A Deep Dive into the Final Rule:
Meaningful Use Modifications for 2015 -2017 and Beyond
October 21, 2015
Marlene Hodges and Sandy Swallow
1
Breaking News!
Modified Stage 2 Meaningful Use Rule
Issued October 6, 2015
2
https://s3.amazonaws.com/public-inspection.federalregister.gov/2015-25595.pdf
Today’s Objectives
A Deep Dive into Modified Stage 2 Final Rule
•
•
•
•
•
•
•
3
Key Concepts and long term program alignment
Updated participation timeline
Program changes
Attestation updates
Payment Adjustments and hardship exceptions
Measures/Objectives
Comments for Stage 3 and MIPS
Modified Stage 2 – 2015 through 2017
Key Concepts:
• Aligned EHR reporting period with the calendar year for
ALL providers
• Changed reporting period to 90-day period in 2015
• Restructured objectives/measures to align with Stage 3
• Relaxed patient engagement objectives that require
“patient action”
• Streamlined the program by removing redundant,
duplicative and topped-out measures to reduce burden
• CQM reporting for both EPs and EH remains as previously
finalized
4
Long Term Program Alignment
Timeline, Stages and Vendor Requirements
• All participants attest to modified version of Stage 2;
with accommodations for Stage 1 Providers; 2014 CEHRT
2015
• All EH and EP attest to modified version of Stage 2, at
Stage 2 thresholds; 2014 or 2015 CEHRT
2016
• Attest to either modified version of Stage 2 or full
version of Stage 3; 2014 or 2015 CEHRT
2017
2018
5
• Attest to full version of Stage 3 with 2015 CEHRT
Updated MU Timeline
First year as a
meaningful EHR user
stage of meaningful use
Stage of Meaningful Use
2015
2016
2017
2011
Modified Stage 2
2014 CEHRT
Modified Stage 2
2014 or 2015 CEHRT
Modified Stage 2 or 3
2014 or 2015 CEHRT
2012
Modified Stage 2
2014 CEHRT
Modified Stage 2
2014 or 2015 CEHRT
Modified Stage 2 or 3
2014 or 2015 CEHRT
2013
Modified Stage 2
2014 CEHRT
Modified Stage 2
2014 or 2015 CEHRT
Modified Stage 2 or 3
2014 or 2015 CEHRT
2014
Modified Stage 2*
2014 CEHRT
Modified Stage 2
2014 or 2015 CEHRT
Modified Stage 2 or 3
2014 or 2015 CEHRT
2015
Modified Stage 2*
2014 CEHRT
Modified Stage 2
2014 or 2015 CEHRT
Modified Stage 2 or 3
2014 or 2015 CEHRT
2016
N/A
Modified Stage 2
2014 or 2015 CEHRT
Modified Stage 2 or 3
2014 or 2015 CEHRT
In 2018, Everyone Moves to Stage 3 with 2015 CEHRT
6
* Special accommodations for Stage 1 providers
EHR Reporting Periods in 2015 - 2017
Year
Eligible Professional
Eligible Hospital/CAH
2015
All Participants
Any continuous 90-day period
from
Jan. 1 to Dec. 31, 2015
Any continuous 90-day period from
Oct. 1, 2014 to Dec. 31. 2015
2016
Returning participants
Full calendar year January 1 through December 31, 2016
2016
New participants
Any continuous 90-day period between January 1 and December 31, 2016
2017
Returning participants
Full calendar year January 1 through December 31, 2017
2017
New participants and/or
choose to implement
Stage 3
7
2018
All Providers (except
Medicaid 1st yr. EP)
Any continuous 90-day period between January 1 and December 31, 2016
Full calendar year January 1 through December 31, 2017
Objective and Measure Requirements
Single Set
• 10 Core Criteria for EPs
– Including consolidated
Public Health Objective
• 9 Core Criteria for EH/CAHs
– Including consolidated
Public Health Objective
8
MU Objectives 2015 - 2017
Objective
EP Measure
EH/CAH
Measure
Protect Elec Health Info
Conduct SRA/correct deficiencies
Same
Clinical Decision Support
5 rules related to 4+ CQM; drug/drug
and drug/allergy interaction check
Same
CPOE
>60% med, >30% lab, > 30% radiology
Same
eRx
>50%; drug formulary query
>10%; drug form. query
Health Information Exchange
Use CEHRT to create summary; >10%
electronically transmit
Same
Patient Specific Education
>10% unique patients
Same
Medication Reconciliation
>50% transitions of care
Same
Patient Elec Access (VDT)
>50% timely access; 1 patient VDT
Same
Secure Electronic Messaging
Fully enabled
n/a
Public Health
3 measure options attest to 2
4 measure options attest to 3
9
Relaxed Measures
10
Objective
Old
Current
Patient Electronic
Access (View,
Download or Transmit)
Measure = 5% of the
patients
Measure = 1 patient
Secure Messaging with
Patients
(EP only)
Measure = 5% of the
patients
Yes/No, stating
“functionality fully
enabled”
Modified Stage 2 - Clinical Quality Measures
Clinical Quality Measures
• 9 EP or 16 EH/CAH measures out of
64, covering at least three domains
• None are “required” but some are
recommended
• Zero in the denominator is a positive
response
• Can report through attestation system
or the PQRS portal (EP) and
QualityNet Portal (EH/CAH)
• 2015 CQM reporting period can be
different than the rest of MU (90 day)
11
Attestation Deadlines - EPs
2015
• Attestation will open January 4, 2016
• For new and returning EPs the deadline is February 29, 2016 to
avoid 2017 payment adjustments (PA)
2016
• For returning EPs the deadline is February 28, 2017 to avoid 2018
payment adjustments
• For new EPs the deadline is October 1, 2016 to avoid 2017 payment
adjustment
• For new EPs the deadline is February 28, 2017 to avoid 2018 payment
adjustments
12
Attestation Deadlines - EHs
2015
• Attestation will open January 4, 2016
• For new and returning EHs the deadline is February 29, 2016 to
avoid 2017 payment adjustments (PA)
2016
• For returning EHs the deadline is February 28, 2017 to avoid 2018
payment adjustments
• For new EHs the deadline is October 1, 2016 to avoid 2017 payment
adjustment
• For new EHs the deadline is February 28, 2017 to avoid 2018
payment adjustments
13
Attestation Deadlines - CAHs
2015
• Attestation will open January 4, 2016
• For new and returning CAHs the deadline is February 29, 2016 to
avoid 2015 payment adjustments
2016
• For new and returning CAHs the deadline is February 28, 2017 to
avoid 2016 payment adjustments
2017
• For new and returning CAHs the deadline is February 28, 2018 to
avoid 2017 payment adjustments
14
Attestation Updates
Medicaid EHR Participants Need to Know
• Attesting to AIU does not result in avoiding the Medicare payment
adjustment
• Changes to reporting period, stages and objectives criteria apply
• If Medicaid patient volume fall below program thresholds providers
will be able to avoid a Medicare payment adjustment by using the
Medicare Registration and Attestation system to attest
• Medicaid participants will not earn an incentive for that program year
• Does not effect their Medicaid program eligibility for subsequent
years
• Would not constitute a switch in programs
15
Payment Adjustments Facts
• EH - applied as a reduction to the applicable percentage increase to IPPS
payment rate tied to a specific year (page 571 Final Rule)
• CAH - adjustment to Medicare’s reimbursement for inpatient services
• EP - applied to MPFS and amounts established by law
o For 2015 – 99% of MPFS
o For 2016 – 98% of MPFS
o For 2017 and 2018 – 97% of MPFS
• Providers not eligible to participate in the Medicare EHR Incentive
Program (i.e. PA, ARNP, CMW) are not subject to payment adjustment
• Annual attestation required to avoid adjustment
• Stop after the calendar year it was applied if the provider meets MU
16
Hardship Exceptions
If you do not successfully attest in 2015, you may
apply for a hardship exception
• Apply in 2016 to avoid the 2017 Medicare payment
adjustments
–
–
–
–
Infrastructure
Lack of control
Lack of face-to-face interaction
Unforeseen and/or uncontrollable circumstances
• Hardship application tool will be available in early 2016
– July 1, 2016 deadline for EP and EH
17
Recently Released Hardship FAQs
Switching Vendors – Can I apply for a hardship?
• If a provider switches EHR vendors during the Program Year
and is unable to demonstrate meaningful use, the provider
may apply for an Extreme and/or Uncontrollable
Circumstances hardship exception and if approved may be
exempt from the payment adjustment.
• For example, if an eligible professional (EP) switches EHR
vendors in 2015 and is unable to demonstrate meaningful use
in 2015, the EP can apply for an EHR Vendor Issue hardship,
before the July 1, 2016 submission deadline, and be exempt
from the payment adjustment in 2017.
18
FAQ 12653
Created 9/23/15
Recently Released Hardship FAQs
What if your product is decertified?
• If your product is decertified, you can still use that product to attest
if your EHR reporting period ended before the decertification
occurred. If your EHR reporting period ended after the
decertification occurred, you can apply for a hardship exception.
• If the decertification occurs after the hardship exception period has
already closed for the payment adjustment year which would be
applicable for your reporting period, please contact CMS Hardship
Coordinator at EHRinquiries@cms.hhs.gov to apply for a hardship
exception under the Extreme and/or Uncontrollable Circumstances
category per CMS discretion to allow such an application.
19
FAQ 12657
Created 9/23/15
Recently Released Hardship FAQs
Unable to attest in 2015 due to timing of
Modification Rule release?
• If a provider is unable to meet the requirements of meaningful use
for an EHR reporting period in 2015 for reasons related to the timing
of the publication of the final rule, a provider may apply for a
hardship exception under the "extreme and uncontrollable"
circumstances category. Each hardship exception application will be
reviewed on a case-by-case basis, as required by law.
• In the past, CMS has considered these applications seriously and, in
fact, has approved over 85% of hardship exemptions. Hardship
applications will be available in early 2016 on website
https://www.cms.gov/EHRIncentivePrograms
FAQ12845
20
Created 10/7/2015
Updated 10/8/2015
Hospital-Based Providers
Qualifications for Hospital-Based EPs
• EP is ineligible for incentive payment and payment
adjustments if >90% covered professional services in
sites of service identified as:
– POS 21 (inpatient)
– POS 23 (emergency room)
• CMS did not proceed to change the definition to
include POS 22 (outpatient)
21
A Closer Look
A Deep Dive
Into the Modified Version Stage 2
Objectives and Measures
22
Objectives & Measures for Stage 2
Demonstrators
1) Protect Patient Health Information
Objective: Protect electronic health information created
or maintained by the CEHRT through the implementation
of appropriate technical capabilities.
• Conduct or review a security risk assessment
• To include encryption of ePHI created or maintained
• No exclusions
Link to SRA tool developed by ONC and OCR
https://www.healthit.gov/providers-professionals/security-riskassessment-tool
23
Objectives & Measures for Stage 2
Demonstrators
2) Clinical Decision Support (CDS)
• Objective: Use clinical decision support to improve
performance on high-priority health conditions.
• Measure 1: Implement 5 CDS interventions related to 4+
CQMs at a relevant point of care for the entire EHR reporting
period. If there are not 4 related to scope of practice or patient
population CDS must be related to high priority conditions.
• Exclusions: None
• Measure 2: Enable & implement drug-drug and drug-allergy
interaction checks for entire reporting period.
• Exclusion: EP who writes fewer than 100 prescriptions
*There is an exclusion and alternative objective for Stage 1 providers
24
Objectives & Measures for Stage 2
Demonstrators
3) Computerized Provider Order Entry for EP
• Objective: Use CPOE for medication, laboratory and radiology
orders directly entered by any licensed healthcare professional
that can enter orders into the medical record per state, local and
professional guidelines during the EHR reporting period.
• Measure 1: Use CPOE for 60%+ medication orders
• Measure 2: Use CPOE for 30%+ lab orders
• Measure 3: Use CPOE for 30%+ radiology orders
• Exclusions: Any EP who writes <100 medication, laboratory or
radiology orders during the reporting period
*There is an exclusion and alternative objective for Stage 1 providers
25
Objectives & Measures for Stage 2
Demonstrators
3) Computerized Provider Order Entry for EH/CAH
• Measure 1: Use CPOE for 60%+ medication orders created by
authorized providers of the EH/CAH inpatient or emergency
department during the reporting period
• Measure 2: Use CPOE for 30%+ lab orders created by authorized
providers of the EH/CAH inpatient or emergency during the
reporting period
• Measure 3: Use CPOE for 30%+ radiology orders created by
authorized providers of the EH/CAH inpatient or emergency
during the reporting period
• Exclusions: None for EH/CAH
*There is an exclusion and alternative objective for Stage 1 providers
26
Objectives & Measures for Stage 2
Demonstrators
4) ePrescribing (eRx) for EP
• Objective: Generate and transmit permissible prescriptions
electronically (eRx)
• EP Measure: 50%+ permissible prescriptions written by the
EP are queried for a drug formulary and transmitted
electronically using CEHRT
• EP Exclusions:
̶ Writes <100 permissible prescriptions during reporting
period
̶ Does not have a pharmacy w/I 10 miles that accepts eRx
*There is an exclusion and alternative objective for Stage 1 providers
27
Objectives & Measures for Stage 2
Demonstrators
4) ePrescribing (eRx) for EH/CAH
• EH/CAH Measure: 10%+ hospital discharge medication
orders for permissible prescriptions (new and changed) are
queried for drug formulary and transmitted electronically
using CEHRT
• EH/CAH Exclusions:
o does not have an internal pharmacy that can accept eRx and
that is not located w/in 10 miles of any pharmacy that accepts
eRx.
o In 2015, Stage 2 demonstrators that did not intend to select
eRx Menu Objective can claim an exclusion
*There is an exclusion and alternative objective for Stage 1 providers
28
Objectives & Measures for Stage 2
Demonstrators
5) Health Information Exchange
• Objective: EP, EH or CAH that transitions or refers their patient to
another setting of care or provider of care provides a summary of
care record for each transition of care or referral
• Measure: Provider that refers must -- Use CEHRT to create a summary of care record, and
- Electronically transmit such summary to a receiving provider
for 10%+ of transitions of care or referrals
• Exclusion: Any EP who transfers a patient to another setting or refers
at patient to another provider <100 times during the reporting
period. No exclusions for EH or CAH.
*There is an exclusion and alternative objective for Stage 1 providers
29
Objectives & Measures for Stage 2
Demonstrators
5) Health Information Exchange (continued)
• Maintains the data elements included in the summary of
care document at 77FR 54016 as follows:
̶
̶
̶
30
Patient name, referring provider’s name, office and contact
information, procedures, encounter diagnosis, immunizations,
lab results, vital signs, smoking status, functional status,
demographic information, care plan, goals, discharge
instructions (hospital), reason for referral (EP) (if information
is not available may leave blank)
Current problem list, medication list and allergy list must be
included and not left blank
Providers should work with their EHR developer to limit
parameters
Objectives & Measures for Stage 2
Demonstrators
6) Patient Specific Education
• Objective: Use clinically relevant information from CEHRT to
identify patient-specific education resources and provide those
resources to the patient.
• Measure: Patient-specific education resources identified by
CEHRT are provided to patients for 10%+ of all unique patients
with an office visit seen by the EP or admitted as inpatient or
emergency room for EH or CAH during the reporting period
• Exclusions: Any EP who has no office visits during the reporting
period. No exclusion for EH or CAH.
*There is an exclusion and alternative objective for Stage 1 providers
31
Objectives & Measures for Stage 2
Demonstrators
7) Medication Reconciliation
• Objective: the EP, EH or CAH that received a patient from another
setting of care or provider of care or believes an encounter is relevant
performs medication reconciliation.
• EP Measure: the EP performs medication reconciliation for 50%+ of
transitions of care in which the patient is transitioned into the care of
the EP
• EP Exclusion: Any EP who was not the recipient of any transitions of
care during the reporting period
• EH/CAH Measure: the EH or CAH performs medication reconciliation
for 50%+ of transitions of care in which the patient is admitted to
inpatient or emergency department (POS 21 or 23)
• EH/CAH Exclusion: none
*There is an exclusion and alternative objective for Stage 1 providers
32
Objectives & Measures for Stage 2
Demonstrators
8) Patient Electronic Access – EP
• EP Objective: Provide patients the ability to VDT their health information within
4 business days of the information being available to the EP.
• EP Measure 1: 50%+ of all unique patients seen by the EP during the reporting
period are provided timely online access to their health info. to VDT to a 3rd party.
• EP Measure 2 for 2015 and 2016: at least one patient (or authorized
representative) seen by the EP during the reporting period views, downloads or
transmits (VDT) his or her health info. to a third party during the reporting period.
• EP Measure 2 for 2017: 5%+ of unique patients (or authorized representative) seen
by the EP during the reporting period VDT to a third party their health information
during the reporting period.
• Exclusions: Any EP who neither orders nor creates any of the information listed for
inclusion. Conducts 50%+ of patient encounters, or is located in county that does
not have 50%+ housing units with 4Mbps broadband availability from FCC.
33
*There is an exclusion and alternative objective for
Stage 1 providers
Objectives & Measures for Stage 2
Demonstrators
8) Patient Electronic Access – EH or CAH
• EH/CAH Objective: Provide patients the ability to VDT their health information
within 36 hours of hospital discharge.
• EH/CAH Measure 1: 50%+ of all unique patients who are discharge from the
inpatient or emergency department of an eligible hospital or CAH are provided
timely online access to VDT to a third party their health information.
• EH/CAH Measure 2 for 2015 and 2016: at least one patient discharged from the
inpatient or emergency department (or authorized representative) views,
downloads or transmits (VDT) his or her health information to a third party during
the reporting period.
• EH/CAH Measure 2 for 2017: 5%+ of unique patients discharged from the
inpatient or emergency department (or authorized representative)VDT to a third
party their health information during the reporting period.
• Exclusions: Any EH or CAH that is located in a county that does not have 50%+ of
its housing units with 4Mbps broadband availability from FCC on the first day of
the reporting period.
34
*There is an exclusion and alternative objective for
Stage 1 providers
Recently Released Patient Electronic
Access FAQ
If multiple eligible professionals or eligible hospitals contribute information to a
shared portal or to a patient's online personal health record (PHR), how is it
counted for meaningful use when the patient accesses the information on the
portal or PHR?
This answer is relevant to the following meaningful use measures:
• For Eligible Professionals:
“More than 5 percent of all unique patients seen by the eligible professional during the
EHR reporting period (or their authorized representatives) view, download or transmit
to a third party their health information.”
• For Eligible Hospitals and Critical Access Hospitals:
“More than 5 percent of all unique patients (or their authorized representatives) who
are discharged from the inpatient or emergency department (Place of Service 21 or 23)
of an eligible hospital or CAH view, download or transmit to a third party their
information during the EHR reporting period.”
• EP Measure:
"Patient-specific education resources identified by CEHRT are provided to patients for
more than 10 percent of all unique patients with office visits seen by the EP during the
EHR reporting period."
35
Recently Released Patient Electronic
Access FAQ – Continued
•
•
If an EP sees a patient during the EHR reporting period, the EP may count the patient in the
numerator for this measure if the patient (or an authorized representative) views online,
downloads, or transmits to a third party any of the health information from the shared portal or
online PHR. The same would apply for an eligible hospital or CAH if a patient is discharged
during the EHR reporting period. If patient-specific education resources are provided
electronically, it may be counted in the numerator for any provider within the group sharing
the CEHRT who has contributed information to the patient's record if that provider has the
patient in their denominator for the EHR reporting period. The respective EP, EH, or CAH must
have contributed at least some of the information identified in the Stage 2 final rule to the
shared portal or online PHR for the patient. However, the respective provider need not have
contributed the particular info. that was viewed, downloaded, or transmitted by the patient.
Although availability varies by state and geographic location, some Health Information
Exchanges (HIEs) provide shared portal or PHR services. If a provider uses an HIE for these
services to make information available to patients, in order to meet meaningful use
requirements the provider must use an HIE that is certified as an EHR Module for that purpose.
The HIE must be able to verify whether a particular provider actually contributed some of the
information identified in the Stage 2 final rule to the shared portal or PHR for a particular
patient. If a provider elects to use the HIE for these shared portal or PHR services, the
provider must include the HIE’s certification number as part of their attestation.
36
FAQ12821; Created 10/2/2015
Recently Released Patient Electronic
Access FAQs
If a patient sends a message or accesses his/her health information made available
by their eligible professional (EP), can the other EPs in the practice get credit for
the patient’s action in meeting the objectives?
Yes. This transitive effect applies to the Secure Messaging, the 2nd measure of the Patient
Access (View, Download and Transmit) core objectives, and Patient Specific Education.
• If a patient sends a secure message about a clinical or health related subject to the group
practice of their EP, that patient can be counted in the numerator of the Secure
Messaging measure for any of the EPs at the group practice who use the same certified
electronic health records technology (CEHRT) that saw the patient during their EHR
reporting period.
• Similarly, if a patient views, downloads or transmits to a third party the health information
that was made available online by their EP, that patient can be counted in the numerator
of the 2nd Patient Access measure for any of the EPs in that group practice who use the
same CEHRT and saw that patient during their EHR reporting period.
• If patient-specific education resources are provided electronically, it may be counted in
the numerator for any provider within the group sharing the CEHRT who has contributed
information to the patient's record if that provider has the patient in their denominator
for the EHR reporting period.
37
FAQ12825; Created 10/2/2015
Objectives & Measures for Stage 2
Demonstrators
9) Secure Electronic Messaging (EP Only)
38
EP Objective: Use secure electronic messaging to communicate with patients
on health information.
2015: the capability for patients to send and receive a secure electronic
message with the EP was fully enabled during the entire reporting period.
2016: at least 1 patient seen by the EP during the reporting period was sent a
secure message using the electronic messaging function (or authorized
representative), or in response to a secure message sent by the patient (or
authorized representative).
2017: 5%+ unique patients seen by the EP during the reporting period was sent
a secure message using the electronic messaging function (or authorized
representative), or in response to a secure message sent by the patient (or
authorized representative).
Exclusion: any EP who has no office visits during the reporting period, or
conducts 50%+ encounters in a county that does not have 50%+ of its housing
units with 4Mbps broadband availability from
the FCC.
*There is an exclusion and alternative objective for Stage 1 providers
Objectives & Measures for Stage 2
Demonstrators
10) Public Health Reporting
• Objective: The EP, EH or CAH is in “active engagement”
with a public health agency to submit electronic public
health data from CEHRT except where prohibited and in
accordance with applicable law and practice.
• EP must meet 2 and EH/CAH must meet 3
• 3 definitions of “Active engagement”
Option 1: Completed registration to submit data
Option 2: Testing and validation
Option 3: Production
*There is an exclusion and alternative objective for Stage 1 providers
39
Objectives & Measures for Stage 2
Demonstrators
Public Health Reporting (continued)
Measure
Measure Specification
Maximum times measure
can count towards
objective
Measure 1 – Immunization
Registry
EP, EH or CAH
1
Measure 2 – Syndromic
Surveillance
EP, EH or CAH
1
Measure 3 – Specialized
Registry
EP, EH or CAH
2 for EP, 3 for EH
EH or CAH
1 EH
Measure 4 - Electronic Lab
Results Reporting
40
Objectives & Measures for Stage 2
Demonstrators
Public Health Reporting (continued)
Exclusions:
1.
2.
3.
Don’t administer immunization, or collect surveillance data, diagnosis
and treat any disease or perform reportable lab results.
Operate in jurisdiction for which immunization registry, public health
agency receives surveillance data, capable of accepting electronic
registry transactions in specific standards.
Operates in jurisdiction where no immunization registry, public health
agency or specialized registry declares readiness to receive transactions
at the beginning of the EHR reporting period.
Exclusions don’t count toward 2 (EP) or 3 (EH/CAH) measures
unless you can exclude from specialized registries.
41
Accommodations for Stage 1 Providers
You are attesting to Stage 1 in
2015…
42
• Stage 1 based on the same
core objectives
• Attest to Stage 1
thresholds
• Will take an exclusion for
the Stage 2 measures if
there is no equivalent
Stage 1 measure
• Menu objectives move to
core objectives
Accommodations for Stage 1 Providers
Objective
Alternate Measure, Exclusion/Specifications for 2015
Protect Elec Health Info
None
CDS
EP, EH and CAH - Implement one CDS rule relevant to
specialty or high clinical priority, along with the ability to
track compliance
CPOE*
EP, EH and CAH - >30% med, exclusion for lab and radiology
eRx*
EP - >40 % EP;
EH and CAH – may take an exclusion for Stage 1 and Stage 2
did not intend to demonstrate as a Menu in Stage 2
Health Information Exchange EP, EH and CAH - Exclusion
Patient-Specific Education
EP, EH and CAH - Exclusion, if did not intend to demonstrate
as a Menu objective in Stage 1
*In 2016, EH and CAHs previously scheduled to be in Stage 1 may claim an alternate exclusion.
43
Accommodations for Stage 1 Providers
(Continued)
44
Objective
Alternate Measure, Exclusion/Specifications in 2015
Med. Reconciliation
EP, EH and CAH - Exclusion, if did not intend to demonstrate
as a Menu objective in Stage 1
Pt. Electronic Access
EP, EH and CAH – Exclusion for the second measure; does
not have equivalent measure
Secure Electronic Messaging
(EP only)
EP - Exclusion; does not have equivalent measure
Public Health
EP – must meet 1 measure
EH and CAH – must meet 2 measures
Preparing for 2015 Attestation
• Watch the 2015 EHR Incentive Program Requirements website
– Updated Measures Specifications Sheets
– FAQs
– Attestation guides
• Verify registration information is accurate
–
–
–
–
–
Confirm your Stage
Check registration information
NPPES login information
Make sure e-mail address is correct
Make sure payment information is correct
– Identify and Access Management (I & A)
45
CMS Seeks Public Comment
MACRA alters the EHR Incentive Programs for EPs
• Comment topic:
– Incorporation of Stage 3 Meaningful Use into MACRA and MIPS
• Submit Comments by December 17, 2015
– Electronically: http://www.regulations.gov
– Regular mail: CMS, Dept. of HHS, Attention: CMS-3310 &3311-FC, P.O. Box
8013, Baltimore, MD 21244-1850
– Overnight mail: CMS, Dept. of HHS, Attention: CMS-3310 &3311-FC, Mail Stop
C4-26-05, 7500 Security Boulevard, Baltimore, MD 21244-1850
46
Resource Library
•
EHR Incentive Stage 3 and Modification Rule 2015-2017
https://s3.amazonaws.com/public-inspection.federalregister.gov/2015-25595.pdf
2015 EHR Incentive Program Requirements
https://www.cms.gov/Regulations-andGuidance/Legislation/EHRIncentivePrograms/2015ProgramRequirements.html
Hardship Exception
https://www.cms.gov/Regulations-andGuidance/Legislation/EHRIncentivePrograms/PaymentAdj_Hardship.html
EHR Incentive Program Website
https://www.cms.gov/Medicare/Medicare-Fee-for-ServicePayment/PhysicianFeedbackProgram/valuebasedpaymentmodifier.html
National Institutes of Health
http://www.nih.gov/health/clinicaltrials/registries.htm
National Quality Registry Network (NQRN)
http://www.ama-assn.org/ama/pub/physician-resources/physician-consortium-performanceimprovement/nqrn.page
National Broadband Map (NBM)
http://www.broadbandmap.gov/developer/api/county-broadband-availability-api-search-by-countyname
•
•
•
•
•
•
47
Who to Call for Help?
QINQIO Colorado Contact:
Terrey Currie
720.554.1396
Terrey.currie@area-d.hcqis.org
QINQIO Iowa Contact:
Sandy Swallow
515-223-2105
Sandy.swallow@area-d.hcqis.org
QINQIO Illinois Contacts:
Linda Brewer
630.928.5819
Linda.brewer@area-d.hcqis.org
Temaka Williams
630.928.5838
Temaka.williams@area-d.hcqis.org
EHR Incentive Program Information Center:
• 888-734-6433 , press option 1 (TTY 888-734-6563)
• Monday – Friday: 8:00 am – 8:00 pm EST
Questions or comments can be sent to: meaningfuluse@cdc.gov
48
Thank you for joining!
Sandy Swallow
515-223-2105
Marlene Hodges
515-457-3707
Sandy.swallow@area-d.hcqis.org
mhodges@telligen.com
This material was prepared by Telligen, the Medicare Quality Innovation Network Quality Improvement Organization, under contract
with the Centers for Medicare & Medicaid Services (CMS), an agency of the U.S. Department of Health and Human Services. The
contents presented do not necessarily reflect CMS policy. 11SOW-QIN-B4-10/2015-11282
49