Tag: Meaningful Use
The meaningful use program is on the cusp of major changes, the Centers for Medicare and Medicaid Services Acting Administrator Andy Slavitt said late Monday, adding that 2016 would likely see the end of the program altogether.
The Medicare Access & CHIP Reauthorization Act of 2015, with its emphasis on a new Merit-Based Incentive Payment System and alternative payment models, demands a new streamlined regulatory approach, he said, speaking at the J.P. Morgan Healthcare Conference in San Francisco.
While offering few details, Slavitt pointed to March 25 as “an important date” for these new initiatives, according to a report from Internal Medicine News – which quoted him as saying that “We have to get the hearts and minds of physicians back. I think we’ve lost them.”
That’s been the feeling for some time, especially from the perspective of groups such as the American Medical Association.
Despite less than a year ago describing Stage 3 as “what everybody will be doing … in 2018 and beyond,” and declaring, as recently as this past October, that Stage 3 would proceed as planned, CMS looks to be changing its tune.
Beth Israel Deaconess Medical Center CIO John Halamka, MD, said in a blog post a few months back that meaningful use has served its purpose.
“Stage 1 created a foundation of functionality for everyone. That was good,” he wrote. “Stage 2 tried to change too much too fast and required an ecosystem of applications and infrastructure that did not exist. Clinicians struggled to engage patients and exchange data because they could send payloads but there were few who could receive them. Stage 3 makes many of the same mistakes as Stage 2, trying to do too much too soon.”
Especially with so many new regulations coming from CMS, now could be good time to reconsider a the six-year-old program, he suggested.
“The layers of requirements in Meaningful Use, the HIPAA Omnibus Rule, the Affordable Care Act, ICD-10 and (MACRA) are so complex and confusing that even government experts struggle to understand the implementation details,” Halamka wrote. “Each of the regulations leads to various audits. My experience is that even the auditors do not understand the regulatory intent and ask for documentation that far exceeds the capabilities of existing technology.”
As the new year quickly approaches, so does the start of meaningful use attestation under the new final Stage 2 Modifications Rule. With that final rule comes many changes to Stage 2 Meaningful Use that providers will need to take into account as they attest in 2016.
What are these changes? What information do providers need to know about attestation? Below is a roundup of materials from the Centers for Medicare & Medicaid Services (CMS) and EHRIntelligence.com articles to help providers prepare for meaningful use attestation in 2016:
Stage 2 Meaningful Use Attestation Timeframes
Under the final rule, which was released in early October of this year, attestation timeframes were adjusted to align with the full calendar year. Starting in 2016, both eligible professionals (EPs) and eligible hospitals (EHs) will need to attest to Stage 2 Meaningful Use between January 1 and December 31 of 2016.
However, all first-time Stage 2 participants, as well as those attesting for 2015, will only need to attest to a 90-day timeframe. These 90 days must be consecutive and occur between January 1 and December 31 of 2016.
Streamlining Objectives Measures
In a webinar following the release of the Modifications Rule, CMS provided a comprehensive summary to the various changes to Stage 2, as well as the rationale behind it. Specifically, CMS discussed Stage 2 objectives measures and the way they have been compressed.
Under the Stage 2 Modifications rule, EPs attesting for 2016 will only need to attest to 10 core objectives. One of these core objectives must be an overarching public health reporting objective that includes three reporting measures.
The Modifications Rule also streamlines objectives for EHs and critical access hospitals (CAHs), reducing the number of objectives to nine, with one overarching public health reporting objective that includes four reporting measures.
These objectives were changed to align better with the goals and requirements of Stage 3 Meaningful Use, as well as to get rid of “redundant and duplicative” requirements.
Certified EHR Technology
Although 2015 attestations required providers to use the 2014 edition of Certified EHR Technology, the 2016 attestation requirements provide more flexibility. According to CMS, providers may attest using either the 2014 certification edition, or the newly-released 2015 edition.
The Department of Health and Human Services (HHS) Office of the National Coordinator for Health IT (ONC) released the 2015 EHR certification criteria at the same time as the Meaningful Use final rule. The 2015 criteria put an emphasis on interoperability and health information exchange (HIE).
Specifically, the criteria call for mandatory HIE testing reports, as well as updated data export to facilitate adequate interoperability.
As stated above, attesting with these EHR certification criteria is optional in 2016, but becomes mandatory in 2018.
Because providers may not have EHR systems that can support the new provisions in the Modified Stage 2 Meaningful Use guidelines, CMS is offering several alternate exclusions. CMS has released a comprehensive list of alternate exclusions for EPs, EHs, and CAHs as an attachment to other Meaningful Use attestation guidelines.
However, CMS has addressed notable exclusions including those for public health reporting. Due to an influx of concern regarding the ability to attest to public health reporting measures, CMS is offering alternate exclusions stating that EPs may report on only two of the three measures, but that one of the two measures must be measure 1, which pertains to immunization registry reporting.
EHs and CAHs applying for an alternate exclusion may attest to only three of four measures, but one of the measures must be measure 3, which involves specialized registry reporting.
When attesting to Stage 2 in 2016, providers and hospitals alike will need to bear in mind these changes to the program in order to ensure a smooth attestation. Provided CMS’s rationale for the Stage 2 modifications — which includes the consistency between Stage 2 and Stage 3 requirements — adhering to these new modifications will allow for a better transition to Stage 3 come 2018.
The Texas Medical Association wants Congress to intervene and make changes to the federal electronic health-record incentive payment Meaningful Use program it’s calling “meaningful abuse.”
The group says stage 3 of the program meant to get physicians using EHRs could jeopardize Medicare doc payment rules.
The TMA, the largest state medical association in the country, wants Congress to lift what it’s describing as the $31.6 billion program’s “convoluted and tedious” meaningful-use requirements.
In a letter Texas’ two U.S. senators, John Cornyn, and Ted Cruz, and to the Texas delegates to the House of Representatives, TMA President Dr. Tom Garcia asked legislators to co-sponsor two bills to alter the meaningful-use landscape.
One is the Flex-IT 2 Act by Rep. Renee Ellmers, (R-N.C.), which would delay Stage 3 meaningful-use rules until at least Jan. 1, 2017. The other is the Transparent Ratings on Usability and Security to Transform Information Technology, or TRUST IT Act by Sens. Bill Cassidy (R-La.) and Sheldon Whitehouse (D-R.I.) which is aimed at ensuring health IT systems perform better in the field.
“We believe Congress must enact legislation that provides positive incentives for physicians to acquire and maintain health information technology,” Garcia wrote. “Until electronic health records truly add value to medical care and can seamlessly interact with other systems, we want Congress to reform the program and eliminate federal mandates that compel physicians to engage in unnecessary activities and reporting.”
The TMA went on to stress that numerous other organizations and individuals are protesting the implementation of Stage 3.
“EHR State of Mind,” a video by physician-rapper Dr. Zubin Damania has drawn nearly 200,000, according to the medical society. The TMA also pointed to a town hall event hosted by the American Medical Association and the Medical Association of Georgia which concluded that EHRs could be helpful, but that government regulations like meaningful use have made them almost unusable.
“Help us put real meaning back into medical practice,” Garcia wrote.
The Centers for Medicare & Medicaid Services (CMS) released final Meaningful Use rules that simplify requirements and add new flexibilities for providers to make, electronic health information available when and where it matters most and for health care providers and consumers to be able to readily, safely, and securely exchange that information. The final rules for 2015 Edition Health IT Certification Criteria (2015 Edition) and final rules with comment period for the Medicare and Medicaid Electronic Health Records (EHRs) Incentive Programs will help continue to move the health care industry from a paper-based system, where a doctor’s hand-writing had to be interpreted and patient files could be misplaced.
CMS heard from physicians and other providers about the challenges and burdens they face making this technology work well for their individual practices and for their patients. In recognition of these concerns, the final regulations make significant changes to current requirements by easing the reporting burden for providers, supporting interoperability, and improving patient outcomes. CMS is also encouraging providers to apply for exemptions if they had difficulty with or needed to switch their EHR vendor or experienced challenges due to the timing of the rules and EHR implementation. Additionally, the new rules will enable the development of user-friendly technology, allowing individuals easier access to their information so they can be engaged and empowered in their care.
Overview of Rule Provisions
CMS reviewed and considered more than 2,500 comments on the two proposed rules to create the final policies, with the opportunity for additional comment, for participation in the EHR Incentive Programs. In recognition of the issues raised, CMMS made significant changes to ease reporting burden for all providers, supporting health information exchange, and improving patient outcomes. For example, the regulations:
- Shift the paradigm so health IT becomes a tool for care improvement, not an end in itself.
- Provide simplicity and flexibility so that providers can choose measures that use in their practices and report progress that are most meaningful to their practice.
- Give providers and state Medicaid agencies more time – 27 months, until January 1, 2018 – to comply with the new requirements and prepare for the next set of system improvements.
- Give developers more time to create the next advancements in technology that will be easier to use and more appropriate to new models of care and access to data by consumers.
- Support provider exchange of health information and a more useful interoperable infrastructure for information exchange between providers and with patients
- Give developers more time to create the next advancements in technology that will be easier to use and more appropriate to new models of care and access to data by consumers.
- Address health information blocking and interoperability between providers and with patients.
For the EHR Incentive Programs in 2015 through 2017, major provisions include:
- 10 objectives for eligible professionals including one public health reporting objective, down from 18 total objectives in prior stages.
- 9 objectives for eligible hospitals and critical access hospitals (CAHs) including one public health reporting objective, down from 20 total objectives in prior stages.
- Clinical Quality Measures (CQM) reporting for both eligible professionals (EPs) and eligible hospitals/CAHs remains as previously finalized.
CMS evaluated the current programs and identified areas where modifications could be made to align with the long-term vision and goals for Stage 3. CMS restructured the objectives and measures of the EHR Incentive Programs in 2015 through 2017 to align with Stage 3, and modified “patient action” measures in Stage 2 objectives. These changes recognize the progress providers have made and realign with long term goals.
For Stage 3 of the EHR Incentive Programs in 2017 and subsequent years, major provisions include:
- 8 objectives for eligible professionals, eligible hospitals, and CAHs: In Stage 3, more than 60 percent of the proposed measures require interoperability, up from 33 percent in Stage 2.
- Public health reporting with flexible options for measure selection.
- CQM reporting aligned with the CMS quality reporting programs.
- Finalize the use of application program interfaces (APIs) that enable the development of new functionalities to build bridges across systems and provide increased data access. This will help patients have unprecedented access to their own health records, empowering individuals to make key health decisions.
The Stage 3 requirements are optional in 2017. Providers who choose to begin Stage 3 in 2017 will have a 90-day reporting period. All providers will be required to comply with Stage 3 requirements beginning in 2018 using EHR technology certified to the 2015 Edition. Objectives and measures for Stage 3 include increased thresholds, advanced use of health information exchange functionality, and an overall focus on continuous quality improvement.
In addition, the final rule adopts flexible reporting periods that are aligned with other programs to reduce burden, including moving from fiscal year to calendar year reporting for all providers beginning in 2015, and offering a 90-day reporting period in 2015 for all providers, for new participants in 2016 and 2017, and for any provider moving to Stage 3 in 2017.
As part of today’s regulations, CMS announced a 60-day public comment period to facilitate additional feedback about Stage 3 of the EHR Incentive Programs going forward, in particular with the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), which established the Merit-based Incentive Payment System (MIPS) and consolidates certain aspects of a number of quality measurement and federal incentive programs into one more efficient framework. We will use this feedback to inform future policy developments for the EHR Incentive Programs, as well as consider it during rulemaking to implement MACRA, which we expect to release in the spring of 2016.
Because the Centers for Medicare and Medicaid Services (CMS) has yet to issue the so-called “modification rule” for the electronic health record (EHR) Meaningful Use program for 2015, the AMA is calling on the agency to create an automatic hardship exemption for physicians who did not have the opportunity to report successfully this year.
In April, CMS proposed modifications to stages 1 & 2 of the program that reduced the reporting period from a full calendar year to 90 days. Stakeholders believed this was necessary since many physicians could not update systems, change products, or accommodate Internet outages or other disruptions under a 365-day reporting program.
“The AMA welcomed and supported the proposed changes, but it’s now Oct. 1 and CMS has left physicians without any guidance or assurances that they will be capable of meeting program requirements before the end of the year,” said AMA President Steven J. Stack, M.D. “The AMA has regularly stressed that CMS must finalize Meaningful Use modifications well ahead of Oct. 1 to provide the time that physicians need to plan for and accommodate these changes, yet CMS has continued to delay finalizing this rule. As a result, many physicians who were counting on this flexibility will be subject to financial penalties under the rules currently in place. The AMA is asking CMS to create an automatic hardship exemption as soon as possible so that physicians are not penalized for regulatory delays that are outside their control.”
Previous AMA efforts to shape the Meaningful Use program can be found at AMA Wire. For additional information visit BreaktheRedTape.org, or join the discussion on Twitter using #FixEHR.
New data published by the Office of the National Coordinator for Health Information Technology shows high levels of office-based physician EHR use of certified EHR technology (CEHRT) and even greater EHR adoption numbers in 2014.
The most recent ONC brief puts the percentage of office-based physician CEHRT users at 74 percent as compared to 51 percent using a basic EHR and a total of 83 percent using any type of EHR technology.
Of those physician EHR users with CEHRTs, more than half (56%) have plans to participate in the EHR Incentive Programs although one-third that number (18%) have no plans or remain unsure as to their participation in meaningful use.
As for the basic EHR functionalities being used by office-based physicians, the figures hovered around 80 percent with the exception of viewing imaging results. Less than two-thirds of office-based physician EHR users reported have the ability to view imaging results electronically, 25-percentage points fewer than the most common computerized functionalities of recording demographic information (86%) and computerized prescription order entry (85%). Other functionalities topping the 80-percent mark were:
- Recording patient’s medications and allergies (84%)
- Recording clinical notes (83%)
- Recording patient problem lists (82%)
Based on specialty, primary care physicians reported the highest rates of EHR adoption across all types of EHR technology — 87 percent. Medical specialists and surgical specialists were not too far behind at 80 percent and 78 percent, respectively, and equal in terms of physician CEHRT users (70%).
Generally an indicator of EHR adoption, practice size proved to be a significant differentiator in 2014 for office-based physician EHR adoption.
Solo practitioners reported the lowest percent of EHR adoption across the board, at a total of 64 percent for all EHR technology and 55 percent for CEHRT. The highest percentage of EHR adoption was reported by practices of 11 or more physicians, 97 percent of which had adopted EHR technology of any type and 86 percent of CEHRT. Sandwiched between these two sets of physicians were 6-10 physician practices and 2-5 physician practices.
A rather ambiguous finding in the report deals with physician EHR adoption by practice setting:
- 98 percent of physicians in community health centers had adopted EHR technology; 76 percent CEHRT
- 44 percent of physicians in community health centers and physician or group-owned practices were using all Basic EHR functionalities
- Physicians in physician- or group-owned practices reported the lowest EHR adoption rates across all EHR types
- HMO-owned or other healthcare corporation-owned physician practices reported the highest adoption rates of certified EHRs at 87%
“These findings may be related to the fact that the Basic EHR definition includes functionalities that apply primarily to certain physician specialties and may not be broadly applicable across the care continuum,” the ONC report states.
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