Stage 2 Meaningful Use: Menu Objectives and Clinical Quality Measures

James R. Christina, DPM Director Scientific Affairs

APMA

What Stage Am I In?

2

2

CMS Proposed Rule On May 20, 2014 CMS and Office of the National

Coordinator (ONC) released a notice of proposed rulemaking (NPRM) that would allow providers participating in the EHR Incentive Programs to use the 2011 Edition of certified electronic health record technology (CEHRT) for calendar and fiscal year 2014.

The NPRM will grant flexibility to providers who are

experiencing difficulties fully implementing 2014 Edition CEHRT to attest this year. The proposed rule would allow providers to use EHRs that have been certified under the 2011 Edition, a combination of the 2011 and 2014 Editions, or the 2014 Edition.

Beginning in 2015, all eligible providers would be required to

report using 2014 Edition CEHRT.

If you can attest to not being able to ‘fully implement 2014 CEHRT” then you have the following options

You would be able to attest for MU:

If you were

scheduled to

demonstrate:

Using 2011 Edition

CEHRT to do:

Using 2011 & 2014 Edition CEHRT to

do:

Using 2014 Edition

CEHRT to do:

Stage 1 in 2014

2013 Stage 1 objectives

and measures

2013 Stage 1 objectives and

measures -or-

2014 Stage 1 objectives and

measures

2014 Stage 1 objectives

and measures

Stage 2 in 2014

2013 Stage 1 objectives

and measures

2013 Stage 1 objectives and

measures -OR-

2014 Stage 1 objectives and

measures -OR-

Stage 2 objectives and

measures

2014 Stage 1 objectives

and measures -OR-

Stage 2 objectives

and measures

FACTS ABOUT PROPOSED RULE: This is a proposed rule meaning that there is a 60 day comment period. APMA will comment on the

proposed rule, particularly stating that there should not be the need to attest to inability to “fully implement” but all providers should have the option of choosing what CEHRT they want to use to attest. The comment period will end on July 21, 2014.

CMS will probably not issue the final rule on this until around September 1, 2014. That will mean when

the final rule comes out there will be only one calendar quarter (Oct-Dec) left to meet the requirements for MU for 2014.

CMS has indicated that if you feel that you will attest to not being able to fully implement 2014 CEHRT

and you are able to meet the MU requirements in the proposed rule during one of the calendar quarters prior to the final rule, you will be able to attest to that calendar quarter once the rule is finalized. So for example, if you were scheduled to demonstrate Stage 1 or Stage 2 of MU in 2014 and during one of the calendar quarters you were still using your 2011 CEHRT, if you met the 2013 Stage 1 objectives and measures, you would be able to attest to that quarter once the final rule was published.

Note that the options in the table listed depend on whether you were scheduled to report on Stage 1

or Stage 2 in 2014. Note that it will still only require a 90 day attestation linked to one of the calendar quarters for 2014. Reporting of clinical quality measures will depend on whether you are meeting 2013 or 2014 objectives

and measures

If you have upgraded to a 2014 CEHRT but are not able to “fully implement” all of the features you can attest to 2014 Stage 1 objectives and measures. As stated in the proposed rule:

“A provider’s ability to fully implement all of the functionality of 2014 Edition CEHRT may be limited by the availability and timing of product installation, deployment of new processes and workflows, and employee training. This effect is compounded for providers in Stage 2 as some providers may not be able to fully implement all of the functions included in 2014 Edition CEHRT that are necessary to meet the Stage 2 objectives and measures in time to complete their EHR reporting period in 2014. Therefore, under our proposal, providers who are scheduled to begin Stage 2 for the 2014 EHR reporting period but are unable to fully implement all the functions of their 2014 Edition CEHRT required for Stage 2 objectives and measures due to delays in 2014 Edition CEHRT availability would have the option of using 2014 Edition CEHRT to attest to the 2014 Stage 1 objectives and measures for the 2014 EHR reporting period. Providers who are scheduled to begin Stage 2 in 2014 who choose this option must attest that they are unable to fully implement 2014 Edition CEHRT because of issues related to 2014 Edition CEHRT availability delays when they attest to the meaningful use objectives and measures.”

Reporting Period for 2014 (remains unchanged even with proposed rule)

Stage 2 Requirements

Menu Objectives

Submit electronic syndromic surveillance data to public health agencies

Record electronic notes in patient records

Imaging results accessible through CEHRT

Record patient family health history

Report cancer cases to a public health central cancer registry

Report specific cases to a specialized registry

Qualified Clinical Data Registry (QCDR)

For 2014, these registries are CMS-approved entities that collects medical and/or clinical data for the purpose of patient and disease tracking to foster improvement in the quality of care provided to patients.

U S Wound Registry (USWR) The U.S. Wound Registry (USWR) is one of many specialty registries developed and operated by the non-profit Chronic Disease Registry. It became a PQRS registry at the outset of the registry process in 2008 and is one of most experienced PQRS registries. As a non-profit organization focused on quality of care for patients with chronic wounds, the USWR began to shed light on “gaps in practice” such as why off-loading is so poorly implemented for diabetic foot ulcers. 1 USWR worked with the Institute for Clinical Outcomes Research (ICOR) to develop the Wound Healing Index (WHI) to stratify patients by severity in order to provide a more equitable way to report healing outcomes.2 In conjunction with the Alliance of Wound Care Stakeholders (AWCS) USWR submitted new wound care quality measures to CMS in 2009 and 2011 and started the “Do the Right ThingTM” project to pilot test these quality measures in outpatient wound centers (e.g. DFU off-loading, venous ulcer compression, vascular assessment of patients with leg ulcers).3 For many years the USWR has lead the way in PQRS reporting for wound care clinicians.

APMA relationship with USWR Complete the survey TODAY:

http://uswoundregistry.com/APMASurvey Beginning on March 31, 2014 when specifications are posted

online, select the APMA recommended measures and ask you EHR vendor to program the specifications into your EHR. You may want to have to contact your EHR vendor beforehand to discuss any integration issues.

Download the Business Associate Agreement (BAA) from the USWR website (http://www.uswoundregistry.com), sign it, and return it by fax to the USWR at 832-550-2941 or to enrollment@uswoundregistry.com.

Once your vendor has completed the programming to allow you to submit your measures, you are ready to create an account for payment.

Work with your assigned USWR representative to finish your set up and begin reporting!

APMA members receive a $50 discount

What If None of the Menu Objectives Are Relevant? It’s rare, but it’s possible that none of the

menu objectives are applicable to your scope of practice. If that is the case for you and you qualify for all of the exclusions for each of the menu objectives, then you can select 3 menu objectives and claim the exclusion for each.

However, if you do not qualify for all of the exclusions to the menu objectives, you must go back and select menu objectives on which you can report.

Clinical Quality Measures (CQMs)

Changes to CQMs in 2014 Beginning in 2014, the reporting of clinical

quality measures (CQMs) will change for all providers.

EHR technology that has been certified to the 2014 standards and capabilities will contain new CQM criteria, and eligible professionals will report using the new 2014 criteria regardless of whether they are participating in Stage 1 or Stage 2 of the EHR Incentive Programs.

How to Submit CQM Data in 2014 All Medicare eligible professionals have the option of

submitting three months of CQM data online through the CMS Registration & Attestation System.

Medicare eligible professionals also have the option to

submit a full year of data electronically using the QRDA format to receive credit for the EHR Incentive Program and the Physician Quality Reporting System.

Please note that your attestation for the Medicare

EHR Incentive Program is not complete until you submit clinical quality measure data, so your EHR incentive payment will be held until your electronic submission is processed.

How to Select CQMs in 2014 Beginning in 2014, eligible professionals must select and report on 9 of a

possible list of 64 approved CQMs for the EHR Incentive Programs. 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 domains are: ◦ Patient and Family Engagement ◦ Patient Safety ◦ Care Coordination ◦ Population and Public Health ◦ Efficient Use of Health Care Resources ◦ Clinical Processes/Effectiveness

You can find a complete list of the 2014 CQMs for the EHR Incentive

Programs and their associated National Quality Strategy domains at: Clinical Quality Measure webpage at http://www.cms.gov/Regulations-and-Guidance/Legislation/ EHRIncentivePrograms/ClinicalQualityMeasures.html

Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention (Population and Public Health)

Preventive Care and Screening: Influenza Immunization (Population and Public Health)

Pneumonia Vaccination Status for Older Adults (Clinical Processes/Effectiveness)

Diabetes: Eye Exam (Clinical Processes/Effectiveness) Diabetes: Foot Exam (Clinical Processes/Effectiveness) Diabetes: Hemoglobin A1c Poor Control (Clinical Processes/Effectiveness)

Hemoglobin A1c Test for Pediatric Patients (Clinical Processes/Effectiveness)

Diabetes: Urine Protein Screening (Clinical Processes/Effectiveness) Diabetes: Low Density Lipoprotein (LDL) Management (Clinical Processes/Effectiveness)

Falls: Screening for Future Fall Risk (Patient Safety)

Documentation of Current Medications in the Medical Record (Patient Safety)

Closing the referral loop: receipt of specialist report (Care Coordination)

Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up (Population and Public Health)

Preventive Care and Screening: Screening for High Blood Pressure and Follow-Up Documented (Population and Public Health)

Potential CQMs for Podiatrists

CQMs are a reporting requirement

Unlike the Physician Quality Reporting System (PQRS), reporting CQMs for Meaningful Use is a reporting requirement only—you do not have to meet a threshold for performance.

It is acceptable to report CQMs in which you have patients in the denominator but zero in the numerator (you did not perform the quality measure)

RESOURCES

Questions

James R. Christina, DPM jrchristina@apma.org

301-581-9265