You will learn how to overcome continuing Stage 2 hurdles, and how to prepare for Meaningful Use Audits and MU Stage 3, to achieve success.

1. Presented By: Iatric Systems
Presenter Name: Kay Jackson
PROPOSED NPRM: Meaningful Use Stage 3:
How You Can Succeed

2. Breaking News: Friday April
10th
• New NPRM Outlines Proposed EHR Requirements
• Providers in 2015 through 2017
• May not release final until August.
Comment Period closed on June 15 PM
https://s3.amazonaws.com/public-
inspection.federalregister.gov/2015-08514.pdf

3. What Does this Mean????
First Change for Eligible Hospitals, removing:
• Demographics
• Vitals
• Smoking Status
• Structured Lab Results
• Patient List
• Summaries of Care (Core 12.1 and Core 12.3
only)
• eMAR
• Advance Directives
• Electronic Notes
• Imaging Results
• Family Health History

4. Change in Reporting Period
• Proposing a 90-day MU period for
2015 only-any 90 days!
• 2015 Reporting Period: Hospitals
would be able to choose any 90-
day range between 10/1/14
through 12/31/15-does not
need to match a quarter!

5. Change Portal Measure Core 6
• The View/Download/Transmit
changed
• From >5% to AT LEAST 1 PATIENT
• Not 10 or 10%, but 1 patient!

6. eRX Will be Required-Menu now
• No more Menu and Core
• The remainder of the measures will be required
• BUT FYI:
Stage 2 objectives for an EHR
reporting period in 2015 who were not
intending to attest to the eRx menu
objective and measure may also claim
an exclusion

7. What About Core 12?
Goodbye Core 12.1 and Core 12.3:
(1) uses CEHRT to create a summary of care
record; and (2) electronically transmits
such summary to a receiving provider for
more than 10 percent of transitions of care
and referrals.

8. How Many Comments?
Medicare and Medicaid Programs; Electronic
Health Record Incentive Program--Modifications
to Meaningful Use in 2015 through 2017
http://www.regulations.gov/#!
documentDetail;D=CMS-2015-0045-0001
What is your guess for total?

9. Stage 3 Update-Now just
waiting game

10. How Many Comments? (Closed
5/29)
EHR Incentive Program Stage 3
http://www.regulations.gov/#!
documentDetail;D=CMS-2015-0033-0002
What is your guess for total?

12. First Thing to Know About
Stage 3:
• Stage 3 info is All Proposed at this time
• Final regulations due this Fall??
• NPRM released on March 20, 2015
• Comment Period ended: Friday May 29th
• Cost of program from 2017-2020 is $3.7 billion
• Have not yet seen the Method Description
Overview:
• EHs, CAHs and EPs have same 8 Objectives
• Core and Menu no longer apply

13. Proposed Transitions of Care
• All discharges from an inpatient setting
are considered transitions of care
• For transitions from an emergency
department, eligible hospitals and CAH's
must count any discharge where follow up
care is ordered by an authorized provider,
regardless of how complete the
information available to the receiving
provider

14. Stage 3 will bring enormous
change:
• Data deluge and unprecedented access and
interoperability of clinical information in
electronic health records
• Liberation of clinical data
• Empowering payer to push for standardized
data and assist ACO’s
• $45 billion annually paid by Medicare for medical
care that was medically unnecessary or not
acceptable documentation

15. Electronic Submission of Medical
Documentation (esMD )
• Uses C-CDA (term used over 100 times in
the proposed rule)
• ID and reduce cost for federal payers
• Private payers will also use

16. http://www.healthit.gov/sites/default/files/c-cda_and_meaningfulusecertification.pdf

17. What are key dates?
1/1/2017
• Changing reporting period to calendar year and full 365 days
• Voluntary Stage 3 reporting
• Attestation between 1/1/18 and 2/28/2018
1/1/2018
• All providers regardless of Stage must to track Stage 3 and EP, EH
and CAH all same measures
• Attestation between 1/1/19 and 2/28/2019
12/31/2019
• Stage 3 ends-as of now Stage 4 will not occur
• Attestation between 1/1/2020 and 2/28/2020
• BUT appears you may need to continue to report measures

18. Payment Adjustments and
Hardships
• Lack of internet
• New EP or EH-one time exception
• Natural disasters case by case
• EP only exceptions due to a combination of
clinical features limiting a provider's
interaction with patients

19. Certification Requirements
• Some changes in criteria
• 2015 Edition Health IT Certification Criteria-all
providers use starting 2018
• API cert added
• ONC ACBs has new and revised conduct
• “Common Clinical Data Set” replaces “Common
MU Dataset”
• Have you seen the facelift for CHPL?

21. New Terms
• “ONC HIT Certification Program” to “ONC
Health IT Certification Program”
• “EHR Module” to “Health IT Module”
• “EHR” and “EHR Technology” to “Health IT”

22. Proposed Objective 1:
Protect Health Information
• Yes/No Measure
• Expanded explanation
• Administrative safeguards
• Risk Analysis-reviewed each year-365 days
• Risk Analysis upon upgrade to a new Edition
of certified EHR technology
• Review and update ongoing

23. Proposed Objective 1 Resources:
Guidance of Risk Analysis Requirement under HIPAA
Security Rule:
http://www.hhs.gov/ocr/privacy/hipaa/
administrative/securityrule/rafinalguidancepdf.pdf
Security Risk Assessment Tool (SRA Tool):
http://www.healthit.gov/providers-professionals/
security-risk-assessment-tool

24. Proposed Objective 2:
Electronic Prescribing
• >80% measure
• Permissible prescriptions
• Controlled substances (EPCS) now legal in many
states-why?
• Median Rate 53%
• OTC not included
• EP and EH exclusions
• Stage 3 will be only new and changed RX
• Formulary unavailable –can count

25. Proposed Objective 3:
Clinical Decision Support (CDS)
• Two Yes/No Measures
• Same as Stage 2 except:
• Explained relevant point of care
• Types of CDS allowed
• Implement CDS interventions which relate to care
quality improvement goals and a related outcome
measure CQM
• Only exclusions are for EP

26. Objective 3: Measure 1
• Must implement five clinical decision support
interventions related to four or more CQMs at a
relevant point in patient care for the entire EHR
reporting period.
• Absent four CQMs related to an EP, EH, or CAH's
scope of practice or patient population, the
clinical decision support interventions must be
related to high-priority health conditions.

27. Objective 3: Measure 2
• The Provider must enable and implement the
functionality for drug-drug and drug-allergy
interaction checks for the entire EHR
reporting period

28. Proposed Objective 4:
CPOE
• Three % Measures to track-just like Stage 2 but
Stage 3 expands to include diagnostic imaging to
included ultrasound, magnetic resonance and
computed tomography
• Orders entered by any licensed healthcare professional
or credentialed medical assistant
• CPOE function should be used the first time the order
becomes part of the patient's medical record and before
any action can be taken on the order
• Protocol and standing orders still excluded

29. Objective 4: Measure 1
• >80% Medication orders via CPOE
• Median score of 93%
• Stage 2 requirement is >60%

30. Objective 4: Measure 2
• >60% lab orders via CPOE
• Median score of 80%
• Stage 2 requirement is >30%

31. Objective 4: Measure 3
• >60% diagnostic imaging orders
• Unique Patient Measure
• Median score of 83% required
• Stage 2 requirement is >30%

32. Proposed Objective 5:
Patient Electronic Access to Health
Information
• Two % measures to track
• Some exclusions
• Unique patient measure
• API-new functionality to support data access
and patient exchange (application
programming interface)
• Patients will be able to collect their health
information from multiple providers and
potentially incorporate all of their health
information into a single portal

33. Example: Apple Health

34. NEW for Stage 3: API
If the provider elects to implement an API,
the provider would only need to:
• Fully enable the API functionality
• Provide patients with detailed instructions
on how to authenticate
• Provide supplemental information on
available applications which leverage the API

35. Proposed Objective 5 Measure 1:
• >80% The EP, EH or CAH provides access for
patients to view online, download, and transmit their
health information, or retrieve their health information
through an API, within 24 hours of its availability
• Stage 2 requirement is >50%
• Stage 2 currently is EH/CAH within 48 hours, and EP
is within 4 business days
** Use Demo Recall –historical measures

36. Quote from CMS:
“The Objective does not require the Provider to
made extraordinary efforts to assist patients in
use or access of the information, but the
provider must inform patients of these options,
and provide sufficient guidance so that all
patients could leverage this access.”
WHAT???? How else would you reach the %?

37. Proposed Objective 5 Measure:
Three Options:
1. Access provided with a portal
2. Access provided with an ONC-certified API
3. Access provided to an ONC-certified API that
can be used by third-party applications or
devices to provide patients (or patient-
authorized representatives) access to their
health information

38. Proposed Objective 5 Measure 2:
• >35% The EP, EH or CAH must use clinically
relevant information from CEHRT to identify
patient-specific educational resources and
provide electronic access to those materials
of unique patients seen by the EP or discharged
from the EH or CAH inpatient or emergency
department (POS 21 or 23) during the EHR
reporting period
• For Stage 2, Patient Education was covered in
Core 10 and required >10%

39. In Proposed Objective 5:
• The providers may withhold from online
disclosure any information either prohibited
by federal, state, or local laws or if such
information provided through online means
may result in significant harm.

40. Proposed Objective 6:
Coordination of Care through
Patient Engagement
• Three % Measures and Providers must report
on all three but must meet two
• Some exclusions
• Unique patient measure
• Stage 3 removed “paper communications”

41. Proposed Objective 6 Measure 1:
• >25% VDT patient or authorized representative
• Stage 2 requirement is >5% and EH struggled
• EH Median score of 11%
• Two options:
• Standard method portal
• Or API

42. Proposed Objective 6 Measure 2:
• >35% a secure message was sent using
electronic messaging function of CEHRT to
the patient OR in response to a secure
message sent by the patient (or authorized
representative) and provider must respond.

43. Provider/Patient situation:
“For measure 2, we propose to include in the
measure numerator situations where providers
communicate with other care team members
using the secure messaging function of certified
EHR technology, and the patient is engaged in
the message and has the ability to be an active
participant in the conversation between care
providers.”

44. Q: What types of communication
is excluded?
A: “However, we note that messages with
content exclusively relating to billing questions,
appointment scheduling, or other
administrative subjects should not be included
in the numerator.”

45. Proposed Objective 6 Measure 3:
>15% non clinical incorporated into EHR-ED
and inpatients

46. Proposed Objective 7:
Health Information Exchange
• Three % Measures and providers must report
on all three but must meet two
• Some exclusions
• Stage 3 must include the requirements and
specifications included in the Common
Clinical Data Set (CCDS)
• Unique device identifier (UDI) for implantable
medical devices

47. Note: Big Changes to Summary
of Care
• The purpose of this objective is to ensure a
summary of care record is transmitted or
captured electronically and incorporated
into the EHR for patients seeking care among
different providers in the care continuum,
and to encourage reconciliation of health
information for the patient
• Provider incorporates summary of care
information from other providers into their
EHR using the functions of certified EHR
technology

48. Referral Definition
• Referrals are cases where one provider refers
a patient to another provider, but the
referring provider also continues to provide
care to the patient
• Stage 3 Change: The inclusion of
transitions of care and referrals in which
the recipient provider may already have
access to the medical record maintained
in the referring provider's CEHRT, as long as
the providers have different billing
identities within the EHR Incentive Program

49. Proposed Objective 7 Measure 1:
• >50% patients create a summary of care
and electronically exchange
• Stage 2 requirement is combination of paper
and electronic paper-NO MORE PAPER
• Allows just clinically relevant lab tests
• Provider discretion where beneficial

50. Proposed Objective 7 Measure 2:
• >40% of transitions or referrals incorporated
in the EHR
• Recipients actively seek to incorporate
an electronic summary of care into the
patients record

51. Proposed Objective 7 Measure 3:
• >80% where provider has never encountered
the patient to perform clinical information
reconsolidation:
• Medication
• Medication allergy
• Problem list

52. Proposed Objective 8:
Public Health and Clinical Data Registry
Reporting:
• Yes/No measures
• EH and CAH must attest to a total of 4
• Importance of communication that should
exist between providers and public health
agencies
• Some exclusions
• Remove "ongoing submission" requirement
and replace it with an "active engagement”

53. Active Engagement Option 1:
• Registration to submit data
• Completed within 60 days of the start of the
reporting period
• If you are already registered, do not need to
submit registration

54. Active Engagement Option 2:
• Testing and validation
• Providers must respond from PHA within 30
days
• Failure to response twice within a reporting
period –would not meet the measure

55. Active Engagement Option 3:
• Production
• Completed testing and validation and
electrically submitting production date to the
PHA (Public Health) or CDR (Clinical Data
Registry)

57. CQMs
• 16 required CQMs
• Alignment between EHR Incentive Program and
CQM reporting programs such as IQR or PQRS
• CMS encourages EH/CAH to submit eCQMs for
2017
• Starting 1/1/2018 must submit eCQMs ***
• CQM measure Certification not required until RP
2018
• Between now and 2017, CQM can attest with
Core Measures, any version of the CQM’s OK

59. July 23, 2015
http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/
eCQM_Library.html

60. FAQ 7/2/15
New FAQ related to reporting CQMs with a zero
numerator and/or denominator

61. Resources
• NPRM
https://www.federalregister.gov/regulations/0938-AS26/electronic-health-record-ehr-
incentive-programs-stage-3-cms-3310-p-
• Data and Reports Median
http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/
Downloads/March2015_HITPCPresentation.pdf
• HIMSS One Source
http://www.himss.org/library/meaningful-use
• Interoperable
http://www.healthit.gov/sites/default/files/CMS-Stage-3-Meaningful-Use-proposed-rule
%20_FactSheet.pdf
• Federal Register
https://s3.amazonaws.com/public-inspection.federalregister.gov/2015-06685.pdf
• Infographic Stage 3
http://www.healthcareitnews.com/infographic/infographic-stage-3-objectives-hospitals?
mkt_tok=3RkMMJWWfF9wsRoisqjIZKXonjHpfsX56e8kX6G3lMI/0ER3fOvrPUfGjI4ETsZrI
+SLDwEYGJlv6SgFQ7LHMbpszbgPUhM=
• 20 Things to know about MU
http://www.beckershospitalreview.com/healthcare-information-technology/20-things-
to-know-about-meaningful-use.html

62. Meaningful Use Stage 3: How You
Can Succeed
Follow Us
Contact Us
Iatric Systems Account Executive: info@iatric.com
or visit our blog http://new.iatric.com/blog-home
Download the on-demand webcast
here: http://bit.ly/1fwO18t