1. September 16, 2015 Antonio Vega Sandy Swallow
A Quick Glance at Meaningful Use “Proposed” Modifications for 2015 and MIPS
September 16, 2015
Antonio Vega Sandy Swallow

2. “Pending Review” Status
Proposed Modified Stage 2
Changes mid-year and mid-program
in the Final Rule

3. Proposed Modified Stage 2
Today’s Objectives
Proposed Modified Stage 2
A Quick Glance:
Program goals and long term program alignment
Updated participation timeline
Significant program changes for 2015
Medicare Incentives beyond 2017
MIPS

4. Proposed Modified Stage 2
Program Goals
Proposed Modified Stage 2
Modified Stage 2 Goals
Align with Stage 3 proposed rule
Align reporting period with full calendar year for ALL
Change reporting period to 90-day period in 2015
EH 10/1/ to 12/31/15
EP 1/1/15 to 12/31/15
Synchronize objectives and measures to reduce burden
Remove redundant, duplicative, and topped out
Modify patient action measures related to patient engagement

5. Timeline, Stages and Vendor Requirements
Proposed Modified Stage 2
Long Term Program Alignment
Timeline, Stages and Vendor Requirements
2015
All participants attest to modified version of Stage 2; with accommodations for Stage 1 Providers; 2014 CEHRT
2016
All EH and EP attest to modified version of Stage 2, at stage 2 thresholds; 2014 or 2015 CEHRT
2017
Attest to either modified version of Stage 2 or full version of Stage 3; 2014 or 2015 CEHRT
2018
Attest to full version of Stage 3 with 2015 CEHRT

6. Proposed Modified Stage 2 Stages of Meaningful Use
Updated MU Timeline
Proposed Modified Stage 2
First Payment Year
Stages of Meaningful Use
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021 1 2
2 or 3 3 2*
Everyone Moves to Stage 3 in 2018
* Special accommodations for Stage 1 providers

7. Proposed Modified Stage 2
Program Changes
Proposed Modified Stage 2
9 Core Criteria
1 Public Health Criterion
Applies to all eligible professionals, hospitals and critical access hospitals

8. MU Objectives 2015 -2017 Objective EP Measure EH Measure
Protect Elec Health Info
Conduct SRA/correct deficiencies
Same
Clinical Decision Support
5 rules related to 4+ CQM; drug/drug and drug/allergy interaction check
CPOE
>60% med, >30% lab, > 30% radiology
eRx
>50%; drug formulary query
>10%; drug form. query
Summary of Care
Use CEHRT to create summary; >10% electronically transmit
Patient Specific Education
>10% unique patients
Medication Reconciliation
>50% transitions of care
Patient Elec Access (VDT)
>50% timely access; 1 patient VDT
Secure Messaging
Fully enabled
n/a
Public Health
5 measure options
6 measure options

9. Proposed Modified Stage 2
Removed Measures
Proposed Modified Stage 2
Record Demographics
Record Vital Signs
Record Smoking Status
Structured Lab Results
Patient List
Electronic Notes
Imaging Results
Family Health History
Summary of Care
Measure 1 and 3
Clinical Summaries (EP)
Patient Reminders (EP)
eMAR (EH)
Advanced Directive (EH)
Structure Labs to Ambulatory Providers (EH)

10. Proposed Modified Stage 2
Relaxed Measures
Proposed Modified Stage 2
Objective
Old
Current
Patient Electronic Access (View, Download or Transmit)
Measure = 5% of the patients
Measure = 1 patient
Secure Messaging with Patients
Yes/No, stating “functionality fully enabled”
Public Health Objective and Clinical Data Registry
Multiple
One consolidate with 6 measures
- EH must attest to 3
- EP must attest to 2

11. Modified Stage 2 Objectives
Public Health and Clinical Data Registry (CDR) Reporting
Attest to any 2 (EP) or 3 (EH)…
1. Immunization registry reporting (bi-directional)
2. Syndromic surveillance reporting
3. Case reporting
4. Public health registry reporting*
5. Clinical data registry reporting*
6. Electronic Reportable Laboratory Reporting
*May choose to report to more than one registry to meet the number of measures required

12. Modified Stage 2 - Clinical Quality Measures
9 measures out of 64, covering at least three domains
None are “required” but some are recommended
Zero in the denominator is a positive response
Can report through the PQRS portal
CQM reporting period can be different than the rest of MU

13. Accommodations for Stage 1 Providers
You are attesting to Stage 1 in 2015…
Stage 1 based on the same 10 objectives
Attest to Stage 1 thresholds
Will take an exclusion for the Stage 2 measures if there is no equivalent Stage 1 measure
Menu objectives move to core objectives

14. Accommodations for Stage 1 Providers
Objective
Alternate Measure, Exclusion/Specifications
Protect Elec Health Info
None
CDS
Implement one CDS rule EP; no exclusion EH
CPOE
>30% med, exclusion for lab and radiology
eRx
>40 % EP; exclusion EH Stage 1 and Stage 2 did not intend to demonstrate as a Menu in Stage 2
Summary of Care
Exclusion
Pt-Specific Education
Exclusion, if did not intend to demonstrate as a Menu objective in Stage 1
Med. Reconciliation
Pt. Electronic Access
Secure Electronic Messaging
Public Health

15. Hospital-Based EPs Qualifications for Hospital-Based EPs
Proposed
Modified Stage 2
Qualifications for Hospital-Based EPs
Include place of service 22 (outpatient) for those EPs considered hospital-based*
EP is ineligible for incentive payment and payment adjustments if >90% covered professional services in sites of service identified as:
POS 21 (inpatient)
POS 22 (outpatient)*
POS 23 (emergency room)

16. Proposed Modified Stage 2
Attestation Updates
Proposed Modified Stage 2
Attestation will not begin until after January 1, 2016
In 2015 only -
First time EH and EP participants will have until February 29, 2016 to attest; but may be subject to a payment adjustment on claims submitted prior to attestation to MU for an EHR reporting period in 2015

17. Payment Adjustments Facts
Hardship Exceptions were due July 1, 2015
Lack of Infrastructure
Unforeseen and/or Uncontrollable Circumstances
Lack of Control over the Availability of Certified EHR Technology
Lack of Face-to-Face Interaction
Began in January 2015; 1% and increases every year until 2018 when government makes a decision
Annual attestation required to avoid adjustment

18. Merit-Based Incentive Payment System (MIPS)
Medicare Incentives Beyond 2017
Merit-Based Incentive Payment System (MIPS)
Federal Quality Program combines PQRS, MU and VBM
Replaces the SGR reimbursement formula
Goal is to lower cost while improving quality of care by rewarding high-performers and penalizing low-performers based on a composite threshold score
2017 will be the first performance year

19. Eligibility for MIPS 2019 & 2020 (First two years) 2021 onward
Physicians, PAs, Certified Registered Nurse Anesthetists, NPs, Clinical Nurse Specialists, Dentists, Podiatrist and Groups that include such professionals
2021 onward
Dietitians, Midwives, Psychologist and most other healthcare professionals
Excluded EPs
Qualifying APM participants
First year Medicare participation
Low volume threshold exclusions
MIPS DOES NOT apply to RHC or FQHC payments

20. Potential Annual Score 0-100 Points
MIPS Assessment Categories
Potential Annual Score Points
Quality pts.
Resource Use pts.
Meaningful Use pts.
Clinical Practice Improvement pts.

21. Payment Alignment

22. Telligen QIN QIO
Telligen: Quality Innovation Network-Quality Improvement Organization (QIN-QIO) for Colorado, Illinois and Iowa

23. IHIN Contact: Antonio Vega 515.362.8311 avega@telligen.com
Thank you!
QIN-QIO Contact: Sandy Swallow telligenqinqio.com
IHIN Contact: Antonio Vega
This material was prepared by Telligen, the Medicare Quality Innovation Network Quality Improvement Organization, under contract with the Centers for Medicare & Medicaid Services (CMS), an agency of the U.S. Department of Health and Human Services. The contents presented do not necessarily reflect CMS policy. 11SOW-QIN-B4-9/