Quality Measurement Task Force 2016 Physician Fee Schedule (PFS) July 24, 2015 Cheryl Damberg, Co-Chair Kathleen Blake, Co-Chair

Membership 2 First NameLast nameMember TypeOrganization CherylDambergCo-chairSenior Principal Researcher, Rand Corporation KathleenBlakeCo-chairMD, AMA LoriCoynerMemberDirector of Health Analytics, Oregon Health Authority FloydEisenbergMemberMD, MPH, iParsimony, LLC JoeKimuraMemberDeputy Chief Medical Office, Atrius Health GinnyMeadowsMemberVP, Regulatory Strategy, McKesson Corporation ElizabethMitchellMember President and CEO, NHRI JasonMitchellMember MD, Chief Medical and Clinical Transformation Officer for Presbyterian Healthcare Services SallyOkunMemberVP Advocacy, Policy and Patient Safety, Patients Like Me FrankOpelkaMemberMedical Director of Quality and Health Policy, American College of Surgeons DanRiskinMemberMD, MBA, FACS, and CEO and Founder of Vanguard Medical Technologies DavidLanskyMemberPresident and Chief Executive Officer, Pacific Business Group on Health

Radiology SMEs 3 First NameLast nameOrganization CharlesTruwitMD, Chief Innovation Officer and Chief of Radiology, Hennepin Health System MichaelMirroMD, Chief Academic/Research Officer, Parkview Mirro Center for Research and Innovation

Proposed QMTF Schedule QMTF CallJuly 21 st 10:00 AM – 11:30 AM ET 09:00 AM – 10:30 AM CT 07:00 AM – 08:30 AM PT QMTF CallJuly 24th 2:30 PM – 3:30 PM ET 1:30 PM – 2:30 PM CT 11:30 AM – 12:30 PM PT QMTF CallJuly 30 th 2:00 PM – 3:00 PM ET 1:00 PM – 2:00 PM CT 11:00 AM – 12:00 PM PT Final QMTF CallAugust 4 th 12:00 PM – 1:00 PM ET 11:00 AM – 12:00 PM CT 9:00 AM – 10:00 AM PT Presenting at HIT Policy Committee Meeting: August 11 th,

2016 PFS Areas for Review 5 Task Force to Focus on: 1. Appropriate Use Criteria (AUC) for Radiology CDS 2. Revision of Certified EHR Technology (CEHRT) to require clinical quality measures (eCQM) reporting using CMS’ QRDA IG (for providers who choose to submit eCQMs) 3. Meaningful Use (MU) measure for Accountable Care Organizations (ACO)

PAMA Sec 218 directs the secretary to consider a variety of qualified clinical decision support mechanisms, including mechanisms within certified EHRs, which ordering professionals must use to consult AUC when ordering radiology images: 1. How are providers successfully using EHRs and other health IT tools to consult clinical decision support criteria today? 2. Could existing CDS criterion meet anticipated needs, and what are the key forthcoming standards and certification criteria which may support these processes in the future? 3. What are the key strategic considerations ONC must address to ensure certified EHRs support these activities? Appropriate Use Criteria (AUC) for Radiology CDS Recap 6

Appropriate Use Criteria (AUC) for Radiology CDS (cont.) 1.What are the key attributes/principles for how certified health IT (as a qualified clinical decision support mechanisms) should support the processes described in PAMA Sec 218 in the future? What is the vision of how HIT supports this ecosystem? Sample principles might include: Ordering professionals should be able to use certified health IT to access AUC for advanced diagnostic imaging seamlessly at the point of care. Certified health IT should support access to AUC that is updated on a continuous basis and delivered through certified health IT tools. Certified health IT should enable users to easily switch between approved AUC content providers. Certified health IT should capture additional information about why AUC were not followed to support quality improvement and provide meaningful performance feedback over time. Certified health IT should deliver actionable recommendations to clinicians based on third party data derived from AUCs. AUC should be available in standardized formats that can be consumed by any certified health IT application. 7

Appropriate Use Criteria (AUC) for Radiology CDS (cont.) 2.What are the major strategic considerations for arriving at this vision? What are the key decision points around standards development and prioritization that ONC and CMS will need to focus on to realize this vision? Key considerations might include: Currently available clinical decision support standards may not be ready to serve these needs. How should ONC address future readiness of standards to support these processes? When should this be addressed? An API or a link to a hosted service embedded in the EHR may be preferable to or serve as a complement to a decision support standard. How should ONC frame and address the tradeoffs between these approaches? When should this be addressed? AUC in use today have not been developed with EHR implementation or certification standards in mind. How are AUC content providers likely to evolve to deliver standardized AUC that can be consumed using certified health IT? 8

CY 2015 PFS Final Rule: Beginning in CY 2015, eligible providers (EPs) are not required to ensure that their CEHRT products are recertified to the most recent version of the electronic specifications for the CQMs. »EPs must still report the most recent version of specifications for the CQMs. FY 2016 IPPS Rule: ONC proposed a certification criterion for “CQMs-report”. »This proposal would require that health IT enable users to electronically create a data file for transmission of CQM data in accordance with the Quality Reporting Document Architecture (QRDA) Category 1 and Category III at minimum. »As part of the “CQMs – report” criterion, ONC also proposed to offer optional certification for EHRs according to the “form and manner” that CMS required for electronic submission to participate in the EHR Incentive Programs and PQRS. FY 2016 IPPS Rule: CMS stated they anticipate proposing to require EPs, eligible hospitals, and CAHs seeking to report CQMs electronically as part of meaningful use under the EHR Incentive Programs for 2016 to adhere to the additional standards and constraints on the QRDA standards for electronic reporting as described in the CMS QRDA IG. »CMS stated anticipating proposing to revise the definition of CEHRT to require certification to the optional portion of the 2015 Edition CQM reporting criterion in the CY 2016 Medicare Physician Fee Schedule. Revision of CEHRT to require eCQM reporting using CMS’ QRDA IG (for providers who choose to submit eCQMs) 9 Overview

Revision of CEHRT to require eCQM reporting using CMS’ QRDA IG (for providers who choose to submit eCQMs) cont. To revise the CEHRT definition to require providers to possess technology that can report CQMs using industry standards (QRDA Cat I and Cat III) and in the form and manner of CMS submission (according to the CMS QRDA IG) This would be optional for and required for 2018 and beyond. 10

Advance Reading for Next Call 11 Members are welcome to view the following slides regarding the Meaningful Use measure for ACOs in preparation of the next QMTF call.

Meaningful Use Measure for Accountable Care Organizations (ACOs) In the November 2011 final rule, CMS finalized one measure under the Care Coordination/Information Systems domain, the percent of PCPs within an ACO who successfully qualify for an EHR Incentive Program incentive (76 FR 67878). CMS expanded it to include eligible professionals that qualified for payments to adopt, implement, or upgrade EHR technology, in addition to those receiving a payment for meeting Meaningful Use Requirements, in order to include these participants in the measure. A notice of proposed rulemaking for “Stage 3” of the EHR Incentives program, released in March 2015 (80 FR 16731), and a related proposed 2015 Edition of ONC certification criteria (80 FR 16804), aim to support provider’s ability to exchange a common clinical dataset across the continuum of care. In addition, ONC released a document entitled “Connecting Health and Care for the Nation: A Shared Nationwide Interoperability Roadmap” which focuses on actions that will enable a majority of individuals and providers across the care continuum to send, receive, find and use a common set of electronic clinical information at the nationwide level by the end of 2017.Connecting Health and Care for the Nation: A Shared Nationwide Interoperability Roadmap 12 Background

Meaningful Use Measure for Accountable Care Organizations (ACOs) (cont.) CMS is seeking early comment for the 2017 performance year: How this measure might evolve in the future to ensure providers are being incentivized and rewarded for continuing to adopt and use more advanced health IT functionality and broadening the set of providers across the care continuum that have adopted these tools. 1. Should this measure be expanded in the future to include all eligible professionals, including specialists, consistent with an updated definition of eligible professionals in the Medicare Access and Chip Reauthorization act? 2. How could the current measure be updated to reward providers who have achieved higher levels of Meaningful Use? 3. Should we substitute or add another measure which would focus specifically on the use of health information technology, rather than meeting overall MU requirements, for instance, the transitions of care measure required for the EHR Incentives program? 4. What other measures of IT-enabled processes would be most relevant to participants within ACOs? How could we seek to minimize the administrative burden on providers in collecting these measures? 13