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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.

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.