CMS and ONC Release New EHR Regulation Affecting Hospitals

Review the Changes to the EHR Incentive Programs for Hospitals Included in New Interim Final Rule with Comment

CMS and ONC have released an Interim Final Rule with Comment (IFC) that makes several changes to the Medicare and Medicaid EHR Incentive Programs and 2014 Edition EHR Certification Criteria that will affect hospitals. The rule also provides notice of CMS's intention to issue technical corrections to the electronic specifications for clinical quality measures (CQMs) released on October 25, 2012.

The IFC's major changes include:

• Revising the regulation text for the hospital measures for the objective of making patient information available online. The measure will now base the denominator not on all patients, but all unique patients.

• Expanding the denominator options for the objective of sending electronic lab results to ambulatory providers. It now allows hospitals to choose between a denominator of all lab orders received from ambulatory providers or all lab orders received electronically from ambulatory providers.

• Moving the CQM minimum denominator threshold effective date from 2014 to 2013, so hospitals can begin taking advantage of this flexibility right away.

More information about the comment period will be included in an upcoming listserv.

 

Want more information about the EHR Incentive Programs?

Make sure to visit the EHR Incentive Programs website for the latest news and updates on the EHR Incentive Programs.

Reporting EHR Clinical Quality Measures in 2014

Reporting Clinical Quality Measures Will Change for All Providers in 2014

On August 23, 2012, the Centers for Medicare & Medicaid Services (CMS) published the final rule for Stage 2 of the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. The rule provides new criteria that eligible professionals (EPs), eligible hospitals, and critical access hospitals (CAHs) must meet to successfully participate in the EHR Incentive Programs. 

The final Stage 2 rule establishes that beginning in 2014, the reporting of clinical quality measures (CQMs) will change for allproviders, regardless of whether they are participating in Stage 1 or Stage 2. EHR technology certified to the 2014 standards and capabilities will contain new CQM criteria. 

In 2014, EPs, eligible hospitals, and CAHs in both Stage 1 and Stage 2 of the EHR Incentive Programs must use the new criteria. All providers must report on CQMs to demonstrate meaningful use, even though CQM reporting was removed as a core objective.

 

Provider	Before 2014	2014 and Beyond
EPs	Complete 6 out of 44 CQMs 3 core or 3 alternate core 3 menu Selected CQMs must cover at least 3 of the National Quality Strategy  (NQS) domains	Complete 9 out of 64 CQMs Choose  at least 1 measure in 3 NQS domains Recommended core CQMs include: 9 CQMs for the adult population 9 CQMs for the pediatric population Prioritize NQS domains
Eligible Hospitals and CAHs	Complete 15 out of 15	Complete 16 out of 29 Choose  at least 1 measure in 3 NQS domains

Reporting CQMs in 2014 and Beyond

• All Medicare-eligible providers in their second year and beyond of demonstrating meaningful use must electronically report CQM data to CMS, starting in 2014 


• Medicaid providers will electronically report CQM data to their state

CQM Tipsheet
CMS has published a tipsheet that includes more information on the CQM 2014 changes.

Want more information about the EHR Incentive Programs?
Visit the EHR Incentive Programs website for the latest news and updates.

CMS Publishes Stage 2 Overview Tipsheet

Now Available: Stage 2 Overview Tipsheet

On August 23, 2012, the Centers for Medicare & Medicaid Services (CMS) published the final rule for Stage 2 of the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. The rule provides new criteria that eligible professionals (EPs), eligible hospitals, and critical access hospitals (CAHs) must meet to successfully participate in the EHR Incentive Programs. 

CMS developed a Stage 2 Overview Tipsheet, a resource that provides a summary of the Stage 2 final rule and highlights key changes to the EHR Incentive Programs, including:

• Stage 2 Timing – The earliest eligible hospitals and CAHs will demonstrate meaningful use of Stage 2 criteria will be fiscal year 2014, or calendar year 2014 for EPs. Providers who were early demonstrators of meaningful use in 2011 will meet three consecutive years of meaningful use under the Stage 1 criteria before advancing to the Stage 2 criteria in 2014. 


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  Stage 2 Core and Menu Objectives – Stage 2 retains the Stage 1 core and menu structure for meaningful use objectives. Although some Stage 1 objectives were either combined or eliminated, most of the Stage 1 objectives are now core objectives under the Stage 2 criteria.


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  To demonstrate meaningful use under Stage 2 criteria:
  
  
  
  
  • EPs must meet 20 measures (17 core and 3 of 6 menu).
  
  
  • Eligible hospitals must meet 19 (16 core and 3 of 6 menu).
  
  
  
  

The end of the tipsheet contains a complete list of the Stage 2 core and menu objectives for both EPs and eligible hospitals and CAHs.

• Reporting Periods in 2014 – All providers, regardless of their stage of meaningful use, are only required to demonstrate meaningful use for a three-month EHR reporting period. CMS is permitting this one-time, three-month reporting period in 2014 only so that all providers who must upgrade to 2014 certified EHR technology will have adequate time to implement their new Certified EHR systems. 


• Clinical Quality Measures in 2014 – Beginning in 2014, all providers, regardless of their stage of meaningful use, will report on CQMs in the same way.
  
  
  
  • All Medicare EPs and eligible hospitals beyond their first year of demonstrating meaningful use must electronically report their CQM data to CMS.
  
  
  • All Medicaid providers that are eligible only for the Medicaid EHR Incentive Program will electronically report their CQM data to their state.
  
  
  • Additionally, all providers will complete this number of CQMs in 2014:
    
    
    
    • EPs must report on 9 out of 64 CQMs
    
    
    • Eligible hospitals and CAHs must report on 16 out of 29 CQMs.
    
    
    
    
  
  
  
  

The tipsheet is available on the CMS website and should be reviewed in its entirety to effectively prepare for Stage 2 requirements. 

 

Want more information about the EHR Incentive Programs?

Make sure to visit the EHR Incentive Programs website for the latest news and updates on the EHR Incentive Programs.

Learn How to Send CQM Data Electronically

Did you know that you can now submit your CQM data for the Medicare EHR Incentive Program electronically?

The Physician Quality Reporting System (PQRS) Medicare Electronic Health Record (EHR) Incentive Pilot allows eligible professionals to meet the clinical quality measure (CQM) reporting objective of meaningful use requirements  for the EHR Incentive Program through electronic submission while also reporting for the PQRS program. 

 

A provider who wishes to participate in the electronic reporting pilot must submit 12 months of clinical quality measures data. Eligible professionals must submit the data between January 1, 2013 and February 28, 2013.

 

CQM data for the electronic reporting pilot must be derived from certified EHR technology.  If you decide to submit the data directly from your EHR, your EHR also needs to be PQRS “qualified.” You can also have a PQRS-qualified data submission vendor submit quality measures data for the electronic reporting pilot on your behalf. 

 

A list of the 2012 PQRS-qualified EHR and data-submission vendors is posted on the PQRS website. 

 

You can register for the electronic reporting pilot program while attesting for the EHR Incentive Program on the online registration page.  Simply check “Yes” on the eReporting page as you go through the attestation process.

Want more information about the EHR Incentive Programs?

Make sure to visit the EHR Incentive Programs website for the latest news and updates on the EHR Incentive Programs.

We've Posted New FAQs to the EHR Website!

Take a Look at the New Medicare and Medicaid EHR Incentive Programs FAQs    

We want to keep you updated with the latest information about the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. These new FAQs include information about clinical quality measures (CQMs), meaningful use, attestation, and other Medicare and Medicaid EHR Incentive Programs topics.

1. Does a provider have to record all clinical data in their certified EHR technology in order to accurately report complete CQM data for the Medicare and Medicaid EHR Incentive Programs? Read the answer.


2. Do providers have to contribute a minimum dollar amount toward their certified EHR technology for the Medicare and Medicaid EHR Incentive Programs? Read the answer.


3. Where can I find a list of public health agencies and immunization registries to submit my data as required by the public health objectives for the EHR Incentive Programs? Read the answer.


4. Can two separate practices with two different TINs purchase a single certified EHR system and share it in order to participate in the Medicare and Medicaid EHR Incentive Programs? Read the answer.


5. For the Medicare and Medicaid EHR Incentive Programs, how should an eligible professional (EP), eligible hospital, or critical access hospital (CAH) that sees patients in multiple practice locations equipped with certified EHR technology calculate numerators and denominators for the meaningful use objectives and measures? Read the answer.


6. For the EHR Incentive Programs, how should an eligible hospital or CAH with multiple certified EHR systems report their CQMs? Read the answer.


7. Does the person who completes the registration for the EHR Incentive Programs need to be the same person who completes the attestation? Read the answer.


8. For the meaningful use objective “Capability to submit electronic syndromic surveillance data to public health agencies,” what is the definition of "syndromic surveillance"? Read the answer.
   

Want more information about the EHR Incentive Programs? Make sure to visit the CMS EHR Incentive Programs website for the latest news and updates on the EHR Incentive Programs.

Sign up for CMS' CQM Webinar For Small-Practice Providers

CMS is Holding a Second Webinar on the CQMs and the EHR Incentive Programs for Small-Practice Providers

Overview

What:Webinar- The CMS EHR Incentive Programs: Small-Practice Providers and Clinical Quality Measures (CQMs)

When: October 25 from 1:00 – 2:30 p.m. EDT Why: To help small-practice providers successfully report CQMs How: Register online  

The Centers for Medicare & Medicaid Services (CMS) is holding a second webinar on CQMs and their importance in attesting to meaningful use for the EHR Incentive Programs. CMS hopes to help small-practice and rural providers become more knowledgeable in the topics below:

• An overview of the CQMs


• How to report CQMs during attestation


• Why CQMs are included in the EHR Incentive Programs


• Answers to many FAQs on the CQMs and the EHR Incentive Programs

Although, small-practice providers are the intended audience of this webinar, anyone is welcome to join.

 

The webinar presentation, a document with over 300 questions and answersfrom the webinar held on August 30, and an informational CQM fact sheet will be provided to participants before the webinar as downloadable handouts.

 

Additionally, registrants will be given an opportunity to submit questions through the registration site before the webinar that will be answered by CMS subject matter experts and posted to the CMS EHR website a few weeks after the webinar has been completed.

Registration

Individuals can register online for the webinar. After successfully registering, they will be sent a confirmation message with a link to the webinar site. Space is limited, so interested participants should register now to secure their place. 

Want more information about the EHR Incentive Programs? 

Make sure to visit the CMS EHR Incentive Programs website for the latest news and updates on the EHR Incentive Programs.

Meaningful Use: Attesting to the Data

What Does Attestation for the EHR Incentive Programs Entail?

Over 114,000 eligible professionals and hospitals have registered for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. As more hospitals move towards meeting meaningful use and attesting, the Centers for Medicare & Medicaid Services (CMS) wants to make sure everyone understands what attestation entails.

 

In order to attest, successfully demonstrate meaningful use, and receive an incentive payment under the Medicare EHR Incentive Program, eligible hospitals must indicate that they agree with several attestation statements.

 

Eligible hospitals must agree that the information submitted:

• is accurate to the knowledge and belief of the hospital or the person submitting on behalf of the hospital.


• is accurate and complete for numerators, denominators, exclusions, and measures applicable to the hospital.


• includes information on all patients to whom the measure applies.


• for clinical quality measures (CQMs), was generated as output from an identified certified EHR technology.

By agreeing to the above statements, the hospital is attesting to providing all of the information necessary from certified EHR technology, uncertified EHR technology, and/or paper-based records in order to render complete and accurate information for all meaningful use core and menu set measures except CQMs.

 

Attesting to CQM Data's Validity

CMS considers information to be accurate and complete for CQMs to the extent that it is identical to the output that was generated from certified EHR technology. In other words, the hospital is only attesting that what was put in the attestation module is identical to the output generated by its certified EHR technology. Therefore, the numerator, denominator, and exclusion information for CQMs must be reported directly from information generated by certified EHR technology.

 

CMS, through meaningful use, does not require any data validation. Eligible hospitals are not required to provide any additional information beyond what is generated from certified EHR technology in order to satisfy the requirement for submitting CQM information, even if the reported values include zeros. If a hospital has concerns about the accuracy of its output, the hospital can still attest but should work with its vendor and/or the Office of the National Coordinator for Health Information Technology to improve the accuracy of the individual product and/or the level of accuracy guaranteed by certification.

 

CMS recommends that hospitals print out or save an electronic copy of the CQM report used at attestation from their certified EHR. The eligible hospital should retain this copy for its records so that the hospital can show its numbers in the event of an audit. Upon audit, this documentation will be used to validate that the hospital accurately attested and submitted CQMs.

 

For more information about the Medicare and Medicaid EHR Incentive Programs, please visit the CMS EHR website, and see the Frequently Asked Questions page for answers on various topic areas of the programs.

The CQM Webinar Presentation is Now Online

View the Presentation from the August 30 CQM Webinar

On August 30, CMS held a webinar to discuss the clinical quality measures (CQMs) and how to successfully report them during Stage 1 of meaningful use for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs.

A PDF of the webinar presentation is now available online. Go to the Spotlight and Upcoming Event Section of the Medicare and Medicaid EHR Incentive Programs website to download this presentation.

The presentation includes information on:

• An overview of the CQMs


• How  to report CQMs during attestation


• Why CQMs are included in the EHR Incentive Programs

The webinar also included an hour-long question-and-answer session with CMS subject matter experts. In the coming weeks, a transcript with all of these questions and answers, along with a video of the webinar, will be made available online.

CMS plans to host another CQM webinar soon. Stay tuned for updates on how you can join this informational session. 

Want more information about the EHR Incentive Programs? Make sure to visit the Medicare and Medicaid EHR Incentive Programs websitefor the latest news and updates on the EHR Incentive Programs.