Meaningful Use (MU) Community of Practice (CoP ......Meaningful Use (MU) Community of Practice (CoP)...
34
Meaningful Use (MU) Community of Practice (CoP) February 4, 2016 2:00 PM Eastern Time Medicaid Electronic Health Record (EHR) Team (MeT) Centers for Medicare and Medicaid Services (CMS) MODIFIED STAGE 2: QUESTIONS AND ANSWERS This is an advanced copy of the Meaningful Use presentation for your review only. This presentation is subject to change and should not be reproduced. The final version of the presentation will be posted to the Medicaid HITECH TA Web site at a later date.
Transcript of Meaningful Use (MU) Community of Practice (CoP ......Meaningful Use (MU) Community of Practice (CoP)...
Meaningful Use (MU) Community of Practice (CoP)
February 4, 2016
2:00 PM Eastern Time
Medicaid Electronic Health Record (EHR) Team (MeT)
Centers for Medicare and Medicaid Services (CMS)
MODIFIED STAGE 2: QUESTIONS AND ANSWERS
This is an advanced copy of the Meaningful Use
presentation for your review only. This presentation is
subject to change and should not be reproduced. The
final version of the presentation will be posted to the
Medicaid HITECH TA Web site at a later date.
Today’s CMS & MeT Resources
David Koppel: [email protected]
CMS, Health Information Technology for Economic and Clinical Health
(HITECH) Coordinator
Phone: (214) 767-4403
Izanne Leonard-Haak: [email protected]
MeT, Team Member
Health Management Associates
Matt McGeorge [email protected]
MeT, Team Member
Health Management Associates
2
Agenda
CMS and MeT Updates
– EHR Incentive Program Timelines
– Adopt, Implement or Upgrade(AIU) Tool – Maximizing EP Enrollment in
Program Year 2016
Modified Stage 2
– Polls
– Responses to Some FAQs
– Open Discussion
– Resources
3
4
CMS and MeT Updates
Izanne Leonard-Haak
Medicaid EHR Team
CMS Update
5
• The MACRA legislation only addresses Medicare physician and clinician payment adjustments.
• Providers who demonstrate meaningful use as defined in the 2015 EHR Incentive Programs final rule (or attest to adopting, implementing, or upgrading to certified EHR technology) in 2016 may earn an incentive in the Medicaid program and may continue to earn incentives in subsequent years for demonstration of the meaningful use.
Will MACRA impact the Medicaid EHR Incentive
Program?
• The current law requires that we continue to measure the meaningful use of ONC Certified Health Information Technology under the existing set of standards.
• The approach to meaningful use under MACRA won’t happen overnight.
When does this go into effect?
• In December, Congress gave us new authority to streamline the process for granting hardship exception’s under meaningful use. This will allow groups of health care providers to apply for a hardship exception instead of each doctor applying individually.
• New FAQ was released on February 2, 2016 (see next slide for FAQ)
What else is changing with the MU program?
CMS and ONC Statement on Meaningful Use Program http://blog.cms.gov/2016/01/19/ehr-incentive-programs-where-we-go-next/
CMS Update
6
CMS has released an FAQ outlining the documentation requirements for submitting the new hardship application to avoid the 2017 payment adjustment.
FAQ #14113 - On the new hardship application form for the 2017 payment adjustment there is nothing which says documentation is required to be submitted with the application form. Does this mean that CMS will only require the selection of a hardship category and the completion of the provider’s identifying information in order to approve a hardship exception? Or will CMS be reviewing the application and documentation on a case-by-case basis for each provider?
CMS does not require an EP, eligible hospital, or CAH – or any group of providers – to submit documentation for the hardship category selected and CMS will not be reviewing documentation supporting the application on a case-by-case basis. CMS will review the application to record the category selected and use the identifying information to approve the hardship exception for each provider listed on the application. Providers should retain documentation of their circumstances for their own records, but no such documentation is required for review by CMS.
CMS has also updated FAQ #12845 to reflect these changes and to provide additional guidance specific to sub-category 2.2d of PAMPA – EHR Certification/Vendor Issues (CEHRT Issues). This category can be used for issues related to the 2015 rulemaking timeline and is included under the existing category for extreme and uncontrollable circumstances related to the implementation and use of certified EHR technology.
Providers who experienced an issue with their CEHRT related to the rule timing – and any other provider for whom the timing of the rule caused a significant hardship – should select sub-category 2.2d on the 2017 hardship exception application. No additional documentation is required for this selection.
To review the hardship exception application and instructions, visit:
https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/PaymentAdj_Hardship.html
7
MeT Update
Tool is available on the Medicaid HITECH TA Web site (must have login information): http://www.medicaidhitechta.org/LinkClick.aspx?fileticket=ho5pbiweTA4%3d&portalid=0
Adopt, Implement or Upgrade: Maximizing EP Enrollment - 2016
Adopt, Implement or Upgrade: Maximizing EP Enrollment - 2016
8
Additional information about the tool will be presented on the February 7th
Performance Progress CoP
Tool is available on the Medicaid HITECH TA Web site (must have login information): http://www.medicaidhitechta.org/LinkClick.aspx?fileticket=ho5pbiweTA4%3d&portalid=0
• How to identify EPs that have not attested
Understanding the Target Population
• How to communicate with EPs to encourage program participation
Developing an Engagement Strategy
• Provides communication template that states can use
Sample Communication
Structure of the Tool
MeT Update
9
MeT Update
Tool is available on the Medicaid HITECH TA Web site (must have login information): http://www.medicaidhitechta.org/LinkClick.aspx?fileticket=ho5pbiweTA4%3d&portalid=0
Adopt, Implement or Upgrade: Maximizing EP Enrollment - 2016
10
Modified Stage 2: Polls
Izanne Leonard-Haak
Medicaid EHR Team
Have you already been communicating that 2016
is the last year to receive an incentive for AIU?
(Select One)
- Yes
- No: Plan to in near future
- No: Focused on MU
- Unsure
11
If you have you been communicating that 2016 is the last
year to receive an incentive for AIU, what methods are you
using? (Select all that apply)
- Listserv (emails)
- Webinars
- Website Updates
- Communications via Provider Associations
- Other
12
When will your SLR be available to EPs for
PY 2015 attestations? (Select One)
- Is currently available/by the end of Feb. 2016
- By the end of March 2016
- By the end of April 2016
- By the end of June 2016
- After June 2016
13
- By February 29, 2016
- By March 31, 2016
- By June 30, 2016
- After June 30, 2016
14
When does your PY 2015 EP attestation
tail/grace period end?
15
Based on your discussions with EPs what modified stage 2
objective is the most difficult to address in PY 2015?
(Select One)
- Health Information Exchange (Objective 5)
- Patient Electronic Access (Objective 8)
- Public Health (Objective 10)
- Other (Objectives 1, 2, 3, 4, 6, 7, 9)
- CMS Specification Sheets and other Information Sheets
- Hosting Webinars
- Publishing New FAQs and Information Sheets (Not CMS)
- Referring to RECs or REC like organization
- Other
16
What types of modified stage 2 resources are you making
available to providers? (Select all that apply)
17
Modified Stage 2: Responses to Some FAQs
Matt McGeorge
Medicaid EHR Team
Non-Measure Specific
After 2015, does “scheduled for Stage 1” have any significance?
• Answer: Yes but minimal (EP CPOE)
Can CMS issue updated guidance on how EPs should validate exclusions taken?
• Answer: CMS will work with States on their MU EHR audit strategies and recommends that states explain expectations with their stakeholders. Generally speaking EPs should document internally their reason for taking an exclusion and have that available if it is requested.
18
Objective 1: Protect Patient Health Information
Given 90-day reporting, if an organization conducts an Annual SRA every December, can a December 2014 SRA be used for 2015 reporting period of June-July-August 2015 if a state Medicaid registry is available November 2015 for attestation submission?
• Answer: Review of an SRA must be done annually, it is not “episodic”. If an SRA was used for previous year’s attestation, no, that SRA review cannot be used again for the following year’s attestation.
19
Objective 5: Health Information Exchange (HIE)
On 10/02/15, CMS released FAQ 12817 before the final rule was made public. Does this FAQ limit the transport mechanism for “sending electronically”? This FAQ has led some to believe that they must use a third party.
• Answer: No, this FAQ does not limit the transport mechanism nor does it intend to mean that one must use a third party to send. The fact that the EP is sending a CCD-A out is what CMS is focusing on under 2015 – 2017 Modification. The EP must have the capacity to create (and do so) in CEHRT for each TOC and send it out as consumable (in CCD-A format).
Does the consolidated architecture have any specified use in sending the electronic Summary of Care at this point?
• Answer: Yes. The EP must have the capacity to create in CEHRT and send it out as consumable (in CCD-A format). 20
Objective 5: Health Information Exchange (HIE)
Is faxing considered a means of electronic transmission? (Modern faxing, cloud based faxing, etc., has come a long way from analog faxing.)
• Answer: No, faxing is not an acceptable means for the initial send. The EP must send a CCD-A, one cannot fax CCD architecture format. However, if the EP sends to a third party, the third party may convert it to a fax (or other formats) before delivering to the receiving provider. See CMS FAQs 12817 and 10660 re Third Party.
Other than the faxing question above, can CMS elaborate on the electronic transmission methods that are acceptable? Or, will “the expansion of available transport mechanisms” be for the EP (or their employing organization) to define? Is there a potential MU audit vulnerability?
• Answer: There are lots of ways to send. CMS has heard from many developers about different, acceptable transport mechanisms. The rule is pretty broad. If an EP needs to manually count the numerator, that is fine. CMS FAQ 3063 does indeed still apply. 21
Objective 5: Health Information Exchange (HIE)
Can CMS confirm that the proof of receipt of a Summary of Care document is no longer part of the HIE measure?
• Answer: Proof of receipt has not been removed from the measure. CMS maintained measure 2 (of former Stage 2 Measure 15) as written, having only changed the specificity of transport. Per the Modification Final rule, “reasonable” proof of receipt is okay.
Is CMS FAQ 9690 still valid and/or applicable? (“…which transitions would count toward the numerator of the measure?”)
• Answer: Excerpt from the FAQ: “A transition of care is defined as the movement of a patient from one setting of care (hospital, ambulatory, primary care practice, ambulatory specialty care practice, long-term care, home health, rehabilitation facility) to another.” The denominator should be all transitions to other settings of care.
22
Objective 9: Secure Messaging
Does Secure Messaging need to be enabled for the entire reporting period? Rule verbiage, “EP Measure: For an EHR reporting period in 2015, the capability for patients to send and receive a secure electronic message with the EP was fully enabled during the EHR reporting period.”
• Answer: At some point during the reporting period
If a Stage 2 EP in 2015 performs encounters at multiple locations equipped with CEHRT, will the EP need to have secure electronic messaging enabled at all such locations during their EHR reporting period, or may the EP pass the objective if more than 50% of patient encounters occur at locations with secure electronic messaging enabled during the entire reporting period?
• Answer: It must be enabled at all locations.
23
Additional information
• Preceding responses were excerpted from a
presentation given by Elisabeth Meyers on
November 19, 2015
• Link to the audio/slide deck from the Nov. 19,
2015 meeting:
https://attendee.gotowebinar.com/recording/698
2129004985989633
24
25
Modified Stage 2: MeT Q and A Summary: AIU and Program Switch Timelines
Is 2016 the last year for eligible providers to start participating in the EHR program or, can they start after this date but will not receive the full incentive money because they will not be participating for the full 6 years? Also, can you tell me the date in which providers can no longer switch between the Medicare and Medicaid program.
• Answer: 2016 is the last year providers can start the program (AIU or 1st year MU). They cannot attest for their first year after 2016. The deadline to switch programs was program year 2014; so the end date to switch programs was Jan 1, 2015 (actually, the 2014 tail periods)
26
Modified Stage 2: MeT Q and A Summary: Security Risk Analysis
Can a provider conduct the SRA during the tail period? Example: For a Program Year 2015 application, could a provider conduct the SRA in January of 2016 and then attest for Program Year 2015 in February of 2016?
• Yes, if January is considered a part of the states tail period, the SRA could be conducted in January 2016 and count towards the 2015 program year attestation, but it is important to note that since that SRA was used for a 2015 attestation, that the same SRA could not be used in 2016 as well even though it was conducted in the program year.
27
Modified Stage 2: MeT Q and A Summary: CQM Reporting Periods
Can an EP use two different 90 day periods for their EHR reporting period and their CQM reporting period?
• Yes, CMS finalized the rule to include a limited exception for EPs demonstrating meaningful use for the first time under the Medicaid EHR Incentive Program. For these EPs, the reporting period for CQMs would be any continuous 90-day period within the CY, with the modification that it could be a different 90-day period than their EHR reporting period for the incentive payment under Medicaid.
28
Modified Stage 2:
Open Discussion
Elisabeth Myers Policy Lead, EHR Incentive Program,
Centers for Clinical Standards &
Quality, CMS
29
2015 – 2017 Modified Stage 2: Resources
Matt McGeorge
Medicaid EHR Team
CMS Help Desks
EHR Information Center Help Desk
– (888) 734-6433 / TTY: (888) 734-6563
– Hours of operation: Monday-Friday 8:30 a.m. – 4:30 p.m. in all time zones (except on Federal holidays)
NPPES Help Desk
– Visit https://nppes.cms.hhs.gov/NPPES/Welcome.do
– (800) 465-3203 / TTY (800) 692-2326
PECOS Help Desk
– Visit https://pecos.cms.hhs.gov/
– (866)484-8049 / TTY (866)523-4759
Identification & Access Management System (I&A) Help Desk
– PECOS External User Services (EUS) Help Desk Phone: 1-866-484-8049
– TTY 1-866-523-4759
– E-mail: [email protected]
30
Other CMS Resources
• Additional information available on the new 2015
Program Requirements page:
https://www.cms.gov/Regulations-and-
Guidance/Legislation/EHRIncentivePrograms/2015Progr
amRequirements.html
• CMS FAQs on the EHR Incentive Programs:
https://questions.cms.gov/faq.php?id=5005&rtopic=1979
31
MeT Resources
• 2015 – 2017 Meaningful Use Training Module: http://www.medicaidhitechta.org/LinkClick.aspx?fileticket=4p5gEmPIlqo%3d&portalid=0
• 2015 – 2017 Modifications Checklists and Quick
Reference Guides: http://www.medicaidhitechta.org/Home.aspx
• 2015 – 2017 Reporting Period Tool http://www.medicaidhitechta.org/LinkClick.aspx?fileticket=_YaxTVIOScI%3d&portalid=0
32
Next MU CoP
April 7, 2016 at 2:00 p.m.
MU CoP is usually the first Thursday every
other month at 2:00 p.m. EST
If you have suggestions for MU CoP sessions please send those to:
33
34
David Koppel: [email protected]
CMS, Health Information Technology for Economic and Clinical Health
(HITECH) Coordinator
Phone:(214) 767-4403
Izanne Leonard-Haak: [email protected]
MeT, Team Member
Health Management Associates
Matt McGeorge [email protected]
MeT, Team Member
Health Management Associates
![SummaryMap ward2 [Converted] · 2019-10-01 · MU-2 MU-6 MU-16 MU-14 MU-6 MU-2 MU-20 MU-9 MU-4 MU-13 MU-15 MU-13 MU-16 MU-18 MU-22 MU-19 MU-16 MU-27 MU-4 MU-3A MU-17 MU-13 MU-4 ...](https://static.fdocuments.in/doc/165x107/5f5e4f591750d150e9633369/summarymap-ward2-converted-2019-10-01-mu-2-mu-6-mu-16-mu-14-mu-6-mu-2-mu-20.jpg)
