Nalashaa - EHR Certification measures for the Quality Payment Program
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EHR certification requirements, and the capabilities an EHR should build to be eligible for QPP. Interoperability, data access and security are some of the core of QPP.
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Nalashaa - EHR Certification measures for the Quality Payment Program
- 1. Quality Payment Program – EHR certification measures iOS ANDROID WINDOWS CRM MICROSOFT SOCIAL CRM DESIGN EXPERIENCE CLOUDJAVA RWD www.nalashaa.com
- 2. www.nalashaa.com QPP – Through providers’ lens 2 Disparate programs such as EHR incentive program, PQRS and VBM tied together to yield ONE score Advanced APMs MIPS ACI Quality IA Cost EHR incentive program PQRS Value-ModifierNEW 2018 Report using a 2015 edition CEHRT
- 3. www.nalashaa.com What needs to be done? Capabilities that EHRs need to have for 2015 Edition 3
- 4. www.nalashaa.com Problem list and Family health history Demographics Patient Information 4 • Support newer baseline version of SNOMED CT (Sept 2015 or higher) • Conform to standards for Sexual Orientation and Gender Identity, CDC-OMB mapping for race and ethnicity • Optionally record data for Social, Psychological and Behavioral Data through questionnaire • Record UDIs for implantable devices; obtain and associate GUDID attributes Implantable devices Patient Health Information Capture Import documents shared by patient through reference or links Label, record and access the documents; support external site
- 5. www.nalashaa.com Common Clinical Data Set Interoperability 5 Support updated C-CDA Release 2.1 across document templates Implement bilateral asynchronous cutover, display clinical relevance information Optionally add a New Care Plan represents synthesis of multiple plans of care/treatment Support Edge protocol for DIRECT Apply and recognize security labels, support DS4P IG Export data using configurable storage location, time period, user privilege access to export summaries Receipt of C-CDA for both versions; support both passive and active communication Validation of accurate reconciliation Clinical Information Reconciliation & Incorporation
- 6. www.nalashaa.com Application Access Data Access 6 Receive request, return ID/token for subsequent retrieval of patient related information through APIs (ONC recommends FHIR) Technical impact includes implementing OAuth 2.0 through trusted connection Document the accessibility of API Respond to individual data elements under CCDS, within specific date range Third party should be able to receive patient data, common clinical data set using discrete data and get document Audit interactions between systems Real-time access of data to patient through APIs; Support new C-CDA version View, Download and transmit to 3rd party Adopt updated Info button standard (Release 2) and associated updated IGs (SOA-based IG and URL-based IG) Request using preferred language(optional) Patient-specific education
- 7. www.nalashaa.com Privacy & Security 7 Audit reports, Auditable events and tamper resistance • Audit changes in user privileges • SHA-2 or higher; Integrity • Counterparts Application Access to common clinical data set measure Trusted Connection
- 8. www.nalashaa.com Public Health Agencies 8 Immunization Registry (Bi-directional) • Receive history and forecast; updated IG (v1.5) • NDC code support for administered vaccines; CVX for historical Syndromic Surveillance (Optional) • No updates for Ambulatory; Updated IG for Inpatient Cancer Registry (Optional) • TNM Clinical Stage observation separated into a nested series of smaller templates Antimicrobial Use & Resistance reporting (Optional) • Generate CDA based on HAI Antimicrobial Use and Resistance, summary report for denominator and numerator Healthcare Surveys (Optional) • Include data elements in survey document; aligns with CCDA Electronic case reporting • Implement trigger codes, match patient list, send a constrained ToC
- 9. www.nalashaa.com eRx Care Coordination via Patient Engagement Patient Electronic Access HIE Reporting – Automated Measures 9 170.315(b) (1) - Transitions of Care (2) - Clinical information réconciliation and incorporation 170.315(b)(3) - Electronic Prescribing (a)(10) - Drug- Formulary and Preferred Drug List Checks 170.315 (g)(7) - Application access – patient selection (g)(8) - Application access – data category request (g)(9) - Application access – all data request (a)(13) - Patient-Specific Education Resources 170.315(e) (1) - View, Download, and Transmit to 3rd party (2) - Secure Messaging (3) - Patient Health Information Capture
- 10. www.nalashaa.com Record, Export and Report Clinical Quality Measures 10 Support updated IG for QRDA Cat I (Release 3) which aligns with C-CDA 2.1 and QRDA Cat III Import CQM data formatted to QRDA standard for one or multiple patients Only support implementation of QRDA Cat I (Release 3) Filter CQM results at patient and aggregate levels; create data file and display results Import & Calculate * Filter * Choose at least 1 HIGH PRIORITY measure or 1 OUTCOME based measure
- 11. www.nalashaa.com Improvement Activities under ACI 11 Expanded Practice Access Provide 24/7 access to eligible clinicians or groups who have real-time access to patient's medical record Has EHR impactHigh weightage Medium weightage Care Coordination • Implementation of use of specialist reports back to referring clinician or group to close referral loop • Implementation of documentation improvements for practice/process improvements • Implementation of use of specialist reports back to referring clinician or group to close referral loop • Practice improvements for bilateral exchange of patient information Population Management • Anticoagulant management improvements • Glycemic management services • Chronic care and preventative care management for empaneled patients • Implementation of episodic care management practice improvements • Implementation of medication management practice improvements • Implementation of methodologies for improvements in longitudinal care management for high risk patients
- 12. www.nalashaa.com Improvement Activities under ACI 12 Beneficiary Engagement • Use of CEHRT to capture patient reported outcomes • Engagement of patients through implementation of improvements in patient portal • Engagement of patients, family and caregivers in developing a plan of care Has EHR impactHigh weightage Medium weightage Behavioral and Mental Health • Implementation of integrated PCBH model • Electronic Health Record Enhancements for BH data capture Patient safety and practice assessment • Use of decision support and standardized treatment protocols Achieving Health Equity • Leveraging a QCDR to standardize processes for screening
- 13. www.nalashaa.com 27% 15% 4% 36% 18% Split of effort across various areas in MU3 CCDA FHIR PHA Rest MU Quality Highlights 13 CQMs API access • Structural changes and New templates (expect this in future too) • Need to support backward compatibility • Future-proof yourself, through an extensible and flexible design • Over 271 distinct criteria under ‘Quality’ • Offer choice for providers to report on those with the best scores • Eliminate programming changes annually • Open your EHR data to authorized third-parties • Respond to requests for partial or complete data • FHIR recommended • Minimize design changes in future CCDA 28 man- months
- 14. www.nalashaa.com The next 11 months 14 ACI development Certification Quality measures Provider training (6-7 months) (1 month) (3 months)* (1 month) * Assuming an EHR caters to multiple specialties and needs to cover multiple criteria ** Assuming these changes turn out to be simple enough. Note: The timelines mentioned above are indicative and may vary across solution providers Aug 2017 Upgrade (1 month) IA (2 months)** Oct 2017
- 15. www.nalashaa.com For more information, contact amit.m@Nalashaa.com Nalashaa Solutions llc. 555, US Highway One South, Ste 170, Iselin, NJ 08830 +1-732-602-2560 Ext: 200 15 Thank You
Editor's Notes
- MACRA, a landmark bipartisan legislation, advances a forward-looking, coordinated framework for health care providers to successfully take part in the CMS Quality Payment Program – QPP. QPP bedrock includes high quality patient centered care, continuous improvement and useful feedback. While QPP delivers high-quality care, it also rewards value and outcomes to physician by two avenues: Advanced APMs Merit Based Incentive Program For Adv APMs, a subset of APMs, Qualifying physicians can apply to a specific clinical condition, a care episode, or a population which earns QPs a 25% of Medicare Part B payments just by seeing 20% of Medicare patients through Adv APM. Few models that fall under APMs are CPC+, Next Generation ACO, OCM, ESDR care, Shared Savings programs. While the risk is high, the earnings are really more compared to MIPS. The second path to report data under QPP is using MIPS. Many small practices will be excluded from the new requirements due to low-volume threshold. So the eligibility for the MIPS program has been set to those clinicians with less than or equal to $30,000 in allowed charges or less than or equal to 100 Medicare patients, representing approximately 32.5 percent of all clinicians billing Medicare Part B services. Additionally, MIPS eligibility is identified by a unique TIN and NPI combination used to assess the performance as a 1) Physician, 2) Physician assistant, 3)Nurse practitioner, 4) Clinical nurse specialist Or 5) CRNA (certified registered nurse anesthetist) and the group that includes any of these. So the participants of QPP are now referred as Eligible Clinician. MIPS ties together 4 disparate programs under an umbrella and gives weightage for each category ACI – Replaces the Medicare EHR Incentive Program, also known as Meaningful Use which weighs 25% for 2017 Quality – Replaces PQRS and rules in weights with 60% IA – A new Category and weighs 15% Cost – Replaces Value-based modifier, count starting in 2018 This rule finalizes MIPS performance standards and a minimum MIPS performance period of any 90 continuous days during CY 2017 (January 1 through December 31) for all measures and activities applicable to the integrated performance categories. Allows flexible participation options for MIPS eligible clinicians as the program begins and evolves over time. For performance periods occurring in 2017, MIPS eligible clinicians will be able to pick a pace of participation that best suits their practices, including submitting data for a period of less than 90 days, to avoid a negative MIPS payment adjustment. Further, we are finalizing our proposal to use performance in 2017 as the performance period for the 2019 payment adjustment. Therefore, the first performance period will start in 2017 and consist of a minimum period of any 90 continuous days during the calendar year in order for clinicians to be eligible for payment adjustment above neutral. Performance in that period of 2017 will be used to determine the 2019 payment adjustment. Depending on the track of the QPP your clinicians choose for the transition year, the data clinicians submit by March 31, 2018, 2019 Medicare payments will be adjusted up, down, or not at all. The information provided here is only relevant for the 2019 payment year. CMS will provide additional information on payment adjustments for 2020 and beyond beginning next year. Let’s roll on to see what options would clinicians have for reporting
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- While there are a lot of changes that QPP forces upon EHR vendors, below are some that most of your efforts will be focused on. CCDA CCDA is a one stop source to see the patient’s most recent clinical information. These export summaries will be upgraded to C-CDA R2.using HL7 IG for CDA® R2: Consolidated CDA Templates for Clinical Notes, Draft Standard for Trial Use, and Release 2.1 for all the templates. 2015 Edition CCDS includes data for common data set as defined in 2014 Edition, encounter diagnoses, cognitive and functional status. For ambulatory settings– the reason for referral and referral details; for inpatient it includes the discharge instructions. New additions includes implantable device list, goals and health concerns; while few optional sections include patient’s BMI percentile. The CCDS references new and updated vocabulary standard code sets. Besides this, EHR should have the ability to set the time period within which data would be used to create the export summary using the relative date and time say for first of every month, or on a specific date or time or say when user signs a note or visit or an order. EHR should have the capability to send and receive the ToC or referral summaries via Edge protocol using the XDM processing. CEHRT needs to validate the C-CDA conformance by parsing different document types and detecting the errors corresponding to different sections in the document. Clinical Quality Measures There is no requirements for CQM reporting within ACI. However, the providers need to submit quality data for measures specified under the Quality performance category. The reporting of CQMs will be done using data captured in CEHRT to avoid unnecessary overlap and duplicative reporting. EHR vendors need to refine the existing list of CQMs they certified for in 2014 Edition to move the focus away from 3 NQF domains as required in the EHR Incentive Program. Vendors will need to wisely choose the measures that fit in the requirements of the clinicians. A minimum of 6 measures including one outcome measure needs to be implemented. If none of the outcome measures are relevant to the specialties EHR vendors cater to, they will need to implement another high priority measure that fits the specialty or practice requirement. The measures are also categorized into specialty measure sets to ensure right measures are selected for reporting. This demands that the EHR vendors implement new measure sets from the scratch. From experience we have seen that with most implementations the architecture design is not flexible and extensible. This poses a major concern since the measures get updated annually. EHRs need to export QRDA Cat I using QRDA-DSTU R3 and QRDA Cat III using DSTU R1 (September 2014 Errata) Other changes include the capability to import QRDA files into the EHR and ability to filter at the patient and aggregate levels based on patient demographics, problems and provider related information. Application Programming Interface (API) EHRs must now be able to demonstrate use of APIs by providing authentication using an ID or token that can be used by the third party. This will be used when the EHR receives a request for patient data, or for each of the individual data categories in the Common Clinical Data Set (CCDS) and application responds to the request for patient data associated with a specific date or within specified date range. The response for CCDS will be in a summary record format as adopted by CCDA version 2.1.ONC recommends use of HL7 FHIR standards to adopt the API implementation which is widely used. EHRs will have to provide documented APIs (explaining the syntax and semantics) for use by third parties.