1. Meaningful Use Monitoring Methodology © 1 Meaningful Use Monitor (MUM) Initial Gap Assessment (IGA) Phase Kit 4/6/2010 Meaningful Use Monitor Indiana Radiology Business Management Association Medical Staff Education November, 2010

2. Meaningful Use Monitoring Methodology © 2 Who Am I? Jay R. Fisher Education as a CPA – Undergraduate: University of Wisconsin – Psychology – Masters Program: Georgia State University - Accountancy 13 Years at Major Consultancies – Arthur Andersen – Deloitte & Touche 10 Years Boutique Consulting – $5 mm annual sales – IT Executive and project consulting, predominantly health care A couple years working for someone else’s consulting firm – Lesson: Strategy (verbalized or not) starts at the top and does not change C3 Partners Meaningful Use Monitor – Lesson: a few committed people with a vision can create organizational and market excitement I think and hope that consulting success has small parts of ideas, brains, secret sauce … all overbalanced by your network, your reputation and your sincere desire to make things better for your clients.

3. Meaningful Use Monitoring Methodology © 3 What have I done that is relevant? General Health Care: Program Manager over IT for an all-digital hospital, built from scratch EHR Implementation PMO for very large health system Two years experience with physician practice management systems Various cost reporting, certificate of need, and SSO project work Core team member in the creation of a Network Model HMO Core team member in the creation of a hospital-based HMO Multiple EHR selection projects for ambulatory groups Meaningful Use: Created a company, and a product to minimize the administrative overhead associated with getting to Meaningful Use Our toolset currently in place for 20 hospitals and around 700 physicians Call center for Meaningful Use Hot Line starting December 1

4. Meaningful Use Monitoring Methodology © 4 Today’s Discussion Topics ARRA HITECH Foundation ARRA HITECH Foundation ARRA HITECH Foundation ARRA HITECH Foundation Step 1: Step 1: Eligible Professional Eligible Professional Step 1: Step 1: Eligible Professional Eligible Professional Step 2: Step 2: Eligible IT Eligible IT Step 2: Step 2: Eligible IT Eligible IT Step 3: Step 3: Eligible Processes Eligible Processes Step 3: Step 3: Eligible Processes Eligible Processes Step 4: Step 4: Program Monitoring Program Monitoring Step 4: Step 4: Program Monitoring Program Monitoring Step 5: Step 5: Strategies Step 5: Step 5: Strategies Step 6: Step 6: Getting Help Getting Help Step 6: Step 6: Getting Help Getting Help Meaningful Use of Certified EHR What it is, does it effect me, and what can I do about it? In “presentation mode”, click the steps to navigate

5. Meaningful Use Monitoring Methodology © 5 Law, Regulations and Grounding ARRA HITECH Foundation ARRA HITECH Foundation ARRA HITECH Foundation ARRA HITECH Foundation Step 1: Step 1: Eligible Professional Eligible Professional Step 1: Step 1: Eligible Professional Eligible Professional Step 2: Step 2: Eligible IT Eligible IT Step 2: Step 2: Eligible IT Eligible IT Step 3: Step 3: Eligible Processes Eligible Processes Step 3: Step 3: Eligible Processes Eligible Processes Step 4: Step 4: Program Monitoring Program Monitoring Step 4: Step 4: Program Monitoring Program Monitoring Step 5: Step 5: Strategies Step 5: Step 5: Strategies Step 6: Step 6: Getting Help Getting Help Step 6: Step 6: Getting Help Getting Help In “presentation mode”, click the steps to navigate

6. Meaningful Use Monitoring Methodology © 6 ARRA HITECH Foundation Regulatory Content The Language of HITECH  EP = Eligible Professional (you folks) Unique requirements Unique eligibility Unique payment and penalty Time tables  Eligible Hospital and CAH  Certification = something an EHR vendor must do to their software  Meaningful Use = something you must do with Certified Software

7. Meaningful Use Monitoring Methodology © 7 ARRA Foundation Scope and Discussion Threads for Today How are Radiologists impacted in their practices? – Within Imaging Centers – On Hospital Premises – As a contracted Employee How are Radiologists impacted in the context of inpatient work? – Hospitals are impacted too, and much of the change falls on the shoulders of clinicians practicing there whether those clinicians are financially involved or not – Hospitals may expect you to do new tasks, or to do some current tasks differently

8. Meaningful Use Monitoring Methodology © 8 ARRA HITECH Foundation Regulatory Content CMS issued MU Final Ruling on 07/28/10 –Defines activities clinicians must follow, and data clinicians must populate into Certified EHR for Provider to qualify for funding –Hospital must meet 19 of 24 Meaningful Use Requirements, and populate the data for 15 Quality Measures into a Certified EHR –EP’s must meet 15 of 25 Meaningful Use Requirements, and populate the data for 6 of 41 Quality Measures CMS in the early stages of Certifying EHR Software –Providers can move forward with Usage within existing EHR in anticipation of Certification, with some caveats –Certification is generally in the hands of the EHR vendors, but providers can choose to “self-certify” EHR modules

9. Meaningful Use Monitoring Methodology © 9 Interesting, but not directly relevant to us: –Beacon Communities –Regional Extension Centers –State Health Information Exchanges –IT Educational support –Strategic Health Advanced IT Research Projects (SHARP) Directly Relevant to US: –Meaningful Use of the EHR (Electronic Health Record Incentive Program) ARRA-HITECH Foundation What does the law cover?

10. Meaningful Use Monitoring Methodology © 10 ARRA-HITECH Foundation Timelines for achieving Meaningful Use January 2011 Registration for the EHR Incentive Programs begins April 2011Attestation for the Medicare EHR Incentive Program begins May 2011EHR incentive payments begin November 30, 2011 Last day for eligible hospitals and CAHs to register and attest to receive an incentive payment for FFY 2011 February 29, 2012 Last day for EPs to register and attest to receive an incentive payment for CY 2011 2015Medicare payment adjustments begin for EPs and eligible hospitals that are not meaningful users of EHR technology 2016Last year to receive a Medicare EHR incentive payment; Last year to initiate participation in Medicaid EHR Incentive Program 2021Last year to receive Medicaid EHR incentive payment

11. Meaningful Use Monitoring Methodology © 11 ARRA-HITECH Foundation How much is at stake for your practice?

12. Meaningful Use Monitoring Methodology © 12 ARRA-HITECH Foundation What Penalties Apply? Hospital Penalty – Portion of Market Basket Reduced to Zero 2015 - 33.3% of three-quarters 2016 - 66.7% of three-quarters 2017+ - 100% of three-quarters Physician Penalty 2015 - 1% of Medicare fee schedule 2016 - 2% of Medicare fee schedule 2017+ - 3% of Medicare fee schedule Observations Penalties begin against Medicare Stimulus Payments regardless of EP’s choice to participate in Medicaid, or to “join” the Reimbursement program 2016 is the first Penalty Year – and no Medicare Stimulus Payments will be made in 2016 or later Requirements to qualify become more rigorous over time CMS / DHS budget constraints, and Final Rules explicitly cite Audit Process (currently in development) If CMS finds that adoption levels are less than 75% of EP’s by 2018, penalties can increase another 1% per year, up to maximum of 5%

13. Meaningful Use Monitoring Methodology © 13 Summary Point It is not just about eligibility If you fall within the rules: – Over 5 or 6 years you will be eligible to receive $44k or $63k in Stimulus funding – After 2015, if you are not considered a Meaningful User, you will start to lose Medicare Reimbursement – Your practice will be listed on a CMS website as a Meaningful User, if you qualify. Some organizations will use this to competitive advantage (or disadvantage!) Alt

14. Meaningful Use Monitoring Methodology © 14 What rules define who must participate? ARRA HITECH Foundation ARRA HITECH Foundation ARRA HITECH Foundation ARRA HITECH Foundation Step 1: Step 1: Eligible Professional Eligible Professional Step 1: Step 1: Eligible Professional Eligible Professional Step 2: Step 2: Eligible IT Eligible IT Step 2: Step 2: Eligible IT Eligible IT Step 3: Step 3: Eligible Processes Eligible Processes Step 3: Step 3: Eligible Processes Eligible Processes Step 4: Step 4: Program Monitoring Program Monitoring Step 4: Step 4: Program Monitoring Program Monitoring Step 5: Step 5: Strategies Step 5: Step 5: Strategies Step 6: Step 6: Getting Help Getting Help Step 6: Step 6: Getting Help Getting Help In “presentation mode”, click the steps to navigate

15. Meaningful Use Monitoring Methodology © 15 Step 1: Eligible Professional Provider TypeHospitals As a practical matter, you should assume all hospitals will be eligible Your interaction with a hospital’s MU program will be limited to a few specific requirementsHospitals As a practical matter, you should assume all hospitals will be eligible Your interaction with a hospital’s MU program will be limited to a few specific requirements EP - Medicare Starting point is “physician”, or: Doctor of Medicine or Osteopathy, Doctor of Dental Surgery or Dental Medicine Doctor of Podiatric Medicine Doctor of Optometry Chiropractor Hospital Based Providers not Eligible (we’ll come back to this later) EP - Medicare Starting point is “physician”, or: Doctor of Medicine or Osteopathy, Doctor of Dental Surgery or Dental Medicine Doctor of Podiatric Medicine Doctor of Optometry Chiropractor Hospital Based Providers not Eligible (we’ll come back to this later) EP – Medicaid Physicians, dentists, certified nurse-midwives, nurse practitioners, and physician assistants practicing in an FQHC or RHC that is so led by a physician assistant. Hospital Based restrictions same as Medicare, except Medicaid EPs practicing predominantly in an FQHC or RHC are not subject to the hospital- based exclusion EP – Medicaid Physicians, dentists, certified nurse-midwives, nurse practitioners, and physician assistants practicing in an FQHC or RHC that is so led by a physician assistant. Hospital Based restrictions same as Medicare, except Medicaid EPs practicing predominantly in an FQHC or RHC are not subject to the hospital- based exclusion

16. Meaningful Use Monitoring Methodology © 16 Step 1: Eligible Professional Place of Service Hospital-Based Providers Not eligible to receive payments 90% of work done in hospital environment = hospital-based Hospital based determined by POS codes on HCFA 1500’s – 21—Inpatient Hospital – 23 – Emergency Room CMS will pre-determine Hospital-based status from prior year claims experience Radiology billing based on where the interpretation is done Hospital-Based Providers Not eligible to receive payments 90% of work done in hospital environment = hospital-based Hospital based determined by POS codes on HCFA 1500’s – 21—Inpatient Hospital – 23 – Emergency Room CMS will pre-determine Hospital-based status from prior year claims experience Radiology billing based on where the interpretation is done The appropriate POS code is the place where the service takes place. If the interpretation is performed in the hospital setting, the POS code is hospital outpatient (22). If the interpretation is performed at a location other than the location of the physician’s office and the location meets the definition of office, the POS code is office (11). If the physician performs the interpretation from home, the POS code is either office (11) if it meets the definition of office or other (99).

17. Meaningful Use Monitoring Methodology © 17 What rules define if my environment qualifies? ARRA HITECH Foundation ARRA HITECH Foundation ARRA HITECH Foundation ARRA HITECH Foundation Step 1: Step 1: Eligible Professional Eligible Professional Step 1: Step 1: Eligible Professional Eligible Professional Step 2: Step 2: Eligible IT Eligible IT Step 2: Step 2: Eligible IT Eligible IT Step 3: Step 3: Eligible Processes Eligible Processes Step 3: Step 3: Eligible Processes Eligible Processes Step 4: Step 4: Program Monitoring Program Monitoring Step 4: Step 4: Program Monitoring Program Monitoring Step 5: Step 5: Strategies Step 5: Step 5: Strategies Step 6: Step 6: Getting Help Getting Help Step 6: Step 6: Getting Help Getting Help In “presentation mode”, click the steps to navigate

18. Meaningful Use Monitoring Methodology © 18 Step 2: Eligible IT How do I know if my EHR is Certified?

19. Meaningful Use Monitoring Methodology © 19 Step 2: Eligible IT How do I know if my EHR is Certified? What does it mean to have a Certified EHR?

20. Meaningful Use Monitoring Methodology © 20 What must I do with my IT to qualify? ARRA HITECH Foundation ARRA HITECH Foundation ARRA HITECH Foundation ARRA HITECH Foundation Step 1: Step 1: Eligible Professional Eligible Professional Step 1: Step 1: Eligible Professional Eligible Professional Step 2: Step 2: Eligible IT Eligible IT Step 2: Step 2: Eligible IT Eligible IT Step 3: Step 3: Eligible Processes Eligible Processes Step 3: Step 3: Eligible Processes Eligible Processes Step 4: Step 4: Program Monitoring Program Monitoring Step 4: Step 4: Program Monitoring Program Monitoring Step 5: Step 5: Strategies Step 5: Step 5: Strategies Step 6: Step 6: Getting Help Getting Help Step 6: Step 6: Getting Help Getting Help In “presentation mode”, click the steps to navigate

21. Meaningful Use Monitoring Methodology © 21 Step 3: Eligible Processes Our Vendor’s Role and Our Role alt

22. Meaningful Use Monitoring Methodology © 22 MUHospitalEligible Provider Core Meaningful Use – must meet all core requirements 1415 Menu Meaningful Use – select from list of 10 55 Core - Quality measures – must meet all core requirements 153 Alternate Core – quality measures used only if EP has no patients for Core n/a3 Menu – quality measures – select from list of 38 n/a3 Step 3: Eligible Processes Requirements Overview

23. Meaningful Use Monitoring Methodology © 23 Step 3: Eligible Processes Why such a high degree of diligence? We must hit: – every single metric, – for every single requirement, – in every single department – by every single clinician When was the last time any organization made zero mistakes? Prudent management suggests powerful control mechanisms » CMS audits are likely at some point; failure to prove that you actually did what you said is Medicare fraud No room for these..

24. Meaningful Use Monitoring Methodology © 24 Step 3: Eligible Processes Pragmatic Considerations – All or Each?Hospitals Each objective must be met across all clinicians in the hospital As a result, hospitals are likely to engage in significant measurement and education activities, to which you may be asked to be a partyHospitals Each objective must be met across all clinicians in the hospital As a result, hospitals are likely to engage in significant measurement and education activities, to which you may be asked to be a party EP Rules Each EP qualifies individually No relationships between EP’s ability to qualify Each EP has individual penalties, too EP Rules Each EP qualifies individually No relationships between EP’s ability to qualify Each EP has individual penalties, too Qualifying in your practice has no impact on whether / how your hospital clients will qualify (and vice-versa)

25. Meaningful Use Monitoring Methodology © 25 Step 3: Eligible Processes Pragmatic Considerations - Objectives not relevant to my practice After consideration of the public comments received, we have identified, for each meaningful use objective, whether the EP, eligible hospital, or CAH may attest that they did not have any patients or insufficient actions on which to base a measurement of a meaningful use for the EHR reporting period. For objectives in the core set, such an attestation would remove the objective from consideration when determining whether an EP, eligible hospital, or CAH is a meaningful EHR user. In other words, the EP, eligible hospital, or CAH could satisfy the core set objectives by satisfying all remaining objectives included in the core set. For objectives in the menu set, such an attestation would also remove the objective from consideration when determining whether an EP, eligible hospital, or CAH is a meaningful EHR user. For example, if for one objective included in the menu set an EP attests that he or she did not have any patients or insufficient actions during the EHR reporting period on which to base a measurement of a meaningful use objective, rather than satisfy 5 of the 10 meaningful use objectives included in the menu set for EPs, the EP need only satisfy 4 of the 9 remaining meaningful use objectives included in the menu set for EP’s. CMS-0033-F Page 61 After consideration of the public comments received, we have identified, for each meaningful use objective, whether the EP, eligible hospital, or CAH may attest that they did not have any patients or insufficient actions on which to base a measurement of a meaningful use for the EHR reporting period. For objectives in the core set, such an attestation would remove the objective from consideration when determining whether an EP, eligible hospital, or CAH is a meaningful EHR user. In other words, the EP, eligible hospital, or CAH could satisfy the core set objectives by satisfying all remaining objectives included in the core set. For objectives in the menu set, such an attestation would also remove the objective from consideration when determining whether an EP, eligible hospital, or CAH is a meaningful EHR user. For example, if for one objective included in the menu set an EP attests that he or she did not have any patients or insufficient actions during the EHR reporting period on which to base a measurement of a meaningful use objective, rather than satisfy 5 of the 10 meaningful use objectives included in the menu set for EPs, the EP need only satisfy 4 of the 9 remaining meaningful use objectives included in the menu set for EP’s. CMS-0033-F Page 61 Bottom Line: You need not comply with objectives corresponding to circumstances that don’t exist in your practice. In reporting to CMS, you must attest that the measure is irrelevant to your practice, and why

26. Meaningful Use Monitoring Methodology © 26 1.Computerized physician order entry (CPOE) 2.E-Prescribing (eRx) 3.Report ambulatory clinical quality measures to CMS/States 4.Implement one clinical decision support rule 5.Provide patients with an electronic copy of their health information, upon request 6.Provide clinical summaries for patients for each office visit 7.Drug-drug and drug-allergy interaction checks 8.Record demographics 9.Maintain an up-to-date problem list of current and active diagnoses 10.Maintain active medication list 11.Maintain active medication allergy list 12.Record and chart changes in vital signs 13.Record smoking status for patients 13 years or older 14.Capability to exchange key clinical information among providers of care and patient-authorized entities electronically 15.Protect electronic health information Step 3: Eligible Processes EP Core Objectives Candidates to consider as exclusions for Radiologists Probable applicable to Radiologists

27. Meaningful Use Monitoring Methodology © 27 Step 3: Eligible Processes CPOE OBJECTIVE: Use CPOE for medication orders directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local and professional guidelines. METHOD OF MEASURE CALCULATION: Denominator is based on counting actions for patients whose records are maintained using certified EHR technology NUMERATOR: The number of patients in the denominator that have at least one medication order entered using CPOE. DENOMINATOR: Number of unique patients with at least one medication in their medication list seen by the EP or admitted to an eligible hospital’s or CAH’s inpatient or emergency department (POS 21 or 23) during the EHR reporting period. The only patients that are included in the denominator are those patients whose records are maintained using certified EHR technology. THRESHOLD: The resulting percentage must be more than 30 percent in order for eligible hospital or CAH to meet this measure. EXCLUSIONS: EP - If an EP’s writes fewer than one hundred prescriptions during the EHR reporting period they would be excluded from this requirement. Radiologist Action: Candidate for “no patients or Insufficient actions” Radiologist Action: Candidate for “no patients or Insufficient actions”

28. Meaningful Use Monitoring Methodology © 28 Step 3: Eligible Processes e-Prescribing OBJECTIVE: Generate and transmit permissible prescriptions electronically (eRx). ASSOCIATED MEASURE: More than 40% of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technology. METHOD OF MEASURE CALCULATION: Denominator is based on counting actions for patients whose records are maintained using certified EHR technology. NUMERATOR: The number of prescriptions in the denominator generated and transmitted electronically. DENOMINATOR: Number of prescriptions written for drugs requiring a prescription in order to be dispensed other than controlled substances during the EHR reporting period. THRESHOLD: The resulting percentage must be more than 40 percent in order for an EP to meet this measure. EXCLUSIONS: This objective and associated measure do not apply to any EP who writes fewer than one hundred prescriptions during the EHR reporting period. Radiologist Action: Candidate for “no patients or Insufficient actions” Radiologist Action: Candidate for “no patients or Insufficient actions”

29. Meaningful Use Monitoring Methodology © 29 Step 3: Eligible Processes Report Clinical Quality measures OBJECTIVE: Report hospital \ ambulatory clinical quality measures to CMS (or, for eligible hospitals seeking the Medicaid incentive payment, the States) ASSOCIATED MEASURE: For 2011, an EP or eligible hospital or CAH would provide the aggregate level data for the numerator, denominator, and exclusions through attestation as discussed in section II.A.3 of this final rule. For 2012, an EP or eligible hospital or CAH would electronically submit the measures as discussed in section II.A.3. of this final rule. METHOD OF MEASURE CALCULATION: Measure requires only a Yes/No attestation. THRESHOLD: Requires attestation to ability to report the 6 EP or 15 hospital quality measures EXCLUSIONS: None Note: This requirement decomposes into 6 unique quality reporting requirements, chosen from a field of 44 Radiologist Action: Review quality measures list, select those for which your practice is most likely to be able to populate data elements Radiologist Action: Review quality measures list, select those for which your practice is most likely to be able to populate data elements

30. Meaningful Use Monitoring Methodology © 30 Step 3: Eligible Processes Clinical Decision Support OBJECTIVE: Implement one clinical decision support rule related to a high priority hospital condition along with the ability to track compliance with that rule. ASSOCIATED MEASURE: Implement one clinical decision support rule. METHOD OF MEASURE CALCUALTION: Measure requires only a Yes/No attestation. THRESHOLD: Implement at least one clinical decision support rule EXCLUSIONS: None Radiologist Action: Identify one relevant clinical decision support rule, turn it on in your EHR, and Attest YES Radiologist Action: Identify one relevant clinical decision support rule, turn it on in your EHR, and Attest YES

31. Meaningful Use Monitoring Methodology © 31 Step 3: Eligible Processes Provide Electronic Information to Patients OBJECTIVE: Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, medication allergies, discharge summary, procedures), upon request. ASSOCIATED MEASURE: More than 50 percent of all patients of the EP or of the inpatient or emergency departments of the eligible hospital or CAH (POS 21 or 23) who request an electronic copy of their health information are provided it within 3 business days (Monday through Friday - excluding federal and state holidays where administrative staff is unavailable). METHOD OF MEASURE CALCULATION - Denominator is based on counting actions for patients whose records are maintained using certified EHR technology. NUMERATOR: The number of patients in the denominator who receive an electronic copy of their electronic health information within three business days. DENOMINATOR: The number of patients of the EP or eligible hospital’s or CAH’s inpatient or emergency departments (POS 21 or 23) who request an electronic copy of their electronic health information four business days prior to the end of the EHR reporting period. The only patients that are included in the denominator are those patients whose records are maintained using certified EHR technology. THRESHOLD: The resulting percentage must be more than 50 percent in order for an EP, eligible hospital, or CAH to meet this measure EXCLUSIONS: If the EP, eligible hospital, or CAH has no requests from patients or their agents for an electronic copy of patient health information during the EHR reporting period they would be excluded from this requirement. Radiologist Action: 1.Monitor patients who request electronic copies of their imaging and/or interpretations 2.Track the occurrences of when you provided this information electronically Radiologist Action: 1.Monitor patients who request electronic copies of their imaging and/or interpretations 2.Track the occurrences of when you provided this information electronically

32. Meaningful Use Monitoring Methodology © 32 Step 3: Eligible Processes Provide Clinical Summaries OBJECTIVE: Provide clinical summaries for patients for each office visit ASSOCIATED MEASURE: Clinical summaries provided to patients for more than 50 percent of all office visits within 3 business days. METHOD OF MEASURE CALCULATION: Denominator is based on counting actions for patients whose records are maintained using certified EHR technology. NUMERATOR: Number of patients in the denominator who are provided a clinical summary of their visit within three business days. DENOMINATOR: Number of unique patients seen by the EP for an office visit during the EHR reporting period. The only patients that are included in the denominator are those patients whose records are maintained using certified EHR technology. THRESHOLD: The resulting percentage must be more than 50 percent in order for an EP to meet this measure. EXCLUSIONS: EP's who have no office visits during the EHR reporting period would be excluded from this requirement. Radiologist Action: Candidate for “no patients or Insufficient actions” Radiologist Action: Candidate for “no patients or Insufficient actions”

33. Meaningful Use Monitoring Methodology © 33 Step 3: Eligible Processes Drug-Drug and Drug-Allergy OBJECTIVE: Implement drug-drug and drug-allergy checks. ASSOCIATED MEASURE: The EP has enabled this functionality for the entire EHR reporting period. METHOD OF MEASURE CALCULATION: Measure requires only a Yes/No Attestation. THRESHOLD: Not applicable EXCLUSIONS: None Radiologist Action: Turn on Functionality in EHR and Attest YES Radiologist Action: Turn on Functionality in EHR and Attest YES - OR - Radiologist Action: Candidate for “no patients or Insufficient actions” Radiologist Action: Candidate for “no patients or Insufficient actions”

34. Meaningful Use Monitoring Methodology © 34 Step 3: Eligible Processes Record Demographics OBJECTIVE: Record demographics o preferred language o gender o race o ethnicity o date of birth ASSOCIATED MEASURE: More than 50 percent of all unique patients seen by the EP have demographics recorded as structured data. METHOD OF MEASURE CALCULATION: Denominator is unique patients regardless of whether the patient's records are maintained using certified EHR technology. NUMERATOR: The number of patients in the denominator who have all the elements of demographics (or a specific exclusion if the patient declined to provide one or more elements or if recording an element is contrary to state law) recorded as structured data. DENOMINATOR: Number of unique patients seen by the EP during the EHR reporting period. THRESHOLD: The resulting percentage must be more than 50% in order for an EP to meet this measure. EXCLUSIONS: None Radiologist Action: Candidate for “no patients or Insufficient actions” Radiologist Action: Candidate for “no patients or Insufficient actions”

35. Meaningful Use Monitoring Methodology © 35 Step 3: Eligible Processes Problem Lists OBJECTIVE: Maintain an up-to-date problem list of current and active diagnoses. ASSOCIATED MEASURE: More than 80 percent of all unique patients admitted to the eligible hospital’s or CAH’s inpatient or emergency departments (POS 21 or 23) have at least one entry or an indication that no problems are known for the patient recorded as structured data. METHOD OF MEASURE CALCULATION - Denominator is unique patients regardless of whether the patient's records are maintained using certified EHR technology. NUMERATOR: The number of patients in the denominator who have at least one entry or an indication that no problems are known for the patient recorded as structured data in their problem list. DENOMINATOR: Number of unique patients admitted to an eligible hospital’s or CAH’s inpatient or emergency department (POS 21 or 23) during the EHR reporting period. (Total Number of Unique Patients - Regardless of Whether the Patient’s Records Are Maintained Using Certified EHR Technology). THRESHOLD: The resulting percentage must be more than 80 percent in order for an EP, eligible hospital, or CAH to meet this measure. EXCLUSIONS: None Radiologist Action: Capture as part of normal interpretations Radiologist Action: Capture as part of normal interpretations

36. Meaningful Use Monitoring Methodology © 36 Step 3: Eligible Processes Active Meds List OBJECTIVE: Maintain active medication list ASSOCIATED MEASURE: More than 80 percent of all unique patients seen by the EP or admitted to the eligible hospital’s or CAH’s inpatient or emergency departments (POS 21 or 23) have at least one entry (or an indication that the patient is not currently prescribed any medication) recorded as structured data. METHOD OF MEASURE CALCULATION - Denominator is unique patients regardless of whether the patient's records are maintained using certified EHR technology. NUMERATOR: The number of patients in the denominator who have a medication (or an indication that the patient is not currently prescribed any medication) recorded as structured data. DENOMINATOR: Number of unique patients admitted to an eligible hospital’s or CAH’s inpatient or emergency departments (POS 21 or 23) during the EHR reporting period. A definition of unique patient is discussed under the objective of CPOE. (Total Number of Unique Patients - Regardless of Whether the Patient’s Records Are Maintained Using Certified EHR Technology). THRESHOLD: The resulting percentage must be more than 80 percent in order for an EP, eligible hospital, or CAH to meet this measure. EXCLUSIONS: None Additional Note in Regulations: We are only concerned with medications that are known to the provider through querying the patient, their own records and the transfer of records from other providers. Meaningful use cannot address situations where the information is withheld from the EP, eligible hospital, or CAH by the patient or by other providers. Radiologist Action: Candidate for “no patients or Insufficient actions” Radiologist Action: Candidate for “no patients or Insufficient actions”

37. Meaningful Use Monitoring Methodology © 37 Step 3: Eligible Processes Active Med Allergies OBJECTIVE: Maintain active medication allergy list ASSOCIATED MEASURE: More than 80 percent of all unique patients admitted seen by the EP or admitted to the eligible hospital’s or CAH’s inpatient or emergency departments (POS 21 or 23) have at least one entry (or an indication that the patient has no known medication allergies) recorded as structured data. METHOD OF MEASURE CALCULATION - Denominator is unique patients regardless of whether the patient's records are maintained using certified EHR technology. NUMERATOR: The number of unique patients in the denominator who have at least one entry (or an indication that the patient has no known medication allergies) recorded as structured data in their medication allergy list. DENOMINATOR: Number of unique patients admitted to an eligible hospital’s or CAH’s inpatient or emergency departments (POS 21 or 23) during the EHR reporting period. The definition of “a unique patient” is provided under the objective of CPOE. (Total Number of Unique Patients - Regardless of Whether the Patient’s Records Are Maintained Using Certified EHR Technology). THRESHOLD: The resulting percentage must be more than 80 percent in order for an EP, eligible hospital, or CAH to meet this measure. EXCLUSIONS: None Radiologist Action: Candidate for “no patients or Insufficient actions” Radiologist Action: Candidate for “no patients or Insufficient actions”

38. Meaningful Use Monitoring Methodology © 38 Step 3: Eligible Processes Record and chart changes in vital signs OBJECTIVE: Record and chart changes in vital signs: o height o weight o blood pressure o Calculate and display: BMI o Plot and display growth charts for children 2-20 years, including BMI. ASSOCIATED MEASURE: For more than 50 percent of all unique patients age 2 and over admitted to eligible hospital’s or CAH’s inpatient or emergency department (POS 21 or 23), height, weight and blood pressure are recorded as structured data. METHOD OF MEASURE CALCULATION - Denominator is based on counting actions for patients whose records are maintained using certified EHR technology NUMERATOR: The number of patients in the denominator who have at least one entry of their height, weight and blood pressure are recorded as structure data. DENOMINATOR: Number of unique patients age 2 or over admitted to an eligible hospital’s or CAH’s inpatient or emergency department (POS 21 or 23) during the EHR reporting period. A unique patient is discussed under the objective of CPOE. The only patients that are included in the denominator are those patients whose records are maintained using certified EHR technology. THRESHOLD: The resulting percentage must be more than 50 percent in order for an EP, eligible hospital, or CAH to meet this measure. EXCLUSIONS: None Radiologist Action: Candidate for “no patients or Insufficient actions” Radiologist Action: Candidate for “no patients or Insufficient actions”

39. Meaningful Use Monitoring Methodology © 39 Step 3: Eligible Processes Smoking Status OBJECTIVE: Record smoking status for patients 13 years old or older ASSOCIATED MEASURE: More than 50 percent of all unique patients 13 years old or older admitted to the eligible hospital’s or CAH’s inpatient or emergency departments (POS 21 or 23) have smoking status recorded as structured data. METHOD OF MEASURE CALCULATION: Denominator is based on counting actions for patients whose records are maintained using certified EHR technology NUMERATOR: The number of patients in the denominator with smoking status recorded as structured data. DENOMINATOR: Number of unique patients age 13 or older admitted to an eligible hospital’s or CAH’s inpatient or emergency departments (POS 21 or 23) during the EHR reporting period. A unique patient is discussed under the objective of maintaining an up-to- date problem list. THRESHOLD: Threshold: The resulting percentage must be more than 50 percent in order for an EP, eligible hospital, or CAH to meet this measure. EXCLUSIONS: None Radiologist Action: Candidate for “no patients or Insufficient actions” Radiologist Action: Candidate for “no patients or Insufficient actions”

40. Meaningful Use Monitoring Methodology © 40 Step 3: Eligible Processes Exchange Key Clinical Information OBJECTIVE: Capability to exchange key clinical information (for example, discharge summary, procedures, problem list, medication list, medication allergies, diagnostic test results), among providers of care and patient authorized entities electronically. ASSOCIATED MEASURE: Performed at least one test of certified EHR technology's capacity to electronically exchange key clinical information. Measure requires only a Yes/No Attestation. METHOD OF MEASURE CALCULATION: Measure requires only a Yes/No attestation. THRESHOLD: To be considered an ‘‘exchange’’ for this objective and measure the clinical information must be sent between different legal entities with distinct certified EHR technology or other system that can accept the information EXCLUSIONS: None Radiologist Action: Develop EHR integration with one or more referring physicians, or one hospital Radiologist Action: Develop EHR integration with one or more referring physicians, or one hospital

41. Meaningful Use Monitoring Methodology © 41 Step 3: Eligible Processes Protect Electronic Health Information OBJECTIVE: Protect electronic health information created or maintained by the certified EHR technology through the implementation of appropriate technical capabilities ASSOCIATED MEASURE: Conduct or review a security risk analysis per 45 CFR 164.308(a)(1) of the certified EHR technology, and implement security updates and correct identified security deficiencies as part of its risk management process. METHOD OF MEASURE CALCULATION: Measure requires only a Yes/No attestation THRESHOLD: Conduct one security risk assessment. EXCLUSIONS: None Radiologist Action: Conduct HIPAA Security Assessment, and monitor your progress on any shortcomings Radiologist Action: Conduct HIPAA Security Assessment, and monitor your progress on any shortcomings

42. Meaningful Use Monitoring Methodology © 42 Step 3: Eligible Processes EP: Menu Set Objectives* Eligible Professionals – select 5 from list* 1.Drug-formulary checks 2.Incorporate clinical lab test results as structured data 3.Generate lists of patients by specific conditions 4.Send reminders to patients per patient preference for preventive/follow up care 5.Provide patients with timely electronic access to their health information 6.Use certified EHR technology to identify patient- specific education resources and provide to patient, if appropriate 7.Medication reconciliation 8.Summary of care record for each transition of care/referrals 9.Capability to submit electronic data to immunization registries/systems* 10.Capability to provide electronic syndromic surveillance data to public health agencies* *At least 1 public health objective must be selected 25 Candidates to consider as exclusions for Radiologists Probable applicable to Radiologists

43. Meaningful Use Monitoring Methodology © 43 Step 3: Eligible Processes Drug-Formulary checking OBJECTIVE: Implement drug formulary checks ASSOCIATED MEASURE: Drug formulary check system is implemented and has access to at least one internal or external drug formulary for the entire reporting period. METHOD OF MEASURE CALCULATION: Measure requires only a Yes/No Attestation. THRESHOLD: Capability must be enabled for entire reporting period EXCLUSIONS: None Radiologist Action: Create or enable access to drug formulary (payer or hospital) And turn on checking capability Radiologist Action: Create or enable access to drug formulary (payer or hospital) And turn on checking capability Selection Recommendation Do not select this rule Selection Recommendation Do not select this rule

44. Meaningful Use Monitoring Methodology © 44 Step 3: Eligible Processes Incorporate Clinical Lab Test Results OBJECTIVE: Incorporate clinical lab test results into EHR as structured data ASSOCIATED MEASURE: More than 40 percent of all clinical lab tests results ordered by authorized provider of the eligible hospital or CAH for patients admitted to its inpatient or emergency department (POS 21 or 23) during the EHR reporting period whose results are in either in a positive/negative or numerical format are incorporated in certified EHR technology as structured data METHOD OF MEASURE CALCULATION: Denominator is based on counting actions for patients whose records are maintained using certified EHR technology. NUMERATOR: The number of lab test results whose results are expressed in a positive or negative affirmation or as a number which are incorporated as structured data. DENOMINATOR: Number of lab tests ordered during the EHR reporting period by the authorized providers of the eligible hospital or CAH for patients admitted to an eligible hospital’s or CAH’s inpatient or emergency department (POS 21 & 23) whose results are expressed in a positive or negative affirmation or as a number. The only patients whose lab test orders are included in the denominator are those patients whose records are maintained using certified EHR technology. THRESHOLD: The resulting percentage must be more than 40 percent in order for an EP, eligible hospital, or CAH to meet this measure. EXCLUSIONS: If an EP orders no lab tests whose results are either in a positive/negative or numeric format during the EHR reporting period they would be excluded from this requirement as described previously in this section under our discussion of whether certain EP, eligible hospital or CAH can meet all Stage 1 meaningful use objectives given established scopes of practices. Selection Recommendation Do not select this rule Selection Recommendation Do not select this rule Radiologist Action: Candidate for “no patients or Insufficient actions” Radiologist Action: Candidate for “no patients or Insufficient actions”

45. Meaningful Use Monitoring Methodology © 45 Step 3: Eligible Processes Generate Lists by Specific Conditions OBJECTIVE: Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research, or outreach ASSOCIATED MEASURE: Generate at least one report listing patients of the EP or eligible hospital with a specific condition. (Note: report only needs to contain patients whose records are maintained in the certified EHR) METHOD OF MEASURE CALCULATION: Measure requires only a Yes/No attestation. THRESHOLD: Only one report in required for any given EHR reporting period. EXCLUSIONS: None Radiologist Action Radiologist Action: Generate reporting based on selected condition Radiologist Action Radiologist Action: Generate reporting based on selected condition Selection Recommendation Select this Rule Selection Recommendation Select this Rule

46. Meaningful Use Monitoring Methodology © 46 Step 3: Eligible Processes Send Reminders per Patient Preference OBJECTIVE: Send reminders to patients per patient preference for preventive/ follow up care. ASSOCIATED MEASURE: More than 20 percent of all patients 65 years or older or 5 years old or younger were sent an appropriate reminder during the EHR reporting period. METHOD OF MEASURE CALCULATION: Denominator is based on counting actions for patients whose records are maintained using certified EHR technology. NUMERATOR: The number of patients in the denominator who were sent the appropriate reminder. DENOMINATOR: Number of unique patients 65 years old or older or 5 years old or younger. The denominator is based on patients whose records are maintained using certified EHR technology. THRESHOLD: The resulting percentage must be more than 20% in order for an EP to meet this measure. EXCLUSION: If an EP has no patients 65 yeras or older or 5 years or younger with records maintained using certified EHR technology that EP is excluded from this requirement Selection Recommendation Do Not Select this Rule Selection Recommendation Do Not Select this Rule Radiologist Action: Candidate for “no patients or Insufficient actions” Radiologist Action: Candidate for “no patients or Insufficient actions”

47. Meaningful Use Monitoring Methodology © 47 Step 3: Eligible Processes Provide patients electronic access OBJECTIVE: Provide patients with timely electronic access to their health information (including lab results, problem list, medication lists, medication allergies) within four business days of the information being available to the EP. ASSOCIATED MEASURE: At least 10 percent of all unique patients seen by the EP are provided timely (available to the patient within four business days of being updated in the certified EHR technology) electronic access to their health information subject to the EP’s discretion to withhold certain information. METHOD OF MEASURE CALCULATION: Denominator is unique patients regardless of whether the patient's records are maintained using certified EHR technology. NUMERATOR: The number of patients in the denominator who have timely (available to the patient within four business days of being updated in the certified EHR technology) electronic access to their health information online. DENOMINATOR: Number of unique patients seen by the EP during the EHR reporting period. THRESHOLD: The resulting percentage must be at least 10 percent in order for the EP to meet this measure. EXCLUSION: If an EP neither orders nor creates any of the information listed in the ONC final rule 45 CFR 170.304(g) and therefore included in the minimum data for this objective during the EHR reporting period they would be excluded from this requirement. Radiologist Action Radiologist Action: Provide interpretations and images electronically as requested Radiologist Action Radiologist Action: Provide interpretations and images electronically as requested Selection Recommendation Select this Rule Selection Recommendation Select this Rule

48. Meaningful Use Monitoring Methodology © 48 Step 3: Eligible Processes Provide patient-specific education resource to patient OBJECTIVE: Use certified EHR technology to identify patient-specific education resources and provide those resources to the patient if appropriate. ASSOCIATED MEASURE: More than 10% of all unique patients seen by the EP or admitted to eligible hospital's or CAH's inpatient or emergency department (POS 21 or 23) are provided patient-specific educational resources. METHOD OF MEASURE CALCULATION - Denominator is unique patients regardless of whether the patient's records are maintained using certified EHR technology. NUMERATOR: Number of patients in the denominator who are provided patient education specific resources. DENOMINATOR: Number of unique patients seen by the EP during the EHR reporting period. (Total Number of Unique Patients - Regardless of Whether the Patient’s Records Are Maintained Using Certified EHR Technology). THRESHOLD: The resulting percentage must be more than 10 percent in order for an EP, eligible hospital, or CAH to meet this measure. EXCLUSIONS: None Radiologist Action Radiologist Action: Incorporate educational resources, and issue to patient (or referring physician) as requested Radiologist Action Radiologist Action: Incorporate educational resources, and issue to patient (or referring physician) as requested Selection Recommendation Select this Rule Selection Recommendation Select this Rule

49. Meaningful Use Monitoring Methodology © 49 Step 3: Eligible Processes Medication Reconciliation at Transition of Care OBJECTIVE: The EP or eligible hospital or CAH who receives a patient from another setting of care or provider of care or believes an encounter is relevant should perform medication reconciliation ASSOCIATED MEASURE: The EP or eligible hospital or CAH performs medication reconciliation for more than 50 percent of transitions of care in which the patient is admitted to the eligible hospital’s or CAH’s inpatient or emergency department (POS 21 or 23). METHOD OF MEASURE CALCULATION: Denominator is based on counting actions for patients whose records are maintained using certified EHR technology. NUMERATOR: The number of transitions of care in the denominator where medication reconciliation was performed. DENOMINATOR: Number of transitions of care during the EHR reporting period for which the EP was the receiving party of the transition. The only patients whose medication reconciliations are included in the denominator are those patients whose records are maintained using certified EHR technology. THRESHOLD: The resulting percentage must be more than 50 percent in order for an EP, eligible hospital, or CAH to meet this measure. EXCLUSIONS: None Selection Recommendation Do Not Select this Rule Selection Recommendation Do Not Select this Rule Radiologist Action: Candidate for “no patients or Insufficient actions” Radiologist Action: Candidate for “no patients or Insufficient actions”

50. Meaningful Use Monitoring Methodology © 50 Step 3: Eligible Processes Provide Summary of Care Record OBJECTIVE: The EP, eligible hospital or CAH who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care should provide summary care record for each transition of care or referral. ASSOCIATED MEASURE: The EP or eligible hospital or CAH who transitions or refers their patient to another setting of care or provider of care provides a summary of care record for more than 50 percent of transitions of care and referrals. METHOD OF MEASURE CALCULATION: Denominator is based on counting actions for patients whose records are maintained using certified EHR technology. NUMERATOR: The number of transitions of care and referrals in the denominator where a summary of care record was provided DENOMINATOR: Number of transitions of care and referrals during the EHR reporting period for which the EP or eligible hospital’s or CAH’s inpatient or emergency department (POS 21 to 23) was the transferring or referring provider. The only patients whose transitions of care and referrals are included in the denominator are those patients whose records are maintained using certified EHR technology. THRESHOLD: The percentage must be more than 50 percent in order for an EP,eligible hospital, or CAH to meet this measure. EXCLUSIONS: None Selection Recommendation Do Not Select this Rule Selection Recommendation Do Not Select this Rule Radiologist Action: Candidate for “no patients or Insufficient actions” Radiologist Action: Candidate for “no patients or Insufficient actions”

51. Meaningful Use Monitoring Methodology © 51 Step 3: Eligible Processes Submit Electronic data to Immunization Registries OBJECTIVE: Capability to submit electronic data to immunization registries or Immunization Information Systems and actual submission in accordance with to applicable law and practice ASSOCIATED MEASURE: Performed at least one test of certified EHR technology's capacity to submit electronic data to immunization registries (unless none of the immunization registries to which the EP, eligible hospital, or CAH submits such information have the capacity to receive the information electronically). Test does not have to be successful. METHOD OF MEASURE CALCULATION: Measure requires only a Yes/No attestation THRESHOLD: Perform at least one test of certified EHR technology’s capacity to submit electronic data to immunization registries and follow up submission if the test is successful. A failed attempt would meet the measure. EXCLUSIONS: Eligible hospitals and CAH's that have not given any immunizations during the EHR reporting period are excluded from this measure Selection Recommendation Do Not Select this Rule Selection Recommendation Do Not Select this Rule Radiologist Action: Candidate for “no patients or Insufficient actions” Radiologist Action: Candidate for “no patients or Insufficient actions”

52. Meaningful Use Monitoring Methodology © 52 Step 3: Eligible Processes Submit Electronic Syndromic Surveillance Data OBJECTIVE: Capability to submit electronic syndromic surveillance data to public health agencies and actual submission in accordance with applicable law and practice ASSOCIATED MEASURE: Performed at least one test of certified EHR technology's capacity to provide electronic syndromic surveillance data to public health agencies and follow-up submission if the test is successful (unless none of the public health agencies to which an EP, eligible hospital, or CAH submits such information have the capacity to receive the information electronically). METHOD OF MEASURE CALCULATION: Measure requires only a Yes/No attestation. THRESHOLD: Perform at least one test of certified EHR technology’s capacity to submit electronic data to public health agency and follow up submission if the test is successful. This test must include the transfer of either actual or ‘‘dummy’’ data to the chosen public health agency. A failed attempt would meet the measure. EXCLUSIONS: None. Radiologist Action Radiologist Action: Provide appropriate data as requested, and attest “Yes” Radiologist Action Radiologist Action: Provide appropriate data as requested, and attest “Yes” Selection Recommendation Select this Rule Selection Recommendation Select this Rule

53. Meaningful Use Monitoring Methodology © 53 Step 3: Eligible Processes Meeting Quality Measures The good news is: – Quality measures do not have thresholds – For 2011, it is not necessary to submit electronically to CMS, but may be required in 2012 The bad news is: – All data to support quality measures must be maintained in our certified EHR’s, which is not currently the case Must submit six quality measures three of which must be core or alternate core measures. Can attest to the fact that the EP had no patients for the quality measure

54. Meaningful Use Monitoring Methodology © 54 Planning for compliance and staying on track ARRA HITECH Foundation ARRA HITECH Foundation ARRA HITECH Foundation ARRA HITECH Foundation Step 1: Step 1: Eligible Professional Eligible Professional Step 1: Step 1: Eligible Professional Eligible Professional Step 2: Step 2: Eligible IT Eligible IT Step 2: Step 2: Eligible IT Eligible IT Step 3: Step 3: Eligible Processes Eligible Processes Step 3: Step 3: Eligible Processes Eligible Processes Step 4: Step 4: Program Monitoring Program Monitoring Step 4: Step 4: Program Monitoring Program Monitoring Step 5: Step 5: Strategies Step 5: Step 5: Strategies Step 6: Step 6: Getting Help Getting Help Step 6: Step 6: Getting Help Getting Help In “presentation mode”, click the steps to navigate

55. Meaningful Use Monitoring Methodology © 55 Meaningful Use RequirementsHow Many? Core Meaningful Use – must meet all core requirements 15 Menu Meaningful Use – select from list of 10 5 Core - Quality measures – must meet six of 44 6 Step 4: Program Monitoring Compliance Tracking Summary For Each Requirement For Each Requirement What interpretation do we provide our clinicians ? What report(s) do we run and store long term to prove we were compliant for each reporting year ? What is the operational process flow ? For Each Quality Report For Each Quality Report Where in our EHR is the supporting data stored? In what system is the data currently originated, and how are we getting it into the EHR? What reports do we create and execute, to prove that we have the data in our EHR? What data sets must our clinicians use ? MUM is the framework for all this, and more

56. Meaningful Use Monitoring Methodology © 56 Step 4: Program Monitoring Compliance Tracking Summary The basis for Incentives is predicated on Meaningful Use (MU) of EHRs … However, it’s not just about the technology – there has to be significant changes in clinical processes and procedures Clinical involvement is imperative for achieving Meaningful Use … if it looks complex it probably is - over 100 FAQ’s have been issued by CMS and ONC! Remember: EHR Vendors can get you from Red to Yellow Only process, training, adoption, and data will get you to Green It is initially adequate to Attest, but you must retain Proof of Green for up to 6 years The basis for Incentives is predicated on Meaningful Use (MU) of EHRs … However, it’s not just about the technology – there has to be significant changes in clinical processes and procedures Clinical involvement is imperative for achieving Meaningful Use … if it looks complex it probably is - over 100 FAQ’s have been issued by CMS and ONC! Remember: EHR Vendors can get you from Red to Yellow Only process, training, adoption, and data will get you to Green It is initially adequate to Attest, but you must retain Proof of Green for up to 6 years

57. Meaningful Use Monitoring Methodology © 57 Role of Formalized Compliance Tools  Real-time visibility to all key stakeholders  Repository for all requirements, assigned to appropriate individuals, with any relevant interpretations  The place where your clinical attestation coordinator tracks EHR compliance status  Organize and communicate work accountabilities and status  Provide a pathway to auditable proof of compliance we can save for statutory 6 year audit time frame Program Monitoring Formal Compliance Tools

58. Meaningful Use Monitoring Methodology © 58 Program Monitoring Formal Compliance Milestones

59. Meaningful Use Monitoring Methodology © 59 Program Monitoring Formal Compliance Milestones X – You are here X Status Reporting works best within a visual context. Sample statements might be … So Far we have: Assembled and educated our Leadership Team Prepared our tracking tools Defined a timeline What we are about to do is: Complete education for Executives, Clinicians and Clinical Attestation Coordinators Kick off our detailed Gap Analysis Work on shortfall remediations, identified as EHR Vendor, Clinical Process, and Documentation of Proof

60. Meaningful Use Monitoring Methodology © 60 High level timelines should tie your milestones to CMS program Program Monitoring Formal Compliance Milestones

61. Meaningful Use Monitoring Methodology © 61 Strategies and Tactics to optimize my goals ARRA HITECH Foundation ARRA HITECH Foundation ARRA HITECH Foundation ARRA HITECH Foundation Step 1: Step 1: Eligible Professional Eligible Professional Step 1: Step 1: Eligible Professional Eligible Professional Step 2: Step 2: Eligible IT Eligible IT Step 2: Step 2: Eligible IT Eligible IT Step 3: Step 3: Eligible Processes Eligible Processes Step 3: Step 3: Eligible Processes Eligible Processes Step 4: Step 4: Program Monitoring Program Monitoring Step 4: Step 4: Program Monitoring Program Monitoring Step 5: Step 5: Strategies Step 5: Step 5: Strategies Step 6: Step 6: Getting Help Getting Help Step 6: Step 6: Getting Help Getting Help In “presentation mode”, click the steps to navigate

62. Meaningful Use Monitoring Methodology © 62 Step 5: Strategies What Strategies might we need? ARRA Participation Strategies “Scheduling” Strategies to help manage individual provider eligibility Program Management Strategies EHR Product Strategies Regulatory Intervention and Influencing Strategies (Manage the CMS Relationship)

63. Meaningful Use Monitoring Methodology © 63 Step 5: Strategies ARRA Participation Strategies Cost Benefit of entering program now vs paying penalties later Can / should some providers quallify for Medicaid (it is a choice)? – Higher payments ($63,750 vs $44,000 Medicare) – $63,750 is predicated on allowable costs of EHR (per EP) being at least $75,000 – First Year can be for Adopting, Implementing or Upgrading EHR and need not be meaningful Use – Six year payout, vs Five year for Medicare – EP must have at least 30% of encounters as Medicaid

64. Meaningful Use Monitoring Methodology © 64 Step 5: Strategies Scheduling Strategies Remember that rewards and penalties are attributable to the Individual EP, not the practice. So … To Maximize Stimulus Funding: – If most work is within eligible POS’s, make sure each individual conducts more than 10% in non-hospital settings – If most work is within non-eligible POS’s, try concentrating workload to a small number of professionals who can qualify, and then spread the resulting payments across the practice If you are not planning on being part of ARRA HITECH: – Analyze all encounters across the entire staff – Minimize future penalties by scheduling work so that the minimum number of individuals “qualify”, in order to minimize future penalties. Where possible, conduct interpretations within relevant POS to fit your goals

65. Meaningful Use Monitoring Methodology © 65 Step 5: Strategies Program Management Strategies Achieving Meaningful Use – Some of this you will be doing for other purposes – May not be all that much in incremental cost Federal Program Compliance is not free – CMS predicts you will spend little or no effort in “compliance” activities – Small hospitals are estimating at least one full time equivalent, and many estimate more just for tracking (not achieving) Putting someone in Charge – Project management – Clinical coordination – IT Coordination (get from Red to Yellow as fast as you can. Yellow to Green takes longer)

66. Meaningful Use Monitoring Methodology © 66 Step 5: Strategies EHR Product Strategies Develop points of view on your current (or new) EHR’s capabilities Will your vendor certify the product you currently own, or require an upgrade? – You must own all the functionality even if you don’t use it all – Self-certification may be a viable option for larger groups, but will require some software development as well Reports to calculate metrics Some functionality you may not have Build an Interoperability Strategy, based on the Menu Options you select – Interactions with referring physicians or hospitals – Interactions with public health organizations

67. Meaningful Use Monitoring Methodology © 67 Step 5: Strategies CMS Relationship Strategies Participate in professional societies – Meaningful Use will continue to evolve, and you need your position known – Current regulations likely to contain problems and unintended consequences, for / against which you should lobby – especially for your specialty Stay informed in the current regulations via FAQ and other CMS pronouncements

68. Meaningful Use Monitoring Methodology © 68 Additional Federal Funding, Commercial Sources, Links ARRA HITECH Foundation ARRA HITECH Foundation ARRA HITECH Foundation ARRA HITECH Foundation Step 1: Step 1: Eligible Professional Eligible Professional Step 1: Step 1: Eligible Professional Eligible Professional Step 2: Step 2: Eligible IT Eligible IT Step 2: Step 2: Eligible IT Eligible IT Step 3: Step 3: Eligible Processes Eligible Processes Step 3: Step 3: Eligible Processes Eligible Processes Step 4: Step 4: Program Monitoring Program Monitoring Step 4: Step 4: Program Monitoring Program Monitoring Step 5: Step 5: Strategies Step 5: Step 5: Strategies Step 6: Step 6: Getting Help Getting Help Step 6: Step 6: Getting Help Getting Help In “presentation mode”, click the steps to navigate

69. Meaningful Use Monitoring Methodology © 69 Step 6: Getting Help C3 Partners Sites and Tools Information Overload on the Web. The Final Rule for Meaningful Use is over 800 pages long. Our firm has organized much content, and commits to researching and answering your questions on: http://EverythingHITECH.com – content regarding the rules around eligibility, payments and many other administrative issues http://EverythingHITECH.com http://MUMrequirements.com – the details of what you need to do with your EHR, in a discussion board format http://MUMrequirements.com http://MeaningfulUseMonitor.com – a quick overview of our ARRA HITECH program management software designed to organize your compliance efforts. http://MeaningfulUseMonitor.com http://www.everythinghitech.com/every thing-hitech/2010/08/trouble- navigating-the-800-page-final-rule-.html

70. Meaningful Use Monitoring Methodology © 70 Step 6: Getting Help Regulatory and Professional Sources Information Overload on the Web. The Final Rule for Meaningful Use is over 800 pages long. We try to stick to “primary” sources. Here are a couple that matter: http://www.RadiologyMU.org – I’ve not spent a lot of time here, but this site seems to speak to specialty-specific issues http://www.RadiologyMU.org http://onc-chpl.force.com/ehrcert - The definitive listing of what EHR vendors and modules are currently certified. http://onc-chpl.force.com/ehrcert http://healthit.hhs.gov/portal/server.pt/community/onc_regulations_faqs /3163 - This site is as big and ugly as the URL itself. But it is the place where CMS responds to questions and maintains changes in policy (so far) http://healthit.hhs.gov/portal/server.pt/community/onc_regulations_faqs /3163

71. Meaningful Use Monitoring Methodology © 71 Step 6: Getting Help Regional Extension Centers Regional Extension Centers – Focus of small primary care practices (under 10) – But … they need physicians to sign up with them to get and retain government funding, and sign ups have been slow – REC has federal funding available to help with consulting services (up to $5k per physician), and may charge you for services beyond that rate – Startup organizations in process of building out Meaningful Use assistance capabilities Indiana RECs: – HealthBridge http://www.healthbridge.org/index.php http://www.healthbridge.org/index.php – Indiana Health Information Technology Extension Center (Purdue University) http://www.ihitec.purdue.edu/ http://www.ihitec.purdue.edu/

72. Meaningful Use Monitoring Methodology © 72 Today’s content available for download at: MeaningfulUseMonitor.com On the “Downloads” Panel at the right side of your page