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Meaningful Use Stage 2 | A View on Penalties and Repercussions | Part One

Posted by Kay Wind on November 19, 2013 at 1:16 PM

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The first part in our two-part series: Meaningful Use 2 - A View on Penalties and Repercussions. The series takes an in-depth and comprehensive look at the background of Meaningful Use, as well as the measures and objectives of MU Stage 1 and Stage 2. Click here to read part two

The Health Information Technology for Economic and Clinical Health Act (HITECH Act), which was signed into law as part of the American Recovery and Reinvestment Act of 2009 (ARRA), established a series of incentives and penalties to encourage medical practitioners to adopt electronic health records (EHRs). The HITECH Act established criteria for Meaningful Use (MU). The Centers for Medicare and Medicaid Services (CMS) was tasked with validating MU to ensure that providers and hospitals weren’t just installing EHRs, but using them in a way that actually improved patient outcomes. Medicare and Medicaid eligible providers must meet a series of objectives and then attest to MU by registering with CMS and providing the necessary data.

Meaningful Use Requirements and Attestation

The ARRA includes as much as $27 billion over ten years to support the adoption of EHRs. EHRs can improve patient care and minimize costs by reducing the occurrence of adverse drug events through clinical decision support rules, easier access to patient records, increased patient outreach, and a greater percentage of generic prescribing.

Achieving these and other benefits requires that practitioners not simply move health information from paper to electronic form but also utilize productivity- and safety- enhancing EHR functions such as entering prescriptions through the computer so that the prescription can be automatically checked against the patient’s allergies and for interactions with other drugs that patient is taking. Providers are required to meet progressively more stringent MU requirements over the course of the program in order to ensure that the full potential of EHRs is achieved.

Three Stages of Meaningful Use

CMS has divided MU into three stages.

  • Stage 1 began January 1, 2011, and places a focus on data collection. Eligible providers will participate in no less than 2 years of Stage 1 regulations. In Stage 1, providers are expected to meet performance measures for 15 core and 5 of 10 menu objectives as well as a number of clinical quality measures.

  • Stage 2 is scheduled to begin January 1, 2014 for those providers that have completed a minimum of two years of Stage 1 of Meaningful Use. Stage 2 places a heavy emphasis on exchange of data.

  • Stage 3 is tentatively set to begin on January 1, 2015. No rules have been proposed yet for Stage 3 of Meaningful Use.

EHR Incentive Programs

The HITECH Act established separate incentive programs for providers servicing Medicaid and Medicare patients. The Medicaid program offers a maximum payout of $63,750 over six years, while the Medicare program offers a maximum of $44,000 over five years. The last year to begin participation in the Medicaid program is 2016, while the last year to participate in Medicare program is 2014. To qualify for the Medicaid program, eligible providers must have a minimum of 30% Medicaid population; pediatricians can qualify with a minimum of 20% Medicaid population. Providers must demonstrate the Medicaid population over a 90 day period from the previous calendar year. To qualify for the Medicare program, providers must bill for at least one Medicare patient. Eligible providers also must have a minimum of $24,000 in total Medicare allowables to receive the maximum incentive under the Medicare plan. If the provider ends the year with less than $24,000, the provider will receive 75% of their allowables as their incentive.

 

Disbursement schedule for Medicare MU program

Adopted in 2011

Adopted in 2012

Adopted in 2013

Adopted in 2014

2011 $18,000      
2012 $12,000 $18,000    
2013 $8,000 $12,000 $15,000  
2014 $4,000 $8,000 $12,000 $12,000
2015 $2,000 $4,000 $8,000 $8,000
2016   $2,000 $4,000 $4,000

Total

$44,000 $44,000 $39,000 $24,000

 

Disbursement schedule for Medicaid MU program

Adopted in 2011

Adopted in 2012

 

Adopted 2014

Adopted in 2015

Adopted in 2016

2011 $21,250          
2012 $8,500 $21,250        
2013 $8,500 $8,500        
2014 $8,500 $8,500   $21,250    
2015 $8,500 $8,500   $8,500 $21,250  
2016 $8,500 $8,500   $8,500 $8,500 $21,250
2017   $8,500   $8,500 $8,500 $8,500
2018       $8,500 $8,500 $8,500
2019       $8,500 $8,500 $8,500
2020         $8,500 $8,500
2021           $8,500
Total $63,750 $63,750   $63,750 $63,750 $63,750

 

The Medicaid program allows the provider to receive the first year’s incentive by simply adopting, upgrading or implementing a certified EHR solution. In the second year, the provider only needs to prove MU for any consecutive 90 day period.

After the second year, the provide needs to prove MU for the entire year to receive the incentive. Medicare providers must show MU for 90 continuous days to quality in their first year and show MU for the full year in subsequent years. Medicare providers will be subject to a 1% penalty if they do not successfully attest by October, 1, 2014, while Medicaid providers will not be subject to penalties under current law. A provider that qualifies for both programs should elect to participate in the Medicaid program because of its higher payout and relaxed MU requirements in the first two years.

Providers attest to MU by entering numerators and denominators for each measure at the CMS website for Medicaid providers. The website used for Medicaid registration varies by state. Medicaid providers do not need to attest to MU during Year 1 but must submit evidence they have purchased, implemented or upgraded to a certified EHR solution.

Meaningful Use Stage 1

Stage 1 Meaningful Use objectives

To qualify for MU incentives, providers must use EHR technology that is certified by Office of the National Coordinator (ONC) and Authorized Testing and Certification Bodies (ATCBs). EHR products can be fully certified for all 25 MU objectives and a minimum of 9 Clinical Quality Measures, or modular, which means they are certified for a portion of the 25 objectives and 44 Clinical Quality Measures. Providers can either purchase a fully certified solution or purchase modular solutions that together meet the certification criteria.

Stage 1 Meaningful Use Core Objectives

  1. Use computerized provider order entry (CPOE) for medication orders directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local and professional guidelines.
  2. Implement drug-drug and drug-allergy interaction checks.
  3. Maintain an up-to-date problem list of current and active diagnoses.
  4. Generate and transmit permissible prescriptions electronically (eRx).
  5. Maintain active medication list
  6. Maintain active medication allergy list
  7. Record all of the following demographics:
    1. Preferred language
    2. Gender
    3. Race
    4. Ethnicity
    5. Date of birth
  8. Record and chart changes in the following vital signs:
    1. Height
    2. Weight
    3. Blood Pressure
    4. Calculate and display body mass index (BMI)
    5. Plot and display growth charts for children 2-20 years, including BMI.
  9. Record smoking status for patients 13 years old or older.
  10. Report ambulatory clinical quality measures to CMS or, in the case of Medicaid eligible providers (EPs), the States.
  11. Implement one clinical decision support rule relevant to specialty or high clinical priority along with the ability to track compliance with that rule.
  12. Provide patients with an electronic copy of their health information (including diagnostics test results, problem list, medication lists, medication allergies) upon request.
  13. Provide clinical summaries for patients.
  14. Capability to exchange key clinical information (for example, problem list, medication list, allergies, and diagnostic test results), among providers of care and patient authorized entities electronically.
  15. Protect electronic health information created or maintained by the certified EHR technology through the implementation of appropriate technical capabilities.

Stage 1 MU Menu Objectives

  1. Implement drug formulary checks.
  2. Incorporate clinical lab-test results into EHR as structured data.
  3. Generate patient lists by specific conditions to use for quality improvement, reduction of disparities, research, or outreach.
  4. Send patient reminders per patient preference for preventive/follow-up care.
  5. Provide patients with timely electronic access to their health information (including lab results, problem list, medication lists, and allergies) within four business days of the information being available to the EP.
  6. Use certified EHR technology to identify patient-specific education resources and provide those resources to the patient if appropriate.
  7. The EP who receives a patient from another setting of care or provider of care or believes an encounter is relevant should perform medication reconciliation.
  8. The EP 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 care record for each transition of care or referral.
  9. Capability to submit electronic data to immunization registries or immunization information systems and actual submission according to applicable law and practice.
  10. Capability to submit electronic syndromic surveillance data to public health agencies and actual submission according to applicable law and practice.

Stage 1 MU Performance Measures

Some objectives require performance measures to be met. For example, one of the performance measures requires 40% of the provider’s prescriptions must be sent to the pharmacy electronically. Another performance measure requires providers to enter height, weight and blood pressure measurements into the EHR for 50% of its patients. There are also 44 clinical quality measures (CQM). These measures emphasize collecting further detail during the patient encounter and using that information for follow-up. For example one measure requires providers to distribute a smoking cessation plan to patients who smoke. CQMs do not have performance requirements. However, when attesting to MU, providers must submit numerators and denominators for at least six measures.

In our next post we will be looking at Meaningful Use Stage 2 measures, core objectives, stage 1 versus stage 2, clinical quality measures and penalties and repercussions.

 

 Meaningful Use

 

Topics: Meaningful Use

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