Meaningful Use and PQRS How to help your practices avoid penalties April 25 th,2015 Washington D.C. Mark Norris Medical Records Services, LLC

Meaningful Use in 2015 a moving target, with more changes coming …. “A deal with the devil”  No longer about the Incentive Dollars  Late adopters no longer eligible for Medicare Incentives if did not start in 2014  Still face penalties  New Providers jump in at MU 1 – steeper learning and compliance curve with ongoing changes  Medicaid incentives still available if they start this year  AIU ($21,250) plus 5 years of MU ($8,500)  Must meet eligibility requirements – 30% threshold  Penalties are here for non compliance – could represent tens of thousands of $$ for providers with high Medicare population (traditional Red White and Blue)  2 Year ‘s out at a time Non compliance in 2015 = penalties in 2017  New Proposed rule could change it all again  In 60 day comment period, final rule will be out late summer  If they wait, pushes attestation into 4 th Q with ICD 10

If they started in 2014 They are in year 2 of MU1 in 2015  Eligible professionals must meet:  2014 Rules  13 required core objectives ( 2 eliminated)  5 menu objectives from a list of 9 (1 eliminated)  Must report data on 5 with no exclusions or 4 plus 5 exclusions  Total of 18 objectives  No Flexibility Rule  Electronic Access Changed – must have Patient Portal  CQM’s have changed  12 months reporting

MU1 in 2015

Specific Changes for Stage 1  Patient Electronic Access  Change: Addition of new core objective to provide patients with ability to view online, download, and transmit health information for all providers  Timing/Compliance: Added for 2014 and beyond  New EP Objective:  Provide patients the ability to view online, download and transmit their health information within 4 business days of the information being available to the eligible professional.

Record and Chart Changes in Vital Signs  Change: Increase in age limit for recording blood pressure in patients to age 3; removal of age limit requirement for height and weight  Timing/Compliance: Required in 2014 and beyond  Affected Providers: Eligible professionals, eligible hospitals, and CAHs What It Means: In 2014, all providers must report using the new age limits below  New Measure: More than 50 percent of all unique patients seen by the eligible professional or admitted to the eligible hospital’s or CAH’s inpatient or emergency department (POS 21 or 23) during the EHR reporting period have blood pressure (for patients age 3 and over only) and height and weight (for all ages) recorded as structured data.

Record and Chart Changes in Vital Signs  Exclusion for eligible professionals:  if they see no patients 3 years or older; if  all three vital signs are not relevant to their scope of practice; if height and weight are not  relevant to their scope of practice; or if blood pressure is not relevant to their scope of practice  Timing/Compliance: Replaces prior exclusion criteria starting in 2014  Affected Providers: Eligible professionals  What It Means: Previously, eligible professionals could only exclude this objective if all three vital signs were not relevant to their scope of practice or if they saw no patients 3 years or older. Beginning in 2014, eligible professionals can be excluded from recording blood pressure if blood pressure is not relevant to their scope of practice, or from recording height and weight if both height and weight are not relevant to their scope of practice

Vitals Exclusions  Exclusion: Eligible professionals who:  See no patients 3 years or older are excluded from recording blood pressure;  Believe that all three vital signs of height, weight, and blood pressure have no relevance to their scope of practice are excluded from recording them;  Believe that height and weight are relevant to their scope of practice, but blood pressure is not, are excluded from recording blood pressure; or  Believe that blood pressure is relevant to their scope of practice, but height and weight are not, are excluded from recording height and weight

2014 Clinical Quality Measures  Eligible professionals who demonstrate 2014 clinical quality measures (CQMs) will need to report 9 measures, and eligible hospitals will need to report 16. CQMs may be reported electronically, or via attestation. View the 2014 CQM Electronic Reporting Guides for Eligible Professionals and Eligible Hospitals to learn more about 2014 CQMs and the reporting process.Eligible ProfessionalsEligible Hospitals  National Quality Strategy Domains There is also a new requirement in 2014 that the quality measures selected must cover at least 3 of the 6 available National Quality Strategy (NQS) domains, which represent the Department of Health and Human Services’ NQS priorities for health care quality improvement.  The 6 NQS domains are: 1. Patient and Family Engagement 2. Patient Safety 3. Care Coordination 4. Population/Public Health 5. Efficient Use of Healthcare Resources 6. Clinical Process/Effectiveness

Recommended Core Set of CQM’s  For 2014, CMS is not requiring the submission of a core set of electronic CQMs (eCQMs). Instead, CMS has identified two recommended core sets of eCQMs—one for adults and one for children—that focus on high-priority health conditions and best-practices for care delivery.  9 eCQMs for adult populations that meet all of the program requirements  9 eCQMs for pediatric populations that meet all of the program requirements

EHR Reporting Options for CQM’s for Eligible Professionals in 2014 Include:  Options that only apply for the EHR Incentive Program  Option 1: Attest to CQMs through the EHR Registration & Attestation System  Option 2: eReport CQMs through Physician Quality Reporting System (PQRS) Portal  Options that Align with Other Quality Programs  Option 3: Report individual eligible professionals’ CQMs through PQRS Portal  Option 4: Report group’s CQMs through PQRS Portal  Option 5: Report group’s CQMs through Pioneer ACO participation or Comprehensive Primary Care Initiative participation

Please note: The Stage 2 rule for the EHR Incentive Programs changed several Stage 1 meaningful use objectives, measures, and exclusions for eligible professionals for the 2013 reporting cycle. These changes took effect on January 1, 2013 for eligible professionals, with additional changes taking effect January 1, 2014.

MU2 in 2015 Where we are today…this may change

Many of the objectives in Stage 2 will be familiar to you from Stage 1. Some objectives that were in the menu set in Stage 1 have been moved to the core set for Stage 2 and are now required for all providers. Some objectives that were in the core set in Stage 1 now have higher thresholds that you must achieve in order to successfully demonstrate meaningful use of your EHR in Stage 2. There are also some new Stage 2 core and menu objectives

Went from 30% to 60% for Meds, added Labs and Rads

Went from 40 to 50%, added Formulary and conflict check underneath

Went from 50 to 80%

Went from 50-80%

Went from 50 to 80%

Went from 1 to 5, tied to CQM’s, relevant to point of care, on for entire reporting period

SM1 10 to 50%, SM2 added 10% download

Same threshold, 3 days went to 24 hours

40% went to 55%, moved from Menu to Core

Moved from Menu to Core Quality improvement, reduction of disparities, research, or outreach

Moved from Menu to Core, 20% to 10%, unique patients who have had an office visit with the EP within the 24 months prior to the beginning of the EHR reporting period were sent a reminder, per patient preference

Moved from Menu to Core, Same Threshold

Moved from Menu to Core

Moved from Menu to Core, added sub measures

Moved from Menu to Core

New measure for MU2

Must complete 3 of 6

Population health, depends on State readiness, waiting list

New measure, needs to be discreet data

Difficult for most practices, interoperability issues, image viewer

New measure – easy to achieve once oriented

CMS Proposes New Rule (4/15/15)

Understanding the 2015 Medicare Payment Adjustments

Payment Adjustments In the American Recovery and Reinvestment Act of 2009 (ARRA), Congress mandated that payment adjustments should be applied to Medicare eligible professionals, eligible hospitals, and critical access hospitals (CAHs)that are not meaningful users of Certified Electronic Health Record (EHR) Technology under the Medicare EHR Incentive Program.eligible professionalseligible hospitalscritical access hospitals(CAHs) If a provider is eligible to participate in the Medicare EHR Incentive Program, they must demonstrate meaningful use in either the Medicare EHR Incentive Program or in the Medicaid EHR Incentive Program, to avoid a payment adjustment. Medicaid providers who are only eligible to participate in the Medicaid EHR Incentive Program are not subject to these payment adjustments.Medicare EHR Incentive Program Medicaid EHR Incentive Program Medicare hospitals began to receive payment adjustments on October 1, 2014, and Medicare eligible professionals will begin to receive payment adjustments on January 1, 2015.

Hardship Exceptions to Avoid Medicare Payment Adjustments Eligible professionals and eligible hospitals may be exempt from payment adjustments if they can show that demonstrating meaningful use would result in a significant hardship. To be considered for an exception, an eligible professional or eligible hospital must complete a Hardship Exception application along with proof of the hardship. If approved, the hardship exception is valid for 1 payment year only. A new application must be submitted if the hardship continues for the following payment year. In no case may a provider be granted an exception for more than 5 years.eligible professionaleligible hospital Eligible professionals can use the Hardship Exception Tool to determine if they will avoid the upcoming 2015 and 2016 Medicare EHR Incentive Program payment adjustments by demonstrating meaningful use, or if they should apply for a hardship exception.Hardship Exception Tool The EP submission deadline for a 2016 Medicare EHR Incentive Program hardship exception is 11:59 PM EDT July 1, 2015.

Avoiding 2016 PQRS Payment Adjustments

Programs that affect Payment Adjustments

Q and A Thanks for your attention. Please contact me if you have any questions Mark Norris Medical Records Services, LLC Office Cell