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NOTICE OF DISCLAIMER
This document is not intended to be a legal opinion on the American Recovery and Reinvestment Act of 2009 (ARRA), and is not intended to be a legal opinion on the EHR Incentive Programs, or any other programs under the ARRA. It is also not intended to be a legal opinion on any other statutes, or any programs under any other statutes. Software Quality Solutions LLC (SQS) does not guarantee the accuracy of the information in the document. SQS has made sincere attempts to understand the complex laws, rules and regulations that govern the EHR Incentive programs, and has made a sincere attempt to provide a basic understanding of the EHR Incentive Programs to Healthcare professionals, through this document. SQS is not responsible for inaccuracy of any information contained in the document. SQS makes it clear that there maybe information, references, links, rules, etc., that may have been modified, deleted or become obsolete or inactive since the creation of this document in Oct 2011, and as modified in Jan 2012. Consult a legal attorney or a general counsel or any other professional in the field of law, healthcare, government, or an appropriate profession, as may apply to your needs, to act in a such way to benefit you, your business, or your profession with regard to the EHR Incentive Program under the ARRA. SQS LLC is not a law firm, and it is not a company that deals exclusively in the healthcare industry.
CONTENTS
1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. American Recovery and Reinvestment Act 2009 (ARRA) . 5 HITECH Act (a part of ARRA) . 6 US Department of Health and Human Services (HHS) ... . 7 Meaningful Use (MU) 8 MU Stage 1 Criteria ... 9 MU Stage 1, 2 and Stage 3 Criteria Timeline ..10 Certified EHR Technology and Meaningful Use ... . 11 Medicare Incentive Payments ... . 12 Medicare - Eligible Professionals (EPs) Incentive Payments . 13 Medicare Eligible Hospitals Incentive Payments ... .14 Medicare Critical Access Hospitals (CAHs) ... 15 Medicaid Incentive Payments ... 16 Medicaid Eligible Professionals (EPs) Incentive Payments 17 Medicaid Eligible Hospitals Incentive Payments ... . 18 Medicaid Critical Access Hospitals (CAHs) Incentive Payments ... 19 Industry Adoption EHR Incentive Payments ... 20 MU Stage 1 Criteria - Core Set of Objectives .. ..21 MU Stage 1 Criteria - Core Set of Objectives (1-5) ..22 MU Stage 1 Criteria - Core Set of Objectives (6-10) 23 MU Stage 1 Criteria - Core Set of Objectives (11-16) . 24 MU Stage 1 Criteria Menu Set of Objectives .. . 25 MU Stage 1 Criteria Menu Set of Objectives (1-5) .. 26 MU Stage 1 Criteria Menu Set of Objectives (6-9) .. 27
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CONTENTS
24. 25. 26. 27. 28. 29. 30. 31. 32. 33. MU Stage 1 Criteria Menu Set of Objectives (10-12) .. 28 MU Stage 1 Criteria Clinical Quality Measures (CQMS) for EPs ... 29 MU Stage 1 Criteria CQMS for EPs (Core Set and Alternate Core Set) . 30 MU Stage 1 Criteria CQMS for EPs (Additional Set 1-14) 31 MU Stage 1 Criteria CQMS for EPs (Additional Set 15-28) . 32 MU Stage 1 Criteria CQMS for EPs (Additional Set 29-38) . 33 MU Stage 1 Criteria CQMS for Eligible Hospitals .. . . 34 MU Stage 1 Criteria CQMS for Eligible Hospitals (1 -15 End) . . 35 EHR Incentive Program - Information Resource Links (1-25) 36 EHR Incentive Program - Information Resource Links (25-30) . 37
For questions, suggestions, or feedback please contact via email to manager@sqssolutions.com
Approximate cost of the stimulus package - $787 billion, at the time of passage
Includes, spending in infrastructure, education, energy, health and human services, federal tax incentives, and expansion of unemployment benefits and social welfare provisions About $153 billion was allocated for Health and Human Services spending (out of which $22.6 billion for health information technology investments, and incentive payments)
Not to be mistaken with the Patient Protection and Affordable Care Act, that was passed a year later in March 2010 (also called as Health Care Reform Bill, or by some as Obama Care)
5
HITECH Act
(Health Information Technology for Economic and Clinical Health Act)
Objective: Reform the healthcare infrastructure and improve healthcare quality, healthcare efficiency, and patient safety HITECH Act establishes incentive payments under Medicare and Medicaid programs, for the following participants in the programs: Eligible professionals (EPs); Eligible hospitals; and Critical access hospitals (CAHs) to promote the adoption, and meaningful use of certified EHR technology. Incentives will be distributed through Medicare and Medicaid payments to the participants who are meaningful EHR users. Payment adjustments will be applied under Medicare program, if the participants do not demonstrate meaningful use of certified EHR technology. No payment adjustments in Medicaid program
6
CMS is yet to decide the timeline for issuing Stage 3 Criteria for meaningful use. However, the goal is to align all three stage s of meaningful use criteria by 2015.
ONC issued a certification program on June 24, 2010, that: identified the ONC Authorized Testing And Certification Bodies (ONC-ATCBs), and laid out the process to be followed by ONC-ATCBs to test and certify an EHR technology ONC issued a final rule on July 28, 2010, that : specified a set of standards, implementation specifications, and certification criteria that an EHR technology needs to comply, to be recognized as a Certified EHR Technology These testing standards and criteria issued by the ONC are in alignment with Stage 1 Criteria for meaningful use, defined by the CMS 8
Stage 2 Criteria: Status Very likely to be defined in mid 2012 (pushed from end of 2011). For the year 2013, CMS expects an EP, eligible hospital or CAH to: Repeat demonstration of Stage 1 criteria for meaningful use
Or, Start demonstration of Stage 1 criteria for meaningful use, if they have not demonstrated Stage 1 criteria any year before. For the year 2014, CMS expects an EP, eligible hospital or CAH to: Start demonstration of Stage 2 criteria, if they only demonstrated Stage 1 criteria in 2013.
Or, demonstrate Stage 1 criteria, if they have not demonstrated any meaningful use criteria at all, till then. Stage 3 Criteria: Status Yet to be determined. Will be defined in future rule making. For the year 2015, CMS expectation from EP, eligible hospital and CAH is yet to be determined. The goal is to align all 3 stages of meaningful use criteria by 2015.
10
12
Payment adjustments will be applied , if the EPs do not demonstrate a meaningful use of certified EHR technology in the year 2015 and thereafter. EPs eligible to participate in Medicare and Medicaid EHR Incentive Programs, must choose one they would like to participate. After a payment is made, EPs will be allowed to change once before 2015. EPs serving in a geographic Health Professional Shortage Area (HPSA) are eligible for a 10 percent increase, and the maximum incentive payment they can receive is $48,400.
13
Payment adjustments will be applied if the eligible hospitals do not demonstrate a meaningful use of certified EHR technology in the year 2015 or thereafter. 14
A - Allowable Cost Amount: The allowable cost amount equals the costs of depreciable assets purchased,
such as computers and associated software, excluding any depreciation and interest expenses associated with the acquisition of certified EHR technology. Any previous cost that has not been fully depreciated. M - Medicare Share: [1.Medicare/(2.Total x 3.Charges)] 1.Medicare: number of acute care inpatient bed days (beneficiaries under Part A payment, and MA Part C Beneficiaries). 2. Total: number of Total Acute Care Inpatient Bed Days. 3.Charges: [(Total Charges for such period, minus Charges for Charity Care) divided by (Total Charges)] + a 20 percentage points [added to the Medicare Share calculation (not to exceed 100 percent)]. The incentive payments are as follows: 2011- A * M-> (First Year) 2012- A * M-> 2012- A * M-> (First Year) 2013- A * M-> 2013- A * M-> 2013- A * M-> (First Year) 2014-A * M-> 2014-A * M-> 2014-A * M-> 2014-A * M-> (First Year) 2015 - N/A 2015-A * M 2015-A * M 2015-A * M 2015-A * M (First Year) 2016 - N/A 2016 - N/A 2016 - N/A 2016 - N/A 2016 - N/A
Payment adjustments will be applied if a CAH does not demonstrate a meaningful use of certified EHR technology in the year 2015 or thereafter.
15
16
N/A
Total: $63,750
N/A
Total: $63,750
2021- $8,500 N/A N/A N/A Total: $63,750 No payment adjustments if EPs do not demonstrate meaningful use of certified EHR technology.
17
No payment adjustments if eligible hospitals do not demonstrate meaningful use of certified EHR technology.
18
The Medicaid Incentive Payments to CAHs, are based on the same methodology as Medicaid Eligible Hospital Incentive Payments. (Please see previous slide 17 for Medicaid Eligible Hospitals Incentive Payment)
19
20
21
Measure of Compliance
More than 30% of unique patients with at least one medication in their medication list seen by the EP or admitted to the eligible hospitals or CAHs inpatient or emergency department (POS 21 or 23) have at least one medication order entered using CPOE
2
3
Generate and transmit permissible prescriptions electronically (eRx) Record demographics: Preferred Language; Gender; Race; Ethnicity ; and Date of Birth
N/A
Record demographics: Preferred Language; Gender; Race; Ethnicity ; Date of Birth; and Date and preliminary cause of death in the event of mortality in the eligible hospital or CAH Maintain an up-to-date problem list of current and active diagnoses
More than 40% of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technology More than 50% of all unique patients seen by the EP or admitted to the eligible hospitals or CAHs inpatient or emergency department (POS 21 or 23) have demographics recorded as structured data More than 80% of all unique patients seen by the EP or admitted to the eligible hospitals or CAHs inpatient or emergency department (POS 21 or 23) have at least one entry or an indication that no problems are known for the patient recorded as 22
Measure of Compliance More than 80% of all unique patients seen by the EP or admitted to the eligible hospitals or CAHs inpatient or emergency department (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
More than 80% of all unique patients seen by the EP or admitted to the eligible hospitals or CAHs inpatient or emergency department (POS 21 or 23) have at least one entry (or an indication that the patient has no known medication allergies) recorded as structured data More than 50% of all unique patients age 2 and over seen by the EP or admitted to eligible hospitals or CAHs inpatient or emergency department (POS 21 or 23), height, weight and blood pressure are recorded as structured data More than 50% of all unique patients 13 years old or older seen by the EP or admitted to the eligible hospitals or CAHs inpatient or emergency department (POS 21 or 23) have smoking status recorded as structured data Implement one clinical decision support rule 23
Record and chart changes in vital signs: Height; Weight; Blood Pressure; Calculate and display BMI Plot and display growth chart for 220 years, including BMI Record smoking status for patients 13 years old or older
Record and chart changes in vital signs: Height; Weight; Blood Pressure; Calculate and display BMI Plot and display growth chart for 220 years, including BMI Record smoking status for patients 13 years old or older
10
Implement one clinical decision support rule relevant to specialty or high clinical priority along with the ability to track compliance that rule
Implement one clinical decision support rule relevant to specialty or high clinical priority along with the ability to track compliance that rule
Measure of Compliance
For 2011, provide aggregate numerator and denominator, and exclusions through attestation. For 2012, electronically submit the clinical quality measures. More than 50% of all patients who request an electronic copy of their health information are provided it within 3 business days
12
Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, medication allergies), upon request N/A
13
14 15
Provide clinical summaries for patients for each office visit Capability to exchange key clinical information (for example, problem list, medication list, medication allergies, diagnostic test results), among providers of care and patient authorized entities electronically Protect electronic health information created or maintained by the certified EHR technology through the implementation of appropriate technical capabilities
N/A 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 Protect electronic health information created or maintained by the certified EHR technology through the implementation of appropriate technical capabilities
More than 50% of all patients who are discharged from an eligible hospital or CAHs inpatient department or emergency department (POS 21 or 23) and who request an electronic copy of their discharge instructions are provided it at discharge Clinical summaries provided to patients for more than 50% of all office visits within 3 business days Performed at least one test of certified EHR technology's capacity to electronically exchange key clinical information
16
Conduct or review a security risk analysis per 45 CFR 164.308 (a)(1) and implement security updates as necessary and correct identified security deficiencies as part of its risk 24 management process
25
Measure of Compliance
The EP/eligible hospital/CAH has enabled this functionality and has access to at least one internal or external drug formulary More than 50% of all unique patients 65 years old or older admitted to the eligible hospitals or CAHs inpatient department (POS 21) have an indication of an advance directive status recorded More than 40% of all clinical lab tests results ordered by the EP or by an 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 either in a positive/negative or numerical format are incorporated in certified EHR technology as structured data Generate at least one report listing patients of the EP, eligible hospital or CAH with a specific condition.
N/A
Incorporate clinical lab-test results into certified EHR technology as structured data
Incorporate clinical lab-test results into certified EHR technology as structured data
Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research or outreach Send reminders to patients per patient preference for preventive/ follow up care
Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research or outreach N/A
More than 20% of all unique patients 65 years or older or 5 years old or younger were sent an appropriate reminder during the EHR reporting period
26
Measure of Compliance
More than 10% 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 EPs discretion to withhold certain information
Use certified EHR technology to identify patient-specific education resources and provide those resources to the patient if appropriate The EP, 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 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 of care record for each transition of care or referral
More than 10% of all unique patients seen by the EP or admitted to the eligible hospitals or CAHs inpatient or emergency department (POS 21 or 23) during the EHR reporting period are provided patient-specific education resources The EP, eligible hospital or CAH performs medication reconciliation for more than 50% of transitions of care in which the patient is transitioned into the care of the EP or admitted to the eligible hospitals or CAHs inpatient or emergency department (POS 21 or 23).
The EP, eligible hospital or CAH who transitions their patient to another setting of care or provider of care provides a summary of care record for more than 50% of transitions of care and referrals.
27
Measure of Compliance
Performed 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 (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) Performed at least one test of certified EHR technology capacity to provide electronic submission of reportable lab results to public health agencies and follow-up submission if the test is successful (unless none of the public health agencies to which eligible hospital or CAH submits such information have the capacity to receive the information electronically) 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)
11
N/A
Capability to submit electronic data on reportable (as required by state or local law) lab results to public health agencies and actual submission in accordance with applicable law and practice
12
Capability to submit electronic syndromic surveillance data to public health agencies and actual submission in accordance with applicable law and practice
Capability to submit electronic syndromic surveillance data to public health agencies and actual submission in accordance with applicable law and practice
28
MU Stage 1 Criteria Clinical Quality Measures (CQMS) - Eligible Professionals (EPs) >>
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MU Stage 1 Criteria- Clinical Quality Measures (CQMS) For Eligible Professionals (EPs)
Core Set of CQMS
NQF Measure Number & PQRI Implementation Number
1 NQF 0013
NQF 0028
MU- Stage 1 Criteria CQMS- Additional Set (1-14) For Eligible Professionals (EPs)
Additional Set of 38 CQMS
NQF Measure Number & PQRI Implementation Number
1 NQF 0059; PQRI 1
2
3 4 5 6 7 8
9
10 11 12 13 14
Coronary Artery Disease (CAD): Oral Antiplatelet Therapy Prescribed for Patients with CAD
Heart Failure (HF): Beta-Blocker Therapy for Left Ventricular Systolic Dysfunction (LVSD) Anti-depressant medication management: (a) Effective Acute Phase Treatment, (b)Effective Continuation Phase Treatment Primary Open Angle Glaucoma (POAG): Optic Nerve Evaluation Diabetic Retinopathy: Documentation of Presence or Absence of Macular Edema and Level of Severity of Retinopathy Diabetic Retinopathy: Communication with the Physician Managing Ongoing Diabetes Care 31
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Patients Smoking and Tobacco Use Cessation, Medical Assistance: a) Advising Smokers and Tobacco Users to Quit, b) Discussing Smoking and Tobacco Use Cessation Medications, c) Discussing Smoking and Tobacco Use Cessation Strategies Diabetes: Eye Exam
Diabetes: Urine Screening Diabetes: Foot Exam Coronary Artery Disease (CAD): Drug Therapy for Lowering LDL-Cholesterol Heart Failure (HF): Warfarin Therapy Patients with Atrial Fibrillation Ischemic Vascular Disease (IVD): Blood Pressure Management Ischemic Vascular Disease (IVD): Use of Aspirin or Another Antithrombotic 32
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26 27
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NQF 0004
NQF 0012 NQF 0014
32
33 34 35 36 37 38
NQF 0018
NQF 0032 NQF 0033 NQF 0036 NQF 0052 NQF 0075 NQF 0575
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34
9
10 11 12 13 14 15
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