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Meaningful Use Stage 2 Proposed Rule

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Presentation on theme: "Meaningful Use Stage 2 Proposed Rule"— Presentation transcript:

1 Meaningful Use Stage 2 Proposed Rule
AAMC comment letter: AAMC Contacts: Ivy Baer: Lori Mihalich-Levin: Jennifer Faerberg: Mary Wheatley: Scott Wetzel:

2 Stage 2 Decision Tree: Medicare
INCENTIVE! (CMS)! YES Have you attested to EP quality measures (CMS)? YES NO Have you attested to core & menu measures of meaningful use (CMS)? YES NO Are you using certified EHR technology (ONC)? YES NO 2015: Unless are hospital-based or meet an exception, penalty begins Are you a non-hospital based EP? (CMS) NO YES NO: $0; no penalty Are you an eligible professional (EP)?

3 Stages of Meaningful Use By Payment Year
First Payment Year Payment Year 2011 2012 2013 2014 2015 2016 2017 Stage 1 Stage 2 Stage 3 Stage 2 Source: Federal Register, Table 2 (March 7, 2012 p )

4 Stage 1 Stage 2 EPs 15 core 3 of 5 menu 20 total objectives
5 or 10 menu 20 total objectives EPs 17 core 3 of 5 menu 20 total objectives Hospitals/CAHs 14 core 15 of 10 menu 19 total objectives Hospitals/CAHs 16 core 2 of 4 menu 18 total objectives

5 Stage 1 Menu Moved to Proposed Stage 2 Core
Implement drug-formulary checks Record existence of advance directives (core for EH only) Incorporate lab results as structured data (only where results are available) Generate pt lists for specific conditions Send pt reminders Summary of care record Submit reportable lab data (core for EH only) Submit syndromic surveillance data

6 New Measures – Proposed
EP EH 30% visits have at least 1 electronic EP note 30% of EH pt days have at least one e-note by MD, NP or PA 30% of EH med orders automatically tracked via electronic med admin recording 80% of pts offered ability to view and download via web-based portal w/in 36 hrs of discharge relevant info in the record Online secure pt messaging in use Pt preferences for communication medium recorded for 20% of pts List of care team members (including PCP) available for 10% of pts in EHR Record of longitudinal care plan for 20% of pts with high priority health conditions

7 Major Clinical Quality Measure (CQM) Changes (EPs and Hospitals)
Through 2013 – Report 3 core/alternate core + 3 measures (EPs) Attest to results or EHR-PQRS pilot submission (EPs) Continue to report 15 CQMs finalized in Stage 1 (Hospitals) Changes in 2014 – Criteria for CQM same for all stages (EPs) 3 options for reporting, including group reporting (EPs) Electronic submission (EPs) Report 24 out of 49 (proposed) CQMs (Hospitals) Must have at least one measure in each of the six quality domains (Hospitals) Ability to pick the measures most relevant to their patient population or services offered (Hospitals)

8 2014 CQM - 3 Options for EPs 1a) 12 measures/ 6 domains At least one measure in each of the 6 domains 125 measures 1b) 11 “core” plus 1 measure 11 core measures listed One additional measure 2) PQRS-EHR Follows rules for PQRS-EHR submission Could change in future rule-making Group Reporting >=2 NPI per Tax ID Number ACOs* GPRO* OR * Option only available for Medicare EHR Incentive CMS will finalize either option 1a or 1b.

9 Group Reporting - CQM Three possible methods
2 or more NPIs within single TIN ACO GPRO Group options available for: CQM reporting only AND All EPs in the group are beyond the first year of Stage 1 Data must be reported from Certified EHR Technology

10 Penalties- EPs In general, a penalty will be based on data from 2 years prior to the penalty. (Exception: EPs can apply up to Oct of the previous year if it is their first year of MU) Determining 2015 penalty: 1% percent reduction based on 2013 reporting period (for most EPs) Can report until Oct 2014 if first year reporting Additional 1% reduction if not an e-prescriber in 2014

11 To avoid penalties, do what by when? (Hospitals)
To Avoid Penalties in FY: Existing Meaningful User: MU for All of FY 2013 Attest by November 30, 2013 New Meaningful User: MU for April 3, - June 2, 2014 Attest by July 1, 2014 MU for All of FY 2014 Attest by November 30, 2014 MU for April 3, - June 2, 2015 Attest by July 1, 2015 2015 2016

12 AAMC Concerns/Comments with the Proposed Rule
The requirements and timelines for achieving Meaningful Use Stage 2 are too aggressive. New attesters should have more time to meet the requirements for Meaningful Use Stage 1. The core measures in the proposed rule are new and untested and therefore greater flexibility should be provided to hospitals and EPs to report this information. The proposed CQMs are not market ready and would not lead to better outcomes in patient care. These quality measures should not be incorporated into the pay-for-performance programs without a supplemental process to ensure the validity of the EHR data capture. A group reporting option for CQMs and meaningful use measures should be implemented.

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