The document summarizes changes to the 2016 requirements for meaningful use of electronic health records (EHRs). Key changes include replacing core and menu objectives with a single set of objectives and measures for eligible professionals (EPs) and hospitals. EPs have 10 objectives and hospitals have 9 objectives. The objectives focus more on patient outcomes than technology use. Providers will also have more flexibility to customize goals. Audits of EHR meaningful use attestations will continue to ensure compliance. Providers should maintain documentation for at least 6 years to support any audits.
2. 2016 Program
Requirements
Final Rule Released October 15, 2015
Modified Stage 2 (2015 to 2017)
Stage 3 (2018 and beyond)
Jan 11, 2016
“Meaningful use will likely end in 2016”
- Andy Slavitt, Acting Administrator
Centers for Medicare and Medicaid Services
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3. “The Meaningful Use program as it has
existed, will now be effectively over and
replaced with something better.”
focus will move away from the use of technology
and towards patient’s outcome
providers will be able to customize their goals
leveling the technology playing field by requiring
open application program interfaces (APIs)
interoperability
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4. Medicare Access and CHIP
Reauthorization Act of 2015
(MACRA)
Repeals the sustainable growth rate (SGR)
methodology for determining updates to the Medicare
physician fee schedule.
Establishes annual positive or flat fee updates for 10
years and institutes a two-track fee update beginning
in 2019.
Establishes the Merit-based Incentive Payment
System (MIPS) that consolidates existing Medicare
quality programs.
Establishes a pathway for physicians to participate in
an Alternative Payment Model (APM).
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6. Objectives and Measures
Core and menu objectives replaced with a
single set of objectives and measures.
Eligible providers (EP) have 10 objectives,
Eligible hospitals and CAHs have 9 objectives.
All providers must use 2014 certified EHR
technology
Providers may attest using 2015 certified
technology EHR technology, or a combination of
the two (if the 2015 Edition is available).
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7. EP Objectives and
Measures
1. Protect electronic protected health information
HIPAA (Security Risk Analysis, updates, other)
2. Use clinical decision support to improve
performance on high-priority health conditions.
Implement five clinical decision measures
Enabled and implemented the functionality for drug-drug
and drug-allergy interaction check
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8. EP Objectives and
Measures
3. Use computerized provider order entry for
medication, laboratory, and radiology by
licensed healthcare professional
More than 60 percent of medication orders
More than 30 percent of laboratory orders
More than 30 percent of radiology orders
4. Generate and transmit permissible prescriptions
electronically (eRx).
More than 50 percent of all permissible prescriptions
written by the EP are queried for a drug formulary
and transmitted electronically using CEHRT.
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9. EP Objectives and
Measures
5. Health Information Exchange
Transitions or refers their patient to another setting of
care or provider of care must
1. Use CEHRT to create a summary of care record; and
2. Electronically transmit summary (10% or more).
6. Identify patient-specific education resources and
provide those resources to the patient.
Provide education resources to patients for more
than 10 % of all unique patients with office visits
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10. EP Objectives and
Measures
7. Medication Reconciliation
Performs medication reconciliation for more than 50
% of transitions of care
8. Patient electronic access within 4 business days
of the information being available to the EP.
Provide timely access to more than 50 % of all
unique patients seen during the reporting period
2016, at least one patient during the EHR reporting
period (or patient-authorized representative) views,
downloads or transmits his or her health information
to a third party during the EHR reporting period.
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11. EP Objectives and
Measures
9. Secure electronic messaging communications.
At least 1 patient during the reporting period was
sent a message using the electronic messaging
function of CEHRT
10. Public Health - submit electronic public health
Three Measure Options
○ Immunization Registry Reporting
○ Syndromic Surveillance Reporting
○ Specialized Registry Reporting
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12. Changes to Specific Objectives
The Objective 9, Secure Electronic
Messaging:
Phased approach for its measure’s threshold.
For 2016, the measure is “for at least 1 patient seen
during the reporting period, a secure message was
sent using the electronic messaging function of
CEHRT, or in response to a secure message sent by
the patient.
Objective 10, Public Health Reporting, 2016
EPs must meet two measures,
Eligible hospitals and CAHs must meet three measures.
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13. EHR Reporting Period for 2016
Returning participants
Full calendar year
(Jan 1, 2016 through Dec 31, 2016.
For 1st year participants
Any continuous 90-day period.
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14. Regulations leading to
audits
Meaningful Use,
HIPAA Omnibus Rule,
Affordable Care Act,
ICD-10 and
MACRA
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15. What to expect
1. Electronic letter from audit company from a
CMS e-mail address;
Letter will be addressed to email address
provided during registration
2. Attachment with a request for support
documentation
3. About four weeks to submit documentation
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18. Highlights
Measure 1 – Protect Patient Health
Information
Security Risk Analysis with a date not earlier
than the start of the reporting year and not
later than the date of attestation
Implementation plan with completion dates if
deficiencies were identified
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19. Highlights
Measures 3,4,5,6,7, and 8
Provide EHR report
Measures 2 and 9
Provide Support Documentation
Measure 10
Stage 1 – one measure
Stage 2 – two measure
Note: an exclusion of one measure doesn’t
count unless they meet or exclude themselves
from the other measures
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20. Trends Experienced
Expect e-mail with deficiencies
indicating failure to meet meaningful use
Extensions timelines have been
shortened
Explanations of trends may be asked
Letter from EHR company with basic
information been requested
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21. Key Items to keep in mind
Proof of use Certified EHR.
Need Copy of licensing agreement with the vendor or
invoices for the period.
Letter with same information from HER Vendor may
be requested.
List of office or outpatient facility where
Provider sees patients. Identify if records are
kept outside of EHR.
Report showing compliance with specific Core
Measures must display vendor’s logo or step by step
screenshots which demonstrate that the report was
generated by the EHR.
KEEP INFORMATION FOR A MINIMUM OF
SIX YEARS!
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22. Summary
Meaningful use not going away
Audits will continue
Maintain your own copies of information
submitted for at least six years
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23. Questions
Taino Consultants Inc.
Dr. Jose I. Delgado BP 904-794-7830
E-mail DrDelgado@TainoConsultants.com
Web Site: www.TainoConsultants.com
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Notas del editor
Eligible Professional Objectives and Measures
(1) Protect electronic protected health information created or maintained by the CEHRT through the implementation of appropriate technical capabilities.
(2) Use clinical decision support to improve performance on high-priority health conditions.
(3) Use computerized provider order entry for medication, laboratory, and radiology orders directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local, and professional guidelines.
(4) Generate and transmit permissible prescriptions electronically (eRx).
(5) Health Information Exchange - The EP who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care provides a summary care record for each transition of care or referral.
Eligible Professional Objectives and Measures
(1) Protect electronic protected health information created or maintained by the CEHRT through the implementation of appropriate technical capabilities.
(2) Use clinical decision support to improve performance on high-priority health conditions.
(3) Use computerized provider order entry for medication, laboratory, and radiology orders directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local, and professional guidelines.
(4) Generate and transmit permissible prescriptions electronically (eRx).
(5) Health Information Exchange - The EP who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care provides a summary care record for each transition of care or referral.
(7)The EP who receives a patient from another setting of care or provider of care or believes an encounter is relevant performs medication reconciliation.
(8) Patient electronic access-Provide patients the ability to view online, download, and transmit their health information within 4 business days of the information being available to the EP.
(9) Use secure electronic messaging to communicate with patients on relevant health information.
(10) Public Health Reporting-The EP is in active engagement with a public health agency to submit electronic public health data from CEHRT except where prohibited and in accordance with applicable law and practice.
Measure 1‐Immunization Registry Reporting: The EP is in active engagement with a public health agency to submit immunization data.
Measure 2–Syndromic Surveillance Reporting: The EP is in active engagement with a public health agency to submit syndromic surveillance
data.
Measure 3–Specialized Registry Reporting: The EP is in active engagement to submit data to a specialized registry