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EHR & Meaningful Use
Transcript of EHR & Meaningful Use
Attesting to Meaningful Use Eligible Providers (EP) “who successfully demonstrate meaningful use of certified EHR technology during the relevant EHR reporting period may be eligible for an incentive payment amount, subject to an annual limit, equal to 75 percent of the EP’s Medicare allowed charges submitted not later than two months after the end of the calendar year.” [emphasis added] Registration - NPI Examples & Other "Incentives" The Allowable Charge in locale 99 for 98940 is $24.49.
To receive the $18,000 maximum, a participating provider would need to bill nineteen (19) 1-2 region adjustments a week to Medicare. For Eligible Professionals who predominantly furnish services in a health professional shortage area (HPSA), incentive payments would be increased by 10%.
If physicians do NOT adopt EHR by:
2015 - reimbursements will be reduced by 1% (must attest by October 3, 2014)
2016 - reimbursements will be reduced by 2%
2017 - reimbursements will be reduced by 3%
2018 - reimbursements will be reduced by 4% (less than75% compliance)
2019+ - reimbursements will be reduced by 5% (less than75% compliance) Be an Eligible Provider,
Bill Medicare for services throughout the year,
Utilize fully certified EHR technology,
Exercise Meaningful Use,
Register for the Medicare Incentive Program, and
Attest for incentive payments. Stimulus Funds Big Picture Checklist Is Your EHR Certified? http://onc-chpl.force.com/ehrcert/CHPLHome Chiropractic Physicians are Eligible Providers Items Needed for Incentive Registration
Corporate NPI (if applicable),
PECOS (may supply later),
Indicate Registration is for Medicare Program,
EHR Certification Number (may supply later), and
Contact Information. If you are an EP, you must have an active National Provider Identifier (NPI) and have a National Plan and Provider Enumeration System (NPPES) web user account. Use your NPPES user ID and password to log into this system.
If you are an EP who does not have an NPI and/or an NPPES web user account, navigate to NPPES to apply for an NPI and/or create an NPPES web user account.
Users working on behalf of an Eligible Professional(s) must have an Identity and Access Management system (I&A) web user account (User ID/Password) and be associated to the Eligible Professional's NPI. If you are working on behalf of an Eligible Professional(s) and do not have an I&A web user account, Create a Login in the I&A System. Registration - PECOS Provider Enrollment, Chain and Ownership System What? Why? Internet-based PECOS can be used in lieu of the Medicare enrollment application (i.e., paper CMS-855) to:
Submit an initial Medicare enrollment application
View or change your enrollment information
Track your enrollment application through the web submission process
Add or change a reassignment of benefits
Submit changes to existing Medicare enrollment information
Reactivate an existing enrollment record
Withdraw from the Medicare Program Other Advantages of Internet-based PECOS:
It is a stimulus program requirement. Without PECOS enrollment, there is no $44,000.
Faster than paper-based enrollment (45 day processing time in most cases, vs. 60 days for paper)
Tailored application process means you only supply information relevant to YOUR application
Gives you more control over your enrollment information, including reassignments
Easy to check and update your information for accuracy
Less staff time and administrative costs to complete and submit enrollment to Medicare Must! All eligible hospitals and Medicare eligible professionals must have an enrollment record in PECOS to participate in the EHR Incentive Programs. If you do not have an enrollment record in PECOS, you should still register for the Medicare EHR Incentive Program. Step 1: Check your PECOS enrollment status -
http://www.cms.gov/MedicareProviderSupEnroll/downloads/OrderingReferringReport.pdf Step 2: If you have not enrolled in PECOS, enroll today –
Use the same login as you did for NPPES (NPI) Checklist of Required Information for PECOS Registration:
https://pecos.cms.hhs.gov/pecos/help-main/spchecklist.jsp There will be three stages for meaningful use:
Stage 1: Current plan as we will discuss on this webinar
Stage 2: Coming in 2013 (CMS Proposed Rules on February 23, 2012)
Stage 3: Coming in 2015
Note: This is another reason for early adoption. With the unknown coming in 2013 and 2015, early adopters will be able to attest for 2 or 3 years before the rules change. 15 Core Professional Measures
Must attest to ALL core measures not specifically, individually excluded
10 Professional Menu Set Measures
Must attest to 5 of 10 menu set Core Measure 1 of 15
Use computerized provider order entry (CPOE) for medication orders directly entered by a licensed healthcare professional who can enter orders into the medical record per state, local and professional guidelines.
More than 30% of all unique patients with at least one medication in their medication list seen by the Eligible Professional (EP) have at least one medication order entered using CPOE.
Based on ALL patient records: Any EP who writes fewer than 100 prescriptions during the EHR reporting period would be excluded from this requirement. Exclusion from this requirement does not prevent an EP from achieving meaningful use. Core Measure 2 of 15
Implement drug-drug and drug-allergy interaction checks (i.e. your certified software must have this enabled for the entire period of attestation).
Have you enabled the functionality for drug-drug and drug-allergy interaction checks for the entire EHR reporting period? Note: Certified EHR is required to "automatically and electronically generate and indicate in real-time, notifications at the point of care for drug-drug and drug-allergy contraindications based on medication list, medication allergy list, and computerized provider order entry (CPOE)" Core Measure 3 of 15
Maintain an up-to-date list of current and active diagnoses as well as past diagnoses relevant to the current care of the patient.
More than 80% of all unique patients seen by the EP have at least one diagnosis entry OR a recorded indication that no problems are known for the patient. A unique patient means that even if a patient is seen multiple times during the EHR reporting period they are only counted once. Please note when the measure indicates “More than” a particular percent, the resulting percentage must be higher. For example, for this measure, 8 out of 10 will NOT meet the requirement. However, 81 out of 100 would. Core Measure 4 of 15
Generate and transmit permissible prescriptions electronically (eRx).
More than 40% of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technology.
Based on ALL patient records: Any EP who writes fewer than 100 prescriptions during the EHR reporting period would be excluded from this requirement. Exclusion from this requirement does not prevent an EP from achieving meaningful use. Core Measure 5 of 15
Maintain active medication list.
More than 80% of all unique patients seen by the EP have at least one entry (or an indication that the patient is not currently prescribed any medication) recorded as structured data. An EP is not required to update this list at every contact with the patient. The EP can then use clinical judgment to decide when additional updating is required
There is NO exclusion for this measure. Note: Pay close attention to the specifics of the numerators and denominators. Each are unique to the specific measures. Core Measure 6 of 15
Maintain active medication allergy list.
More than 80% of all unique patients seen by the EP have at least one entry (or an indication that the patient has no known medication allergies) recorded as structured data.
There is NO exclusion for this measure. Core Measure 7 of 15
Record ALL of the following demographics:
Date of birth.
More than 50% of all unique patients seen by the EP have demographics recorded as structured data. Core Measure 8 of 15
Record and chart changes in vital signs: Height, Weight, Blood pressure, Calculate and display body mass index (BMI), AND Plot and display growth charts for children 2-20 years, including BMI.
More than 50% of all unique patients age 2 and over seen by the EP, height, weight and blood pressure are recorded as structured data.
Any EP who either see no patients 2 years or older, or who believes that all three vital signs of height, weight, and blood pressure of their patients have no relevance to their scope of practice. The only information required to be input by the provider is the height, weight, and blood pressure of the patient. The certified EHR technology will calculate BMI and the growth chart if applicable to patient based on age. Height, weight, and blood pressure do not have to be updated by the EP at every patient encounter. The EP can make the determination based on the patient’s individual circumstances as to whether height, weight, and blood pressure need to be updated. Height, weight, and blood pressure can get into the patient’s medical record as structured data in a number of ways. Some examples include entry by the EP, entry by someone on the EP’s staff, transfer of the information electronically or otherwise from another provider or entered directly by the patient through a portal or other means Core Measure 9 of 15
Record smoking status for patients 13 years old or older.
More than 50% of all unique patients 13 years or older seen by the EP have smoking status recorded as structured data. If this information is already in the medical record available through certified EHR technology, an inquiry does not need to be made every time a provider sees a patient 13 years old or older. The frequency of updating this information is left to the provider and guidance is provided already from several sources in the medical community.
Based on ALL patient records (not just records kept in EHR): An EP who did not see patients 13 years or older would be excluded from this requirement. No All Patients Patients in EHR Core Measure 10 of 15
Report ambulatory clinical quality measures to CMS.
Although clinical quality measures are not included in this tool, EPs will be required to submit numerator, denominator, and exclusion information for clinical quality measures during the online attestation process. We will cover the 44 Clinical Quality Measures after Meaningful Use. Core Measure 11 of 15
Implement one clinical decision support rule relevant to specialty or high clinical priority along with the ability to track compliance to that rule.
Have you implemented one clinical decision support rule relevant to specialty or high clinical priority along with the ability to track compliance to that rule? CMS will not issue additional guidance on the selection of appropriate clinical decision support rules for Stage 1 Meaningful Use. Practitioners are expected to design rules that fit their practice and patient base. There are countless examples, and clinical decision support systems are widely used in hospital and allopath clinical settings. An example might be a warning to the physician to x-ray when a female patient over 40 presents with middle back pain. Drug-drug and drug-allergy interaction alerts cannot be used to meet the meaningful use objective for implementing one clinical decision support rule. EPs must implement one clinical decision support rule in addition to drug-drug and drug-allergy interaction checks. Core Measure 12 of 15
Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, medication allergies, and all of the health information available electronically), upon request.
More than 50% of all patients who request an electronic copy of their health information are provided it within 3 business days.
Based on ALL patient records (even though the denominator may exclude non-EHR records) – both EHR and nonEHR: An EP who has no requests from patients or their agents for an electronic copy of patient health information during the EHR reporting period would be excluded from this requirement. Exclusion from this requirement does not prevent an EP from achieving meaningful use. Form and format should be human readable and comply with the HIPAA Privacy Rule. The media could be any electronic form such as patient portal, PHR, CD, USB fob, etc. EPs are expected to make reasonable accommodations for patient preference (i.e. Microsoft HealthVault).
The charging of fees for this information is governed by the HIPAA Privacy Rule which only permits HIPAA covered entities to charge an individual a reasonable, cost-based fee for a copy of the individual’s health information. ICS Members can read more about charging for copies here: http://ilchiro.org/displayindustryarticle.cfm?articlenbr=41874.
If provision of the copy involves the mailing of physical electronic media, then it would need to be mailed by at least the third business day following the request of the patient or their agents.
Third-Party Requests: Only specific third-party requests for information are included in the denominator. Providing the copy to a family member or patient’s authorized representative consistent with federal and state law may substitute for a disclosure of the information to the patient and count in the numerator. A request from the same would count in the denominator. All other third-party requests are not included in the numerator or the denominator. Core Measure 13 of 15
Provide clinical summaries* for patients for each office visit* at no charge.
Clinical summaries provided* to patients for more than 50% of all office visits within 3 business days. If the visit lasts several days, a single summary may be supplied at the end of the last day of visit.
Based on ALL patient records: Any EP who has no office visits during the EHR reporting period would be excluded from this requirement. Exclusion from this requirement does not prevent an EP from achieving meaningful use. Clinical Summary – An after-visit summary that provides a patient with relevant and actionable information and instructions. The summary must include specified information which your EHR can supply. Office Visit – Office visits include separate, billable encounters that result from evaluation and management services provided to the patient and include: (1) Concurrent care or transfer of care visits, (2) Consultant visits, or (3) Prolonged Physician Service without Direct (Face-To-Face) Patient Contact (tele-health). A consultant visit occurs when a provider is asked to render an expert opinion/service for a specific condition or problem by a referring provider. Core Measure 14 of 15
Capability to exchange key clinical information (for example, problem list, medication list, allergies, diagnostic test results), among providers of care and patient authorized entities electronically.
Have you performed at least one test of certified EHR technology’s capacity to electronically exchange key clinical information? Core Measure 15 of 15
Protect electronic health information created or maintained by the certified EHR technology through the implementation of appropriate technical capabilities as required under HIPAA.
Have you conducted or reviewed a security risk analysis as required by the HIPAA Security Rule, implemented security updates (see below) as necessary, and corrected identified security deficiencies as part of your risk management process?
Security Update: This could be updated software for certified EHR technology to be implemented as soon as available, changes in workflow processes or storage methods, or any other necessary corrective action that needs to take place in order to eliminate the security deficiency or deficiencies identified in the risk analysis. Professional Menu Set Measures
Providers must attest to at least 5 of the 10 measures in this list.
Providers have the advantage of choosing measures at the END of the attestation period (90 days for the first year and 12 months for each year after the first year).
Attesting may include measures which the provider chooses to exclude. For example, chiropractic providers may choose to attest “Implement Drug Formulary Checks” then utilize the allowed exclusion for less than 100 prescriptions.
Providers MUST choose at least one of two measures in the Public Health list (immunization data submission and syndromic surveillance data submission).
If the EP is eligible for exclusion on one of the two public health objectives, the IP is required to select and report on the public health measure he or she is able to meet.
If the EP can attest to an exclusion from both public health menu measures, the EP must choose one of the two public health menu measures and attest to the exclusion. Menu Set Measure (9 of 10) –
Public Health 1 of 2
Capability to submit electronic data to immunization registries or immunization information systems and actual submission in accordance with applicable law and practice.
Performed at least one test of certified EHR technology’s capacity to submit electronic data to immunization registries and follow up submission if the test is successful (unless none of the immunization registries to which the EP submits such information have the capacity to receive the information electronically). Exclusions
Based on ALL patient records: An EP who does not perform immunizations during the EHR reporting period would be excluded from this requirement. Chiropractic Physicians cannot administer immunizations in Illinois, therefore this exclusion will apply. However, as a result, Chiropractic Physicians must attest to syndromic surveillance. Exclusion from requirements does not prevent an EP from achieving meaningful use.
Based on ALL patient records: If there is no immunization registry that has the capacity to receive the information electronically, an EP would be excluded from this requirement. Exclusion from requirements does not prevent an EP from achieving meaningful use. Menu Set Measure (10 of 10) –
Public Health 2 of 2
Capability to submit electronic syndromic surveillance data to public health agencies and actual submission in accordance with applicable law and practice.
Performed at least one test of certified EHR technology’s capacity to provide electronic syndromic surveillance data to public health agencies and follow-up submission if the test is successful. Exclusions
If an EP does not collect any (both EHR and nonEHR patients) reportable syndromic information on their patients during the EHR reporting period, then the EP is excluded from this requirement. Exclusion from requirements does not prevent an EP from achieving meaningful use.
If there is no public health agency that has the capability to receive the information electronically, then the EP is excluded from this requirement. Exclusion from requirements does not prevent an EP from achieving meaningful use. “Strictly defined, syndromic surveillance gathers information about patients' symptoms (e.g., cough, fever, or shortness of breath) during the early phases of illness.” – Centers for Disease Control and Prevention Simulated transfers of information are not acceptable to satisfy this objective.
The use of test information about a fictional patient that would be identical in form to what would be sent about an actual patient would satisfy this objective.
If the test is successful, then the EP should institute regular reporting with the entity with whom the successful test was conducted, in accordance with applicable law and practice. Menu Set Measure 1 of 10
Implement drug formulary checks.
The EP has enabled this functionality and has access to at least one internal or external drug formulary for the entire EHR reporting period.
Any EP who writes fewer than 100 prescriptions during the EHR reporting period would be excluded from this requirement. Exclusion from requirements does not prevent an EP from achieving meaningful use. Menu Set Measure 2 of 10
Incorporate clinical lab-test results into EHR as structured data.
More than 40% of all clinical lab test results ordered by the EP during the EHR reporting period are incorporated in certified EHR technology as structure whose results are in either a positive/negative or numerical format are incorporated in certified EHR technology as structured data.
Any EP who orders no lab tests whose results are either in a positive/negative or numeric format during the EHR reporting period would be excluded from this requirement. Exclusion from requirements does not prevent an EP from achieving meaningful use. The EP is not limited to only counting structured data received via electronic exchange, but may count in the numerator all structured data entered through manual entry through typing, option selecting, scanning, or other means. Menu Set Measure 3 of 10
Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research or outreach.
Generate at least one report listing patients of the EP with a specific condition.
There are no specific requirements as to what report must be generated, and the reports are only generated for only those patients in the EHR database. Menu Set Measure 4 of 10
Send reminders to patients per patient preference for preventive/follow up care, within the confines required under the HIPAA Privacy Rule, and according the frequency, means of transmission, and form determined by the provider.
More than 20% of all unique patients 65 years or older or 5 years or younger were sent an appropriate reminder during the EHR reporting period.
Any EP who has no patients 65 years or older or 5 years old or younger with records maintained using certified EHR technology is excluded from this requirement. Exclusion from requirements does not prevent an EP from achieving meaningful use. Menu Set Measure 5 of 10
Provide patients with timely electronic access to their health information (including lab results, problem list, medication lists and allergies) within 4 business days of the information being available to the EP.
At least 10% of all unique patients seen by the EP are provided timely electronic access to their health information subject to the EP’s discretion to withhold certain information.
Based on ALL patient records: Any EP who neither orders nor creates lab tests or information that would be contained in the problem list, medication list, or medication allergy list during the EHR reporting period would be excluded from this requirement. Exclusion from requirements does not prevent an EP from achieving meaningful use. Menu Set Measure 6 of 10
Use certified EHR technology to identify patient-specific education resources and provide those resources to the patient if appropriate.
More than 10% of all unique patients seen by the EP during the EHR reporting period are provided patient-specific education resources. Certified EHR technology must be designed to use either the patient’s problem list, medication list, or laboratory test results to identify the patient-specific educational resources. However, other elements can be used in the identification of educational resources that are specific to the patients needs.
The resources do not have to be stored within or even generated by the certified EHR. However, the provider should utilize the information stored to help determine the needed resources. Menu Set Measure 7 of 10
The EP who receives a patient from another setting of care or provider of care or believes an encounter is relevant should compare the medical record to a list of medications obtained from a patient, hospital, or other provider.
The EP performs medication reconciliation for more than 50% of transitions of care in which the patient is transitioned into the care of the EP.
Based on ALL patient records: An EP who was not on the receiving end of any movement of a patient from one setting of care (hospital, ambulatory primary care practice, ambulatory specialty care practice, long-term care, home health, rehabilitation facility) to another during the EHR reporting period would be excluded from this requirement. Exclusion from requirements does not prevent an EP from achieving meaningful use. Menu Set Measure 8 of 10
The EP who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care should provide summary of care record for each transition of care or referral.
The EP who transitions or refers their patient to another setting of care or provider of care provides a summary of care record for more than 50% of transitions of care and referrals.
An EP who does not transfer a patient to another setting or refer a patient to another provider during the EHR reporting period would be excluded from this requirement. Exclusion from requirements does not prevent an EP from achieving meaningful use. The EP can send an electronic or paper copy of the summary care record directly to the next provider or can provide it to the patient to deliver to the next provider, if the patient can reasonably expected to do so.
If the receiving provider already has access to the medical record maintained by the referring provider then the summary of care record would not need to be provided, and that patient should not be included in the list for transitions of care. Important Tips
Only attest to what you can prove.
Use the exclusion only when it specifically applies.
Choose your Menu Set Measures wisely AND use the exclusions in the Menu Set only when necessary. Clinical Quality Measures Eligible professionals must report on a total of 6 out of 44 clinical quality measures (CQMs) which includes, 3 Core, 3 Alternate Core, and 38 additional CQMs. Core CQMs
EPs must report on 3 required core CQMs, and if the denominator of any of the required core measures is 0, then EPs are required to report results for up to 3 alternate core measures.
NQF 0421 – Adult Weight Screening and Follow-Up
NQF 0013 – Hypertension: Blood Pressure Measurement
NQF 0028 – Preventative Care and Screening Measure Pair:
Tobacco Use Assessment
Tobacco Cessation Intervention Alternate Core CQMs
NQF 0041 – Preventive Care and Screening: Influenza Immunization for Patients >= 50 years old – immunization administration required – does not apply to DCs
NQF 0024 – Weight Assessment and counseling for children and adolescents (2-17) – applies to PCPs and OB/GYNs.
NQF 0038 – Childhood Immunization Status - vaccine administration required – does not apply to DCs NQF 0024 – Weight Assessment and counseling for children and adolescents (2-17) – applies to PCPs and OB/GYNs.
Percentage of patients 2-17 years of age who had an outpatient visit with a Primary Care Physician (PCP) or OB/GYN and who had evidence of BMI percentile documentation, counseling for nutrition and counseling for physical activity during the measurement year. NQF 0421 – Adult Weight Screening and Follow-Up
Percentage of patients aged 18 years and older with a calculated BMI in the past six months or during the current visit documented in the medical record AND if the most recent BMI is outside parameters, a follow-up plan is documented. NQF 0013 – Hypertension: Blood Pressure Measurement
Percentage of patient visits for patients aged 18 years and older with a diagnosis of hypertension who have been seen for at least 2 office visits, with blood pressure (BP) recorded (i.e. BP/patients). NQF 0028 – Preventative Care and Screening Measure Pair:
Tobacco Use Assessment
Percentage of patients aged 18 years and older who have been seen for at least 2 office visits who were queried about tobacco use one or more times within 24 months.
Tobacco Cessation Intervention
Percentage of patients aged 18 years and older identified as tobacco users within the past 24 months and have been seen for at least 2 office visits, who received cessation intervention. 38 Remaining CQM
Each EHR system will have at least 3 more CQM. Examples of the remaining CQM from certain chiropractic specific EHR:
NQF 0018 – Controlling High Blood Pressure
NQF 0027 – Smoking and Tobacco Use Cessation, Medical Assistance:
Advising users to quit
Discussing cessation medications
Discussing cessation strategies
NQF 0052 – Low Back Pain: Use of Imaging Studies
NQF 0059 - Diabetes Control: Hemoglobin A1c >9.0%
NQF 0061 - Diabetic Patients who elevated mmhg V140/90
NQF 0001 - Asthma Assesment (sic)
NQF 0043 - Pnemonia (sic) Vaccination Notes:
CQM are designed for reporting and do not have minimum requirements in order to meet the meaningful use qualification.
According to the CMS Final Rule, Certified EHR is required to calculate each measure’s numerators, denominators and exclusions for each CQM. In short, Certified EHR does the “paperwork” for you.
It is acceptable to report zero in the denominator, even for 1 or more measures, as long as that is the value displayed and calculated by the certified EHR. PQRS vs. Clinical Quality Measures
There is some alignment between the two systems. However, PQRS is claims based and the measures are calculated outside of EHR and CQM Attestation utilizes EHR.
The EHR rules are requiring the programs to align in the future. Additionally, we are hearing that the move is more towards EHR and away from claims based.
CMS has announced: "EPs... beyond their first year of Stage 1 participation would submit CQM data electronically, thereby reducing the associated burden of reporting on quality measures for providers." (i.e. they are tying them together) Other Considerations
If you are not currently a covered entity under HIPAA, you will become a covered entity once you begin to transmit any protected health information electronically.
HIPAA training and adherence is a requirement for all covered entities under HIPAA. This includes the privacy rule AND the security rule. Resources
Full listing of both the core measures and the menu set measures can be found here:
Providers may use the “Meaningful Use Calculator”
Recording and Links
Our Corporate Club members make presentations like this possible
www.icscorporateclub.com Stage II Proposed Rules (This is not in your notes.)
17 Core Measures;
3 of 5 Menu Set Measures;
"The “exchange of key clinical information” core objective from Stage 1 was eliminated in favor of a more robust “transitions of care” core objective in Stage 2;"
The “provide patients with an electronic copy of their health information” objective was eliminated because it has been replaced by an “electronic/online access” core objective;
Combination of some objectives; and
Other small changes to a few measures. How? Through a Personal Health Record, patient portal on a web site, secure e-mail, electronic media such as CD or USB fob, or printed copy. The patient may request to receive a paper.