New MU

Meaningful Use (MU) Overview
MU Overview
The MU Program is an initiative from the Centers for Medicare & Medicaid Services (CMS) that is funded by the stimulus packages of the American Recovery and Reinvestment Act and the Health Information Technology for Economic and Clinical Health Act of 2009. The 5 goals of MU include:
Eligible Professional (EP) vs. Eligible Hospital (EH)
Healthcare professionals and hospitals must meet the eligibility criteria in order to receive incentive payments for implementing EHR programs.

Eligibility Requirements for Professionals:

  • Each EP is only eligible for one incentive payment per year, regardless of how many practices or locations he/she provides services
  • Hospital-based EP's are not eligible for incentive payments. An EP is considered hospital-based if 90% or more of his/her services are performed in a hospital inpatient or emergency room.
  • CMS MU EP Objectives Stage 2.pdf

Eligibility Requirements for Hospitals:

  • Some hospitals may receive incentive payments from both Medicare and Medicaid if they meet all eligibility criteria.
  • EH's under the Medicare EHR Incentive Program includes hospitals paid under the Inpatient Prospective Payment System, Critical Access Hospitals, and Medicare Advantage Hospitals.
  • EH's under the Medicaid EHR Incentive Progrm include acute care hospitals (with at least 10% Medicaid patient volume) and children's hospitals (no Medicaid patient volume requirements)
  • CMS MU EH Objectives Stage 2.pdf 
Medicare vs. Medicaid Incentive Program
Medicare EHR Incentive Program
Medicaid EHR Incentive Program
Run by CMS
Run by State Medicaid Agency
Maximum incentive amount is $44,000
Maximum incentive amount is $63,750
Payments over 5 consecutive years
Payments over 6 years, does not have to be consecutive
Payment adjustments will begin in 2015 for providers who are eligible but decide not to participate
No payment adjustments for providers who are only eligible for the Medicaid program
Providers must demonstrate meaningful use every year to receive incentive payments.
In the first year providers can receive an incentive payment for adopting, implementing, or upgrading EHR technology. Providers must demonstrate meaningful use in the remaining years to receive incentive payments.
The following are considered EP’s who can participate in the Medicare Incentive Program:
  • Doctors of Medicine, Osteopathy, Optometry, Podiatry, Dental Medicine or Dental Surgery, and Chiropractors
  • Provide less than 90% of Medicare services in the inpatient hospital or ED setting
  • Incentive based on a percentage of Medicare allowed charge
 
The following are considered EP’s who can participate in the Medicaid Incentive Program:
  • Physicians, NPs, and certified nurse midwives
  • Provide less than 90% of Medicaid services in the inpatient hospital or ED setting
  • At least 30% of patients are Medicaid patients
  • Pediatricians are eligible for two-thirds of the incentive if 20%-30% of their patients are Medicaid patients.
 

Medicare EP Tip Sheets:

Medicaid EP Tip Sheets:

MU Stages

Stage 1 – Data capturing and sharing

  • To attain meaningful use, providers must meet 13 core objectives and 5 objectives selected from a menu of 9 additional objectives.
  • These objectives include routine activities such as recording patient demographics, and maintaining an up-to-date problem list, but they also include measures such as protecting health information by performing a Security Risk Analysis and reporting clinical quality data.
  • CMS Stage 1 Changes 2014.pdf

Stage 2 – Advanced clinical processes

  • Beginning in 2014, providers who have already met Stage 1 requirements will need to meet the new requirements for Stage 2. Rather than focusing simply on using an EHR and testing its abilities like in Stage 1, Stage 2 focuses more on patient involvement and care coordination between providers.
  • For Stage 2, providers must meet 17 core objectives and 3 objectives selected from a menu of 10 objectives. Thresholds from Stage 1 are raised, and new objectives are required which include secure electronic messaging and providing a summary of care electronically to referring providers.

Stage 3 – Improved outcomes

  • Stage 3 is scheduled to begin in 2017. CMS is expecting to release Stage 3 guidelines in 2015, which will focus on promoting improvements in quality, safety and efficiency leading to improved health outcomes; focusing on decision support for national high priority conditions; patient access to self-management tools; access to comprehensive patient data through robust, secure, patient-centered health information exchange; and improving population health. For Stage 3, CMS intends to propose higher standards for meeting meaningful use, such having every objective in the menu set for Stage 2 be included in Stage 3 as part of the core set. What Stage is the EP in for 2014?
Eligible Professional Progam Eligibility
Eligible Profesionals
The following are considered EPs who can participate in the Medicare MU Incentive Program:
  • Doctors of Medicine, Osteopathy, Optometry, Podiatry, Dental Medicine or Dental Surgery, and Chiropractors
  • Provide less than 90% of Medicare services in the inpatient hospital or ED setting
The following are considered EPs who can participate in the Medicaid MU Incentive Program:
  • Physician Assistants are eligible for the Medicaid EHR Incentive program only if they furnish services in an FQHC or RHC
  • Provide less than 90% of Medicaid services in the inpatient hospital or ED setting
  • At least 30% of patients are Medicaid patients
  • Pediatricians are eligible for two-thirds of the incentive if 20%-30% of their patients are Medicaid patients
Eligibility.PNG

Eligibility Charts:

Eligibility Flow Charts:

 
MU Reporting Periods
Reporting Period.PNG
Eligibility Year.png
EP Exemptions

EPs can apply for hardship exceptions in the following categories:

Infrastructure
  • EPs must demonstrate that they are in an area without sufficient internet access or face insurmountable barriers to obtaining infrastructure (e.g., lack of broadband).
New EPs
  • Newly practicing eligible professionals who would not have had time to become meaningful users can apply for a 2-year limited exception to payment adjustments.
  • For example, EPs who begin practice in calendar year 2015 would receive an exception to the penalties in 2015 and 2016, but would have to begin demonstrating MU in calendar year 2016 to avoid payment adjustments in 2017.
Unforeseen Circumstances
  • Examples may include a natural disaster or other unforeseeable barrier.
Patient Interaction
  • Lack of face-to-face or telemedicine interaction with patients
  • Lack of follow-up need with patients
Practice at Multiple Locations
  • Lack of control over availability of CEHRT for more than 50% of patient encounters
2014 EHR Vendor Issues
  • The EPs EHR vendor was unable to obtain 2014 certification or the eligible professional was unable to implement meaningful use due to 2014 EHR certification delays.
Exemption Guides:
 
 
 
Meaningful Use (MU) Payments and Penalties
Payment Schedules
MU Stage, Incentive, Reporting Period.PNG
2014 MU Incentives and 2016 Payment Adjustments.PNG
Types of Penalties 
  • Payment adjustments are applied beginning of January 1, 2015 for Medicare EPs who are not meaningful users of Certified EHR Technology under the Medicare EHR Incentive Programs.
  • Medicaid EPs who can only participate in the Medicaid EHR Incentive Program and do not bill Medicare are not subject to these payment adjustments.
  • CMS Payment Adjustments and Exceptions.pdf
Cost Of Penalties
  • The payment adjustment is 1% per year and is cumulative for every year that an EP is not a meaningful user.
  • Depending on the total number of Medicare EP's who are meaningful users under the EHR Incentive Programs after 2018, the maximum cumulative payment adjustment can be as high as 5%.
  
How to Avoid Penalties
  • The EP must demonstrate MU every year according to the timeline below in order to avoid Medicare payment adjustments. For example, an EP who demonstrates MU for the first time in 2013 will avoid the payment adjustment in 2015, but will need to demonstrate MU again in 2014 in order to avoid the payment adjustment in 2016.
  • EPs who first demonstrated MU in 2011 or 2012 must demonstrate MU for a full year in 2013 to avoid payment adjustments in 2015. They must continue to demonstrate MU every year to avoid payment adjustments in subsequent years.
  • Because payment adjustments are mandated to begin on the first day of the 2015 calendar year, CMS will apply a prospective determination for payment adjustments. Therefore Medicare EPs must demonstrate MU prior to the 2015 calendar year in order to avoid the adjustments.
Payment Adjustment.PNG
  • The document below shows payment adjustments for EPs who first demonstrated MU in 2013 and 2014.
  
Computerized Provider Order Entry (CPOE)
Stage 1 - Core (P101/CMS 01)
Goal: >30%

Core Objective (from CMS):
Use 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.

Stage 1 Measure (from CMS):
More than 30 percent of all unique patients with at least one medication in their medication list seen by the EP during the EHR reporting period have at least one medication order entered using CPOE.

Numerator The number of patients in the denominator that have at least one
medication order entered using CPOE.
Denominator Number of unique patients with at least one medication in their medication list seen by the EP during the EHR reporting period.
Alternative Denominator

Number of medication orders created by the EP during the EHR reporting period.* 

Exclusions If an EP writes fewer than one hundred prescriptions during the EHR
reporting period they would be excluded from this requirement.
*Note that the Alternative Orders-based Denominator was added in the Stage 2 Final Rule and is available for Stage 1 after you transition your objectives data to Chronicles.
Stage 2 - Core (P201/CMS 01)
Goal: >60% Meds / >30% Labs / >30% Radiology

Core Objective (from CMS):
Use CPOE 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.  

Stage 2 Measure (from CMS):

1. More than 60 percent of medication orders created by the EP during the EHR reporting period are recorded using CPOE.  

2. More than 30 percent of laboratory orders created by the EP during the EHR reporting period are recorded using CPOE.  

3. More than 30 percent of radiology orders created by the EP during the EHR reporting period are recorded using CPOE.  

Num 1 The number of orders in the denominator recorded using CPOE.
Denom 1

Number of medication orders created by the EP during the EHR reporting period. 

Exc 1

Any EP who writes fewer than 100 medication orders during the EHR reporting period. 

Num 2 The number of orders in the denominator recorded using CPOE.
Denom 2

Number of laboratory orders created by the EP during the EHR reporting period.  

Exc 2

Any EP who writes fewer than 100 laboratory orders during the EHR reporting period.

Num 3 The number of orders in the denominator recorded using CPOE.
Denom 3

Number of radiology orders created by the EP during the EHR reporting period. 

Exc 3

Any EP who writes fewer than 100 radiology orders during the EHR reporting period. 

Drug-Drug and Drug-Allergy Checks
Stage 1 - Core (P102/CMS 02)
Goal: Enable drug-drug and drug-allergy check functionality

Core Objective (from CMS):
Implement drug-drug and drug-allergy checks.

 Stage 1 Measure (from CMS):
The eligible professional has enabled this functionality for the entire reporting period. 
 

Numerator and Denominator This measure does not specify a percentage. Clinicians must submit a Yes or No that they have enabled these alerts throughout the entire period.
Stage 2 - N/A Not a Stage 2 Measure
Goal: N/A

Not A Stage 2 Measure.

Drug-Formulary Checks
Stage 1 - Menu (P103/CMS 01)
Goal: Access at least one internal or external formulary

Menu Objective (from CMS):
Implement drug-formulary checks. 

Stage 1 Measure (from CMS):
The eligible professional has enabled this functionality and has access to at least one internal or external formulary for the entire EHR reporting period. 

Numerator and Denominator

This measure does not specify a percentage. Clinicians must submit a Yes or No that they have enabled these alerts throughout the entire period.

Exclusions Any EP who writes fewer than 100 prescriptions during the EHR reporting period.
Stage 2 - N/A Not a Stage 2 Measure
Goal: N/A
Not A Stage 2 Measure.
Problem List
Stage 1 - Core (P104/CMS 03)
Goal: >80%

Core Objective (from CMS):
Maintain an up-to-date problem list of current and active diagnoses. 

Stage 1 Measure (from CMS):
More than 80 percent of all unique patients seen by the EP have at least one entry or an indication that no problems are known for the patient recorded as structured data.  

Numerator

The number of patients in the denominator who have at least one entry or an indication that no problems are known for the patient recorded as structured data in their problem list.

Denominator Number of unique patients seen by the EP during the EHR reporting period
Exclusions

None

Stage 2 - N/A Not a Stage 2 Measure
Goal: N/A

Not A Stage 2 Measure.


E-Prescribing
Stage 1 - Core (P105/CMS 04)
Goal: >40%

Core Objective (from CMS):
Generate and transmit permissible prescriptions electronically (eRx).

The concept of only permissible prescriptions refers to the current restrictions established by the Department of Justice on electronic prescribing for controlled substances.

Stage 1 Measure (from CMS):
More than 40 percent of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technology.

The determination of whether a prescription is a “permissible prescription” for purposes of the eRx meaningful use objective should be made based on the guidelines for prescribing Schedule II controlled substances in effect when the notice of proposed rulemaking was published on January 13, 2010. We define a prescription as the authorization by an EP to a pharmacist to dispense a drug that the pharmacist would not dispense to the patient without such authorization. We do not include authorizations for items such as durable medical equipment or other items and services that may require EP authorization before the patient could receive them.

Numerator The number of prescriptions in the denominator generated and transmitted electronically.
Denominator Number of prescriptions written for drugs requiring a prescription in
order to be dispensed other than controlled substances during the EHR reporting period.
Exclusions •    This objective and associated measure do not apply to any EP who writes fewer than one hundred prescriptions during the EHR reporting period.
•    Any EP who does not have a pharmacy within their organization and there are no pharmacies that accept electronic prescriptions within 10 miles of the EP's practice location at the start of his/her EHR reporting period.*

 

*Note that the second exclusion was added in the CMS Stage 2 Final Rule and applies only to EPs reporting in 2013 and later years.
Stage 2 - Core (P205/CMS 02)
Goal: >50%

Core Objective (from CMS):
Generate and transmit permissible prescriptions electronically (eRx).

Stage 2 Measure (from CMS):
More than 50 percent of all permissible prescriptions, or all prescriptions, written by the EP are queried for a drug formulary and transmitted electronically using certified EHR technology.

Numerator The number of prescriptions in the denominator generated, queried for a
drug formulary, and transmitted electronically using certified EHR technology.
Denominator Number of prescriptions written for drugs requiring a prescription in
order to be dispensed other than controlled substances during the EHR
reporting period.
Alternative Denominator Number of prescriptions written for drugs requiring a prescription in order to be dispensed during the EHR reporting period.
Exclusions •    Any EP who writes fewer than 100 permissible prescriptions during the EHR reporting period
•    Any EP who does not have a pharmacy within their organization and there are no pharmacies that accept electronic prescriptions within 10 miles of the EP's practice location at the start of his/her EHR reporting period.
Active Medication List
Stage 1 - Core (P106/CMS 05)
Goal: >80%

Core Objective (from CMS):
Maintain active medication list.

Stage 1 Measure (from CMS):
More than 80 percent of all unique patients seen by the EP have at least one entry (or an indication that the patient is not currently prescribed any medication) entered as structured data. 

Numerator

The number of patients in the denominator who have a medication (or an indication that the patient is not currently prescribed any medication) recorded as structured data.

Denominator Number of unique patients seen by the EP during the EHR reporting period.
Exclusions None
Stage 2 - N/A Not a Stage 2 Measure
Goal: N/A

See Summary Of Care Measure / TOC (P224)

Medication Allergy List
Stage 1 - Core (Stage 2 N/A) (P107/CMS 06)
Goal: >80% 

Core Objective (from CMS):
Maintain active medication allergy list.  

Stage 1 Measure (from CMS):
More than 80 percent of all unique patients seen by the EP have at least one entry (or an indication that the patient has no known medication allergies) recorded as structured data. 

Numerator

The number of unique patients in the denominator who have at least one
entry (or an indication that the patient has no known medication allergies) recorded as structured data in their medication allergy list.

Denominator Number of unique patients seen by the EP during the EHR reporting period.
Exclusions

None

Stage 2 - N/A Not a Stage 2 Measure
Goal: N/A

Not A Stage 2 Measure.

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