Meaningful Use Stage 2: ONC Request for Comments Ivy Baer, ibaer@aamc.org Jennifer Faerberg jfaerberg@aamc.org
Stages of Meaningful Use By Payment Year First Payment Year Payment Year 2011 2012 2013 2014 2015 2011 Stage 1 Stage 1 Stage 2 Stage 2 TBD 2012 Stage 1 Stage 1 Stage 2 TBD 2013 Stage 1 Stage1 TBD 2014 Stage 1 TBD Source: Federal Register, Table 1 (July 28, 2010, p. 44323) 2
2015 and After For EPs and EHs: if don t achieve meaningful use: PENALTY! 3
ONC Schedule for MU Stage 2 Starting now: Comment period on preliminary recommendations through 2/25/11 Spring 2011: Public meetings Summer 2011: Formal final stage 2 recommendations BUT CMS ISSUES THE NPRM AND FINAL RULE! 4
Remember MU is achieved in consecutive years. If you achieve Stage 1 MU in 2011, and again in 2012, you d have to meet Stage 2 in 2013 5
Stage 2 MU Measures Total of 36 meaningful use measures in Stage 2 preliminary document 30 for EPs (Privacy/Security yet to come) 30 for EHs (Privacy/Security yet to come) 4 are continued from Stage 1 (i.e., no change) 8 are new (7 for EHs and EPs; 1 for EHs only) 6
The BIG Picture We don t know: will they all be required? Getting from Stage 1 to Stage 2: by stepping stones (ONC) or a giant leap? 7
Menu to Core Implement drug-formulary cks Record existence of advance directives Incorporate lab results as structured data (only where results are available) Generate pt lists for specific conditions Send pt reminders Summary of care record Submit reportable lab data (core for EH only) Submit syndromic surveillance data 8
New Measures Measure EP EH 30% visits have at least 1 electronic EP note 30% of EH pt days have at least one e-note by MD, NP or PA 30% of EH med orders automatically tracked via electronic med admin recording 80% of pts offered ability to view and download via webbased portal w/in 36 hrs of discharge relevant info in the record Yes Yes Yes Yes Yes Yes 9
New Measures cont Measure EP EH Online secure pt messaging in use Pt preferences for communication medium recorded for 20% of pts List of care team members (including PCP) available for 10% of pts in EHR Record of longitudinal care plan for 20% of pts with high priority health conditions Yes Yes Yes Yes Yes Yes Yes 10
Let s Compare Stage 1 1. CPOE: 30% for med orders Prelim Stage 2 1. CPOE: for at least 1 med and 1 lab or radiology order: 60% of unique pts (electronic transmission not req d) 2. Drug-drug/drugallergy interaction cks 2. Employ drug-drug and drug-allergy cking on appropriate evidencebased interactions 11
3. erx (EP): 40% 3. 50% of orders (o/p and hospital discharge) transmitted as erx 4. Record demographics: 50% 4. 80% of patients: demographic recorded and can use to produce stratified quality reports 12
5. Report CQM electronically 5. Continue as per Quality Measures Workgroup & CMS 6. Maintain problem list: 80% 7. Maintain active med list: 80% 8. Maintain active med allergy list: 80% 6. Continue Stage 1 7. Continue Stage 1 8. Continue Stage 1 13
9. Record vital signs: 50% 10: Record smoking status: 50% 11. Implement 2 CDS 9. Record vital signs: 80% of unique pts 10: Smoking status: 80% of unique pts 11. Use CDS to improve performance on high-priority health condition. Estab CDS for certification: authenticated; credible; ptcontext sensitive; invokes relevant knowledge; timely; efficient workflow; integrated with EHR; presented to appropriate party who can take action 14
12.Implement drugformulary check 13. Record existence of advance directives (EH): 50% 12. Moved to core 13. Core measure for EPs and EHs: 50% of patients 65 or older have recorded in EHR result of adv. Results of adv. directive discussion and directive itself exists 15
14. Incorporate lab results as structured data: 40% 15. Generate pt lists for specific conditions 16. Send patient reminders (20%) 14. Moved to core, but only where results are available 15. Moved to core. Generate lists for multiple patient-specific parameters 16. Moved to core 16
17. New 18. New 19. New 17. 30% of visits have at least 1 electronic EP note 18. 30% of EH pt days have at least one e-note by MD, NP, or PA 19. 30% EH med orders automatically tracked via electronic med administration recording 17
20. Provide e-copy of health info upon request: 50% 21. Provide e-copy of discharge instructions (EH): 50% 22. EHR-enabled ptspecific educational resources: 10% 20. Continue Stage 1 21. E-discharge instructions offered to at least 80% of pts 22. Continue Stage 1 18
23. New for EH 24. Provide clinical summaries for each office visit (EP): 50% 23. 80% of pts offered ability to view and download via webbased portal w/in 36 hrs of discharge, relevant info in the record about EH i/p encounters 24. Pts have ability to view and download info about a clinical encounter w/in 24 hrs of encounter; links to tests ordered during encounter w/in 4 days of becoming available 19
25. Provide timely electronic access: 10% (EPs) 26. 25. Pts have ability to view and download relevant info in longitudinal record, which is updated within 4 days of being available to the practice 26. EPs: 20% of pts use web-based portal to access their information at least once 20
27. New 27. EPs: online secure pt messaging in use 28. New 28. Pt preferences for communication medium recorded for 20% of pts. 21
29. Perform 1 test of HIE 29. Connect to at least 3 external providers in primary referral network (but outside delivery system that uses the same EHR) OR establish ongoing bidirectional connection to at least 1 HIE 22
30. Perform medication reconciliation: 50 % 30. Med reconciliation conducted at 80% of care transitions by receiving provider 31. Provide summary of care record: 50% 32. New 31. Move to core 32. List of care team members (including PCP) available for 10% of pts in EHR 23
33. New 34. Submit immunization data 33. Record of longitudinal care plan for 20% of pts w/ highpriority health conditions 34. EH and EP: Mandatory test. Some immunizations submitted on ongoing basis to Immunization Info System, if accepted and as required by state law 24
35. Submit reportable lab data 35. EH: move to core EP: lab reporting menu. Ensure that reportable lab results and conditions are submitted to public health agencies either directly or through their performing labs 25
36. Submit syndromic surveillance data 36. Move to core 37. Conduct security review analysis and correct deficiencies 37. Stage 2 coming later 26
ONC Questions How can e-progress notes be defined? Standards regarding accessibility for people with disabilities Strategies to appropriately address barriers to pt access Experiences with incorporating patient-reported data into EHRs 27
Questions cont For future stages of MU assessment, should CMS provide alternative to achieve MU based on demonstration of high performance on clinical quality measures? Should Stage 2 allow for group reporting option for all EPs in the group? Comments on required advance directive recorded for over 50% of 65+ pts and including results of advance directive discussion 28
Questions cont What are reasonable elements of a care plan, clinical summary and discharge summary? What additional MU criteria could be applied to stimulate robust information exchange? Suggestions for appropriate stage 2 objectives that could be meaningful stepping stone criteria for stage 3 objectives 29
ONC Thoughts on Stage 3 Offer electronic self-management tools to pts with high priority health conditions EHRs have capability to exchange data w/ PHRs Pts offered capability to report experience of care measures online Offer capability to upload and incorporate ptgenerated data into EHRs and clinician workflow Public health button for EHR and EP: mandatory test and submit if accepted Pt-generated data submitted to public health agencies 30
Want to comment? ONC document is available at: http://healthit.hhs.gov/media/faca/mu_rfc%20_2 011-01-12_final.pdf Comments are due February 25, 2011 Submit to: www.regulations.gov Please send Ivy or Jennifer a copy 31
If You Want to Contact Us Ivy Baer ibaer@aamc.org 202-828-0499 Jennifer Faerberg jfaerberg@aamc.org 202-862-6221 32