CMS held a provider call Monday, March 12, on the Proposed Rule for Stage 2 Meaningful Use EHR stardards. If you couldn't make the call, here's a breakdown of what you missed:
March 12, 12:30 pm: OK. we've got a deck from CMS, which they describe as "lengthy." It came a few minutes ago. Guess we're not going to study up before the call goes through...
12:32 pm: The hold music is very aggressive. We thought these tunes were chosen for their innocuousness.
12:36 pm: Late again. Meantime, some dates from the presentation: The Final Rule will be out this summer, and the Stage 2 start dates will be Oct 1, 2013 and Jan 1, 2014.
This is interesting too: "Exclusions no longer count to meeting one of the menu objectives." So if you're an EP who needs to meet 20 mixed-menu objectives, and you get an allowed exclusion, that doesn't mean you now need 19 objectives.
12:41 pm: OK, they're on. Speakers: Travis from Dallas, an "expert on MU," Maria Michaels, and Larry Clark.
Travis said they've changes some of the ways they calculate eligibility for MU2, but as to the eligibility categories, they're all the same.
Meaningful Use is meant to "improve quality, safety, efficiency, and reduce health disparities, engage patients and families in their health care," etc. But you knew that.
CMS won't be able to supply guidance on every little thing -- "it's just not possible; your individual circustances are going to be unique to you... [but] when you come to your decision points," he says, "put each objective in the context of the goal." If you're doing CPOE, remind yourself what it's supposed to do -- and make sure it's doing that for you.
Whenever you start your Meaningful Use, you do two years, then you move on.
12:55 pm. There are"more core and less menu objectives." They eliminated one, consolidated others.
(About that exclusion rule we mentioned: If you have so many exclusions you exhaust the available objectives, apparently they let that slide.)
Also, "all denominators include all patient encounters at outpatient locations equipped with certified EHR technology."
Want to see the core objectives for physicians?
1. Use CPOE for more than 60% of medication, laboratory and radiology orders
(Remember -- the denominator is all eligible patients, and it's against that number that your percentage is determined. Other percentages are affected by this, too.)
2. E-Rx for more than 65%
(Was 40%. Would exclude if there's no participating pharmacy within 25 miles.)
3. Record demographics for more than 80%
4. Record vital signs for more than 80%
5. Record smoking status for more than 80%
6. Implement 5 clinical decision support interventions + drug/drug and drug/allergy
7. Incorporate lab results for more than 55%
(Like most of the numbers, these have gone up.)
8. Generate patient list by specific condition
9. Use EHR to identify and provide more than 10% with reminders for preventive/follow-up
10. Provide online access to health information for more than 50% with more than 10% actually accessing
(This 10% is brand-new.)
11. Provide office visit summaries in 24 hours
12. Use EHR to identify and provide education resources more than 10% 20
13. More than 10% of patients send secure messages to their EP
(Secure messaging is new to MU2. "We're looking for actual engagement here... patients engaged back with the EP.")
14. Medication reconciliation at more than 65% of transitions of care
15. Provide summary of care document for more than 65% of transitions of care and referrals with 10% sent electronically
(This 10% is brand-new, too.)
16. Successful ongoing transmission of immunization data
(In MU1, "it was just a test" -- but now it's for real, "moving toward processes that we think can actually improve outcomes.")
17. Conduct or review security analysis and incorporate in risk management process
And here are the menu objectives, which are largely new:
1. More than 40% of imaging results are accessible through Certified EHR Technology
2. Record family health history for more than 20%
3. Successful ongoing transmission of syndromic surveillance data
4. Successful ongoing transmission of cancer case information
5. Successful ongoing transmission of data to a specialized registry
Now, hospital core objectives:
1. Use CPOE for more than 60% of medication, laboratory and radiology orders
2. Record demographics for more than 80%
3. Record vital signs for more than 80%
4. Record smoking status for more than 80%
5. Implement 5 clinical decision support interventions + drug/drug and drug/allergy
6. Incorporate lab results for more than 55%
7. Generate patient list by specific condition
8. EMAR is implemented and used for more than 10% of medication orders
9. Provide online access to health information for more than 50% with more than 10% actually accessing
10. Use EHR to identify and provide education resources more than 10%
11. Provide summary of care document for more than 65% of transitions of care and referrals with 10% sent electronically
13. Successful ongoing transmission of immunization data
14. Successful ongoing submission of reportable laboratory results
15. Successful ongoing submission of electronic syndromic surveillance data
16. Conduct or review security analysis and incorporate in risk management process - Medication reconciliation at more than 65% of transitions of care.
And menu:
1. Record indication of advanced directive for more than 50%
2. More than 40% of imaging results are accessible through Certified EHR Technology
3. Record family health history for more than 20%
4. E-Rx for more than 10% of discharge prescriptions
1:17 pm. Maria Michaels on now. CQMs are no longer a meaningful use core objective, she says, "but reporting CQMs is still a requirement for meaningful use." She talks us through a complex slide of reporting periods which we won't attempt to include here. (This segment has a lot of explaining why they did what they did, with talking points like "Lessen provider burden," "Harmonize with data exchange priorities," "Support primary goal of all CMS quality measurement programs, etc. The main message seems to be: If you don't think this is making better care, or do think that it's too onerous, you should bring that up in comments.)
1:41 pm: Travis is back to talk about payment issues -- specifically, if you don't make the EHR Meaningful Use deadlines, how much will they cut your Medicare-Medicaid payments? Oct 1, 2014 is "the last possible moment" to get into the program, he says, and by keeping all deadlines avoid payment adjustments.
And everyone has to stay on time. Otherwise, you face cuts: for EPs, they're between 1% and (starting in 2019) 5%. For hospitals, your decrease in the percentage increase to the IPPS Payment Rate that the hospital would otherwise receive for that year will range from 25% in 2015 to 75% in 2020 and beyond.
There are hardship exemptions; Travis mentioned hurricanes as a typical acceptable hardship. Basically if an EP can show "lack of direct interaction with patients; lack of need for follow-up care for patients; and lack of control over the availability of Certified EHR Technology" -- all three -- they can get off. for hospitals, it's more or less the same; "new hospitals for at least 1 full year cost reporting period" also can get exemptions. Travis does invite comments on this.