Meaningful Use: Stage 2 Changes

An overall simplification of the program aligned to the overarching goals of sustainability as discussed in the Stage 3 proposed rule Changed the reporting period in 2015 (for everyone) and 2016 (for new participants) Changed thresholds to patient engagement measures Reduced the number of meaningful use objectives to improve advanced use of EHRs Removed redundant measures and those that have become widely adopted (aka “topped out”) Changes

All Eligible Providers would attest for 90 days in 2015 – Any 90 day period in 2015 Only new EP’s report for 90 days in 2016 Back to 90 Days in 2015

The new rule states that starting in 2015, all providers (regardless of what stage they are currently in) must attest to certain objectives and measures found in Stage 2. If a provider is scheduled to be in Stage 1, they will participate in a modified version of Stage 2 that will allow for special exclusions to the measures found only in Stage 2 and not in Stage 1. A Single Set of Objectives Regardless of Stage

In order to simplify Stage 1 and Stage 2, CMS identified measures to remove from the program because they are “redundant,” “duplicative,” or “topped out.” – Record Demographics – Record Vital Signs – Record Smoking Status – Clinical Summaries – Structured Lab Results – Patient List – Patient Reminders – Summary of Care Measure 1 – Any Method Measure 3 – Test – Electronic Notes – Imaging Results – Family Health History Measures Sent into Retirement

Changed the threshold from the Stage 2 Objective for Patient Electronic Access measure number 2 from “5 percent” to “equal to or greater than 1.” – In other words, only one patient must view, download, or transmit his/her health information. Changed the threshold from the Stage 2 Objective Secure Electronic Messaging from a percentage-based measure to a yes-no measure stating the “functionality fully enabled.” Consolidated all public health reporting objectives into one objective with measure options following the structure of the Stage 3 Public Health Reporting Objective. Changes to Existing Measures

Stage 1 and Stage 2 have always required both core objectives and menu objectives. CMS decided to eliminate all menu objectives and offer a shorter list of “core” objectives instead. For providers scheduled to be in Stage 1, this means that three current menu objectives would now be required: – Perform Medication Reconciliation – Patient Specific Educational Resources – Public Health Reporting Objectives (multiple options) Farewell Menu Set

With the removal of measures and consolidation of Stage 1 and Stage 2, all providers in will be required to successfully meet a total of 9objectives plus 1 public health reporting objective. (NOTE: Stage 1 providers can use new exclusions for measures only found in Stage 2.) Farewell Menu Set

Protect Electronic Health Information – Measure: Perform a security risk analysis. No Alternate Exclusions and/or Specifications Clinical Decision Support – Must satisfy both Measures – Measure 1: Implement five clinical decision support interventions related to four or more clinical quality measures at a relevant point in patient care for the entire EHR reporting period. The Core Objectives

Measure 2: The EP has enabled and implemented the functionality for drug-drug and drug allergy interaction checks for the entire EHR reporting period – Exclusions: For an EHR reporting period in 2015 only, an EP who is scheduled to participate in Stage 1 in 2015 may satisfy the following in place of measure 1: (Measure #2 is still mandatory) – Alternate Exclusion: Implement one clinical decision support rule relevant to specialty or high clinical priority along with the ability to track compliance with that rule. The Core Objectives

Computerized Provider Order Entry (CPOE) – Measure 1: More than 60 percent of medication orders created by the EP during the EHR reporting period are recorded using computerized provider order entry. Exclusion: Any EP who writes fewer than 100 medication orders during the EHR reporting period – Measure 2: More than 30 percent of laboratory orders created by the EP during the EHR reporting period are recorded using computerized provider order entry. Exclusion: Any EP who writes fewer than 100 laboratory orders during the EHR reporting period. The Core Objectives

Measure 3: More than 30 percent of radiology orders created by the EP during the EHR reporting period are recorded using computerized provider order entry. – Exclusion: Any EP who writes fewer than 100 radiology orders during the EHR reporting period Alternate Measure 1: For Stage 1 providers in 2015, more than 30 percent of all unique patients with at least one medication in their medication list seen by the EP during the EHR reporting period have at least one medication order entered using CPOE; or more than 30 percent of medication orders created by the EP during the EHR reporting period are recorded using computerized provider order entry. The Core Objectives

Alternate Exclusion for Measure 2: Providers scheduled to be in Stage 1 in 2015 may claim an exclusion for measure 2 (laboratory orders) of the Stage 2 CPOE objective for an EHR reporting period in Alternate Exclusion for Measure 3: Providers scheduled to be in Stage 1 in 2015 may claim an exclusion for measure 3 (radiology orders) of the Stage 2 CPOE objective for an EHR reporting period in The Core Objectives

E-Prescribing (eRx) – Measure 1: More than 50 percent of all permissible prescriptions, or all prescriptions, written by the EP are queried for a drug formulary and transmitted electronically using Certified EHR Technology. – Exclusions: Any EP who - Writes fewer than 100 permissible prescriptions during the EHR reporting period; or Does not have a pharmacy within his or her organization and there are no pharmacies that accept electronic prescriptions within 10 miles of the EP's practice location at the start of his or her EHR reporting period. – Alternate EP Measure: For Stage 1 providers in 2015, more than 40 percent of all permissible prescriptions written by the EP are transmitted electronically using CEHRT. The Core Objectives

Health Information Exchange – Measure: The EP that transitions or refers their patient to another setting of care or provider of care that (1) uses CEHRT to create a summary of care record, and (2) electronically transmits such summary to a receiving provider for more than 10 percent of transitions of care and referrals. Exclusion: Any EP who transfers a patient to another setting or refers a patient to another provider less than 100 times during the EHR reporting period. Alternate Exclusion: Provider may claim an exclusion for the Stage 2 measure that requires the electronic transmission of a summary of care document if for an EHR reporting period in 2015, they were scheduled to demonstrate Stage 1, which does not have an equivalent measure. The Core Objectives

Patient Education – Measure 1: Patient-specific education resources identified by Certified EHR Technology are provided to patients for more than 10 percent of all unique patients with office visits seen by the EP during the EHR reporting period. Exclusion: Any EP who has no office visits during the EHR reporting period. Alternate Exclusion: Provider may claim an exclusion for the measure of the Stage 2 Patient Specific Education objective if for an EHR reporting period in 2015 they were scheduled to demonstrate Stage 1 but did not intend to select the Stage 1 Patient Specific Education menu objective. The Core Objectives

Medication Reconciliation – Measure 1: The EP performs medication reconciliation for more than 50 percent of transitions of care in which the patient is transitioned into the care of the EP. Exclusion: Any EP who was not the recipient of any transitions of care during the EHR reporting period. Alternate Exclusion: Provider may claim an exclusion for the measure of the Stage 2 Medication Reconciliation objective if for an EHR reporting period in 2015 they were scheduled to demonstrate Stage 1 but did not intend to select the Stage 1 Medication Reconciliation menu objective. The Core Objectives

Patient Electronic Access – Measure 1: More than 50 percent of all unique patients seen by the EP during the EHR reporting period are provided timely (within 4 business days after the information is available to the EP) online access to their health information. – Measure 2: At least one patient seen by the EP during the EHR reporting period (or their authorized representatives) views, downloads, or transmits his or her health information to a third party. – Exclusions: Any EP who: Neither orders nor creates any of the information listed for inclusion as part of the measures; or The Core Objectives

– Conducts 50 percent or more of his or her patient encounters in a county that does not have 50 percent or more of its housing units with 4Mbps broadband availability according to the latest information available from the FCC on the first day of the EHR reporting period. – Alternate Exclusion: Providers may claim an exclusion for the second measure if for an EHR reporting period in 2015 they were scheduled to demonstrate Stage 1, which does not have an equivalent measure. The Core Objectives

Secure Electronic Messaging – Measure 1: During the EHR reporting period, the capability for patients to send and receive a secure electronic message with the provider was fully enabled. Exclusion: Any EP who has no office visits during the EHR reporting period, or any EP who conducts 50 percent or more of his or her patient encounters in a county that does not have 50 percent or more of its housing units with 4Mbps broadband availability according to the latest information available from the FCC on the first day of the EHR reporting period. Alternate Exclusion: An EP may claim an exclusion for the measure if for an EHR reporting period in 2015 they were scheduled to demonstrate Stage 1, which does not have an equivalent measure. The Core Objectives

In addition to reporting the objectives above, EPs must also report on either 1 or 2 public health reporting measures. – Providers scheduled to be in Stage 1 must choose 1 of the possible 5 measures. – Providers scheduled for Stage 2 must choose 2 of the possible 5 measures. Immunization Registry Reporting Syndromic Surveillance Reporting Case Reporting Public Health Registry Reporting Clinical Data Registry Reporting NOTE: A measure from options 1-4 must be selected Public Health Measure Options

An EP scheduled to be in Stage 2 in 2015 must meet 2 measures. – Measure Option 1 – Immunization Registry Reporting: The EP is in active engagement with a public health agency to submit immunization data. Exclusions: Any EP meeting one or more of the following criteria may be excluded from the immunization registry reporting measure if the EP– Does not administer any immunizations to any of the populations for which data is collected by its jurisdiction's immunization registry or immunization information system during the EHR reporting period; Operates in a jurisdiction for which no immunization registry or immunization information system is capable of accepting the specific standards required to meet the CEHRT definition at the start of the EHR reporting period; or Operates in a jurisdiction where no immunization registry or immunization information system has declared readiness to receive immunization data from the EP at the start of the EHR reporting period – Measure Option 2 – Syndromic Surveillance Reporting: The EP is in active engagement with a public health agency to submit syndromic surveillance data. Public Health Measure Options

– Exclusion for EPs: Any EP meeting one or more of the following criteria may be excluded from the syndromic surveillance reporting measure if the EP: – Is not in a category of providers from which ambulatory syndromic surveillance data is collected by their jurisdiction's syndromic surveillance system; – Operates in a jurisdiction for which no public Public Health Measure Options

For an EHR reporting period in 2015, all Medicare providers must attest by February 29, Providers will not be able to attest to meaningful use for an EHR reporting period in 2015 prior to January 4, Attestation

EPs must report nine of the MU Stage 2 CQMs in 2015, 2016, and 2017 – For 2015 through 2017, Medicare Eligible Professionals (EPs) can meet the clinical quality measurement (CQM) reporting requirement for the EHR Incentive Program by satisfying nine of the 64 electronic clinical quality measures (eCQMs) in the Stage 2 Final Rule menu: First year Meaningful Use (MU) EPs must attest their selected CQMs. – Returning EPs may attest or eReport their selected measures. EPs choosing to attest in 2015 must capture and report CQMs for a 90-day period within calendar year Clinical Quality Measures

Reporting period requirements vary by year/EP status EPs choosing to attest in 2015 must capture and report CQMs for a 90- day period within calendar year & 2017 Returning MU EPs choosing to attest in 2016 must collect and report data for the full calendar year. First time MU EPs must report on a 90-day period within Clinical Quality Measures

eReport submissions must meet specific requirements: Submissions must include the eCQM reporting program requirements for both MU and the CMS Physician Quality Reporting System (PQRS) program in one submission. Starting in 2016, submissions must capture eCQM data for the full calendar year. Individual EPs will submit their selected CQMs through the PQRS Portal. Groups will electronically report their selected CQMs through the PQRS Portal either using: o Quality Reporting Document Architecture (QRDA), or via the Group Practice Reporting Option (GPRO) Web Interface. Clinical Quality Measures

Dara J. Barrera | Manager, HIT and Practice Management Health Care Delivery Michigan State Medical Society |