How to Achieve Meaningful Use Stage 1: Hot Topics and FAQs

How to Achieve Meaningful Use Stage 1:
Hot Topics and FAQs
Presented by:
- Robert Anthony, Office of E-Health Standards and Services, CMS
Moderated by:
- Kate Berry, CEO, NeHC
July 23, 2012
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Medicare and Medicaid EHR
Incentive Programs:
Stage 1 Meaningful Use
Robert Anthony
Office of E-Health Standards and Services
Centers for Medicare & Medicaid Services
9
What are the Three Main
Components of Meaningful Use?
The Recovery Act specifies the following 3
components of Meaningful Use:
1. Use of certified EHR in a meaningful manner
(e.g., e-prescribing)
2. Use of certified EHR technology for electronic
exchange of health information to improve
quality of health care
3. Use of certified EHR technology to submit
clinical quality measures (CQM) and other such
measures selected by the Secretary
10
What is Meaningful Use?
• Meaningful Use is using certified EHR
technology to
• Improve quality, safety, efficiency, and reduce
health disparities
• Engage patients and families in their health care
• Improve care coordination
• Improve population and public health
• All the while maintaining privacy and security
• Meaningful Use mandated in law to receive
incentives
11
What are the Requirements
of Stage 1 Meaningful Use?
15 + 5 + 6 = MU
Eligible Professionals must complete:
• 15 core objectives
• 5 objectives out of 10 from menu set
• 6 total Clinical Quality Measures
(3 core or alternate core, and 3 out of 38 from menu set)
12
What are the Requirements
of Stage 1 Meaningful Use?
Basic Overview of Stage 1 Meaningful Use:
• Reporting period is 90 days for first year and 1 year
subsequently
• Reporting through attestation
• Objectives and Clinical Quality Measures
• Reporting may be yes/no or numerator/denominator
attestation
• To meet certain objectives/measures, 80% of patients
must have records in the certified EHR technology
13
EP Core Objectives
15 Core Objectives
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
Computerized provider order entry (CPOE)
E-Prescribing (eRx)
Report ambulatory clinical quality measures to CMS/States
Implement one clinical decision support rule
Provide patients with an electronic copy of their health information, upon
request
Provide clinical summaries for patients for each office visit
Drug-drug and drug-allergy interaction checks
Record demographics
Maintain an up-to-date problem list of current and active diagnoses
Maintain active medication list
Maintain active medication allergy list
Record and chart changes in vital signs
Record smoking status for patients 13 years or older
Capability to exchange key clinical information among providers of care and
patient-authorized entities electronically
Protect electronic health information
14
EP Menu Objectives
5 of 10 Menu Objectives
1.
2.
3.
4.
5.
6.
Drug-formulary checks
Incorporate clinical lab test results as structured data
Generate lists of patients by specific conditions
Send reminders to patients per patient preference for preventive/follow up care
Provide patients with timely electronic access to their health information
Use certified EHR technology to identify patient-specific education resources
and provide to patient, if appropriate
7. Medication reconciliation
8. Summary of care record for each transition of care/referrals
9. Capability to submit electronic data to immunization registries/systems*
10. Capability to provide electronic syndromic surveillance data to public health
agencies*
* At least 1 public health menu objective + 4 others
15
Meaningful Use Spec Sheets
You can find detailed information
on all the meaningful use
objectives and measure in our
Meaningful Use
Specification Sheets.
To find the specification sheets:
• Visit our website
(www.cms.gov/EHRIncentivePro
grams)
• Click on the ‘CMS EHR
Meaningful Use Overview’ tab
• Scroll to the bottom
• Select either “Eligible
Professional” or “Eligible
Hospital”
16
Exclusions for Meaningful
Use Objectives
• Some MU objectives not applicable to every
provider’s clinical practice, thus they would not have
any eligible patients or actions for the measure
denominator. Exclusions do not count against the 5
deferred measures
• In these cases, the eligible professional, eligible
hospital or CAH would be excluded from having to
meet that measure
• Eg: Dentists who do not perform immunizations; Chiropractors
do not e-prescribe
17
Clinical Quality Measures
3 Core CQMs
(or 3 Alternate Core
CQMs)
Choose 3 Additional
CQMs
(from a list of 38)
Things you should know:
• There are no thresholds to meet for CQMs
• Always report directly out of your certified EHR
• Reporting zeros is acceptable
• There may not be CQMs applicable to everyone
(e.g., specialists)
18
Primary Barriers to AIU/MU
Knowledge
Gaps
43 States now have
active programs,
with the others
expected to
onboard in 2012.
State
Onboarding
ROI and
Productivity
Technical
Support
Vendor
Support
Specialty Info
19
Technical
Support
• Knowledge gap about
certified EHRs
• Product selection
“What do I look for in an
EHR?”
“Which EHR should I buy?”
“How do I use my EHR
effectively?”
20
Vendor
Support
• Vendor support for
technical/MU issues
• Onboarding delay for
software implementation
21
FAQs
22
FAQs
Nearly 200 FAQs on our website
(www.cms.gov/EHRIncentivePrograms)
Basic to advanced
Learn about new FAQs from our listserv (sign up
on our website)
23
The CMS Top 10 List
10. How should an EP who orders meds
infrequently calculate CPOE? (formerly FAQ
#10639)
Prescribe more than 100 meds during the reporting
period
Maintain med list that includes meds they didn’t order
Orders meds for less than 30 percent of patients with a
med in their med list
If all the above apply, limit the denominator to patients
for whom EP has previously ordered meds.
24
The CMS Top 10 List
9. How do you determine whether a patient has been
“seen by the EP”? (formerly FAQ #10664)
All cases where EP-patient physical encounter
Telemedicine = “seen by the EP”
When an EP does not have face-to-face or telemedicine
encounters, EP should establish a consistent definition
for the denominator
25
The CMS Top 10 List
8. If I see patients in a setting without EHR, can I enter
their info into the EHR once I get back to my
practice? (formerly FAQ #10475)
Yes, but . . . CPOE
CPOE must be entered before action can be taken on the
order
26
The CMS Top 10 List
7. Can I exchange key clinical information
electronically using a CD-ROM, USB, or a printout?
(formerly FAQ #10638)
NO
27
The CMS Top 10 List
6. OK . . . so what methods can I use to electronically
exchange information? (formerly FAQ #10691)
Must do 2 things:
1. Use certified EHR to generate the CCD/CCR
2. Electronically transmit the CCD/CCR
28
The CMS Top 10 List
5. If I share an EHR with another EP, can I “exchange”
information with her? (formerly FAQ #10270)
Different legal entities
Distinct certified EHR
29
The CMS Top 10 List
4. Do you have to capture all of the clinical data for
CQMs to meet the requirements of the program?
(formerly FAQ #10839)
Although we encourage providers to capture complete
clinical data . . . CMS does not require providers to
record all clinical data in their certified EHR technology
at this time.
CMS requires providers to report the CQM data exactly as
it is generated as output from the certified EHR
technology
30
The CMS Top 10 List
3. Who can enter information? Who can enter CPOE
medication orders? (formerly FAQs #10071 and
#10134)
Any licensed healthcare professional if allowed per state,
local, and professional guidelines
Someone who can exercise clinical judgment in case of an
alert
CPOE must happen when order first becomes part of the
record and before any action can be taken on the order.
31
The CMS Top 10 List
2. If I don’t regularly perform an objective as part of my
practice, can I be excluded from meeting it?
(formerly FAQ #10151)
Exclusions are available only when our regulations
specifically provide for an exclusion.
EPs may be excluded from meeting an objective if they
meet the circumstances of the exclusion.
If an EP is unable to meet a Meaningful Use objective for
which no exclusion is available, then that EP would not
be able to successfully demonstrate Meaningful Use
32
The CMS Top 10 List
1. Can drug-drug and drug-allergy interaction alerts
also be used to meet the clinical decision support
measure?
NO
33
New FAQs!
How can I change my attestation information after I have
attested and/or received an incentive payment? (FAQ
#10982)
For “Incorporate clinical lab-test results”, how should a provider
attest if the numerator displayed by their certified EHR
technology is larger than the denominator? (FAQ #10981)
For “Provide summary care record for each transition of care or
referral “, should transitions of care between EPs within the
same practice who share certified EHR technology be
included in the numerator or denominator of the measure?
(FAQ #10980)
34
New FAQs!
For objectives that require a provider to test the transfer of data, such
as "capability to exchange key clinical information" and testing
submission of data to public health agencies, if multiple EPs are
using the same certified EHR technology across several physical
locations, can a single test serve to meet the measures of these
objectives?
For meaningful use objectives that require a provider to test the transfer
of data can the provider conduct the test from a test environment
or test domain?
For the Medicare and Medicaid Electronic Health Record (EHR)
Incentive Programs, how should an eligible professional (EP),
eligible hospital, or critical access hospital (CAH) that sees
patients in multiple practice locations equipped with certified EHR
technology calculate numerators and denominators for the
meaningful use objectives and measures?
35
Newer FAQs!
How can I change my attestation information after I have attested and/or
received an incentive payment? (FAQ #10982)
For “Provide summary care record for each transition of care or referral “,
should transitions of care between EPs within the same practice who
share certified EHR technology be included in the numerator or
denominator of the measure? (FAQ #10980)
For the Medicare and Medicaid Electronic Health Record (EHR) Incentive
Programs, how should an eligible professional (EP), eligible hospital, or
critical access hospital (CAH) that sees patients in multiple practice
locations equipped with certified EHR technology calculate numerators
and denominators for the meaningful use objectives and measures?
NEW!
Can an EP use inpatient or ED certified EHR technology to meet meaningful
use?
36
Newest FAQs!
Does a capital lease for Certified EHR Technology count as a
reasonable cost for Critical Access Hospitals (CAHs)?
NO YES
Can an EP use inpatient Certified EHR technology to achieve MU?
YES
. . . BUT
Inpatient CEHRT is not complete for all EP MU Objectives and no
CQMs
37
Audits
Basic Principles:
• Catch the obvious
• Focus on substantial non-compliance
• Employ smart risk-profiling
• Find the balance between cost of oversight and total
incentive payment
• Find the balance between hi-tech and hands-on
approaches (cost and LOE)
• Maximize existing/3rd party data sources where
appropriate
38
Audits
What You Can Do:
Check and double-check
Retain all relevant supporting documentation for 6 years
post-attestation
• Electronic and paper documentation
• CQM documentation
39
Helpful Resources
• CMS EHR Incentive Programs website
www.cms.gov/EHRIncentivePrograms
•
•
•
•
•
Introduction to EHR Incentive Programs
Frequently Asked Questions (FAQs)
Meaningful Use Attestation Calculator
Registration & Attestation User Guides
Listserv
• PAHCOM.com > Education > CMS Webinar Series
• http://www.pahcom.com/education/ehr-incentive-training.html
•HHS Office of National Coordinator Health IT certified EHR technology list
http://healthit.hhs.gov/CHPL
40
User Guides and Other Resources
• New Screens in the
CMS Registration &
Attestation Module
• User Guides have
been updated with
the new screens
41
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