EHR Incentive Program

Focus on Stage One

Meaningful Use

Kim Davis-Allen,

Outreach Coordinator

Kim.davis@ahca.myflorida.com

October 16, 2014

Checklist

Participation Explanation

Program Updates

Stage One Measures

Certification Flexibility Rule

Florida’s Health Information Exchange

Understanding Participation

Program Year Payment Year Program Year

• January 1st – December 31st

• Year in which you met program requirements

• Program Years through 2021

Payment Year

• Simple count

• For Medicaid: 1 – 6 • Payment Year One: $21,250

• Payment Years Two – Six: $8,500

• For Medicare: 1 - 5 • Payments vary based on when

participation began and program year participation

Meaningful Use Stages

Adopt, Implement, Upgrade

•Not actually using system

•Must be more than a “planned” implementation

2014 Stage One

•13 core measures

•5 out of 9 menu measures

•9 out of 64 Clinical Quality Measures (CQMs)

2014 Stage Two

•17 cores measures

•3 out of 6 menu measures

•9 out of 64 CQMs

Stage Three

•Begins January 1, 2017 for Eligible Professionals (EPs)

**Providers are to complete a minimum of two reporting periods per MU stage before

progressing.

Program Updates

Program Year 2013 applications completed

Processing of Program Year 2014 applications: must have proof of 2014

certified technology

Audits have begun: submit requested documentation within timeframes

New material on website

CMS reopened the Hardship Exemption Application Process for providers

who have been unable to:

• Fully implement 2014 Edition CEHRT due to delays in 2014 Edition CEHRT

availability

• Attest by October 1, 2014 using the flexibility options provided in the CMS 2014

CEHRT Flexibility Rule.

Meaningful Use Documentation

Meaningful use report from your EHR system • Screenshots

• Dashboard

• Summary report

Documents must contain numeric measures • Core measures

• Menu measures

• Clinical Quality Measures (CQMs)

If reporting from multiple systems – must have documentation from the systems • Add numerators/denominators for application

Additional Documentation (AD) Form • Sections A and B not required if only practicing at one location or using same system at

different locations

• Section C is based on location

2014 Eligible Professional (EP)

Stage One

Core Measures

www.cms.gov/regulations-and-guidance/legislation/ehrincentiveprograms/meaningful_use.html

EP 2014 Stage One Meaningful Use

Utilize 2014 Certified Technology

Meet both General Requirements

Attest to 13 Core Measures

Attest to five out of nine Menu Measures (including one Public

Health Measure)

Report on nine Clinical Quality Measures

2014 Stage One General Requirements

50% of encounters must be

at locations equipped with

certified EHR technology.

80% of unique patients seen

at locations with certified

EHR technology must have

their records in a certified

EHR system.

2014 Stage One Core Measures

1. Use computerized order entry (CPOE) for medication orders.

2. Implement drug-drug, drug-allergy checks.

3. Generate and transmit permissible prescriptions

electronically.

4. Record demographics.

5. Maintain an up-to-date problem list of current and active

diagnoses.

6. Maintain active medication list.

2014 Stage One Core Measures (cont.)

7. Maintain active medication allergy list.

8. Record and chart changes in vital signs.

9. Record smoking status for patients 13 years old or older.

10. Implement one clinical decision support rule.

11. Timely electronic access (view, download, and transmit).

12. Provide clinical summaries to patients for individual office

visits.

13. Protect electronic health information (privacy & security).

Computerized Order Entry (CPOE) Objective Use CPOE for medication orders directly entered by any licensed healthcare professional who can

enter orders into the medical record per state, local, and professional guidelines.

Measure More than 30% of unique patients OR total medication orders with at least one medication in their

medication list seen by the EP have at least one medication order entered using CPOE.

Exclusion An EP who writes fewer than 100 prescriptions during the EHR reporting period.

Tips Internal to the practice.

If excluding from CPOE – can also exclude from e-prescribing.

The order must be entered by someone who could exercise clinical judgment in the case that the entry generates any alerts about possible interactions or other clinical decision support aides. This necessitates that the CPOE occurs when the order first becomes part of the patient’s medical record and before any action can be taken on the order.

Common question: Is the physician the only person who can enter information in the EHR in order to qualify for the EHR Incentive Programs? CMS FAQ New ID #2771, Old #10071

Drug-Drug; Drug Allergy

Objective Implement drug-drug and drug-allergy interaction checks.

Measure The EP has enabled this functionality for the entire EHR reporting period.

Exclusion None

Tips

Screenshots throughout the EHR reporting period.

Cannot be used to satisfy the Clinical Decision Support measure.

Problem List

Objective Maintain an up-to-date problem list of current and active diagnoses.

Measure More than 80% of unique patients seen by the EP have at least one entry or an indication that

no problems are known for the patient recorded as structured data.

Exclusion None

Tips

For patients with no current or active diagnoses, an entry must still be made to the problem

list indicating that no problems are known.

An EP is may not be required to update the list at each contact with the patient. The EP can

use his or her clinical judgment to decide when additional updating is required.

E-Prescribing Objective Generate and transmit permissible prescriptions electronically (e-prescribing).

Measure More than 40% of permissible prescriptions written by the EP are transmitted electronically

using certified EHR technology.

Exclusion An EP who writes fewer than 100 prescriptions during the EHR reporting period.

An EP that does not have a pharmacy within their organization and there are no pharmacies

that accept electronic prescriptions within 10 miles of the EP’s practice at the start of his/her

EHR reporting period.

Tips Only applies to permissible prescriptions.

“Prescription” is defined as the authorization by an EP to a pharmacist to dispense a drug that

the pharmacist would not dispense to the patient without such authorization.

Instances where patients specifically request a paper prescription may not be excluded from

the denominator of this measure.

Active Medication List

Objective Maintain active medication list.

Measure More than 80% of 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.

Exclusion None

Tips Screenshots throughout the EHR reporting period.

For patients with no active medications, an entry must still be made to the active medication

list indicating that there are no active medications.

An EP is may not be required to update this list at each contact with the patient. The EP can

use his or her clinical judgment to decide when additional updating is required.

Active Medication Allergy List

Objective Maintain active medication allergy list.

Measure More than 80% of 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.

Exclusion None

Tips For patients with no active medication allergies, an entry must still be made to the active

medication allergy list indicating that there are no active medication allergies.

An EP may not be required to update this list at each contact with the patient. The EP can use

his or her clinical judgment to decide when additional updating is required.

Demographics

Objective Record the following demographics: preferred language, gender, race, ethnicity, date of birth.

Measure More than 50% of unique patients seen by the EP have demographics recorded as structured

data.

Exclusion None

Tips If a patient declines to provide part of the demographic information, or if capturing a patient’s

ethnicity or race is prohibited by state law, such a notation entered as structured data would

count as an entry for purposes of meeting the measure.

Vital Signs Objective Record and chart changes in the following 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.

Measure More than 50 percent of unique patients seen by the EP during the EHR reporting period have

blood pressure (for patients age 3 and over only) and height and weight (for all ages) recorded as structured data.

Exclusion Sees no patients 3 years or older is excluded from recording blood pressure. Believes that blood pressure, height, and weight have no relevance to their practice. Believes that height and weight are relevant, but blood pressure is not, is excluded from

recording blood pressure. Believes that blood pressure is relevant to their scope of practice, but height and weight are

not, is excluded from recording height and weight.

Tips None

Smoking Status

Objective Record smoking status for patients 13 years old and older.

Measure More than 50% of unique patients 13 years or older seen by the EP have smoking status

recorded as structured data.

Exclusion An EP who sees no patients 13 years or older.

Tips This is a check of the medical record for patients 13 years old or older.

If this information is already in the medical record available through certified EHR

technology, an inquiry does not need to be made 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.

Clinical Decision Support (CDS)

Objective Implement one clinical decision support rule relevant to specialty or high clinical priority

along with the ability to track compliance with that rule.

Measure Implement one clinical decision support rule.

Exclusion None

Tips Defined as HIT functionality that builds upon the foundation of an EHR to provide persons

involved in care processes with general and person-specific information, intelligently filtered

and organized, at appropriate times, to enhance health and health care.

Screenshots throughout the EHR reporting period.

Timely Electronic Access

Objective Provide patients the ability to view online, download, and transmit their health information

(with 4 business days of the information being available to the EP).

Measure More than 50% of unique patients seen by the EP during the EHR reporting period are

provided timely access (within 4 business days after the information is available to the EP)

online access to their health information subject to the EP’s discretion to withhold certain

information.

Exclusion Any EP who neither orders nor creates any of the information listed for inclusion, except for

"Patient name" and "Provider's name and office contact information.”

Tips Not required that patient actually access BUT must have information necessary to access.

Clinical Summaries Objective Provide clinical summaries for patients for each office visit.

Measure Clinical summaries provided to patients for more than 50% of office visits within 3 business

days.

Exclusion An EP who has no office visits during the EHR reporting period.

Tips An after-visit summary that provides a patient with relevant and actionable information and

instructions. Minimal data elements required. If an EP believes that substantial harm may arise from the disclosure of particular

information, an EP may choose to withhold that particular information from the clinical summary.

Providers should determine how their system captures and tracks provision of the clinical summary for reporting purposes. For example, some systems only count printing the summary if it occurs after the visit is completed and signed off by the provider in the EHR.

Stamp the copy given to the patient with “patient copy”. If found later, then it is evident that the content was under the control of the patient.

Protect Electronic Health Information

Objective Protect electronic health information created or maintained by the certified EHR technology

through the implementation of appropriate technical capabilities.

Measure Conduct or review a security risk analysis in accordance with the requirements under 45 CFR

164.308(a)(1) and implement security updates as necessary and correct identified security deficiencies as part of its risk management process.

Exclusion None

Tips This analysis is more than a checklist. A checklist can be used as a starting point, but the

analysis is meant to be a complete review of the components specified in the federal regulation, including policies and procedures, and responsible parties.

Staff training should be done to review the analysis once the analysis is completed. Risks and deficiencies must be identified and a mitigation plan in place; including who will

complete the task, how will you complete the task, and when will you complete the task. The analysis must be reviewed, updated, and documented each year as part of your EHR

program attestation.

2014 Menu Exclusions

Providers - Regardless of Stage

--------------------

No longer be permitted to count an exclusion

toward the minimum required if there are

other objectives that can be met.

--------------------

Can claim exclusions for an objective – if qualify

for remaining menu objectives

-----------------------

If you exclude from any menu measure, MAPIR will require

you to answer the remaining menu measures

2014 Stage One Menu Measures

1. Implement drug-formulary checks.

2. Incorporate clinical lab-test results into certified EHR as

structured data.

3. Generate lists of patients by specific conditions to use for

quality improvement, reduction of disparities, research, or

outreach.

4. Send reminders to patients per patient preference for

preventive/follow-up care.

5. Use certified EHR to identify patient-specific education

resources and provide to patient if appropriate.

2014 Stage One Menu Measures (cont)

6. Perform medication reconciliation as relevant.

7. Provide summary care record for transitions in care or

referrals.

8. Capability to submit electronic data to immunization registries

and actual submission.

9. Capability to provide electronic syndromic surveillance data to

public health agencies and actual transmission.

Drug Formulary Checks

Objective Implement drug formulary checks.

Measure The EP has enabled this functionality and has access to at least one internal or external

formulary for the entire EHR reporting period.

Exclusion An EP who writes fewer than 100 prescriptions during the EHR reporting period.

Tips At a minimum an EP must have at least one formulary that can be queried. This may be an

internally developed formulary or an external formulary. The formularies should be relevant for patient care during the prescribing process.

Incorporate Lab Results

Objective Incorporate clinical lab test results into EHR as structured data.

Measure More than 40% of clinical lab test results ordered by the EP during the EHR reporting period

who results are either in a positive/negative or numerical format are incorporated in certified

EHR technology as structured data.

Exclusion An EP who orders no lab tests whose results are either in a positive/negative or numerical

format during the EHR reporting period.

Tips Providers may limit the denominator to only those lab tests that were ordered during the EHR

reporting period and for which results were received during the same EHR reporting period.

CMS FAQ New ID #3263, Old ID #10642

Results can be electronically or manually entered.

Generate Patient Lists

Objective Generate lists of patients by specific conditions to use for quality improvements, reduction of

disparities, research, or outreach.

Measure Generate at least one report listing patients of the EP with a specific condition.

Exclusion None

Tips This objective does not dictate the report(s) which must be generated. An EP is best

positioned to determine which reports are most useful to their care efforts.

The report generated could cover individual patients whose records are maintained using

certified EHR technology or a subset of those patients at the discretion of the EP.

Run the list to maintain as part of the documentation file. A new list must be generated prior

to the end of the reporting period.

Patient Reminders

Objective Send reminders to patients per patient preference for preventive/follow-up care.

Measure More than 20% of patients 65 years old or older or 5 years old or younger were sent an

appropriate reminder during the EHR reporting period.

Exclusion An EP who has no patients 65 years old or older or 5 years old or younger with records

maintained using certified EHR technology.

Tips Can use an outside reminder system but must be captured within the EHR.

Stage 2 significantly changes this measure.

Patient Education

Objective Use certified EHR technology to identify patient-specific education resources and provide

those resources to the patient if appropriate.

Measure More than 10% of unique patients seen by the EP provided patient-specific education

resources.

Exclusion None

Tips Patient-Specific Education Resources – Resources identified through logic built into

certified EHR technology which evaluates information about the patient and suggests

education resources that would be of value to the patient.

Education resources or materials do not have to be stored within or generated by the certified

EHR.

Providers should maintain supporting documentation (e.g. screen shot) showing the certified

technology suggesting educational resources for a patient.

Medication Reconciliation

Objective The EP who receives a patient from another setting of care or provider of care or believes an

encounter is relevant should perform medication reconciliation.

Measure 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.

Exclusion An EP who was not the recipient of any transitions of care during the EHR reporting period.

Tips Transition of Care – The 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.

The measure of this objective does not dictate what information must be included in

medication reconciliation. Information included in the process of medication reconciliation is

appropriately determined by the provider and patient.

Summary Care Record Objective The EP who transitions their patient to another setting of care of provider of care or refers their

patient to another provider of care should provide a summary care record for each transition of care

or referral.

Measure 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.

Exclusion An EP who neither transfers a patient to another setting nor refers a patient to another provider

during the EHR reporting period.

Tips Transition of Care – The 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.

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.

Immunization Registry Objective Capability to submit electronic data to immunization registries or immunization information

systems and actual submission according to applicable law and practice.

Measure 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 has the capacity to receive

the information electronically).

Exclusion An EP who administers no immunizations during the EHR reporting period or where no

immunization registry has the capacity to receive the information electronically.

Tips

http://flshotsusers.com/resources/meaningful-use-verification/

Full year reporting will probably not allow for an exclusion.

Must have documentation form Florida Shots, including verification on ongoing submission.

Shared physical setting only requires one test.

Syndromic Surveillance

Objective Capability to submit electronic syndromic surveillance data to public health agencies and

actual submission according to applicable law and practice.

Measure 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 (unless none of the public health agencies to which an EP submits such information has the capacity to receive the information electronically).

Exclusion An EP who does not collect any reportable syndromic information on their patients during the

EHR reporting period or does not submit such information to any public health agency that has the capacity to receive the information electronically.

Tips DOH only accepts syndromic surveillance from urgent care clinics and hospitals.

2014 Clinical Quality Measures (CQM)

Regardless of Stage

Eligible Professionals- 9 out of 64

Eligible Hospitals- 16 out of 29

Cover at least three of the National Quality Strategy Domains

Core Sets for Adult and Children

Choices driven by what vendor is offering

No threshold that must be met

CQM Reporting

Dually eligible hospitals beyond 1st year of Meaningful Use must electronically report CQM

data.

Medicaid only providers will report to the state through the on-line application

2014 Quality Domains

Patient Safety

(PS)

Clinical Process and

Effectiveness

(CPE)

Care Coordination

(CC)

Efficient Use of

Healthcare Resources

(EHR)

Population and Public

Health

(PPH)

Patient and Family

Engagement

(PFE)

EPs - Recommended Adult CQMs

Controlling High Blood Pressure (CPE)

Use of High-Risk Medications in the Elderly (PS)

Tobacco Use: Screening and Cessation Intervention (PPH)

Use of Imaging Studies for Low Back Pain (EHR)

Screening for Clinical Depression & Follow-Up Plan (PPH)

Documentation of Current Medications in the Medical Record (PS)

Body Mass Index (BMI) Screening and Follow-Up (PPH)

Closing the referral loop: receipt of specialist report (CC)

Functional status assessment for complex chronic conditions (PFE)

EPs - Recommended Child CQMs Appropriate Testing for Children with Pharyngitis (EHR)

Weight Assessment and Counseling for Nutrition and Physical Activity for Children and Adolescents (PPH)

Chlamydia Screening for Women (PPH)

Use of Appropriate Medications for Asthma (CPE)

Childhood Immunization Status (PPH)

Appropriate Treatment for Children with Upper Respiratory Infection (EHR)

ADHD: Follow-Up Care for Children Prescribed Attention-Deficit/Hyperactivity Disorder (ADHD) Medication (CPE)

Screening for Clinical Depression and Follow-Up (PPH)

Children who have dental decay or cavities (CPE)

Progress to Stage Two ONLY

After Two Reporting Periods of Stage

One Eligible Professional

Eligible Hospital

17 Core Measures

3 Menu Measures

9 CQMS

16 CQMS 3 Menu

Measures 16 Core

Measures

Preparing for Stage Two

• Many of the measure are what you are doing

Know what is expected and incorporate now

Focus on patient engagement Know Problem Areas

Certification Flexibility Rule

Effective October 1, 2014

Program Year 2014

The rule grants flexibility to providers who are unable to fully implement

2014 Edition Certified Electronic Health Record Technology (CEHRT) for

an EHR reporting period in 2014 due to delays in 2014 CEHRT

availability.

• Implementation- …a provider’s ability to fully implement the functionality may be

limited by the availability and timing of product installation, deployment of new

processes and workflows, and employee training.

Providers may now use EHRs that have been certified under the 2011

Edition, a combination of the 2011 and 2014 Editions, or the 2014 Edition

for 2014 participation.

Rule effective October 1, 2014

Attestation Options

Unable To Fully Implement Due To . . .

Software development delays

Missing or delayed software updates

Being able to implement 2014 CEHRT for only part of the

reporting period not the full reporting period

Unable to train staff, test the updated system, or put new work

flows in place because of delays associated with installation of

2014 CEHRT

Unable to meet stage 2 summary of care measures due to

recipient of transmittals impacted by 2014 CEHRT issues

NOT Allowable Reasons. . .

Financial issues

Inability to meet one or more measures

Staff turnover and changes

Provider waited too long to engage a vendor

Refusal to purchase the requisite software updates

Providers who fully implemented 2014 Edition CEHRT and

can report in 2014.

Adopt, Implement, Upgrade in 2014

To qualify for an incentive payment under Medicaid for 2014

for AIU, a provider must adopt, implement, or upgrade to 2014

Edition CEHRT only.

System use not required but cannot be a planned

implementation e.g. will be installed in November.

Revised Stage 3 Timeline

Stage 3:

FY 2017 (October 2016 – September 2017) for EHs and CAHs

CY 2017 (January – December) for EPs

Two reporting periods per stage

Medicaid does not require calendar quarter reporting

Additional Considerations Clinical Quality Measure (CQM) reporting will be tied to the reporting option

chosen. For example, providers will not be allowed to attest to 2014 Stage 1

measures and 2013 CQMs.

Additional attestation documents will be required documenting why a 2014 CEHRT

could not be fully implemented.

Changes to MAPIR allowing a provider to attest using a previous edition of

CEHRT are expected to be completed Spring 2015.

• Certification Number entered will determine options

Medicare Payment Adjustment

• Request due by November 30, 2014

• Only for the reasons specified http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/PaymentAdj_Hardship.html

What Does This Mean

Providers are encouraged to talk to their vendor about their options in

accessing 2013 Meaningful Use reports as this ability may no longer be

available once you begin installing 2014 CEHRT.

Providers must have 2014 CEHRT for Program Year 2015

If not your first MU reporting period – then Program Year 2015 will require

a full year reporting period

The rule does not fully address what is allowed but it is very specific on

what is not

Additional Contacts and Resources

Website: www.ahca.myflorida.com/medicaid/ehr

Phone: EHR Incentive Program Call Center:

(855) 231-5472

Email: MedicaidHIT@AHCA.MyFlorida.com

Kim.davis@ahca.myflorida.com

http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/EducationalMaterials.html

Website: www.Florida-HIE.net Phone: Florida HIE Help Desk: 850-412-3752

Email: FLHII@ahca.myflorida.com

Upcoming Events

Webinars

October 30th – Understanding the Auditing Process

November 13th – Focus on Stage Two Meaningful Use

Jacksonville Provider Workshop – November 6th

Orlando Provider Workshop – November 19th

www.ahca.myflorida.com/medicaidehr