Gain added clarity about your 2014 Meaningful Use attestation options to avoid Medicare payment adjustments, including timeline and impacts of recent CMS proposed rule changes. Preview the new interactive decision tool and understand compliance exemptions.
1. Expanded Meaningful Use Mandates, Excep4ons & A8esta4on Strategies Wednesday, August 6, 2014 Disclaimer: Nothing that we are sharing is intended as legally binding or prescrip7ve advice. This presenta7on is a synthesis of publically available informa7on and best prac7ces.
2. Congress mandated payment adjustments to Medicare eligible professionals who are not meaningful users under the EHR Incen=ve Program Payment adjustments will be applied beginning January 1, 2015 May be exempt when able to show that demonstra=ng MU would result in signicant hardship Expanded MU Mandates
3. Expanded MU Payment Adjustments Cumula=ve 1% annual and (depending on total meaningful users under program aLer 2018) max cumula=ve adjustment can reach 5%
4. Expanded MU Payment Adjustments- Medicare Advantage Organiza=ons Audits to be conducted 2years aLer payment year Adjustments about six months aLer MAO no=ed of results Correc=ve plans must be complete within that six month period CMS surveyed all MAOs that received incen=ve payments to determine if able to meet 2014 EHR soLware requirements & concluded they should allow same exibility oered to Fee-for- Service providers for 2014 MAO able to use 2011 edi=on CEHRT or combina=on 2011 & 2014 during 2014 repor=ng period if unable to fully implement 2014 edi=on due availability delay issues Beginning 2015, all eligible professionals and hospitals will be required to report using the 2014 edi=on CEHRT
5. PRIOR TO 5/23/2014 PROPOSED RULE CHANGES All providers mandated to upgrade/adopt cert EHR 2014 All providers regardless of MU stage use only three-month (or 90-day) repor=ng period 2014 EPs who rst demonstrate MU in 2014 must demonstrate 90-day repor=ng period to avoid 2015 adjustments Repor=ng period must occur in rst 9mos of calendar year 2014, must a_est by October 1, 2014 to avoid adjustments EPs must con=nue to demonstrate MU every year to avoid payment adjustments in subsequent years Expanded MU Mandates
6. If nalized, 5/23/14 proposed rule change would allow providers to meet Stage 1 or Stage 2 MU with EHRs cer=ed to the 2011 or 2014 criteria - or a combina=on of both Not a blanket policy for all providers, proposals only apply to those who can demonstrate that they are unable to fully implement 2014 edi=on EHRs Note that Stage 1 objec=ves and measures are referenced two ways: 2013 and 2014 2013 designa=on references the original Stage 1 objec=ves and measures, and the 2014 reects those changes CMS nalized in the Stage 2 Final Rule, eec=ve this year Expanded MU Proposed Changes
7. Expanded MU Strategy
8. Expanded MU Strategy CMS Decision Tool h8ps://www.cms.gov/Regula4ons-and-Guidance/Legisla4on/ EHRIncen4vePrograms/Downloads/ CEHRT_NPRM_DecisionTool-.pdf Note: Beginning in 2015, all eligible providers would be required to report using 2014 Edi7on CEHRT. If.. and.. then..
9. Proposed rule would formalize =meline to extend Stage 2 through 2016 - earliest a provider would par=cipate in Stage 3 of MU would be 2017 CMS proposed to revert CQM repor=ng requirements for providers a_es=ng with 2011 edi=on EHR EPs would report on 6 selected CQMs as they did in previous years regardless of MU stage Providers with 2014 edi=on would s=ll report on the requirements nalized in the Stage 2 Final Rule Providers using a combina=on of 2011 and 2014 Edi=on CEHRTs would need to meet the CQM requirements depending upon their Stage of MU Expanded MU Proposed Changes
10. Expanded MU A_esta=on 2014 Deni=on of Stage 1 EPs must meet: 13 required core objec=ves 5 menu objec=ves from a list of 9 Total of 18 objec=ves Those using 2011 cert EHR or a combina=on of 2011 and 2014 edi=ons choosing to report 2013 Deni=on Stage 1 core & menu objec=ves reference CMS 2013 Deni=on Stage 1 of Meaningful Use webpage
11. Expanded MU A_esta=on What changed for Stage 1 in 2014: Pa4ent Electronic Access-addi=on of new core objec=ve to provide pa=ents with ability to view online, download, and transmit health informa=on Record & Chart Changes in Vital Signs-increase in age limit for recording blood pressure in pa=ents to age 3; removal of age limit requirement for height and weight (exclusion for eligible professionals: if no pa=ents 3 years or older are seen; if all three vital signs are not relevant to scope; if height and weight not relevant to scope; or if blood pressure not relevant to scope) Electronic Copy of Health Informa4on-removal of electronic copy of health informa=on core objec=ve for Stage 1 for all providers Clinical Quality Measures-removal of clinical quality measure (CQM) as a separate core objec=ve for Stage 1 for all providers
12. If approved, exemp=on valid for 1 payment year only New applica=on required for following payment year Cannot be exempted in a any case more than 5 years 2015 EP hardship app deadline was July 1, 2014 2016 applica=on to be published soon Expanded MU Excep=ons
13. !Infrastructure: must demonstrate that they are in an area without sucient internet access or face insurmountable barriers to obtaining infrastructure (e.g., lack of broadband) !New Eligible Professionals: insucient =me to become meaningful users, can apply for a 2-year limited excep=on to payment adjustments (if beginng prac=ce in calendar year 2015 would receive an excep=on to the penal=es in 2015 and 2016, but would have to begin demonstra=ng meaningful use in calendar year 2016 to avoid payment adjustments in 2017) !Unforeseen Circumstances: Examples may include a natural disaster or other unforeseeable barrier Expanded MU Excep=ons
14. !Pa4ent Interac4on: Lack of face-to-face or telemedicine interac=on with pa=ent Lack of follow-up need with pa=ents !Prac4ce at Mul4ple Loca4ons: Lack of control over availability of cert EHR for more than 50% of pa=ent encounters " !2014 EHR Vendor Issues: The eligible professionals EHR vendor was unable to obtain 2014 cer=ca=on or the eligible professional was unable to implement meaningful use due to 2014 EHR cer=ca=on delays Expanded MU Excep=ons
15. A_esta=ons must be completed by each EP reques=ng Excep=on If classied in the Medicare Provider Enrollment, Chain and Ownership System (PECOS) as having one of the following 5 specialty codes below as primary area of prac=ce no exemp=on form is needed automa=cally exempt from the 2015 payment adjustment based on the data in PECOS Diagnos=c Radiology Nuclear Medicine Interven=onal Radiology Anesthesiology Pathology Expanded MU Excep=ons
16. Regardless of whether an EP passes, hardships, skips, or fails their Stage 1, Year 2 performance during 2014 they will be required to move up to the next stage e.g. PRIOR TO 5/23/14 RULE CHANGE :Stage 2, Year 1 in 2015 (with a full year repor=ng period) & will not get to repeat Stage 1 for a third year Policy applies even if the Medicare EP is granted a hardship excep=on for a given repor=ng year, it skips, or it fails Expanded MU A_esta=on
17. Timeline for proposed rule change July 21 public comment closed Unlike a direct nal rule process, CMS will have to promulgate & announce some =me prior to 10/1/14 Will your EPs be compliant Oct-Dec 2014? Is your EHR cer=ed, 100% ready? Will state level registry website be ready with rule change op=ons to facilitate a_esta=on? Will you have systems & policies for pa=ent portal/ informa=on exchange in place? Expanded MU A_esta=on
18. Expanded MU A_esta=on Organiza=ons that have already upgraded to 2014 CEHRT, are conserva=vely encouraged to con=nue progress with building systems as originally planned in 2014, un=l addi=onal clarica=on from CMS through Final Rule Any progress made can only help accomplish the implementa=on of your 2014 compliant EHR for the 2014 and 2015 repor=ng periods
19. Q&A Thank You! Contact your Quirk Project Specialist for Meaningful Use strategy guidance