2 Stage 2 Decision Tree: Medicare INCENTIVE! (CMS)!YESHave you attested to EP quality measures (CMS)?YESNOHave you attested to core & menu measures of meaningful use (CMS)?YESNOAre you using certified EHR technology (ONC)?YESNO2015: Unless are hospital-based or meet an exception, penalty beginsAre you a non-hospital based EP? (CMS)NOYESNO: $0; no penaltyAre you an eligible professional (EP)?
3 Stages of Meaningful Use By Payment Year First Payment YearPayment Year2011201220132014201520162017Stage 1Stage 2Stage 3Stage 2Source: 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 menu20 total objectivesEPs17 core3 of 5 menu20 total objectivesHospitals/CAHs14 core15 of 10 menu19 total objectivesHospitals/CAHs16 core2 of 4 menu18 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 EPEH30% visits have at least 1 electronic EP note30% of EH pt days have at least one e-note by MD, NP or PA30% of EH med orders automatically tracked via electronic med admin recording80% of pts offered ability to view and download via web-based portal w/in 36 hrs of discharge relevant info in the recordOnline secure pt messaging in usePt preferences for communication medium recorded for 20% of ptsList of care team members (including PCP) available for 10% of pts in EHRRecord 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 EPs1a) 12 measures/ 6 domainsAt least one measure in each of the 6 domains125 measures1b) 11 “core” plus 1 measure11 core measures listedOne additional measure2) PQRS-EHRFollows rules for PQRS-EHR submissionCould change in future rule-makingGroup Reporting>=2 NPI per Tax ID NumberACOs*GPRO*OR* Option only available for Medicare EHR IncentiveCMS will finalize either option 1a or 1b.
9 Group Reporting - CQM Three possible methods 2 or more NPIs within single TINACOGPROGroup options available for:CQM reporting only ANDAll EPs in the group are beyond the first year of Stage 1Data must be reported from Certified EHR Technology
10 Penalties- EPsIn 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 reportingAdditional 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 2013Attest by November 30, 2013New Meaningful User:MU for April 3, - June 2, 2014Attest by July 1, 2014MU for All of FY 2014Attest by November 30, 2014MU for April 3, - June 2, 2015Attest by July 1, 201520152016
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.