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They Do Listen: Stage 2 Proposal Includes Some Changes to Stage 1 – Meaningful Use Monday

Posted on April 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.

Included in the Proposed Rule for Meaningful Use Stage 2 are several modifications to the requirements for Meaningful Use Stage 1—likely in response to a barrage of comments from providers. 

The MU Stage 1 measure requiring a test of the ability to exchange clinical data would be removed effective 2013. Apparently, the concept of a test created a great deal of confusion. This change, however, should not be interpreted as reduced interest in interoperability. In fact, Stage 2 is all about the sharing of data. The measure would be replaced in Stage 2 by numerous other measures that require the sharing of clinical information—both between providers and with patients. 

The “all 3 vital signs dilemma”, (described in a previous Meaningful Use Monday post), would be resolved by a change to the vital signs measure. Separating height and weight from blood pressure, the revised measure would allow a provider to meet the threshold for recording height and weight, while claiming an exclusion for blood pressure, (or vice-versa). This is good news for specialists like orthopaedists who may routinely document height and weight but who rarely document blood pressure unless it is relevant to a specific patient’s problem. This change would be available as an option in 2013, and formalized in 2014. (The vital signs measure would also increase the minimum age requiring blood pressure documentation from 2-year olds to 3-year olds.) 

Many providers reported a problem in meeting the CPOE measure because of the way the calculation was defined—particularly those providers whose treatment does not frequently include prescribing medication. Now, providers would be able to define the denominator as the number of medications ordered, rather than the “number of unique patients with at least one medication in the patient’s medication list”, (since that list often includes medications downloaded from Surescripts and prescribed by other providers.) There is already a CMS FAQ (#10369) that allows providers to use this alternate definition even in 2012.

The government is listening, so make your voice heard. Use your experience in Meaningful Use Stage 1 to influence Meaningful Use Stage 2. Submit your comments on the Proposed Rule for Stage 2.

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.

Helpful Meaningful Use Resources – Meaningful Use Monday

Posted on May 16, 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 spend a lot of my day answering questions about the EHR incentives from SRS clients and also from users of other EHRs. The questions range from extremely basic ones posed by people who are dazed and intimidated by the scope of the program to nuanced questions from those already knee-deep in meaningful use. Since I began writing Meaningful Use Monday, the resources on the subject have grown in number and specificity. Here are a few that physicians and administrators have found helpful recently:

  • Participate in a CMS Provider Call. There is one scheduled for this Thursday (5/19) at 2:30 PM Eastern Time. After the presentation, you will have an opportunity to ask questions and have them answered directly by CMS staffers. To register, click here.
  • The Attestation Users Guide not only provides information about both the registration and attestation processes, but by looking through it page by page, you will gain a in-depth understanding of the program‘s structure and how the requirements all fit together.
  • The CMS FAQ website is continually updated and has a search function that allows you to zero in on the information you need without reading through all (currently 148) questions.
  • Call the EHR Information Center: 1-888-734-6433 when you have questions or subscribe to the CMS Listserv to receive meaningful use news and updates.
  • I also invite you to take advantage of the meaningful use section of the SRSsoft website, where you will find a great deal of distilled information on the EHR incentives program and links to where you can find more.

 

Next week I will write about some interesting information I learned during a recent CMS call when I asked a question related to the reporting of clinical quality measures.

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.

CMS Registration Portal: Efficiencies Coming – Meaningful Use Monday

Posted on March 21, 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.

Registration and attestation are detailed processes which will demand a significant amount of physicians’ time. During a CMS/ONC session at HIMSS, an audience member asked whether each of her organization’s 800 physicians had to personally go onto the CMS portal and register individually. In response to the answer “yes”, she suggested that CMS should at least allow physicians to assign a “proxy” to an administrative staff member to complete the registration process on their behalf.

I am happy to report that such a process is in the planning stages for both registration and attestation, (at least for participants in the Medicare program), according to a recently posted FAQ on the CMS website—but physicians will have to wait until at least May to take advantage of it. Physicians must still register and attest individually, (as opposed to by group), but they will be able to designate a third party to handle these administrative tasks for them. Until this system is in place, however, each eligible professional will have to register for himself or herself. So, unless a physician is planning to attest to meaningful use early this year, it might pay to wait a few months to register.

Lynn Scheps is Vice President, Government Affairs at EMR 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 the previous Meaningful Use Monday posts.