Meaningful Use

Meaningful Use and Your Practice

In April 2015, the Department of Health and Human Services, Centers for Medicare and Medicaid Services (CMS) issued a proposed rule with meaningful use (MU) changes for 2015 through 2017. The proposal followed a CMS proposal for MU Stage 3, announced March 2015, that would govern MU in 2017 and after.

The proposal offered in April would go into effect for the 2015 reporting year and align Stage 1 and Stage 2 objectives and measures of the Medicare and Medicaid Electronic Health Record (EHR) Incentive Program. Criteria to meet MU modified Stage 2 thresholds will be easier to meet under the proposal, but penalties for MU will increase until 2018 when MU is rolled into the Merit Based Payment System (MIPS), along with the Physician Quality Reporting System, and the Electronic Prescribing (eRX) Incentive Program.

Critical proposals for American Academy of Family Physician members to know include:

  • Changing the Medicare and Medicaid EHR Incentive Program reporting period for all eligible professionals (EPs) in 2015, and for new participants in 2015 and 2016. The proposal allows a reporting period for both cohorts of any continuous 90-day period within the calendar year.
  • Reducing the number of stages of MU to two (modified Stage 2 and Stage 3), with both stages sharing common objectives. Modified Stage 2 contains alternative measures and exclusions for some of the objectives, which are optional for EPs scheduled to do Stage 1 in 2015.

Proposed changes to individual objectives and measures for Stage 2 of MU include:

  • Changing the threshold for patient electronic access measure that requires patients to view, download, or transmit their health information from “5 percent” of patients to “equal to or greater than 1” patient.
  • Changing the threshold for secure electronic messaging from being a percentage-based measure, to “yes or no” measure, stating the “functionality fully enabled.”
  • Consolidating all public health reporting objectives into one objective with measure options following the structure of the Stage 3 public health reporting objective.
  • Eliminating the distinction between menu and core measures. Retained objectives and measures would be required for the program.
  • Reporting on nine objectives and one consolidated public health reporting objective for both Stage 1 and Stage 2.

Year-by-Year Breakdown

In order to best explain the proposed MU changes, here is a year-by-year breakdown of the rule proposals.

2015

There are two potential cohorts, depending on the first year the physician attested to MU.

For those who first attested from 2011 thru 2013, your reporting period will be 90 days, and you will have to meet the modified Stage 2 measures. You are not allowed to use any of the alternative measures or exclusions.

For those who first attested from 2014 thru 2015, your reporting period will also be 90 days, and you will also have to meet the modified Stage 2 measures. However, since you were scheduled to attest to Stage 1, you can use any of the alternative measures or exclusions.

2016

Everyone is required to meet the modified Stage 2 measure, and you are not allowed to use any of the alternative measures and exclusions.

For those who first attested from 2011 to 2015, your reporting period is a full calendar year.

For those who are attesting for the first time in 2016, your reporting period is 90 days.

2017

Regardless of your first attestation year, everyone has a reporting period of a full calendar year. Everyone has the option to either meet the modified Stage 2 measures (without using any of the alternative measures or exclusions); or meet the Stage 3 measures.

2018

Everyone will be required to meet Stage 3 measures and report for a full calendar year.

Redundant, Duplicative, or Topped out Objectives and Measures

CMS has identified the following list of objectives and measures from MU Stage 1 and Stage 2 as redundant, duplicative, or topped out. Many of these objectives and measures may be valuable, and CMS encourages their continued use, but under the proposal, they will not require reporting.

Objectives and Measures for Eligible Professional

Objectives and Measures for Eligible Professional

:

Record Demographics

Objectives and Measures for Eligible Professional

:

Record Vital Signs

Objectives and Measures for Eligible Professional

:

Record Smoking Status

Objectives and Measures for Eligible Professional

:

Clinical Summaries

Objectives and Measures for Eligible Professional

:

Structured Lab Results

Objectives and Measures for Eligible Professional

:

Patient List

Objectives and Measures for Eligible Professional

:

Patient Reminders

Objectives and Measures for Eligible Professional

:
Summary of Care (Measure 1 – Any Method; Measure 3 – Test)

Objectives and Measures for Eligible Professional

:

Electronic Notes

Objectives and Measures for Eligible Professional

:

Imaging Results

Objectives and Measures for Eligible Professional

:

Family Health History

Objectives and Measures for Eligible Hospital/CAH

Objectives and Measures for Eligible Hospital/CAH

:

Record Demographics

Objectives and Measures for Eligible Hospital/CAH

:

Record Vital Signs

Objectives and Measures for Eligible Hospital/CAH

:

Record Smoking Status

Objectives and Measures for Eligible Hospital/CAH

:

Structured Lab Results

Objectives and Measures for Eligible Hospital/CAH

:
Patient List

Objectives and Measures for Eligible Hospital/CAH

:
Summary of Care (Measure 1 – Any Method; Measure 3 – Test)

Objectives and Measures for Eligible Hospital/CAH

:
eMAR

Objectives and Measures for Eligible Hospital/CAH

:

Advanced Directives

Objectives and Measures for Eligible Hospital/CAH

:

Electronic Notes

Objectives and Measures for Eligible Hospital/CAH

:
Imaging Results

Objectives and Measures for Eligible Hospital/CAH

:

Family Health History

Proposed Structure

The proposed structure for MU for 2015 through 2017 include nine required objectives for EPs using Stage 2, and eight required objectives for EHs and CAHs using Stage 2, with alternate exclusions and specifications for Stage 1 providers in 2015.

The current stage structure, retained objectives, and proposed structure is as follows:

 

Current Stage 1 Structure

Retained Objectives

Proposed Structure

EP

Current Stage 1 Structure

:

13 core objectives

5 of 9 menu objectives, including 1 public health objective

Retained Objectives

:

6 core objectives

3 menu objectives

2 public health objectives

Proposed Structure

:

9 core objectives

1 public health objective (2 measure options)

EH/CAH

Current Stage 1 Structure

:

11 core objectives

5 of 10 menu objectives, including 1 public health objective

Retained Objectives

:

5 core objectives

3 menu objectives

3 public health objectives

Proposed Structure

:

8 core objectives

1 public health objective (3 measure options)

 

Current Stage 2 Structure

Retained Objectives

Proposed Structure

EP

Current Stage 2 Structure

:

17 core objectives, including public health objectives

3 of 6 menu objectives

Retained Objectives

:

9 core objectives

0 menu objectives

4 public health objectives

Proposed Structure

:

9 core objectives

1 public health objective (2 measure options)

EH/CAH

Current Stage 2 Structure

:

16 core objectives including public health objectives

3 of 6 menu objectives

Retained Objectives

:

7 core objectives

1 menu objective

3 public health objectives

Proposed Structure

:

8 core objectives

1 public health objective (3 measure options)

The Proposed 9 Core Objectives and Public Health Measure Options

1. Protect Electronic Health Information

  • Measure: Perform a security risk analysis.

2. Clinical Decision Support

  • 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.
  • Measure 2: The EP has enabled and implemented the functionality for drug and drug allergy interaction checks for the entire EHR reporting period.

3. 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 CPOE.
  • Measure 2: More than 30 percent of laboratory orders created by the EP during the EHR reporting period are recorded using CPOE.
  • Measure 3: More than 30 percent of radiology orders created by the EP during the EHR reporting period are recorded using CPOE.

4. Electronic Prescribing (eRx)

  • Measure: 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.

5. Summary of Care

  • Measure: The EP that transitions or refers their patient to another setting of care or provider of care (1) uses certified EHR technology 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.

6. Patient Education

  • Measure: 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.

7. Medication Reconciliation

  • Measure: 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.

8. 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 four 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.

9. Secure Electronic Messaging

  • Measure: During the EHR reporting period, the capability for patients to send and receive a secure electronic message with the provider was fully enabled.

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 below. Providers scheduled for Stage 2 must choose 2 of the possible 5 measures below.

  • Immunization Registry Reporting
  • Syndromic Surveillance Reporting
  • Case Reporting
  • Public Health Registry Reporting
  • Clinical Data Registry Reporting

Background

CMS's EHR Medicare and Medicaid Incentive Program provides incentive payments to expedite and encourage EPs, eligible hospitals (EHs), and critical access hospitals (CAHs) to adopt, implement, or upgrade certified-EHR technology, and to demonstrate the "meaningful use" of certified-EHR technology.

EPs, EHs, and CAHs must demonstrate MU by meeting certain requirements. Those who fail to meet those requirements under the program will forfeit their incentive payment. However, starting in 2015, providers failing to meet criteria under the program face downward payment adjustments.

The program was designed to consist of three stages of MU, with each stage consisting of increasing requirements. Providers advance through each stage.

Stage 1 was intended to establish requirements for the electronic capture of clinical data, including providing patients with electronic copies of their health information.

Stage 2 focused on the data captured in Stage 1 being exchanged among health care providers and patients in order to improve coordination of care. Stage 2 also implemented a set of clinical quality measures (CQMs) for all providers to report in 2014, regardless of which stage they were in.

Stage 3 focuses on the advanced use of EHR technology to promote improved patient outcomes by increasing interoperability of health data and sharing among providers.

References

Acumen Physician Solutions. Meaningful use in 2015-2017: Only 9 objectives? http://www.acumenmd.com/blog/meaningful-use-in-2015-2017-only-9-objectives/(www.acumenmd.com). Accessed May 29, 2015.

Centers for Medicare and Medicaid Services. Federal register: Medicare and Medicaid programs; electronic health record incentive program—modifications to meaningful use in 2015 through 2017; proposed rule. Department of Health and Human Services. 2015. DHHS80(72)42CFR(495). http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/Modifications_MU_Rule.pdf(www.cms.gov). Accessed May 29, 2015.

Healthcare Information and Management Systems Society (HIMSS). New CMS NPRM offers significant meaningful use flexibility in 2015 through 2017 program years. http://www.himss.org/News/NewsDetail.aspx?ItemNumber=41714(www.himss.org). Accessed May 26, 2015.

Hinshaw Health Law Alert. CMS issues proposed Stage 3 meaningful use standards. http://www.hinshawlaw.com/assets/htmldocuments/Articles/HealthLawAlert_LongBranded_04062015.pdf(www.hinshawlaw.com). Accessed May 27, 2015.