Meaningful Use to MACRA - Greenway Health · © Greenway Health, LLC. All rights reserved. Confidential and proprietary. Not for distribution except to authorized persons. 1 Meaningful

1© Greenway Health, LLC. All rights reserved. Confidential and proprietary. Not for distribution except to authorized persons.

Meaningful Use to MACRA

Alex Goulding

Industry & Government Affairs


Agenda

• Attestation

– 2015 timeline

– Checklist

• MU requirements for 2015-2018

– Reporting timeline

– Stage requirements

• Public health reporting and exclusions

• New hardship exception

• MACRA

• Additional resources

3

Attestation


2015 Attestation timeline

December 31, 2015: End of 2015 calendar year and end of the

2015 reporting period for all providers

January 4, 2016: Medicare attestation opens for the 2015

program year

February 29, 2016: Attestation deadline

for the 2015 program year


Attestation checklist

• Met all of the necessary measures to successfully demonstrate MU

• Completed the appropriate reporting period and timeframe

• Have a successful and active registration status in the Registration and Attestation System: https://ehrincentives.cms.gov/hitech/login.action

• Have your EHR Certification Number: http://oncchpl.force.com/ehrcert

Before you attest you should have:

https://ehrincentives.cms.gov/hitech/login.action

http://oncchpl.force.com/ehrcert

6

MU Requirements 2015-2018


Reporting timelines 2015-2018

• 90 days, all Stage 1 or Stage 2 EPs, through Dec. 31, 2015

• Attestation Jan. 4 –Feb. 29, 2016

• Also any 90 days for CQM reporting in 2015

2015

• 90 days, if NEW (Stage 1 year 1) to MU

• Recurring or returning EP, entire calendar year

2016•Entire calendar

year, all EPs (last year of Stage 2*)

•*Voluntary Stage 3 in 2017

2017

2018

• All EPs begin Stage 3 in 2018


Stage 1/2 program requirements for 2015-2017

• 2015-2017:

– Stage 1/2• EPs: 10 objectives, including one public health reporting objective

• 2014 Edition of certified software

• Stage 1 in 2015 = exclusions within 7 of 10 Objectives

• Stage 1 in 2016 = exclusions only within 1 Objective (CPOE)

– Public Health Objective

• Stage 1 2015 = 1

• Stage 2 2015 = 2

• 2016-2017 = 2 regardless of Stage


Stage 1/2 measures and exclusions chart

http://www.greenwayhealth.com/blog/meaningful-use-final-rule-announced/

http://www.greenwayhealth.com/blog/meaningful-use-final-rule-announced/


Stage 3 program requirements for 2017-2018

• 2017:– Voluntary Stage 3 (2017 only)

• EPs: 8 objectives, including one public health reporting objective


– Public Health Objective

• 2016-2017 = 2 regardless of Stage

• 2018:– Stage 3

• EPs: 8 objectives, including one public health reporting objective


– Public Health Objective• 2018 = 2


Poll question

• Which Stage do you plan to attest to in 2017?

– Stage 2

– Voluntary Stage 3

– Do not plan to attest

– Unsure


MU alignment

1. Protection Patient Health Information –Security Risk Analysis

2. Electronic Prescribing

3.Clinical Decision Support

4. CPOE

5. Patient Electronic Access to Health Information/VDT

6. Coordination of Care

7. Health Information Exchange

8. Public Health Reporting

9.Medication Reconciliation

10. Secure Messaging

Protection Patient Health Information –Security Risk Analysis

2. Electronic Prescribing

3.Clinical Decision Support

4. CPOE

5. Patient Electronic Access to Health Information/VDT

6. Coordination of Care

7. Health Information Exchange

8. Public Health Reporting

Stage 1/2(2015-2017)

Stage 3(2017+)


Public Health Objectives


Stage 1/2 public health reporting

Measure Measure Specification# measure can count

Measure 1:Immunization Registry Reporting

The EP is in active engagement with a public health agency to submit immunization data

1

Measure 2: Syndromic Surveillance Reporting

The EP is in active engagement with a public health agency to submit syndromic surveillance data

1

Measure 3: Specialized Registry Reporting

The EP is in active engagement with a public health agency to submit data to a specialized registry

2

Measure 4: Electronic Reportable Laboratory Result Reporting

The EP is in active engagementwith a public health agency to submit ELR results

1

Number of measures to meet:

2015

• 1 if you were in Stage 1

• 2 if you were in Stage 2


2016

• 2


2017

• 2


Stage 3 public health reporting

Measure Measure Specification# measure can count

Measure 1:Immunization Registry Reporting

The EP is in active engagement with a public health agency to submit immunization data

1

Measure 2:Syndromic Surveillance Reporting

The EP is in active engagement with a public health agency to submit syndromic surveillance data

1

Measure 3: Case reporting

The EP is in active engagement with a public health agency to submit case reporting of reportable conditions

1

Measure 4: Public Health Registry Reporting

The EP is in active engagement with a public health agency to submit data to public health registries

2

Measure 5: Clinical Data Registry Reporting

The EP is in active engagement to submit data to a clinical data registry

2


2017

• 2


2018+

• 2


Public health active engagement

• 3 Levels of Active Engagement to meet Measure Option – attest to at least one of 3

– Completed Registration to Submit Data

• Within 60 days of start of attestation period

• No need to register per reporting period if have done so

– In Testing and Validation phase

• Must respond within 30 days of agency/registry request

– Failure to do so twice means failing measure

– Production or actively submitting

• Testing and validation completed, are actively submitting

• https://questions.cms.gov/faq.php?isDept=0&search=12985&searchType=faqId&submitSearch=1&id=5005

https://questions.cms.gov/faq.php?isDept=0&search=12985&searchType=faqId&submitSearch=1&id=5005


Public health general exclusions

• No registry exists or capable of receiving in jurisdiction

• EP does not administer to populations for which data is collected

• EP practice or specialty does not match the registry

• EP does not diagnose or treat disease or condition associated with registry

• Registry will not declare readiness to receive six months prior to reporting period (Stage 3)


Hardship Exception


Applying for a hardship exception in 2015

• March 15, 2016: Hardship exception application deadline for Medicare provider to avoid the 2017 payment adjustment

• Updated FAQ from CMS (released 2/1)– CMS is not requiring EPs – or any group of providers – to submit

documentation. Providers should retain documentation of their circumstance for their own records, but no such documentation is required for review by CMS.

– Issues relating to the 2015 rulemaking timeline is included in the existing category for extreme and uncontrollable circumstances related to implementation and use of certified HER technology (sub-category 2.2d)

– https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/PaymentAdj_Hardship.html

https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/PaymentAdj_Hardship.html


MACRA


Poll question

• How familiar are you with MACRA?

– Not at all

– Somewhat

– Well versed


• Basics

– Medicare reimbursement increases of 0.5% through 2019

– In 2019, establishes merit-based incentive payment system (MIPS): 100-point scale

– Bundles MU, PQRS and VBM• Sunsets individual program payment adjustments

• Extra incentives for “APM” participation

– Alternative Payment Models TBD per regulations

– 5% bonus in 2019 if already reside within an eligible APM

– Dual-sided risk APMs = MIPS opt out

Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)


Merit Based Incentive Payment System (MIPS) Scoring

Clinical improvement

15%

Resource use30%

Quality30%

Meaningful use25%


Timeline

Source: CMS.gov (https://goo.gl/54ON3Y)


Additional Resources


Additional resources

• EPs: What you need to know for 2015 tipsheet: https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/Stage3_EP.pdf

• What’s Changed for EHR Incentive Programs in 2015 through 2017 (Modified Stage 2): https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/2015_Stage2ComparisonFactSheet.pdf

• MACRA “Path to Value”: https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/MACRA-LAN-PPT.pdf

https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/Stage3_EP.pdf

https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/2015_Stage2ComparisonFactSheet.pdf

https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/MACRA-LAN-PPT.pdf


Thank you!

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Meaningful Use to MACRA - Greenway Health · © Greenway Health, LLC. All rights reserved. Confidential and proprietary. Not for distribution except to authorized persons. 1 Meaningful