2017 Final Score

Final Scores for 2017 have been released!

Sign in at https://qpp.cms.gov/login with your EIDM credentials to retrieve your final score!

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If your score isn’t quite what you wanted it to be, don’t hesitate to contact us to discuss what we can do to help you.

• Perhaps your quality measure percentages were lower than they should have been. Our custom reports would be a great option. They allow providers to continue their normal documentation patterns while still capturing that data and aggregating it according to the latest specifications.

• Maybe your overall score is still below 70. Our QPP Monitoring Program is still available if you need some additional assistance with understanding or workflow. **100% of our practices were above 70 when they reported last year, a few were even at 100**.

Do you have MIPS Submission Stress?

Practices depending on their EHR vendor or other third parties for submission can run into problems if the vendor is unable to submit in a timely manner. This could be for any myriad of reasons. I just wanted to make sure you know you are not stuck. You may have started the year thinking you would submit through your EHR, for example, but it isn’t too late to change your mind! Remember, MARCH 31, 2018 IS THE DEADLINE.

Quality Measures: You can still submit your quality measures through a registry. What do you need to do next?

1. Gather the following data for the reports you are using:

   • IPP – Initial Patient Population

   • Numerator

   • Exclusions

   • Exceptions

2. Find a registry to use. The one we used is $100./provider for group reporting if you have a relationship with us. But, there are others, the list is here: 2017 Qualified Registries . Some specialty organizations provide submission at no cost. **You may still be able to get the End to End reporting bonus even if you use a registry.

Improvement Activities and ACI: The registry we used allowed for submission of all 3 categories in the same file. However, you can also attest through the QPP website. What do you need to do next?

1. Know your EIDM log in information

2. Go to the QPP website and sign in

3. Complete the required fields

4. Submit your data
   **Some of the information on the QPP website is old such as the providers linked to your account. If this is correct in the PECOS system, you are good to go.
   **Some of the information is wrong, such as giving double points to small practices for improvement activities. CMS will fix this as they pull the data to begin incentive payments in 2019.

Need help or additional information? Contact us so we can help you.

To Dos in January 2018...

1. Log into EIDM website. Directions below from CMS:

• Make sure that the NPIs affiliated with your Tax ID Number are current

• Pull your 2016 Annual QRUR reports (Needed for 2018 cost performance category)

• Verify your financial information to make sure your bank and account numbers are correct. This can hold up your payment.

2. Think about whether you meet the Data Completeness definition for your 2017 data

• Data completeness means that you are reporting on a high percentage of the patients that meet the denominator criteria. This is currently set at 50% for 2017.

• If you have lots of charts that the billing level has not been assigned, typically unsigned encounters, then these patient/charts are not being pulled by the ETL and are therefore not being reported on. This impacts your data completeness.

Submission for the 2017 Quality Payment Program

Making sure you prepare for an audit BEFORE the audit…

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This strategy makes audits as stress free as an audit can be. So, while you are preparing your MIPS data for submission, make sure you have copies of the following:

• The Certification ID for the CEHRT version(s) you used during the performance period. This could be a 2014 and/or a 2015 certified version.

  • Using the website, https://chpl.healthit.gov/#/search

    • Search for Allscripts Professional

    • Click the Cert ID+ to add all EHR versions used during the performance period to your cart

      • How can you tell which versions you were on during the reporting period?

        • Go to back office reports

        • Create and run the Allscripts Product Install report for the same performance period

      • Click the Get Certification ID button to generate the ID. Print a copy for your records.

• Quality Measures:

1. Whether you are MIPS, an APM or an AAPM, you will need the actual report data validating the Denominator, Denominator Exception, Denominator Exclusion, and Numerator for each individual NPI (if you are submitting for your individual providers) or for the group (if you are submitting as a group). I have not ever had to submit the actual patient details, but technically, they could ask for them.

2. Since your reports are run electronically, you are not excluding patients from those reports and are therefore reporting on 100% of your patients. This is your data completeness number. Consider a notarized statement or attestation letter that includes your level of data completeness.

• Improvement Activities

1. Evidence that your practice has implemented one or more improvement activities.

2. This evidence might be written meeting minutes from reviewing patient satisfaction surveys, reports from back office reports to prove same day access to care, or other improvement activities that are customarily tracked by Patient Centered Medical Home.

• Advancing Care Information (MIPS only)

1. A copy of each report to validate the data you are submitting to CMS.

2. A summary of your security risk assessment and date of review.

3. Proof of active engagement with the Immunization Registry if you have a live interface.

4. Proof of active engagement with a Specialized Registry Reporting if you have a live interface.

5. Proof of active engagement with a Syndromic Surveillance Reporting if you have a live interface.

Active Engagement is the process of moving towards sending “production data”. There are 3 options: 1) Registration complete and waiting to submit, 2) Testing and Validation, and 3) Production.

We will offer classes in January to discuss submission and documentation in more detail and to answer any additional questions you might have.

Clinical Quality Measures - Why Accuracy Matters

The Quality Performance Category of the Merit-based Incentive Payment Program counts for 60% of your final score. You accumulate points for each measure based on your performance compared to the benchmark of others that submitted via the same method last year in PQRS. Let’s look at some examples:

Controlling High Blood Pressure – QID 236 (EHR Submission)

If my performance score is 59%, I would only get 4 points instead of 5.

Preventive Care and Screening: BMI and Follow-Up – QID 128 (EHR Submission)

If I have been following up all year, but couldn’t get patients to count in the numerator because I was not following a prescribed workflow, my numbers are not accurate and I am losing points. Perhaps my reported percentage is 0, when I know it should be at least 50%. That is a difference of 6 points. It is possible to report accurate numbers even if you didn’t use the correct workflow.

Preventive Care and Screening: Screening for Clinical Depression and Follow-Up Plan – QID 134 (EHR Submission)

Did you copy the depression screening tool and impact the number of patients in your denominator? Again, it isn’t too late to get accurate numbers to report to CMS.

The accuracy of the data you submit directly impacts the number of points you receive which directly impacts the positive reimbursement you could be eligible for in 2019.

It isn’t too late in the year to get accurate data or to get a final score above 70, putting you in the exceptional performer tier of eligible clinicians that will share in the 500 million allocated for disbursement in 2019.

Do you have confidence in your numbers?

Do you know what your final score is?

We can help you with both of these if needed!

Medicare Quality Payment Program Year Two Proposed Rules

Many of you may have attended the Medicare MACRA/MIPS Year 2 Proposed Rule Overview this week. I just wanted to highlight a few of the major points:

• Low Volume Threshold: Increase to >= $90,000 in Medicare claims or >= 200 Medicare patients

• Additional Bonuses
  • Small Practice Bonus <= 15 providers (5 points) 
  • Health Care Shortage Area Bonus (5 points)
  • Potential adjustment for patient complexity (1 – 3 points)
  • Scoring Improvement Bonus (up to 10 points)
     
• Virtual Groups – Allow small practices with 10 or less clinicians and different TINs to come together in a group for reporting purposes. This must be declared before the beginning of the performance period, so prior to December 1st, 2017 for a virtual group in 2018.
   
• Performance Categories
  • Quality – Remains at a 60% portion of the final score with a 12 month reporting period
     
  • Cost – Proposed to be 0% again
     
  • Improvement Activities
    • 15% towards final score,
    • can choose a 90-day period,
    • more activities will be added to the list of those eligible for the 10 ACI bonus points
       
  • Advancing Care Information
    • 25% towards final score,
    • allow 2014 or 2015 CEHRT again for 2018; however, bonus points for providers that use 2015 CEHRT,
    • can choose a 90 day reporting period
    • additional bonus points for registry reporting (10 instead of just 5)

These are just some important tidbits. MACRA/MIPS money is so accessible this year, do not miss your opportunity!

Additional Resource: https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/Proposed-rule-fact-sheet.pdf

Updated Advanced Beneficiary Notice Effective 6/21/2017

Professional Content Update (PCU) 17.4 was recently announced Generally Available (GA) by Allscripts. It includes the updated Advanced Beneficiary Notice (ABN) form approved by CMS in March 2017. This revised form explains beneficiary rights regarding non-discrimination and how they can request an ABN in an alternate format. The effective date for using this new form is 6/21/2017.
 
In addition to the ABN, the following enhancements are also included, along with a few fixes for reported issues.

1. New CHADIS questionnaires:
   1. Vanderbilt Initial Parent Informant (with Medication Supplements)
   2. Vanderbilt Follow-Up Parent Informant
   3. Vanderbilt Follow-Up Parent Informant (with Medication Supplements)
   4. Screen for Child Anxiety Related Disorders (SCARED) Parent Version (To be filled out by the PARENT)
   5. Screen for Child Anxiety Related Disorders (SCARED) Child Version (To be filled out by the CHILD)
   6. Brenner 'Families in Training'
   7. Mood Disorder Questionnaire, and
2. Report criteria:
   1. Lab Result, Most Recent, Date Range (Lab Catalog)
   2. Lab Result, Most Recent, Date Range (LOINC)
   3. Lab Result, Most Recent, Days (Lab Catalog)
   4. Lab Result, Most Recent, Days (LOINC)

Resource: Allscripts Professional EHR Professional Content Update (PCU) 17.4 Client Release Notes

MIPS Submission and Bonus Points

You can receive bonus points based on how you submit data to CMS in both the Quality and ACI categories. These points will increase your final score and assist you in attaining the highest reimbursement possible in 2019.

The Quality category allows for bonus points for end to end electronic reporting as defined below:

“The end-to-end electronic reporting bonus point is not specific to certain CQMs, but would apply in any case where the submission pathway maintains fully electronic management and movement of patient demographic and clinical data once it is initially captured in the eligible clinician’s certified health IT. Where a registry is calculating and submitting the Quality Payment Program-accepted measures on the MIPS eligible clinician’s behalf, this means that: (1) the MIPS eligible clinician uses certified health IT to capture and electronically provide to the registry clinical data for the measures, using appropriate electronic means (for example, through secure access via API or by electronic submission of QRDA documents); and (2) the registry uses verifiable software to process the data, calculate, and report measure results to CMS (in CMS-specified electronic submission format). In order to qualify for a bonus point, submission via a QCDR or the CMS Web Interface would need to adhere to these principles. Any submission pathway that involves manual abstraction and re-entry of data elements that are captured and managed using certified health IT is not end-to-end electronic quality reporting and is not consistent with the goal of the bonus.”

If you are utilizing a third party registry, verify that CMS has approved their process for meeting the direct end to end submission criteria. In the Quality category, bonus points can equal up to 10% of your total possible quality score.

In the Advancing Care Information or Advancing Care Information, Transitional category, you can receive up to 15% bonus points.

5% bonus points are allocated for practices that submit to a specialized or syndromic surveillance registry. This could be the CDC, an HIE that you participate with and receive feedback reports from, or submission of your quality data electronically.

10% bonus points are allocated for practices that utilize their certified EHR technology (CEHRT) to participate in Improvement Activities (regardless of submission method) selected from the 18 approved bonus measures. These measures are:

For more information, access the fact sheet on the QPP website.

eHealth Consulting March News and Updates: MIPS Forecasting

Greetings from eHealth Consulting!

Meaningful Use is officially over and we are almost 3 months into MIPS! I hope you have an idea of how your practice is doing. Practices we are monitoring have a projected final score between 50 and 70 points. These practices are now able to strategically focus on specific workflow implementation so they are eligible for their portion of the 500 million dollars of additional reimbursement! Do you know what your projected final score is? If not, consider our Quality Payment Program monitoring.

Speaking of Quality – It is so important that your quality data is accurate now that you are getting paid based on performance. Are you confident that your numbers are correct? I know it is hard sometimes to get everyone to conform to the prescribed workflow, especially if it is really outside the norm of documentation patterns. To help you improve the accuracy of capturing your work, we are now offering custom SQL report packages for clients that are able to provide access to their database server

6 reports @ $1000 per report -  $6000
8 reports @ $900 per report   -  $7200
10 reports @ $850 per report -  $8500

This package includes meeting with you prior to writing the reports in order to understand your workflow for each measure, report validation, and training on how to run the reports and view the data. In other words, it will still be a prescribed workflow, but you will be writing the prescription. This meeting also results in a workflow document for staff - an added bonus! 

Click here for more information regarding our Quality Payment Program Monitoring

Are you interested in Practice Management training? We can offer classes for Allscripts PM now and need to know what topics you would like us to provide. Please email us with topics for PM or EHR. Don’t forget to check out this month’s calendar. There are a lot of great classes to attend!

Click here to check out the full calendar of classes for March

Quality Payment Program
Thursday, March 16th
1:00 - 2:30 PM EST

Quality Payment Program
Wednesday, March 29th
1:30 - 3:00 PM EST

Have a great week,
 

Trisha Conway |Principal Consultant

919.696.0371 | C

trishaconway@ehealthconsults.com
www.ehealthconsults.com

Quality Payment Program Pointers

I have been reading several posts on Client Connect and it seems there are some very mixed up messages floating around the Professional EHR community. I thought I would share a recent post with all of you since I am not sure how many of you are avid Client Connect users.

Here are some key points for the Merit-based Incentive Program/Quality Payment Program:

1. CEHRT - In 2017, 2014 CEHRT (ideally you would be using Pro EHR version 15.x or higher) can be used. In 2018, 2015 CEHRT must be used (v17).
2. Performance period - 90 days up to the full calendar year, the longer the better for positive payment adjustments
3. Advancing Care Information (ACI) Performance Category - there is a path for Modified Stage 2 and a path for Stage 3 meaningful use requirements. The maximum number of points is the same regardless of which you choose.  Electronic patient education is a Stage 3 measure.
4. You can self-monitor your performance or have another vendor/consulting firm do this for you. You do have choices!
5. A submission vendor will be necessary for the Quality Measures, other performance categories can be submitted via attestation. You will need the Allscripts 2015 package for Pro EHR or Touch Works.

 Most importantly, don't panic. It is highly likely that you are already well on your way to preventing a negative payment adjustment in 2019. In fact, you may already be in the positive adjustment pool without changing any workflows. Why don't you find out where you are? You can evaluate yourself against the performance category or we could do it for you either as a one-time evaluation or as part of our Quality Payment Program Monitoring.

PCMH Updates

PCMH 2017 Program new Redesign - What You Need to Know

On March 31, 2017, NCQA will launch the Redesigned PCMH 2017 Program. PCMH 2017 is slated to simplify the documentation and reporting requirements and includes ongoing support from a designated NCQA representative. The new program offers a single recognition level with annual check-ins with your NCQA representative to evaluate and build on progress to meet the new NCQA PCMH 2017 objectives. All practices will eventually move from the traditional three-year recognition as a level 1, 2 or 3 PCMH.

The PCMH 2017 program will align with MACRA’s Quality Payment Program. As health care shifts to a value-based payment system, practices which are PCMH or PSRP recognized will have some advantages. Under the MACRA legislation there are two new payment tracks for practices:

Merit-Based Incentive Payment System (MIPS): The MIPS track includes a category called Clinical Practice Improvement Activities (CPIA) that is worth up to 40 points and contributes 15% of each provider’s MIPS final score. Providers in practices that earn NCQA PCMH recognition (either 2014 or 2017) would automatically get full credit for the CPIA category.
 

Alternative Payment Models (APM): Criteria for participating in eligible advanced APM programs, such as Comprehensive Primary Care Plus (CPC+) or certain Medicare ACOs (such as Next Gen), include being a PCMH.

PCMH 2017 Redesigned Recognition Process

The redesigned program will retain the principles of the PCMH model of care. The redesigned program’s recognition process will have three parts:

Commit: During this step the practice will complete a self-assessment and work with their designated representative to develop a plan.

Transform: During this time, practices show their progress by submitting documentation and data to NCQA through a new system designed to reduce paperwork and administrative hassles. Along the way, NCQA conducts virtual reviews—online check-ins—with the practice to gauge progress and to discuss next steps in the evaluation.

Succeed: Once the practice has earned recognition, it will continue to implement and enhance their PCMH model. There will be an annual check-in with their designated representative to attest to certain policies and procedures and submit their quality data.

Where to start

It is very important to begin your PCMH Renewal 9-12 months before the expiration of your current PCMH recognition. New Applicants should start 12 or more months before they intend to submit as this will allow time to educate your staff, implement new workflows and create or update required policies/procedures.

Practices looking to move to the PCMH 2017 program from the PCMH 2011 or PCMH 2014 program have a couple of options. Practices that want to stay with or become certified under the 2014 recognition levels should keep in mind that March 31, 2017 is the deadline to purchase PCMH 2014 survey licenses with a submission deadline of September 30, 2017.

Practices Currently Recognized Under PCMH 2011

·       Renew under the 2017 redesigned process

·       Convert to PCMH 2014

o   Conversion is an option for practices with significant time left on their recognition (at least 12 months when the conversion Survey Tool is submitted) and requires submission for 6 Elements instead of 27.

·       Renew under PCMH 2014 standards

o   Renew is for practices with an expiring recognition who are renewing for another three-year recognition period. 

For more information click here

Practices Currently Recognized Under PCMH 2014 Standards:

·       If you are a Level 3 2014 recognized practice, NCQA is offering a direct entrance into the “Sustain” process of the PCMH 2017 program when your recognition expires.

·       If you are a Level 1 or 2 2014 recognized practice you have three options:

·       Complete an Add-On Survey to earn PCMH 2014 Level 3 Recognition

·       “Transform” through the redesigned program.

·       Renew under PCMH 2014 for the established three-year period

For more information click here

Summary of Care - what you need to know now...

There are a couple of things to note about the Summary of Care measure- Numerator A is no longer required for Meaningful Use or Patient Centered Medical Home according to the recent NCQA update. That being said, there may be other programs you are participating in that are tracking this measure.              

First, there is a new document category in Output Manager called “Summary of Care” .

You should place any referral letters in the Summary of Care Document category so that you will get credit for sending correspondence to the referral provider. While this does not count for MU any longer, it is important for an accurate numerator in other quality metrics.

Second, Numerator B, which measures whether or not an electronic document was sent should be your main focus. The calculation of this measure does not change in version 15, so pay attention to that change and start sending electronic documents now.]

In addition, there is a new requirement for the CQM of Closing the Referral Loop. This requires the following:

1.       Scan the letter from the consulting provider

2.      Index to the Plan / Referral Order

3.      Assign a Document type of “Consultant Letter” or “Consultation Letter”

4.      Review the Referral Order so it is in the Final, Reviewed status (this would be done by the provider if you sent the document for review)

April Special

We are having an April special on classes! If you would like to try out one of our classes for free, send an email to chanelc@ehealthconsults.com and include the title of the class you would like to attend. The New Employee Orientation is not part of this special. Enjoy!

Release Notes

Would you like the cliff notes of implementing Pro EHR version 15? Ones that actually recommend how to use the new functionality? Get them by either attending the Implementing 15.0 class or send a request to chanelc@ehealthconsults.com. If you are not attending a class, the cost is $35.00.

**Screen shots are from Allscripts Professional EHR

eHealth Consulting News and Updates: MU and PHO

Meaningful Use and Public Health Options Q&A Forum
 

Join Trisha Conway on Wednesday, February 24th at 10:30 AM EST for a Q&A session regarding Meaningful Use and Public Health Options. 

Let’s discuss how to handle the Public Health Options for Meaningful Use:

• Do you really need to connect to a registry that provides no clinical value?
• What documentation should you keep to demonstrate an exclusion?
• What is the real intent?

Take care,

Trisha Conway |Principal Consultant

919.696.0371 | C

trishaconway@ehealthconsults.com | www.ehealthconsults.com

Copyright © 2016 eHealth Consulting, All rights reserved.

eHealth Consulting News and Updates: PHO

Greetings! Can you believe it is already the second week in February? I can’t. What significance does that hold? It means that you have 21 more days to become “Actively Engaged” with a public health registry. It also means that PQRS submissions will be due soon as well. Different registry vendors have different cut off dates, so make sure you are familiar with yours.

There is a lot of buzz lately about public health options, so I wanted to take a few minutes to review some key points. First and foremost, the intent of the measure is to exchange meaningful data with another entity that can use the data to generate meaningful results. It isn’t intended to be an exercise in futility. In addition, a “public health registry is one that is administered by, or on behalf of a local, state, territorial, or national PHA and which collects data for public health purposes.”

There are three measures:
Measure 1 - Immunization Registry Reporting: active engagement with a PHA to submit immunization data.
Measure 2 – Syndromic Surveillance Reporting: active engagement with a PHA to submit syndromic surveillance data.
Measure 3 – Specialized Registry Reporting: active engagement to submit data to a specialized registry.
EP Spec Sheet at CMS.gov 

So how can you meet these measures?
The first two are pretty straightforward, the public health agency in your state either has an Immunization Registry or Syndromic Surveillance registry or it does not and you can typically find a statement to that effect on your state Department of Public Health website. Documentation of your registration to participate, participation, or documentation that the PHA does not currently have an Immunization or Syndromic Surveillance registry available are important for audit purposes. 

If you registered last year or in a previous year and there has been no change in the availability, you do not have to register again. As noted in the specification sheet, registration allows the EP to meet the measure despite the PHA’s limited resources to move forward. Registration must occur within the first 60 days of the reporting period (no later than 2/29/2016). If there is no registry at the beginning of the reporting period, you qualify for an exclusion. Other exclusions can be found on the EP Spec Sheet link above.

If you are excluded from either Immunization Registry or Syndromic Surveillance or both, you must look to the Specialized Registry options. You can use two specialized registries to meet the Public Health Options measure. You can also use “methods beyond the functions of the CEHRT to meet the requirements”. This means you can think outside the box and you do not necessarily have to purchase something extra to meet the measure. The word “jurisdiction” is also a key part of the Specialized Registry measure.

“An EP must complete two actions in order to determine available registries or claim an exclusion:
•    Determine if the jurisdiction (state, territory, etc.) endorses or sponsors a registry; and,
•    Determine if a National Specialty Society or other specialty society with which the provider is affiliated endorses or sponsors a registry.”

Recommendations:
1.    Contact your public health agency (ideally by email so you have documentation) to ask about specialized registries that are pertinent to your specialty.
2.    Contact your specialty local, state, and/or national organization (ideally by email so you have documentation) to ask if there are opportunities for data sharing. 
3.    Contact the HIE in your state, if available, and find out the data sharing capabilities and if appropriate, register your intent to participate.
4.    Attend the Reporting Module class to discover what you can already do with your data.

Obtaining your Certification ID

The CHPL website has changed! Follow these steps to find the EHR Certification ID:

1.        Go to http://oncchpl.force.com/ehrcert
 

2.       Enter Allscripts Professional EHR and click Search, select the checkbox beside the product you used.
Note the YOUR PRODUCTS section at the top of the screen with the down arrow has changed to (1). Click the down arrow to expand, displaying more detail about the product or products you have selected.

3.       Click on View Progress

4.      On the View Progress screen, you will see the information about the product and in the bottom right hand corner the blue “Get Certification ID”

5.      The CMS EHR Certification ID displays. Choose either Email or Print or perhaps both.

Comments on the Modifications to Meaningful Use in 2015 Through 2017

Reporting Period, Page 14:

Due to the many obstacles in meeting the Stage 2 objectives to date for patient engagement and direct messaging, as well as vendor challenges with delivering use-able, stable, compliant software, the shortened 90 day reporting period will allow providers an opportunity to successfully attest during the 2015 calendar year. The flexibility of the reporting period beginning outside of a specific calendar quarter is important for successful attestation in 2015 considering when this rule will be finalized.

Patient Engagement, Page 15:

I agree that the ability to test whether or not the physician has the functionality needed to interact with their patient (Secure Messaging and Timely Access) is a much better means of measuring patient engagement. Physicians have no control over the patient’s level of comfort towards allowing their health information to be published online or the adoption of messaging related to health matters. Adoption is increasing, but these two measures are definitely time intensive, can detract from the patient visit and often times require hiring additional personnel to make sure the provider does actually meet the measure threshold.

Patient Electronic Access, alternate proposal for threshold calculation, Page 50:

The measure for VDT (b) should be based on a denominator of patients with an office visit during the reporting period with a web account. Basing the threshold on patients that currently have an account would give the provider the appropriate denominator to calculate a meaningful threshold. Making this change would also normalize the data for comparison across providers. For example, you could compare a rural provider with an urban provider because the basis of the measurement is now equivalent.

Summary of Care, Page 67:

Exchanging C-CDA documents electronically has been a tremendous challenge for providers. While the providers that have the required CEHRT are able to create a compliant C-CDA and are able to send the document through direct messaging, other vendor systems are not necessarily able to receive that data in a readable format. It wasn’t until just recently that confirmation of receipt was available from the receiving entity because it required the receiving system to communicate through the HISP and then back into the receiving system. In light of these challenges, I request that you specifically define electronically. Does that include fax? Traditional email with encrypted attachments? Are there any other means you consider electronic?

In addition, will the exclusion posted in the Modifications to the Medicare and Medicaid Electronic Health Record (EHR) Incentive Program for 2014 and Other Changes to the EHR Incentive Program be upheld such that if the referral sources the provider is accustomed to using do not have direct messaging then the provider can claim an exclusion to this measure?

Public Health Options – Immunization Registry, Page 198:

The Immunization option under Public Health reporting reads as if only a bi-directional interface would count as successfully meeting this option – “receive immunization forecasts and histories”. Please clarify whether or not this is the case and if there will be any grandfathering of current registries. Most states are not able to exchange immunization data in a bi-directional manner and if required, this would pose a significant obstacle and financial hardship for providers to meet the public health option for immunization registry. To date, immunization registry reporting has been the most successful interoperability measure of meaningful use.

Public Health Options – Case Reporting, Page 198:

Cancer Registry reporting is one method of case reporting that many states support, but few CEHRT vendors are able to support. If a practice has purchased certified EHR technology that is unable to transmit to their state cancer registry, would they still be able to meet the definition of active engagement if they register their intent to participate with the state registry as soon as their EHR technology is able to transmit?

Providers need additional examples of case reporting and how they can actively engage in the event that they are excluded from all other public health options. Would a manual batch C-CDA export followed by a manual batch import or upload to a health organization meet the requirements for case reporting?

Public Health Options – Clinical Data Registry, Page 198

Can you further define clinical data registry? For example, if a CEHRT supports an extract, transform, and load process to move data from the client database to a cloud based data warehouse so that the data can be normalized, analyzed and reported on in various methods (PQRS, CQMs, PCMH, etc.), would that meet the definition of clinical data registry reporting?

Meaningful Use and PQRS Extension

We still have time, it is not too late!

The Centers for Medicare and Medicaid Services has extended the attestation deadline for Eligible Professionals participating in the Medicare Meaningful Use program to March 20, 2015, this is great news!

Use the following worksheets to assist with your attestation:

Stage 1 2013 Attestation worksheet

Stage 2 Attestation worksheet

The PQRS deadline was also extended to March 20, 2015. Be sure to verify submission deadlines with your vendor for PQRS also.

This extension means you still have time to both make money this year and avoid penalties in future years.  Remember that 2014 is the last year to receive an incentive for PQRS and the last year to begin participating in the Medicare MU program and be eligible for any incentive money.  Do not leave your incentive money behind, Meaningful use is possible and we can help you!

MEDICAID MU ATTESTATION DEADLINE IS STILL TODAY -- 2/28/2015.

PQRS – Don’t leave your money on the table!

Did you know you could still participate in PQRS for 2014 and not only receive your 0.5% reimbursement based on charges for covered services billed in 2014, but also avoid the 2.0% penalty next year? The deadline for reporting is now as late as March 13th with some vendors.

What is PQRS?

A separate incentive program from meaningful use that is available to eligible providers who provide Medicare part B services. Submitting clinical quality measure data associated with meaningful use does not automatically meet the PQRS reporting requirement, even though some of the measures do overlap.

Who qualifies?

Physicians, practitioners and therapists that bill Medicare Part B services. For a full list, go to: http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/Downloads/PQRS_List-of-EligibleProfessionals_022813.pdf .

What do you do?

1. Choose a reporting option: Clinical registry reporting or claims registry reporting. You can access a list of vendors and pricing on the Medicare website: http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/Downloads/2014QualifiedRegistries.pdf .
2. Based on your choice in #1, you may be able to report on a measure group (Asthma, HTN, Low back pain, etc.) versus picking individual measures. This is easier because it involves a 20 patient sample, 11 of which must be Medicare.

• Measure group – Pick the patient sample based on the measure group you choose, for example, the Preventive Care group is based on a patient sample of 50 years and older with a new or established visit (99201-99205, 99212-99215), so you would pick 20 patient that meet that criteria, 11 of which must be Medicare patients. Then audit those charts against the measures included in that particular measure group.
• Individual measures – Pick 9 PQRS measures based on the measures supported by the vendor you choose and follow the vendor’s instructions for collecting and submitting the data.

Need help? Let us know on the Contact page.

Meaningful Use in 2014 - The Flexibility Rule can make a difference for you!

Do you find that you are forced to use the last calendar quarter of 2014 as your meaningful use reporting period due to installation delays? Are you finding that the certified EHR technology you need to support you in meeting the Stage 2 objectives is just not available or has not been implemented yet? Are you experiencing training nightmares as a result of these delays? If you answered yes to one or more of the questions above, you may experience significant relief from the Flexibility Rule published by CMS on 9/4/2014. Here are some key points:

1.       Providers may use any calendar quarter in 2014 to capture data for attestation, they are not limited to the last quarter of the year.

2.      There is a special provision for providers that are unable to meet the Summary of Care, measure 2, due to the inability to identify recipients of an electronic transmission. In other words, if none of your referral providers have direct addresses for you to send your referral documentation (Summary of Care consolidated-CDA), this would apply to you.

3.       Providers may be able to attest to the 2014 Stage 1 objectives and measures and in some special circumstances the 2013 Stage 1 measures thanks to the flexibility rule.

4.       Providers will have to prove that they were not able to fully implement the 2014 edition of CEHRT. This could be due to availability and timing of software installation (clinical decision support, direct messaging, and clinical quality measure availability, for example) and ties into the ability to implement any new workflows and/or processes necessary to meet the objectives. This is a bit of subjective area so documentation is key in justifying your choice.

Once you make the decision as to whether or not you are eligible for a flexibility option in 2014, the CMS (Table 2) below, does a good job of giving you available options.

Do you know what is in your database?

Data exchange is a hot topic lately. The idea of a health care system with complete and accurate data exchange is very powerful and can open the doors to better, more cost efficient care. With Stage 2 of Meaningful Use forging the way, everyone is in a hurry to get connected without necessarily thinking through what the data looks like and the safeguards that should be implemented to protect your data. As health care providers, we must be vigilant about maintaining the accuracy of the data that we share with others.

Why isn't my data accurate you may wonder?

Data Issue # 1: One reason for inaccurate data is attributable to renaming of clinical items. Imagine that you are searching your EHR for a diagnosis you don't use very often, Kidney Disease for example, and you cannot find it after 4 or 5 tries. Because you have 40 more patients to see, you enter Keloids and change the name to Kidney Disease. Fortunately and unfortunately, the data in the database is identified by one or more codes and just because you change the name or description of the clinical item, the code does not change.

Implications: If I send the chart of the above person using some form of data exchange, the recipient will believe the patient has a history of Keloids instead of Kidney Disease. This has significant clinical implications and is unfortunately very common.

Data Issue # 2: A second reason data is inaccurate is due to the use of free text diagnoses, allergies, medications, etc. Since text varies and cannot be accurately coded it does not exchange well.

Implications: In the event of free text clinical data, you are looking at data being being omitted altogether from the exchange or exchanged in a format that is not usable by the receiving system. This can be quite serious if a patient has a true allergy to a medication that is not communicated.

These are just a couple of the significant issues I am aware of in looking at real life data. It is imperative that we work together towards cleaning up the data we are sharing. 

Consider joining me on the 27th to talk more about exporting and importing patient data.