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Meaningful Use Stage 2 Final Rule: What You Need to Know—At Least For Now – Meaningful Use Monday

Posted on August 27, 2012 I Written By

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money.

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money. Check out Lynn’s previous Meaningful Use Monday posts.

Without delving into all the specifics detailed in the 672-page Final Rule for Stage 2, what is important to comprehend—for now—is how Stage 2 raises the bar set by Stage 1 and how it intensifies the focus on health information exchange and patient engagement.

The following are some highlights of Stage 2:

  • The Final Rule not only confirms 2014 as the earliest effective date for Stage 2 (as expected), but it provides additional leeway for providers and for vendors by limiting the Stage 2 reporting period to 90 days in 2014, instead of a full year.
  • EPs must meet or exclude all 17 core measures and must meet—not “meet or exclude”—3 of the 6 menu measures. (Unlike Stage 1, exclusions of menu measures do not count unless the EP cannot find 3 relevant menu measures.)
  • All Stage 1 menu measures except syndromic surveillance become core measures.
  • 5 new menu measures have been added: access to imaging results, family history, progress notes, reporting to cancer registries, and reporting to specialized registries.
  • Stage 2 increases most Stage 1 thresholds.
  • CPOE is expanded to include lab and radiology orders, in addition to prescriptions.
  • Patient portals play an important role as a means of providing patients with access to their medical records. Physicians will have to ensure that at least 5% of the patients they see actually view, download or transmit their health information and that over 5% of the patients seen send them a secure e-mail message containing clinical information, (i.e., not just a request for an appointment.)
  • Clinical summaries of office visits must be available to patients within 1 day, instead of the 3-day timeframe in Stage 1.
  • The Stage 1 measure requiring a test of the ability to exchange clinical data with another provider has been dropped effective 2013, in favor of a more robust 2014 Stage 2 requirement for ongoing exchange of a significantly more extensive data set.
  • EPs will report on 9 of 64 clinical quality measures, and after the provider’s first incentive year, the CQM data must be submitted electronically, rather than by attestation.
  • In an effort to streamline the reporting process, Stage 2 offers opportunities for batch reporting by group practices and for consolidated CQM reporting for PQRS and meaningful use.
  • Penalties and hardship exemptions are defined, establishing October 1, 2014 as the latest date by which an EP can attest for the first time and avoid a 1% payment adjustment in 2015.

More information about Stage 2 will follow in future Meaningful Use Monday posts.

Comments Submitted on Stage 2: Is the Bar Being Raised Too High? – Meaningful Use Monday

Posted on May 7, 2012 I Written By

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money.

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money. Check out Lynn’s previous Meaningful Use Monday posts.

The 60-day comment period on the Proposed Rule for Stage 2 Meaningful Use ends today. If the length and depth of the comments published so far are any indication, CMS will have a lot of reading and thinking to do between now and August, when the Final Rule is expected. 

The tone of the comments is somewhat consistent—general support for the direction and spirit of the rule, but concern that the bar is being raised too high, too quickly. One fear is that if providers perceive the requirements to be unachievable or impractical, they could be discouraged from even trying to meet them.  

These are some of the common themes that are already emerging:

  • Although MU Stage 2 was postponed to 2014, the timing is still very challenging. Several groups have already recommended a 90-day reporting period for the first year of MU Stage 2, which would provide for a phasing-in of the increased requirements, similar to MU Stage 1.
  • Meaningful Use Stage 2 is considerably more complex than Meaningful Use Stage 1, with the introduction of new measures and the addition of sub-components to Stage 1 measures. Many would require physicians and staff to implement new and more complex workflows.
  • The core and menu structure continues, but the menu options are fewer and would leave many providers with no real choices since several of the menu measures would not apply to their practices.
  • While increased patient engagement is recognized as an important goal, providers are expressing concern about having their incentives be dependent on actions by patients—actions over which they have no real control. For example, one proposed measure would require that 10% of patients access their information on the physician’s portal, and another that 10% of patients send a secure e-mail message to their physician.
  • Some measures could have significant cost implications for physicians—for example, there are often costs associated with developing the interfaces necessary to send data to registries and/or HIEs.
  • Clinical quality measure reporting, described in one set of comments as “daunting,” is eliciting detailed comments. Developing a reasonable set of requirements that are harmonized with other government programs will require a great deal of work. 

More to come, as more comments become publicly available.

Tips for Successful MU Attestation – Meaningful Use Monday

Posted on January 9, 2012 I Written By

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money.

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money. Check out Lynn’s previous Meaningful Use Monday posts.

Having just experienced the attestation process firsthand as I watched an SRS client successfully attest to meaningful use, I am happy to report that this part of demonstrating meaningful use is relatively easy—a bit tedious if you are attesting for multiple providers, but not at all difficult. CMS has created a user-friendly, web-based attestation system. Assuming that your EHR provides the information you need in a useful format, you have successfully met all the required measures, and you come prepared, there should be no reason to have an unsuccessful attestation.

Here are some tips that will ensure your success:

  • Register in advance: Even though you can register as late as at the time of attestation, the combined task would be overwhelming—particularly if you are attesting “on behalf of” a provider. Registering in advance ensures that everything is up-to-date in NPPES and PECOS and that you have all the necessary information.
  • Make sure that all measures have been met: If your EHR does not show the percentages for measures that have thresholds, do the math yourself to verify your success on each one. CMS offers a worksheet that you might find helpful for this purpose. Verify that you have also met all other (non-numerical) measures. If you fail to satisfy even one measure, do not attest now—go back and try another reporting period.
  • Have documentation for each provider:
    – Registration confirmation page with registration ID#

    – Password

    – EHR certification number

    – Reporting period dates (make sure it covers at least 90 days)

    – Printout of all meaningful use measures: numerators and denominators, exclusions and reasons

      (when there is more than one possible reason)

    – Clinical Quality Measure report: numerators, denominators, exclusions

  • Do not hit “Submit” until you have reviewed the “Attestation Summary” page: Double check your data. Make sure that you have said “yes” to all yes/no measures and that your numbers are entered accurately. The summary page does not display percentages, so you have to do the math yourself to be sure that you meet the thresholds.
  • Submit attestation and print the “Submission Receipt” as confirmation: If you have done everything correctly it will state that “all measures are accepted and meet MU minimum standards.”

While not necessary, I highly recommend having a second person help you attest. A second set of eyes will shorten the time the process takes and will reduce the potential for errors in posting your data.

Some of the Thinking Behind Meaningful Use Stage 2 – Meaningful Use Monday

Posted on August 29, 2011 I Written By

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money.

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money. Check out Lynn’s previous Meaningful Use Monday posts.

A great deal of work, discussion, and debate by the HIT Policy Committee and its Workgroup members went into developing the recommendations for meaningful use Stage 2 (discussed in the last two Meaningful Use Monday posts). Meetings were frequent and lengthy, but I tried to listen in on most of them to gain some insights into the thinking behind the decisions being made and the future direction of meaningful use. 

Committee members struggled with striking the right balance between aggressively pressuring providers so that adoption would be accelerated, on the one hand, and maintaining a realistic and practical view of their capabilities, on the other. Some committee members were adamant about staying on track to reach the Stage 3 end goals within the predetermined 2015 time frame, (i.e. remaining on the escalator, as the progression is often referred to), while others recognized that overburdening providers could lead to program failure, i.e., discouraging adoption by imposing unreasonable expectations that would cause providers to doubt their ability to earn the incentives and abandon the effort altogether. The debate led to an open question: does everything have to be accomplished under the umbrella of meaningful use?

 An issue that I think could have used more discussion is how to make meaningful use relevant for specialists—a subject raised frequently by Committee member Gayle Harrell. There was general agreement about the importance of having all types of physicians participate in the incentive program, and testimony from a variety of specialists was solicited. Other than suggesting a large number of new clinical quality measures, however, the basic recommendations are still predominantly primary-care focused. 

Lastly, there was a prevailing sense of frustration over the fact that the calendar did not allow time for an analysis of the experience of Stage 1 before requiring the definition of Stage 2.

EMRs, ICD-10 Pave the Way to Business Intelligence

Posted on June 16, 2011 I Written By

Two articles I’ve written in the last 24 hours have gotten me thinking that we’ve already entered the post-implementation era of EMRs, even as implementation remains in progress at so many healthcare organizations. While the vast majority of hospitals and physician practices in the U.S. still don’t have full-featured EMRs in place, many are already looking well into the future.

As you may already know, HIMSS on Tuesday released its first-ever survey on “clinical transformation.” According to HIMSS and survey sponsor McKesson, “Clinical transformation involves assessing and continually improving the way patient care is delivered at all levels in a care delivery organization. It occurs when an organization rejects existing practice patterns that deliver inefficient or less effective results and embraces a common goal of patient safety, clinical outcomes and quality care through process redesign and IT implementation. By effectively blending people, processes and technology, clinical transformation occurs across facilities, departments and clinical fields of expertise”

As I reported for InformationWeek, 86 percent of organizations surveyed had a plan for clinical transformation in place or at least under development, and just 12 percent of respondents called organizational commitment a barrier to reporting on quality measures. And though nearly 8o percent indicated that they still gather quality data by hand and 60 said they don’t capture data in discrete format, more than half already had software specifically for business intelligence. This tells me that analytics is here to stay.

I kind of knew that anyway, since the bulk of the program at last week’s Wisconsin Technology Network Digital Healthcare Conference was devoted to BI, data governance and advanced analytics tools, even in the context of Accountable Care Organizations. (My story about this for WTN News appeared this morning.)

“I’m ready to declare the era of business intelligence,” said Galen Metz, CIO and IS director for Madison-based Group Health Cooperative of South Central Wisconsin. Though he criticized the proposed ACO rules for being too “daunting” for the average provider, Galen and other speakers said that it’s time to harness all the new, granular data being generated by EMRs and, soon, ICD-10 coding.

It may seem “daunting” now in the midst of all the preparations for ICD-10 and meaningful use, but it’s good to know that many healthcare organizations see a light at the end of the tunnel and know that the future bring better healthcare information in exchange for all the hard work and investment today.

 

Clinical Quality Measures Revisited: Who Defines Relevance? – Meaningful Use Monday

Posted on May 23, 2011 I Written By

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money.

The fact that the CMS FAQ website contains 7 questions on clinical quality measure (CQM) reporting is an indication of the confusion surrounding this core meaningful use measure.

Many specialists are concerned that very few, or none, of the CQMs are relevant to their practices. According to FAQ #10144, “In the event that none of the 44 clinical quality measures applies to an EP’s patient population, the EP is still required to report [but with] a zero for the denominators.” It would be logical, therefore, for physicians to conclude that they should report a zero denominator for quality measures related to problems or conditions they do not treat.

For the purpose of meaningful use, however, it is not the physician who determines whether a particular quality measure applies—it is the EHR.  In one of the final steps of the attestation process, physicians must confirm that “the information submitted for CQMs was generated as output from an identified certified EHR technology.”

This means that, in reality, physicians will rarely be able to report a zero denominator.  Any secondary problem documented in a patient’s chart will place the patient in the denominator of all measures related to that problem—even if the physician did not treat the patient for it. For example, an ENT specialist who records vital signs, (see “The “All 3” Vital Signs Dilemma”), will have to report on whether she documented a weight management plan for patients who have a body mass index outside of the norm, even though she only treated those patients for an earache or sinusitis. An orthopaedist will have to report on how many times he provided smoking cessation guidance to patients who presented with tennis elbow—and whether he documented the blood pressure of patients he diagnosed with a sprained ankle or broken wrist, who happen to have hypertension. Pediatricians who have even a few patients over age 18, (and most do), will have to report on the core CQMs designed for adult populations, rather than on the more relevant pediatric-focused alternate measures such as immunization status or childhood weight management.

The above has no effect on eligibility for incentives—physicians will qualify for the EHR incentives regardless of the numerators they report for these CQMs, since there are no thresholds that must be met. CMS acknowledges that for now, the clinical quality measure reporting requirement is simply that—a reporting requirement.

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money. Check out Lynn’s previous Meaningful Use Monday posts.

Meaningful Use Measures: Clinical Quality Measures – Meaningful Use Monday

Posted on April 11, 2011 I Written By

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money.

I am starting the discussion of the individual meaningful use measures with “reporting on clinical quality measures (CQM)” for two reasons: It is one of the three pillars of meaningful use identified in the legislation, and it is a measure that appears to be causing a great deal of confusion.

Just one of the 15 core measures required of meaningful users, it sounds a lot like PQRI (now PQRS); and many of the measures are, in fact, taken from that program. However, unlike PQRS, meaningful use requires reporting only—it does not set required thresholds, at least not in Stage 1—and reporting is not limited to Medicare patients. Interestingly, physicians can earn both PQRS and EHR Incentives in the same reporting period (in contrast to ePrescribing and EHR incentives.)

While EPs cannot exclude this measure, providers can report “0”s (for denominators and numerators) if they cannot find measures that apply to their patient population.

The Final Rule shortened the list of quality measures contained in the Proposed Rule—eliminating the specialty-specific measure sets—and created a list of 44 CQMs from which EPS must choose. Some specialists perceived this change as good news, while others were disappointed.

Reporting Requirements:

Eligible professionals must report on 3 “Core CQMs” and 3 “Additional CQMs” as follows:

  • There are 3 Required Core CQMs” (Hypertension, Smoking Cessation, and Adult Weight Screening) and 3 “Alternate Core CQMs” (Weight Assessment for Children, Flu Vaccinations for Patients over 50, and Childhood Immunizations.) EPs must report on the 3 Required Core CQMs. If a physician reports “0”s for one or more of the 3 Required Core CQMs, he/she must then report on up to 3 Alternate Core CQMs. (Some specialists, therefore, may have to report on as many as 6 core CQMs.)
  • There are 38 Additional CQMs from which physicians must also select 3. Again, there will be some specialists who find few measures, if any, that are relevant to their patient populations. They must still report on 3 of these measures with actual numerators and denominators where possible and “0”s for the others.

You can read more about the quality measures and their specifications in the Final Rule, pages 44398-44408, and on the CMS website.

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money. Check out Lynn’s previous Meaningful Use Monday posts.

Meaningful Use Measures – Exclusions – Meaningful Use Monday

Posted on April 4, 2011 I Written By

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money.

In response to strong lobbying activity and numerous comments from physicians, the Final Rule on Meaningful Use (Stage 1) included a provision for physicians to exclude certain measures that are outside the scope of their practice. This was primarily an accommodation made to enable specialists to participate in the EHR incentives program without substantially changing their practices—although some primary care physicians may find exclusions applicable to them as well.

For a physician to exclude a measure:

  • The measure must be explicitly identified as “excludable” in the Final Rule—not all measures contain such a provision. (6 core and 7 menu measures are potentially excludable, but for some there will be very few providers who would meet the criteria.)
  • The physician must meet the defined criteria for exclusion of that particular measure.
  • The physician must attest that he/she meets these criteria.

Excluding a measure is the equivalent of meeting that measure. Therefore, if a physician excludes one (or more) of the menu measures, he/she only has to satisfy 4 of the remaining 9 menu measures (or 3 of the 8, etc.) The excluded measure does not have to be replaced by another measure.

In the next Meaningful Use Monday posts, I will address each of the measures individually and will identify the eligibility criteria where exclusions exist. I’ll start with Reporting on Clinical Quality Measures (one of the 15 Core meaningful use measures) because while not technically excludable, there is an accommodation available for the many specialists who find none of the measures relevant.

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money. Check out Lynn’s previous Meaningful Use Monday posts.