Last Tuesday, CMS and ONC released rulings for 2015-2017 Modified Stage 2 objectives as well as some details for Stage 3 MU. News spread quickly that the changes outlined in the Modified Stage 2 objectives opened up the field for eligible providers to meet MU Stage 1 and Stage 2 for this reporting year, whereas the previous criteria were quite challenging for most. CMS has provided the summary of changes for the new objectives for 2015-2017. What happens now that the final ruling has passed? First, each healthcare organization will need to understand what actually has changed in the new Modified Stage 2 and how it impacts end users. Likewise, Electronic Health Record (EHR) vendors and organizations with alternative reporting warehouses will need to accommodate the changes to the new metrics for MU reporting. I have highlighted some key areas to consider with the final ruling below.
- 90-day reporting period for MU 2015, both Core and Clinical Quality Measures
- Patient Access – now only one patient is required to view, download, or transmit his/her information during the reporting period. Previously, it was 5% of patients.
- Secure Messaging – The original threshold of 5% of patients being required to send or receive messages has been eased. To receive credit, clinicians now only need to demonstrate the ability to generate secure messaging.
- Single set of ten (10) objectives for all EPs regardless of Stage (1 or 2)
- No Menu objectives to select from in the Modified Stage 2 objectives
- Clinical Quality Measures are the same for MU
What goes? Does that mean we stop doing it? The original intent of MU was to focus on the use of the EHR to improve patient care, and the later stages focus on patient quality outcomes. Some of the criteria were certainly viewed as “busy work” by staff. However, many of the core measures below that have been removed are still required to some degree as part of the Clinical Quality Measures. For example, obtaining blood pressure and smoking status for NQF 0018 and NQF 0028, respectively, remain quality metrics for Physician Quality Reporting System (PQRS) and MU Clinical Quality Measures reporting.
- Record demographics
- Capture vitals
- Smoking status
- Provide clinical summaries
- Lab Results
- Generate patient list
- Patient reminders
What stays? Ten Objectives are required in Modified Stage 2. All providers, whether they attest to Stage 1 or 2, will report on the exact same measures. There are some caveats. If EPs are reporting on Stage 1 in the Modified Stage 2 objectives, they will see lower thresholds for many of the objectives, which is listed in the ten objectives outlined by CMS.
- Protect Patient Health
- Clinical Decision Support
- Computerized Provider Order Entry
- Electronic Prescribing
- Health Information Exchange
- Patient Education
- Medication Reconciliation
- Patient Electronic Access
- Secure Messaging
- Public Health Reporting
What’s next? What do healthcare organizations need to consider?
- Organizations should begin internal communications on the changes contained in this latest ruling. Be clear on what work is no longer required to be performed. Detailed discussions on what items remain will need to take place. For many organizations, there may be discussion around maintaining workflows for measures such as providing a clinical summary or sending patient reminders and the value added along with detailed directions to end users. Organizations will need to consider any configuration changes based on these decisions (for example, if an EHR has alerts for certain items such as vitals or demographics, should they remain enabled?).
- Once modifications are completed, organizations with their own data warehouse (EDW) will need to ensure reports are updated and validated to capture the correct metrics for the 90-day reporting period.
- 2016 and 2017 will be a full calendar reporting period for all EP’S unless newly attesting for the first time for MU. Organizations will need to have close monitoring throughout next year to ensure providers stay on track with the new measures and quickly identify any poor performers for early remediation.
As a reminder, PQRS is still a full calendar year reporting period for 2015. Organizations will need the capability to pull those metrics for the full calendar year for 2015 to avoid penalties in payment year 2017. If you have questions on MU, PQRS, or other incentive programs such as Medicare Chronic Care Management and how it may impact your organization, please feel free to contact us at email@example.com, we’d be happy to answer your questions.