Do you have unanswered questions or concerns about meeting Stage 2 Meaningful Use (MU) requirements? If so, read on for key information on attestation for MU in 2014 and achieving Stage 2 requirements in 2015.
CEHRT Flexibility Rule
Last September, the Centers for Medicare & Medicaid Services (CMS) issued a ruling that allows providers to use various types of certified electronic health record technology (CEHRT) to attest to the 2013 Stage 1, 2014 Stage 1, or 2014 Stage 2 Objectives and Measures.
However, this option is only available for “providers who are unable to fully implement 2014 Edition CEHRT for an EHR reporting period in 2014 due to delays in 2014 CEHRT availability.” To determine whether your practice qualifies under the CEHRT Flexibility Rule, contact your EHR vendor. Many vendors will also provide a letter of support if you qualify.
MU Stage 2 measures
MU Stage 2 measures have higher thresholds than those in Stage 1. Orthopaedic surgeons have found the following measures to be particularly challenging.
Core Measure 6: Use clinical decision support to improve performance on high-priority health conditions.
The submeasure of this core measure requires providers to implement five clinical decision support interventions that are related to four or more clinical quality measures (CQMs). In the absence of relevant CQMs, providers can choose clinical decision support interventions relevant to the provider’s scope of practice. Finding four or more relevant CQMs is usually challenging for orthopaedists, so identifying those interventions that are most relevant to the scope of practice will be the best approach.
Core Measure 9: Protect electronic health information created or maintained by the CEHRT through the implementation of appropriate technical capabilities.
This measure requires providers to perform a security risk assessment or to review a previously conducted Health Insurance Portability and Accountability Act (HIPAA) security risk assessment. A security risk analysis of CEHRT includes addressing encryption/security of data and implementing updates as necessary. The security risk analysis can be conducted after the reporting period, but must be completed prior to attestation.
Failure to perform a HIPAA security risk assessment can lead to HIPAA breaches and may also result in failing a CMS MU audit. CMS audits 1 out of every 10 providers for HIPAA security risk assessments.
Core Measure 15: Provide a summary of care record for each transition of care or referral.
This measure has the following three required components:
- Provide a summary of care record for more than 50 percent of transitions of care and referrals
- Provide a summary of care record for more than 10 percent of transitions and referrals that is transmitted either (a) electronically using CEHRT or (b) via an exchange that is facilitated by an organization participating in the eHealth Exchange (previously the Nationwide Health Insurance Network), or that is validated through a governance mechanism established by the Office of the National Coordinator for Health Information Technology
- Satisfy one or both of the following criteria: (a) conducts successful electronic exchanges of a summary of care document (part of which is counted in “measure 2”) with a separate entity that uses a different type of EHR technology than the sender’s, or (b) successfully completes test(s) with the CMS-designated test EHR during the EHR reporting period.
A provider who transfers a patient to another setting or refers a patient to another provider fewer than 100 times during the EHR reporting period is excluded from all three measures.
A transition of care summary document could play an important role in improving care coordination. The care summary document allows the new care provider to make well-informed treatment decisions based on a review of the most pertinent information from the referring provider. Patients also appreciate that their providers communicate with each other.
Although achieving this measure appears daunting, providers can start by conducting a thorough review of current workflows for transitions of care and referrals. A process to ensure that a summary of care record is provided for at least 50 percent of all care transitions and referrals should be developed and implemented. This will satisfy the first of the three-part Stage 2 requirements.
The next step would be to identify which transitions of care and referrals are to a recipient who has no organizational affiliation with the practice and uses a different CEHRT vendor. A process to ensure that more than 10 percent of those care transitions or referrals use electronic submission of the summary of care record must be developed and implemented. This will satisfy the remaining parts of the requirement.
Core Measure 17: A secure message was sent using the electronic messaging function of CEHRT by more than 5 percent of unique patients (or their authorized representatives) seen by the provider during the reporting period.
This measure is a core component of patient engagement. However, providers face two major challenges—getting patients to use a patient portal and having patients submit at least one secure message to the practice. (To learn how one practice is addressing this challenge, see “Meeting Meaningful Use: One Practice’s Experiences.”)
To meet these challenges, practices can set up their patient portals so that once a patient is enrolled and logs in for the first time, a message is automatically sent to the clinic confirming successful enrollment. This can be counted as the secure message. Patients can complete enrollment with the assistance of the front desk staff, who can have patients log into the portal before they leave. This ensures that patients are enrolled and the secure message sent. This scenario works best if the reception area includes a private area where patients can sign up for the portal.
Some physicians have expressed concerns about the time required to answer emails from patients. This has not been a problem for several reasons. With immediate access to their laboratory and other test results, patients have less need to call their doctor. Electronic reminders for visits and follow-up appointments also eliminate the need for calls. Emails on medication orders and other aspects of treatment can go directly to a nurse; only those questions beyond the nurse’s scope are forwarded to the physician.
A provider who has no office visits during the reporting period or who practices in an area with low broadband availability is excluded from this measure. Low broadband availability is defined as a county with less than 50 percent of housing units with 3Mbps broadband availability.
The reporting period for CQMs is the same as for MU Stage 2—Jan. 1 to Dec. 31, 2015. CQMs do not have thresholds that must be met, but the data must be reported.
Providers must select and report on 9 of a possible 64 approved CQMs. CQMs must cover at least three of the following domains:
- patient and family engagement
- patient safety
- care coordination
- population/public health
- efficient use of healthcare resources
- clinical process/effectiveness
Orthopaedic surgeons should select the most relevant measures for orthopaedics and measures for which data will be available. The other measures could be those with an expected “zero” response. Providers using the group practice reporting option under the Physician Quality Reporting System (PQRS) should report the same 9 measures for both MU and PQRS.
Help from CMS
Although the requirements for MU were established primarily for primary care providers in practices and hospitals, they also apply to specialists. According to CMS, the requirements are based on improving quality of care for patients and are independent of specialty.
However, specialty practices such as orthopaedics can use specialty templates. For example, an orthopaedic surgeon is not required to do a physical exam of all systems. Due to the nature of the practice, specialist providers may obtain exceptions to some of the requirements. These exceptions should be handled individually with CMS.
Sunny Saran, MBA, a NextGen Certified Professional in Electronic Health Records and Practice Management, is the founder of e2o Health and its subsidiaries MeaningfulUseExperts.com and HIPAAWatchDog.com