Gain added clarity about your 2014 Meaningful Use attestation options to avoid Medicare payment adjustments, including timeline and impacts of recent CMS proposed rule changes. Preview the new interactive decision tool and understand compliance exemptions.

1. Expanded
Meaningful
Use
Mandates,
Excep4ons
&
A8esta4on
Strategies
Wednesday,
August
6,
2014
Disclaimer:
Nothing
that
we
are
sharing
is
intended
as
legally
binding
or
prescrip7ve
advice.
This
presenta7on
is
a
synthesis
of
publically
available
informa7on
and
best
prac7ces.

2. • Congress
mandated
payment
adjustments
to
Medicare
eligible
professionals
who
are
not
meaningful
users
under
the
EHR
Incen=ve
Program
• Payment
adjustments
will
be
applied
beginning
January
1,
2015
• May
be
exempt
when
able
to
show
that
demonstra=ng
MU
would
result
in
significant
hardship
Expanded
MU
Mandates

3. Expanded
MU
Payment
Adjustments
• Cumula=ve
1%
annual
and
(depending
on
total
meaningful
users
under
program
aLer
2018)
max
cumula=ve
adjustment
can
reach
5%

4. Expanded
MU
Payment
Adjustments-­‐
Medicare
Advantage
Organiza=ons
• Audits
to
be
conducted
2years
aLer
payment
year
• Adjustments
“about
six
months”
aLer
MAO
no=fied
of
results
• Correc=ve
plans
must
be
complete
within
that
six
month
period
• CMS
surveyed
all
MAOs
that
received
incen=ve
payments
to
determine
if
able
to
meet
2014
EHR
soLware
requirements
&
concluded
they
should
allow
same
flexibility
offered
to
Fee-­‐for-­‐
Service
providers
for
2014
• MAO
able
to
use
2011
edi=on
CEHRT
or
combina=on
2011
&
2014
during
2014
repor=ng
period
if
unable
to
fully
implement
2014
edi=on
due
availability
delay
issues
• Beginning
2015,
all
eligible
professionals
and
hospitals
will
be
required
to
report
using
the
2014
edi=on
CEHRT

5. PRIOR
TO
5/23/2014
PROPOSED
RULE
CHANGES
• All
providers
mandated
to
upgrade/adopt
cert
EHR
2014
• All
providers
regardless
of
MU
stage
use
only
three-­‐month
(or
90-­‐day)
repor=ng
period
2014
• EPs
who
first
demonstrate
MU
in
2014
must
demonstrate
90-­‐day
repor=ng
period
to
avoid
2015
adjustments
• Repor=ng
period
must
occur
in
first
9mos
of
calendar
year
2014,
must
a_est
by
October
1,
2014
to
avoid
adjustments
• EPs
must
con=nue
to
demonstrate
MU
every
year
to
avoid
payment
adjustments
in
subsequent
years
Expanded
MU
Mandates

6. • If
finalized,
5/23/14
proposed
rule
change
would
allow
providers
to
meet
Stage
1
or
Stage
2
MU
with
EHRs
cer=fied
to
the
2011
or
2014
criteria
-­‐
or
a
combina=on
of
both
• Not
a
blanket
policy
for
all
providers,
proposals
only
apply
to
those
who
can
demonstrate
that
they
are
unable
to
fully
implement
2014
edi=on
EHRs
• Note
that
Stage
1
objec=ves
and
measures
are
referenced
two
ways:
2013
and
2014
– 2013
designa=on
references
the
original
Stage
1
objec=ves
and
measures,
and
the
2014
reflects
those
changes
CMS
finalized
in
the
Stage
2
Final
Rule,
effec=ve
this
year
Expanded
MU
Proposed
Changes

7. Expanded
MU
Strategy

8. Expanded
MU
Strategy
CMS
Decision
Tool
h8ps://www.cms.gov/Regula4ons-­‐and-­‐Guidance/Legisla4on/
EHRIncen4vePrograms/Downloads/
CEHRT_NPRM_DecisionTool-­‐.pdf
Note:
Beginning
in
2015,
all
eligible
providers
would
be
required
to
report
using
2014
Edi7on
CEHRT.
If..
and..
then..

9. • Proposed
rule
would
formalize
=meline
to
extend
Stage
2
through
2016
-­‐
earliest
a
provider
would
par=cipate
in
Stage
3
of
MU
would
be
2017
• CMS
proposed
to
revert
CQM
repor=ng
requirements
for
providers
a_es=ng
with
2011
edi=on
EHR
–
EPs
would
report
on
6
selected
CQMs
as
they
did
in
previous
years
regardless
of
MU
stage
• Providers
with
2014
edi=on
would
s=ll
report
on
the
requirements
finalized
in
the
Stage
2
Final
Rule
• Providers
using
a
combina=on
of
2011
and
2014
Edi=on
CEHRTs
would
need
to
meet
the
CQM
requirements
depending
upon
their
Stage
of
MU
Expanded
MU
Proposed
Changes

10. Expanded
MU
A_esta=on
• 2014
Defini=on
of
Stage
1
EPs
must
meet:
– 13
required
core
objec=ves
– 5
menu
objec=ves
from
a
list
of
9
– Total
of
18
objec=ves
• Those
using
2011
cert
EHR
or
a
combina=on
of
2011
and
2014
edi=ons
choosing
to
report
2013
Defini=on
Stage
1
core
&
menu
objec=ves
reference
CMS
2013
Defini=on
Stage
1
of
Meaningful
Use
webpage

11. Expanded
MU
A_esta=on
• What
changed
for
Stage
1
in
2014:
– Pa4ent
Electronic
Access-­‐addi=on
of
new
core
objec=ve
to
provide
pa=ents
with
ability
to
view
online,
download,
and
transmit
health
informa=on
– Record
&
Chart
Changes
in
Vital
Signs-­‐increase
in
age
limit
for
recording
blood
pressure
in
pa=ents
to
age
3;
removal
of
age
limit
requirement
for
height
and
weight
(exclusion
for
eligible
professionals:
if
no
pa=ents
3
years
or
older
are
seen;
if
all
three
vital
signs
are
not
relevant
to
scope;
if
height
and
weight
not
relevant
to
scope;
or
if
blood
pressure
not
relevant
to
scope)
– Electronic
Copy
of
Health
Informa4on-­‐removal
of
electronic
copy
of
health
informa=on
core
objec=ve
for
Stage
1
for
all
providers
– Clinical
Quality
Measures-­‐removal
of
clinical
quality
measure
(CQM)
as
a
separate
core
objec=ve
for
Stage
1
for
all
providers

12. • If
approved,
exemp=on
valid
for
1
payment
year
only
• New
applica=on
required
for
following
payment
year
• Cannot
be
exempted
in
a
any
case
more
than
5
years
• 2015
EP
hardship
app
deadline
was
July
1,
2014
• 2016
applica=on
to
be
published
“soon”
Expanded
MU
Excep=ons

13. !Infrastructure:
must
demonstrate
that
they
are
in
an
area
without
sufficient
internet
access
or
face
insurmountable
barriers
to
obtaining
infrastructure
(e.g.,
lack
of
broadband)
!New
Eligible
Professionals:
insufficient
=me
to
become
meaningful
users,
can
apply
for
a
2-­‐year
limited
excep=on
to
payment
adjustments
(if
beginng
prac=ce
in
calendar
year
2015
would
receive
an
excep=on
to
the
penal=es
in
2015
and
2016,
but
would
have
to
begin
demonstra=ng
meaningful
use
in
calendar
year
2016
to
avoid
payment
adjustments
in
2017)
!Unforeseen
Circumstances:
Examples
may
include
a
natural
disaster
or
other
unforeseeable
barrier
Expanded
MU
Excep=ons

14. !Pa4ent
Interac4on:
• Lack
of
face-­‐to-­‐face
or
telemedicine
interac=on
with
pa=ent
• Lack
of
follow-­‐up
need
with
pa=ents
!Prac4ce
at
Mul4ple
Loca4ons:
Lack
of
control
over
availability
of
cert
EHR
for
more
than
50%
of
pa=ent
encounters
"
!2014
EHR
Vendor
Issues:
The
eligible
professional’s
EHR
vendor
was
unable
to
obtain
2014
cer=fica=on
or
the
eligible
professional
was
unable
to
implement
meaningful
use
due
to
2014
EHR
cer=fica=on
delays
Expanded
MU
Excep=ons

15. • A_esta=ons
must
be
completed
by
each
EP
reques=ng
Excep=on
• If
classified
in
the
Medicare
Provider
Enrollment,
Chain
and
Ownership
System
(PECOS)
as
having
one
of
the
following
5
specialty
codes
below
as
primary
area
of
prac=ce
no
exemp=on
form
is
needed
–
automa=cally
exempt
from
the
2015
payment
adjustment
based
on
the
data
in
PECOS
Diagnos=c
Radiology
Nuclear
Medicine
Interven=onal
Radiology
Anesthesiology
Pathology
Expanded
MU
Excep=ons

16. • Regardless
of
whether
an
EP
“passes,”
“hardships,”
“skips,”
or
“fails”
their
“Stage
1,
Year
2”
performance
during
2014
they
will
be
required
to
move
up
to
the
next
stage
– e.g.
PRIOR
TO
5/23/14
RULE
CHANGE
:“Stage
2,
Year
1”
in
2015
(with
a
full
year
repor=ng
period)
&
will
not
get
to
repeat
Stage
1
for
a
third
year
• Policy
applies
even
if
the
Medicare
EP
is
granted
a
“hardship
excep=on”
for
a
given
repor=ng
year,
it
skips,
or
it
fails
Expanded
MU
A_esta=on

17. • Timeline
for
proposed
rule
change
– July
21
public
comment
closed
– Unlike
a
direct
final
rule
process,
CMS
will
have
to
promulgate
&
announce
some
=me
prior
to
10/1/14
• Will
your
EPs
be
compliant
Oct-­‐Dec
2014?
• Is
your
EHR
cer=fied,
100%
ready?
• Will
state
level
registry
website
be
ready
with
rule
change
op=ons
to
facilitate
a_esta=on?
• Will
you
have
systems
&
policies
for
pa=ent
portal/
informa=on
exchange
in
place?
Expanded
MU
A_esta=on

18. Expanded
MU
A_esta=on
• Organiza=ons
that
have
already
upgraded
to
2014
CEHRT,
are
conserva=vely
encouraged
to
con=nue
progress
with
building
systems
as
originally
planned
in
2014,
un=l
addi=onal
clarifica=on
from
CMS
through
Final
Rule
• Any
progress
made
can
only
help
accomplish
the
implementa=on
of
your
2014
compliant
EHR
for
the
2014
and
2015
repor=ng
periods

19. Q&A
Thank
You!
Contact
your
Quirk
Project
Specialist
for
Meaningful
Use
strategy
guidance