronic Transactions – 5010 / ICD-10
    • MIPPA – Value-Based Purchasing
    • CHIPRA – Extended CHIP
    • ARRA – Meaningful Use of Certified EHRs
    • PPACA – Affordable Care for All Americans
    • ↑ Focus on Process and Technology
    • What systems are impacted?
    • How do you align disparate dates of compliance?
    • This is Herculean! Is there a map?
    • CAN I RETIRE!
  • ARRA/HITECH (Generally )
    • Signed 2/17/09 in Denver, CO
    • Purpose : Stimulate the economy through investments in infrastructure, unemployment benefits, transportation, education, and healthcare .
    • Health Care is in the Spotlight
      • Affordable Care Act - Health Care Reform ($828B)
      • Fueling push for HIT ($54B per year savings)
      • Rapid market movement and positioning
    • Up to $45B for direct EHR adoption: 
      • $20B in Medicare Incentives
      • $14B in Medicaid Incentives 
  • Summing-up HITECH Goals
    • Adopt/Use Certified EHR Technology (CEHRT)
    • Capture DATA
    • Move DATA – Interoperability
    • Report DATA – CQMs
    • $27B in “Carrots” - incentives :
      • Up to $48,400 through Medicare
      • Up to $63,750 through Medicaid
    • Stage 1 Meaningful Use = Marks 1 and 2
    • Stage 2 Meaningful Use = Marks 3 and 4
  • Meaningful Use – 3-Part Equation
    • 3-Part Equation for MU:
      • Part 1: Certified EHR Technology – The Tool
      • Part 2: Implementation – Practice Reengineering / Redesign
      • Part 3: Support – Available, Responsive and Ongoing
    Shamrock Meaningful Use of a Shamrock
  • Stage 1 – Objectives & Measures
    • Objectives are broad spanning goals/activities
    • Measures are specific task(s) requirements
    • Meeting the measures = meeting the Objectives for that Stage
    • Stage 1 MU
      • 15 Core Measures required by all EP’s
      • 10 Menu Measures from which EP’s choose 5
    • 13 Exclusion Clauses – Exclusions will reduce the number of Objectives required by EP
  • Medicare Incentive – Stage 1
    • Eligible Provider Types - §495.100 :
      • Medicare: MD, DO, DDS, DMD, DPM, OD, DC
    • Must have PECOS Number with CMS
    • Must register with CMS
      • Registration Website: cms.gov/EHRIncentivePrograms/
    • Year 1: 15 Core + 5 Menu Objectives/Measures for continuous 90-days
    • Year 2 and Beyond: Full Year of MU
    • CY2011-13 - Must gather data, run calculations, attest and send to CMS
    • CY2014 and Beyond – Electronic Submission of CQMs
    • Qualification is reviewed annually
  • Potential Medicare Incentives Calendar Year First Calendar Year in which the EP Receives an Incentive Payment   2011 2012 2013 2014 2015 and subsequent years – Penalties Start 2011 $18,000         2012 $12,000 $18,000       2013 $8,000 $12,000 $15,000     2014 $4,000 $8,000 $12,000 $12,000   2015 $2,000 $4,000 $8,000 $8,000 $0 2016   $2,000 $4,000 $4,000 $0 TOTAL $44,000 $44,000 $39,000 $24,000 $0 Shortage Area Totals* $48,400 $48,400 $42,900 $26,400 $0 * Providers practicing in a federally identified shortage area are eligible for a 10% increase .
  • Medicaid Incentives – Stage 1
    • Eligible Provider Types - §495.100 :
      • Medicaid: Physicians, Dentists, Certified Nurse Midwives, Nurse Practitioners, Physician Assistants (in FQHC/RHC led by a PA)
    • EPs must meet a Medicaid volume threshold
    • Year 1: Adopt, Implement, Upgrade - §495.302 :
      • Acquire, purchase, or secure access to certified EHR technology;
      • Install/use certified EHR technology capable of MU; or
      • Expand functionality of certified EHR solution at the practice with:
        • Staffing,
        • Maintenance,
        • Training, or
        • Upgrading from existing EHR to certified EHR technology.
    • Year 2: MU for 90 continuous days
    • Years 3 through 6: MU for full year
  • Potential Medicaid Incentives Calendar Year First Calendar Year in which the EP Receives an Incentive Payment 2011 2012 2013 2014 2015 2016 2011 $21,250           2012 $8,500 $21,250         2013 $8,500 $8,500 $21,250       2014 $8,500 $8,500 $8,500 $21,250     2015 $8,500 $8,500 $8,500 $8,500 $21,250   2016 $8,500 $8,500 $8,500 $8,500 $8,500 $21,250 2017 $0 $8,500 $8,500 $8,500 $8,500 $8,500 2018 $0 $0 $8,500 $8,500 $8,500 $8,500 2019 $0 $0 $0 $8,500 $8,500 $8,500 2020 $0 $0 $0 $0 $8,500 $8,500 2021 $0 $0 $0 $0 $0 $8,500 TOTAL $63,750 $63,750 $63,750 $63,750 $63,750 $63,750
  • Future of Meaningful Use – Stage 2
    • Quick Overview Final Rule – Stage 1
    • MU - By the Numbers
    • Stage 2 – Infrastructure Wave
    • Stage 2 Proposed Measures
    • Practice Redesign Considerations
    • Questions
  • Meaningful Use – State of the Union
    • Active Registrations
      • Hospitals -> 3,247
      • Medicare Eligible Providers -> 132,445
      • Medicaid Eligible Providers -> 55,912
    • Medicare EP Stage 1 Attestation -> $412,866,000
    • Medicaid EP Year 1 Attestation -> $384,628,458
    YTD Eligible Professionals – Year 1 Payments 4,550 Internal Med. 4,896 Family Med. 1,652 Cardiology 388 OB/Gyn 1,031 Gastro 757 Urology 534 Nephrology 738 Gen’l Surgery 837 Orthopedics 569 Neurology 4,960 Other YTD Eligible Professionals – Year 1 Payments 13,652 Physicians 3,176 Nurse Prac. 401 Mid-Wives 887 Dentists 203 Physician Asst.
  • Meaningful Use – State of the State (AL)
    • Hospitals / Inpatient
      • Type: Acute Care, Hospice, Skilled Nursing, Swing-Beds
      • Medicaid -> 1 ($3,431,698)
      • Medicaid/Medicare -> 63 ($54,645,766)
    • Eligible Providers Registered
      • 2,185 Medicare EPs
      • 1,245 Medicaid EPs
    • Eligible Providers Paid
      • Medicare Stage 1 -> 293 ($5,274,000)
      • Medicaid Year 1 -> 764 ($16,022,510)
    • Moving Data
      • One Health Record (HIE)
      • State Immunization Registry (AL-IIS)
  • Future of Meaningful Use – Stage 2
    • Quick Overview Final Rule – Stage 1
    • MU - By the Numbers
    • Stage 2 – Infrastructure Wave
    • Stage 2 Proposed Measures
    • Practice Redesign Considerations
    • Questions
  • Since Stage 1 Final Rule – July, 2010
    • ONC - Exit Dr. Blumenthal , Enter Dr. Farzad Mostashari
    • Stage 2 – Workgroups
    • Rapid Market Positioning in HC Orgs
    • New Payment Models Developing
      • CMMI -> ACOs
      • PQRS -> Value-Based Modifiers
      • Bundled Payments -> Revenue Cycle Mgmt (RCM) and Enterprise Resource Planning (ERP)
      • Value-Based Purchasing
    • State Initiatives Challenged (RECs, HIEs)
    • Enter the iPad clinicians’ companion device
    • ONC adopting HIE transport standards – Direct , XDS , Exchange
    • Industry Hungry for Data
  • Stage 2 Meaningful Use – HIE
    • ONC Considers Stage 2 the “Infrastructure Wave”
      • Seeking Production HIE
      • HIE across organizations and vendor boundaries
    • Transport Standards Announced
      • Direct (Push of information to a known recipient) required
        • Optional use of Query/Retrieve HIE
      • Standards Consensus announced
        • Specifically noted SNOMED, LOINC
    • Seeking production Registry reporting for Public Health – noting immunizations
      • Optional Menu Measure – State Cancer Registries
      • Optional Menu Measure – Specialty Registries
  • Certified EHR Technology
    • Redefining “Certified EHR Technology” (CEHRT)
      • For the 2011 Edition (Stage 1) – CEHRT meant provider had adopted EHR that met ALL 25 Stage 1 measures
      • For 2014 Edition (Stage 2)
    BASIC EHR – Everyone must have; “fundamental set of criteria;” Statutorily defined BASIC CORE EHR – EHR is certified for Core measures sought for the Stage sought by EP; Addresses specialists E.g., Psychiatrist does not do vitals = no certified vitals product required CORE MENU MENU EHR – Most dynamic; Only certified for that sought by EP for Stage sought
  • Since Stage 1 – Timelines
    • HITPC -> Recommendations to CMS June 16 th
    • ONC NPRM for Vendors (Certification) -> Feb. 22 nd
    • CMS NPRM for Providers -> Feb. 22 nd – Final Rule June / July, 2012
    • 5 Categories for Stage 2 :
      • Static Measures
      • Menu Measures Converted to Core
      • Expansion of Stage 1 Thresholds and Scope
      • New Stage 2 Measures
      • Removed / Consolidated Measures
    • Changes to Stage 1 Proposed in NPRM
    • Possible Stage 4 Noted
  • Meaningful Use – Stage 2Timing
    • Providers Reporting Period – Calendar Year
    • 3 Stages Original Roadmap:
    • CMS Propose Meaningful Use Road Map:
    First Payment Year Payment Year 2011 2012 2013 2014 2015 2011 Stage 1 Stage 1 Stage 2 Stage 2 Stage 3 2012 Stage 1 Stage 1 Stage 2 Stage 3 2013 Stage 1 Stage 2 Stage 3 2014 Stage 1 Stage 3 2015 Stage 3 First Payment Year Stage of Meaningful Use 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2011 1 1 1 2 2 3 3 TBD TBD TBD TBD 2012 1 1 2 2 3 3 TBD TBD TBD TBD 2013 1 1 2 2 3 3 TBD TBD TBD 2014 1 1 2 2 3 3 TBD TBD 2015 1 1 2 2 3 3 TBD 2016 1 1 2 2 3 3 2017 1 1 2 2 3
  • Proposed Stage 1 Changes – CY2013
    • CPOE Denominator
      • Currently: # of Unique Patients with 1 Rx seen by EP
      • “ Alternative”: # of orders for Rx during EHR Reporting Period
      • CY2013 -> EPs can use either
      • CY2014 -> New Denominator Only
    • Vitals Exclusion Clause
      • Currently: BP and Height/Weight not relevant
      • “ Alternative”: EP can split to exclude 1 only
      • CY2013 -> EPs can use either
      • CY2014 -> New Denominator Only
    • Vitals Age Requirements
      • Currently: See no patients age 2+
      • “ Alternative”: Sees no patients age 3+
      • CY2013 -> EPs can use either
      • CY2014 -> New Denominator Only
  • Proposed Stage 1 Changes – CY2013
    • Test of Exchanging Key Clinical Information
      • Proposed: Remove from Stage 1 in 2013; actual submission in 2014
      • Alternative 1: Require a successful test
      • Alternative 2: Remove, but require Rx Reconciliation or Summary of Care for TOC and referrals
      • Alternative 3: Change to 1 case of actual transmission for real patient for TOC or referral
    • 2 Measures -> Making Info Electronically Available and Timely Electronic Access
      • 2014 Edition Vendor Certification = obsolete
      • Proposed: CY2014 Stage 1 EP must replace with Stage 2 measure of Patient View and Download
    • Submission of CQMs Eliminated and Incorporated into definition of “Meaningful EHR User”
    • Encouraging submission of Immunization Data even if not state required
  • Future of Meaningful Use – Stage 2
    • Quick Overview Final Rule – Stage 1
    • MU - By the Numbers
    • Stage 2 – Infrastructure Wave
    • Stage 2 – Proposed Measures
    • Practice Redesign Considerations
    • Questions
  • ONC Original HIE Vision Medicaid Individual Facilities State Agencies Health Information Organizations Inter-State Public Health Corrections Fed Agencies Other States Statewide HIE MD Office MD Offices Hospital (CAHs) Hospital Other Community Providers Private HIE
  • Alabama One Health Record Dr. Smith Rural Health Emergency Urban Center Query Retrieve Billy Bob RHIO ONC Standard XDS Use Case : Car Wreck
  • Alabama One Health Record Dr. Smith Internist Dr. Heart Cardiologist ) Consult Referral Consult Report Betty Lou Use Case : Arrythmia ONC Standard DIRECT
  • Stage 2 Measures – 17 Core 17 Core Objectives No. Objective Measure Threshold New, Revised, Expanded, or Unchanged Exclusion 1 Computerized Provider Order Entry (CPOE) Use CPOE for medication, lab and radiology orders entered by any professional permitted by law 60% ( ↑ from 40%) Expanded EP has < 100 Rx, lab, radiology orders collectively 2 Generate and Transmit Permissible Prescriptions Electronically Using a certified EHR technology and compared to at least 1 drug formulary (still excludes controlled substance [Sch. II-V] and OTC) 65% ( ↑ from 40%) Expanded
    • EP writes < 100 Rx; or,
    • No pharmacy w/in 25 miles of the practice
    3 Record Patient Demographics Gender, race, ethnicity, DOB, and preferred language as structured data 80% ( ↑ from 50%) Expanded None 4 Record Vital Signs and Chart Changes Height & weight (all ages), blood pressure (ages 3+), BMI (all ages), and growth charts for children (0-20) as structured data 80% ( ↑ from 50%) Revised
    • No pts. age 3+
    • Ht., Wt., BP irrelevant
    • BP only irrelevant
    5 Record Smoking Status Patients age 13 and older as structured data 80% ( ↑ from 50%) Expanded EP does not see pts. age 13+
  • Stage 2 Measures – 17 Core 17 Core Objectives No. Objective Measure Threshold New, Revised, Expanded, Consolidated or Unchanged Exclusions 6 Implement Clinical Decision Support and Track Compliance
    • Implement CDS to improve on high-priority condition:
    • 5 CDS interventions for 5 or more CQMs during entire reporting period; and
    • Enable drug-drug and drug-allergy checks for entire reporting period.
    5 Rules and Rx alerting by attestation Expanded / Consolidated None 7 Provide Patients with Clinical Summaries For each office visit to patients within 24 hours , which includes up-to-date lists of problems, medications and Rx allergies (paper and electronic must be avail. to pt.) 50% (Unchanged) Expanded / Consolidated EP has no office visit during EHR reporting period 8 Implement Systems to Protect Privacy and Security of Patient Data Conduct/review a security risk analysis; implement security updates as necessary and correct security deficiencies; encrypt data at rest in accordance with 45 CFR 164.312(a)(2)(iv) and 45 CFR 164.306(d)(3) During Reporting Period by attestation Expanded None 9 Incorporate Clinical Lab Test Results into EHR Incorporated as structured data – positive/negative or numerical format – within the EHR 55% ( ↑ from 40% and made Core) Expanded EP orders no lab tests during EHR reporting period 10 Generate Lists of Patients by Condition 1 List with a Specific Condition for use in quality improvement, reduction of disparities, research or outreach By attestation (Made Core) Unchanged None 11 Send Reminders to Patients Preventative and follow-up care for all patients based on clinically relevant info for anyone with an OV in past 24 months 10% ( ↓ from 20%, all patients and Made Core) Expanded EP has no office visit in previous 24 months
  • Stage 2 Measures – 17 Core 17 Core Objectives No. Objective Measure Threshold New, Revised, Expanded, Consolidated or Unchanged Exclusions 12 Timely Electronic Access to Health Information Patients can view online, download and transfer info within 4 days of being available to EP, subject to EPs discretion to withhold certain info
    • 50% of all pts., and
    • 10% of pts. access
    New
    • EP has no orders / creates info required
    • >50% visit in county with >50% with 4Mbps broadband avail.
    13 Use EHR for Patient-Specific Education Resources Provide patient-specific education resources to all patients 10% (Unchanged but made Core and “if appropriate removed) Expanded EP has no office visit during EHR reporting period 14 Perform Medication Reconciliation During transitions of care (TOC) 65% ( ↑ from 50% and Made Core) Expanded EP not recipient of any TOC during EHR reporting period 15 Provide Summary of Care Record Patients referred or transitioned to another provider or setting and electronically transmit to a different system.
    • 65% of TOC or referrals ( ↑ from 50% and made core)
    • 10% electronically transmitted
    Expanded; New EP neither transfers nor refers patient during EHR reporting period
  • Stage 2 Measures – 17 Core *Exclusion does not apply if the registry can accept data through a designated HIE. 17 Core Objectives No. Objective Measure Threshold New, Revised, Expanded, Consolidated or Unchanged Exclusions 16 Use of secured messaging with Patients Send secured messages to patients seen during reporting period 10% New EP has no office visit during EHR reporting period 17 Submission of Electronic Immunization Data to Registry/Information Systems Ongoing submission During Entire EHR Reporting Period (Made Core) Expanded
    • EP does not admin. immunizations,
    • No electronic registry available*
    • No registry that accepts CEHRT standards available*
  • Stage 2 Measures – 3 of 5 Menu * Exclusion does not apply if data can be accepted through a designated HIE 3 of 5 Menu Objectives No. Objective Measure Threshold New, Revised, Expanded, Consolidated or Unchanged Exclusions 1 Submission of Electronic Syndromic Surveillance Data Ongoing data submission to Public Health agencies (where agencies can accept electronic data) During Entire EHR Reporting Period Expanded
    • EP does not collect any data,
    • No electronic registry available*
    • No registry that accepts CEHRT standards available*
    2 Imaging Results and Information Are accessible through the CEHRT 40% New EP does not perform diagnostic interpret. Of scans/test whose result is an image during reporting period 3 Patient Family Health History Structured data entry for one or more first-degree relatives 20% New EP has no office visits during reporting period 4 Submission of Cancer Cases Ongoing data submission to a state cancer registry During Entire EHR Reporting Period New
    • EP does not diagnose or directly treat CA
    • No public health agency is capable of receiving data
    5 Submission of Specialized Cases Ongoing data submission to a specialized registry During Entire EHR Reporting Period New
    • EP does not diagnose or directly treat CA
    • No public health agency is capable of receiving data
  • Clinical Quality Measures (CQMs)
    • Removed as MU Measure – Now Part of Definition of “Meaningful EHR User”
    • Proposing Group Reporting Option
    • 12 CQMs require, 3 reporting options proposed
      • 12 CQMs from comprehensive table ( 125 CQMs), 1 each of each 6 domains, or
      • 11 “Core” CQMs + 1 “Menu” from comprehensive table, or
      • Participation in EHR-based PQRS = CQMs and Bonuses for Both MU and PQRS
    • Eliminating 3 CQMs starting CY2014
      • NQF #0013 BP Management – lacks NQF continued endorsement
      • NQF #0027 Smoking & Tobacco Cessation – duplicates NQF #0028 a and b
      • NQF #0084 Heart Failure – lacks NQF continued endorsement
    • 2 Oral Health Measures Added
  • Future of Meaningful Use – Stage 2
    • Quick Overview Final Rule – Stage 1
    • MU - By the Numbers
    • Stage 2 – Infrastructure Wave
    • Stage 2 – Proposed Measures
    • Practice Redesign C onsiderations
    • Questions
  • Assessment – “You Are Here”
    • Clinic Culture Prep
      • Think about Users and Roles
      • Create a Vision Statement
      • Identify Leadership (Formal / Informal)
      • Communicate Plans
    • Workflow Assessment – Identify sources of:
      • Assessment Worksheet
      • Inefficiency / Delay / D uplication
      • Risk / Liability / Non-Compliance (e.g. HIPAA)
      • Quality concerns
      • High costs
  • IT Vendor and Practice Redesign
    • Compliant and certified as Complete EHR Software?
    • Senior Leadership and Staff – Ongoing Awareness & Understanding
    • Helps Identify Champions – Formal and Informal
    • Assists with Key Partner Collaboration
      • Network / Hardware Vendor
      • Lab Interfaces
      • Immunization Interface
      • HIE Interface
    • HIPAA Compliance – Datacenter?
    • Implementing New Technologies
      • Patient Portal, CDS, Formulary Management, HIE, Structured Knowledge Base, etc.
      • IT Needs such as iPads, Smartphones, Business Continuity Plans
  • Practice Redesign
    • Plot Data Collection Considerations / Workflows
      • Must be consistent
      • Like CDS - Identifying the “5 Rights” in Workflow
        • Right Information
        • Right Person Collecting
        • Right Format
        • Right Channel (e.g. EHR, Portal, PM)
        • Right Time in Workflow
      • Consider Data Needs – E.g., Outreach, PCMH, Productivity, Health Disparities Reduction, Research, Grant Writing
  • Copies available at: [email_address] Follow me on Twitter: www.twitter.com/Adele_Allison