This is the Year – 2013 is Here:
How to Meet Stage 1 & Stage 2 MU
Requirements and Avoid Penalties
April 17, 2013
Kathy Rivard
QIDE REC Practice Coordinator
1.866.475.9669, Ext. 108
krivard@wvmi.org - www.dehitrec.org
1
Who/What/When/Why/How
– Who should meet MU? Everyone!
– Who is eligible to receive an incentive if they
meet MU and be penalized if they don’t?
– Hospitals and providers, but this presentation is
aimed at providers
– Medicare eligible: MDs, DOs, DDS, DDM,
podiatrists, optometrists, chiropractors
– Medicaid eligible: physicians, nurse
practitioners, certified nurse midwives, dentists,
(no PAs eligible in DE) who have ≥ 30 percent
Medicaid patient volume
What ?
What is MU?
 2009 American Recovery & Reinvestment Act
included HITECH Act encouraging providers
to implement an EHR and use it
“meaningfully” to:
• Improve quality, safety, efficiency, and reduce
health disparities
• Engage patients and families in their care
• Improve Care Coordination
• Improve Population & Public Health
• Ensure privacy & security of PHI
When?
 In 2011, Stage 1 began:
– 15 core objectives + 5 menu objectives
 In 2011, incentive programs started to
encourage use of EHRs:
– Medicare incentives 2011→ 2016
• 5 consecutive years of participation
– Medicaid incentives 2011→ 2021
• 6 years of participation (non-consecutive)
4
When is Stage 2?
 Everyone must meet 2 years of Stage 1
before they begin Stage 2
 The only providers that will begin Stage 2 in
2014:
– Met Stage 1 in 2011, 2012, and 2013, OR
– Met Stage 1 in 2012 and 2013
5
Important Dates
Medicare providers:
 2014 = last year to begin participation
 2016 = last year to receive an incentive
 2015 = penalty if MU not met in 2013
Medicaid providers:
 2016 = last year to begin participation
 2021= last year to receive an incentive
6
Providers that Begin in 2013`
Medicare Incentive Payments if
Starting Program in 2013
2013
2014
2015
2016
Stage 1
Stage 1
Stage 2
Stage 2
$14,700*
after 4/1/13
$11,760
$7,840
$3,920
Stage 1
Stage 1
Stage 2
$11,760
$7,840
$3,920
Maximum
Payment by
Start Year
$38,220
$23,520
CMS Tool
 Informs you of the stage, reporting period, and
maximum incentive for each year
8
Why?
 Improve your patient’s care (care
coordination, clinical decision support)
 Include your patient in his care (patient
engagement)
 Advantage in becoming a Patient Centered
Medical Home
 Receive incentive while it’s still available
 Avoid Medicare penalty – must meet MU in
2013 to avoid penalty in 2015
9
How?
10
20 Objectives Still Required
 Stage 1 = 15 core + 5 menu objectives
 Stage 2 = 17 core + 3 menu objectives
11
General Requirements
 50 percent of all encounters must be at
locations equipped with certified EHR
technology
 80 percent of unique patients seen at
locations with CEHRT must have their
records in the EHR
 MU data is based on ALL patients, all
encounters, not just Medicare and Medicaid
patients
12
2013 Changes for Stage 1
Core Objectives
 CPOE – change in measure
 eRx – change in exclusion
 Vital Signs – change in measure and
exclusion
 CQM – answering measure deleted but
reporting CQM is still required
 Electronic exchange with provider – measure
deleted
13
Change to Core 1
CPOE in 2013
14
Change to Core 4
eRx in 2013
Current Stage 1 Measure
Exclusion =
Exclude if EP writes
<100 Rx during EHR
reporting period
New Stage 1 Option
EP does not have a
pharmacy within their
organization and there
are no pharmacies that
Additional Exclusion =
accept RXs within 10
miles of the EP's practice
location at the start of
EHR reporting period
15
Change to Core 8
Vital Signs in 2013
16
Deletion of Core 14 Electronic
Exchange With Provider in 2013
17
2014 Changes
 ALL participants need to utilize EHRs that
meet 2014 Standards & Certification criteria
– Everyone needs the ‘base’ EHR, then they
only need to add modules that will meet core
and menu objectives that they are reporting on
 Reporting period is reduced to 3 months for
all Medicare providers (to allow time for
providers to implement 2014 certified EHRs)
18
NO Exclusions
for Menu Objectives in 2014
 Currently providers can claim an exclusion for
a menu objective and meet MU
 Beginning in 2014 exclusions will no longer
count towards meeting the 3 required menu
objectives
19
General Changes
from Stage 1 to 2






Increases objective thresholds
Increases exchange between providers
Increases data security requirements
Promotes patient engagement
Requires electronic connectivity
Menu items become core
20
New in Stage 2





Secure messaging
Family health history
Imaging results
Registry reporting
Electronic progress notes
21
Stage 2 Focus on
Clinical Decision Support
 Use CDS to improve performance on high
priority health conditions
 2 parts to meet objective:
– Implement 5 CDS rules related to ≥4 CQMs or
high priority health conditions for entire
reporting period
– Enable and implement drug-drug functionality
and drug-allergy interaction checks for entire
reporting period
22
Stage 2 Focus on
Electronic Exchange
 Menu objective moved to core: Core #15
“Provide summary of care document for >50
percent referrals/transitions of care to another
provider or setting with >10 percent sent
electronically and >1 sent to a recipient with a
different EHR vendor or to the CMS test EHR
successfully
 Must meet all 3 requirements
>50 percent sent via hardcopy, e-mail, fax, etc.
>10 percent sent via EHR or HIE or Direct Messaging
23
Stage 2 Focus on
Patient Engagement
2 core measures that require patient engagement:
 Core 7 - Patient Electronic Access: 1) Provide online access to
health information for >50 percent of patients within 4 business
days, 2) with >5 percent of patients accessing their health
information online to view, download, or transmit to a third party
 Core 17 - Secure Electronic Messaging: >5 percent patients
send secure messages to their provider. Can be e-mail or the
electronic messaging function of a PHR, patient portal, or other
electronic means
–
–
–
–
Ask for prescription renewal
Ask a health related question
Request test results
Request health records
24
Stage 2 Core Objectives
25
Stage 2 Core Objectives - cont’d
26
Stage 2 Menu Objectives
* Order in this list is different from CMS spec sheets
27
Menu 1: Syndromic Surveillance
 Successful ongoing transmission of
syndromic surveillance data
28
Menu 2:
Electronic Progress Notes
 Provider must enter at least 1 electronic
progress note that is created, edited, and
signed for >30 percent of unique patients
seen during the reporting period
 Text must be searchable
29
Menu 3: Imaging Results
 >10 percent of all tests whose result is ≥1
image ordered by the provider during the EHR
reporting period is accessible through CEHRT
 Excluded if provider orders <100 tests whose
result is an image OR any provider who has no
access to electronic imaging results at the start
of the EHR reporting period
 Images and results can be stored natively in
CEHRT or scanned into the CEHRT or
accessible through a link
30
Menu 4: Family Health History
 >20 percent of all unique patients seen by the
provider during the EHR reporting period
have a structured data entry for ≥1 firstdegree relatives (parents, offspring, siblings)
 Structured data entry of “unknown” counts in
the numerator
31
Menu 5: Report Cancer Cases
 Provider must have successful ongoing
submission of cancer information from CEHRT
to a public health central cancer registry for the
entire EHR reporting period
 Exclusions:
– Provider does not diagnose or directly treat cancer
– There is no public health agency capable of
receiving cancer cases, or can enroll the provider at
the beginning of the reporting period, or can provide
timely information if they are capable of receiving
electronic cancer case information
32
Menu 6: Specialized Registry
 Provider must have successful ongoing submission of
‘specific’ case information from CEHRT to a specialized
registry for the entire EHR reporting period
 Exclusions:
– Provider does not diagnose or directly treat any disease
associated with a specialized registry
– There is no public health agency capable of receiving
cases, or can enroll the provider at the beginning of the
reporting period, or can provide timely information if
they are capable of receiving electronic case
information
33
Changes to CQM Effective in 2014 for Everyone
34
2013 CQM - Core Set
35
2013 CQM- Alternate Core Set
Clinical Quality Measures:
Alternate Core Set
NQF Measure Number & PQRI
Implementation Number
Clinical Quality Measure Title
NQF 0024
Weight Assessment and Counseling for
Children and Adolescents
NQF 0041
PQRI110
Preventive Care and Screening: Influenza
Immunization for Patient 50 Years Old or
Older
NQF 0038
Childhood Immunization Status
36
12 Stage 1 CQMs Deleted
37
6 National Quality
Strategy Domains
38
2014 CQM by Domains
39
9 CQM Recommended for PCP
NQF #
CQM Name
0018
Controlling High Blood Pressure
0022
Use of High-Risk Medications in the Elderly
0028
Tobacco Use: Screening & Cessation Intervention
0052
Use of Imaging Studies for Low Back Pain
0418
Screening for Clinical Depression & Follow-Up Plan
0419
Documentation of Current Medications in the Medical Record
0412
Body Mass Index (BMI) Screening & Follow-Up
TBD
Closing the Referral Loop: Receipt of Specialist Support
TBD
Functional Status Assessment for Complex Chronic Conditions
40
Electronic CQM Reporting
 ALL Medicare providers in ≥ 2nd year of
program must electronically report CQM data to
CMS
 Aligning this with PQRS measures so provider
gets credit for both programs, but only reports
once
41
Audits
 MEDICARE:
– Performed by Figliozzi & Company (3 year
contract)
– Providers notified mid-January
 MEDICAID:
– Performed by DMAP & PIP Team
– Audits will be done quarterly
– First group of providers selected in February
42
Initial Request
Initial MU Audit request includes the following:
 Certification document for the CEHRT
 EHR reports with N/D
 Documentation to support “Yes/No” measures
43
TIPS to Prepare for an Audit
 Keep all MU files for 6 years
 Keep a well organized audit file:
– Print ‘attestation summary’
– Print all relevant screen shots for yes/no
measures that include providers name and
have PHI blacked out
– Print all MU related e-mails (i.e. from DPH or
DHIN)
– Print copy of EHR contract verifying certified
version
44
How to Document
Yes/No Measures
 Screenshots showing enabled, active setting at
the beginning, middle, and end of reporting period
 Screenshot of a patient chart with the alerts
warning or CDS fired
 Administrative log showing no change request to
turn off functions during the reporting period
 Letter from EHR vendor with a statement that
functionalities were turned on/activated on a
specific date and time and that the functionality
was not interrupted
45
CMS Audits FAQ


https://questions.cms.gov/faq.php?faqId=7711
Will CMS conduct audits as part of the
Medicare and Medicaid EHR Incentive
Programs?
–
Any provider attesting to receive an EHR incentive
payment through either the Medicare or Medicaid
EHR Incentive Program can potentially be subject to
an audit. Here's what you need to know to make
sure you're prepared:
46
EHR Incentive Program Penalties
 HITECH Act stipulates that all Medicare
providers will be subject to a payment
adjustment if they do not demonstrate MU
 Penalties are based on prior years reporting
periods
 Providers must continue to meet MU every
year to avoid payment adjustments in future
years
47
Penalty Schedule
Effective in 2015
 Attest 2013 to avoid 1 percent penalty in 2015
(2 percent if don’t eRX)
 Attest 2014 to avoid 2 percent penalty in 2016
– Must attest on or before 10/1/14
– Last possible reporting quarter is 7/1/14 - 9/30/14*




Attest 2015 to avoid 3 percent penalty in 2017
Attest 2016 to avoid 4 percent penalty in 2018
Attest 2017 to avoid 5 percent penalty in 2019
Attest 2018 to avoid 5 percent penalty in 2020
48
EP Hardship Exceptions
1. Infrastructure – no internet or broadband
2. Newly practicing providers - receive 2 year
exception to payment adjustments
3. Unforeseen circumstances – natural disaster
4. Providers who lack face-to-face or telemedicine
interaction with patients and lack need to followup patients - *anesthesia, radiology, pathology
5. Lack of control of having >50 percent encounters
at a location with available CEHRT- for providers
who practice at multiple locations
49
EP Hardship Exceptions
 Providers must apply for the hardship
exemption by July 1 of the year before the
adjustment year
 To avoid payment adjustment in 2015,
providers must apply for exemption by
July 1, 2014
50
Medicaid Changes
Patient Volume:
 CY 2012: Based on a representative, consecutive 90day period within the previous calendar year
 CY 2013: Same as above OR a consecutive 90-day
period in the 12 months prior to date of application
Definition of volume:
 CY 2012: An encounter provided to a single person on
a single day for which Medicaid paid all or some part
 CY 2013: Same as above, or services rendered on any
one day to an individual enrolled in a Medicaid program.
Encounters no longer have to be paid to be counted
51
Questions?
This project is made possible through a grant from the Office of the National Coordinator with Department of
Health and Human Services support. Grant No. 90RC0044/01. Publication No. DEREC-LF-041613. App. 4/13.
52