EHR

Advancing Care Information and Improvement Activities-Q&A

shutterstock_498951139The Merit Based Incentive Program (aka MIPS) defines four categories of eligible clinician performance, contributing to an annual MIPS final score of up to 100 points (relative weights are indicated for the CY2017 performance year and associated CY2019 payment year):

  • Quality (60% for 2017)
  • Advancing Care Information (ACI, renamed from Meaningful Use) (25% for 2017)
  • Improvement Activities (CPIA) (15% for 2017)
  • Cost (0% for 2017, but will be weighted for 2018 and beyond)

On December 13, 2016 the Centers for Medicare & Medicaid Services (CMS), briefly discussed two of the four Merit-based Incentive Payment System (MIPS) categories: Advancing Care Information (ACI) and Improvement Activities. Most of the 90-minute session was reserved for questions and answers. Here are some of the questions your colleagues asked, with answers from CMS.

Q: How is the ACI scored for hospital-based and non-facing patient clinicians who are part of a large multi-specialty reporting as a group?

A: That would depend on whether they choose to submit data, or not; they still have the option because they’re hospital-based. If they choose to participate, they will be scored as a group. The resulting update will apply to everybody in the group.

Q: When ACI is set to zero, to what category is the percentage applied?

A: The entire 25 points is moved to the Quality category, so instead of the Quality category being worth 60 points, it will be worth 85 points of the composite performance score (CPS).

Q: Will providers be submitting data through the same system for ACI and Improvement Activities as they did for the Electronic Health Record (EHR) Incentive Program?

A: No. There will be a new system for MIPS. However, if you are eligible to participate in the Medicaid EHR Incentive Program, you will need to attest through the same system as before.

Q: When reporting as a group, will nurse practitioners and physician assistants be excluded from ACI scoring if no data is submitted?

A: Yes. But if they are part of a group ,they will get the same update as everyone else in the group.

Q: Do eligible clinicians need to inform CMS in advance whether they will be attesting as an individual or a group? If so, how do they do that?

A: They don’t have to inform CMS; they just submit the data — unless they are reporting as a group through the CMS Web Interface or reporting Consumer Assessment of Healthcare Providers and Systems (CAHPS) data. Information on these protocols are forthcoming.

Q: For the test portion of Pick Your Pace, which allows for one improvement activity to receive credit, can we pick any activity or do we need to pick a high or medium activity?

A: You can pick a high or medium activity, but a medium activity will only give you have the points (7.5) toward your final score.

Q: If we do not use an EHR and cannot attest to ACI, do we have to attest or submit this fact anywhere?

A: No. Just don’t complete that part of the reporting requirements.

Q: The rule states that ACI performance for groups will be based on a group score. Does that mean the reports showing the numerator/denominator for each eligible clinician in the group have to be combined?

A: The attestation should be aggregate there is one submission — one numerator and denominator per measure — for the group. If the group is using multiple EHR technologies, you will have to sum the numerator/denominator for each measure across the different EHRs for the group.

Q: If you do group reporting, do you only need a “1” in the numerator for the entire group to get credit for the base score under ACI?

A: Yes.

Q: When will the specifics of the improvement activities be released? The working on the 90-plus activities are vague and open to interpretation.

A: We are not planning to issue more specific language around the activities for the transition year. We aren’t requiring any specific data to be submitted. What you see is on the Quality Payment Program (QPP) website is all that is required.

Q: Will the bonus payment be a one-time payment?

A: Whatever score you get in MIPS will be applied to your Physician Fee Schedule amount. The method for paying the added bonus for exceptional performers is still being worked out.

Q: What if your certified EHR technology (CEHRT) year changes mid year due to an upgrade and your submitting a full year of data?

A: You can submit a combination. Aggregate your data between the  two EHRs and submit the data for the ACI category as one submission. This is not the case for Quality reporting, however. You will need to work with a data aggression vendor to report electronic Clinical Quality Measures (eCQMs), in that case.

Q: Does MIPS reporting take the place of EHR reporting? Do we still have to use a qualified EHR or can we do claims-based reporting?

A: The data needs to come out of your EHR. For Quality measures, you’re no longer required to submit eCQMs to earn credit. In the Quality category, you could submit via claims and it wouldn’t count against you.

Q: Can you report as a group under MIPS if not all of your providers are using a CEHRT?

A: Yes.

Q: What type of documentation is required for improvement activities?

A: For improvement activities, we are not requiring documentation. But providers should retain copies of medical records, charts, reports, and any electronic records that are applicable and appropriate for up to 10 years after the conclusion of the performance period, in case of an audit.

See the whole presentation:

CMS Announces July 2015 Transition from IACS to EIDM

CMS 

The Centers for Medicare & Medicaid Services (CMS) would like to inform Physician Quality Reporting System (PQRS) participants and their staff to an important system update scheduled to be in place on July 13, 2015.


The Individuals Authorized Access to CMS Computer Services (IACS) system will be retired, but current IACS user accounts will transition to an existing CMS system called Enterprise Identity Management (EIDM). The EIDM system provides a way for business partners to apply for, obtain approval, and receive a single user ID for accessing multiple CMS applications.


Existing PQRS IACS users, their data, and roles will be moved to EIDM and will be accessible from the ‘PQRS Portal’ portion of the CMS Enterprise Portal at  http://portal.cms.gov. Users will then access the PQRS Portal to submit data, retrieve submission reports, view feedback reports, or conduct various administrative and maintenance activities. New PQRS users will need to register for an EIDM account.


Stay tuned for more information and resources in the coming weeks and months! In the meantime, please ensure that your IACS account is active, current, and you’re able to log in. This will help ensure a smoother transition to EIDM.


For additional assistance regarding IACS or EIDM, contact the QualityNet Help Desk at 1-866-288-8912 (TTY 1-877-715-6222) from 7:00 a.m. to 7:00 p.m. Central Time Monday through Friday, or via email at qnetsupport@hcqis.org. To avoid security violations, do not include personal identifying information, such as Social Security Number or TIN, in email inquiries to the QualityNet Help Desk.

CMS Announces Extension for EPs participating in PQRS via EHR and QCDR (QRDA III format)

The Centers for Medicare & Medicaid Services (CMS) is pleased to announce that the submission deadlines for the PQRS reporting methods below have been extended.  All other submission timeframes for other PQRS reporting methods remain the same.  The revised submission timeframes are:

Reporting Method Submission Period Submission Deadline Time

(All Times are Eastern)

EHR Direct or Data Submission Vendor that is certified EHR technology (CEHRT) 1/1/15 – 3/20/15 8:00 p.m.
Qualified clinical data registries (QCDRs) (using QRDA III format) reporting for PQRS and the clinical quality measure (CQM) component of meaningful use for the Medicare Electronic Health Record (EHR) Incentive Program 1/1/15 – 3/20/15 8:00 p.m.

An Individuals Authorized Access to CMS Computer Services (IACS) account with the “PQRS Submitter Role” is required for these PQRS data submission methods. Please see the IACS Quick Reference Guides for specifics.

PQRS provides an incentive payment to individual eligible professionals (EPs) and group practices that satisfactorily participate or satisfactorily report data on quality measures for covered Medicare Physician Fee Schedule (PFS) services. Additionally, those who do not meet the 2014 PQRS reporting requirements will be subject to a negative payment adjustment on all Medicare Part B PFS services rendered in 2016.

Note:  The deadline listed above does apply to Individual Eligible Professionals and Group Practices participating in other CMS programs such as the Medicare EHR Incentive Program and Comprehensive Primary Care Initiative that are utilizing the reporting methods listed above. Additionally, CMS has extended the deadline for EPs wishing to attest to meaningful use for the EHR reporting period in 2014 for the Medicare Electronic Health Record (EHR) Incentive Program to March 20, 2015. Please be on the lookout for a separate listserv with information regarding the attestation extension.

For questions, please contact the QualityNet Help Desk 1-866-288-8912 or via email at Qnetsupport@hcqis.org from 7:00 a.m. – 7:00 p.m. Central Time. Complete information about PQRS is available at  http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/index.html.

Does the July 1, 2014 MU deadline apply to you?

Are you a bit confused on whether or not you should file an exception this year?  And what about that July 1, 2014 “deadline” fast approaching? 

With so much money…..both in incentives received and fear of losing money due to audits and penalties, we’ve summarized some information surrounding this “deadline” and what it may (or may not) mean for you and your practice.

New participants in 2014

If you are new to the program and intended to demonstrate meaningful use for the first time in 2014, but you are not able to implement 2014 certified EHR technology for the 2014 reporting year, you may apply for a hardship exception for the 2015 payment adjustment.  

An interactive tool is available to help you determine if you will avoid upcoming 2015 and 2016 Medicare EHR Incentive Program payment adjustments by demonstrating meaningful use, or if you should apply for a hardship exception.  The deadline to do this is JULY 1, 2014.  Please bear in mind that if you are a returning eligible professional, you will not need to file an exemption for 2014.

Applying for Hardship Exception When submitting hardship exception applications, entries must include supporting documentation that proves demonstrating meaningful use presented significant hardship.

CMS has posted hardship exception applications on the EHR website for:

Please read and follow the submission instructions on the application. Note that all required supporting documentation must be included at the time of submission. Completing your application online and submitting it electronically to EHRhardship@provider-resources.com, with all required supporting documentation, will reduce the application processing time. Please do not submit hand-written applications.

Hardship Exception Tip sheets You can also avoid payment adjustments by successfully demonstrating meaningful use prior to the payment adjustment.  Tip sheets are available on the CMS website that outline when eligible professionals must demonstrate meaningful use in order to avoid the payment adjustments.

Returning meaningful users in 2014

If you successfully demonstrated meaningful use for the 2013 reporting year, you will not be subject to the 2015 payment adjustment.  If you are not able to implement 2014 certified EHR technology for a 2014 reporting period, you may apply for a hardship for the 2016 payment adjustment.

  • Use the eligible professional hardship exception for 2016 which will be available after July 1, 2014
  • Indicate that you are applying for a hardship because of 2014 vendor issues
  • Submit your application by July 1, 2015

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

New EHR Attestation Deadline

New EHR Attestation Deadline for Eligible Professionals:
March 31, 2014

CMS is extending the deadline for eligible professionals to attest to meaningful use for the Medicare EHR Incentive Program 2013 reporting year from 11:59 pm ET on February 28, 2014 to 11:59 pm ET March 31, 2014.
In addition, CMS is offering assistance to eligible hospitals who may have experienced difficulty attesting to submit their attestation retroactively and avoid the 2015 payment adjustment.
This extension will allow more time for providers to submit their meaningful use data and receive an incentive payment for the 2013 program year, as well as avoid the 2015 payment adjustment.
This extension does not impact the deadlines for the Medicaid EHR Incentive Program or any other CMS program, including the electronic submission for the Physician Quality Reporting System EHR Incentive Program Pilot.

How to attest?
If you are an eligible professional, you may use the registration and attestation system to submit your attestation for meaningful use for the 2013 reporting year. You must attest prior by 11:59 pm ET on March 31, 2014 to meet the new 2013 program deadline.
If you are an eligible hospital, you may contact CMS for assistance submitting your attestation retroactively. You must contact CMS by 11:59 pm on March 15, 2014 in order to participate for the 2013 program year.

Resources
If you are an eligible professional working on your attestation for the 2013 reporting period, there are resources available to help you with the registration and attestation process.
Stage 1 Meaningful Use Calculator
Registration and Attestation User Guides
EHR Incentive Program Website
The EHR Information Center is open to assist you with all of your registration and attestation system inquiries. Please call, 1-888-734-6433 (primary number) or 888-734-6563 (TTY number). The EHR Information Center is open Monday through Friday from 7:30 a.m. – 6:30 p.m. (Central Time), except federal holidays.

Tips
In addition, there are some simple steps you can take which will help to make the process easier for you:
• Ensure that your payment assignment and other relevant information is up to date in the Medicare payment system PECOS
• Make sure to include a valid email address in your EHR program registration
• Consider logging on to use the attestation system during non-peak hours such as evenings and weekends
• Log on to the registration and attestation system now and ensure that your information is up to date and begin entering your 2013 data
• If you experience attestation problems, call the EHR Incentive Program Help Desk and report the problem
• If your organization has more than 1,000 providers assigned to a proxy user, use the PECOS system to designate additional proxies to facilitate attestation.

Eligible Hospital Instructions:
1. Send the following information to EH2013Extension@Provider-Resources.com no later than 11:59 PM EST on 3/15/2014:
o CCN
o Hospital Name
o Contact Person Name
o Contact Person Email
o Contact Person Phone
2. Type “EH 2013 EXTENSION” in the subject line of the email note
3. Each Hospital must be identified in a separate email
CMS will contact the person that you designate in your request to provide additional instructions regarding the Eligible Hospital 2013 attestation submission.

Other changes for 2014

sunriselogo2009With all the chatter going on with ICD-10, I thought it appropriate to write something that doesn’t revolve around ICD-10.  There are changes in Meaningful Use stage 1, and new criteria for Stage 2 Meaningful Use, Clinical Quality Measures and PQRS.  Happy reading!

If you have attested for at least 2 years for stage 1 meaningful use, then stage 2 is next on the docket for your practice. If you have attested once for stage 1 then all those things you attested to before now will change this year. Stage 1 requirements change in 2014 as well as Stage 2 Meaningful Use objectives for those of you who have successfully completed two years of Stage 1.

 Let’s first tackle those changes in 2014 to Stage one Meaningful Use:
1. Electronic Health Record (EHR) software systems have to re-certify their product to meet new regulations for 2014. Right now your current EHR has undergone the certification process for 2014 and will be available early spring of 2014.
2. For those of you that plan on doing stage 1 in 2014, certain “core” and “menu” objectives have been removed/combined and you can no longer count measure exclusions toward meeting menu objectives. You will have to meet 5 of the 9 menu items and 13 (as opposed to 15 in previous years) core objectives.
3. Clinical Quality Measure reporting will change as well. You will have to report on 9 and those 9 need to cover at least 3 of the 6 National Quality Strategy Domains. I’ve explained more later on.
4. Reporting is done in one calendar quarter, as opposed to 90 consecutive days previously (for example, April 1 2014- June 30, 2014). Rules for Medicaid incentive have not changed for 2014 so you can report for any continuous 90 days under Medicaid.
5. This is the last year you are eligible to begin to get incentive payments. If you are planning to start your first year this year you can still earn as much as $24,000 in incentives. AND your meaningful use performance in 2014 will be the basis for 2016 payment adjustments.
6. CPOE Denominator changes-now required (you will not be able to exclude from this measure).
7. Vital sign age limit is 3 years and older (changed from 2 years and older) for blood pressure and no age limit on height and weight. Since BP is separate, you can exclude from the BP measure.
8. The old stage 1 requirement for providing patients with an electronic copy of their health information upon request will be changed in 2014 to “Provide patients the ability to view online, download and transmit their health information within 4 business days of the information being available to the EP”.
9. The old stage 1 requirement for providing patients timely electronic access to their health information within 4 business days will be changed in 2014 to “More than 50 percent of all unique patients seen by the EP during the EHR reporting period are provided timely (within 4 business days after the information is available to the EP) online access to their health information subject to the EP’s discretion to withhold certain information”.

Moving on to what is next with Stage 2 Meaningful Use.

Stage 2 retains the same basic structure as Stage 1; however, all those Menu items in stage 1 become CORE items for Stage 2 with higher thresholds that you must achieve. There are also some new Stage 2 core and menu objectives.

STAGE 1

STAGE 2

 

13 Core Objectives 17 Core Objectives
5 of 10 Menu Objectives + 3 of 6 Menu Objectives
18 total objectives 20 total objectives

+CQM’S

=STAGE 2 MEANINGFUL USE

What are the requirements?
17 Core Objectives – These are objectives that everyone who participates in Stage 2 must meet. Some of the core objectives have exclusions, but many do not.
3 of 6 Menu Objectives – You only have to report on 3 out of the 6 available menu objectives for Stage 2. You can choose objectives that make sense for your workflow or practice. Again, some of these objectives have exclusions.

The following is a list of the Stage 2 Meaningful Use 17 Core Objectives
1. Use computerized provider order entry (CPOE) for medication, laboratory and radiology orders
2. Generate and transmit permissible prescriptions electronically (eRx)
3. Record demographic information
4. Record and chart changes in vital signs
5. Record smoking status for patients 13 years old or older
6. Use clinical decision support to improve performance on high-priority health conditions
7. Provide patients the ability to view online, download and transmit their health information
8. Provide clinical summaries for patients for each office visit
9. Protect electronic health information created or maintained by Certified EHR Technology
10. Incorporate clinical lab-test results into Certified EHR Technology
11. Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research, or outreach
12. Use clinically relevant information to identify patients who should receive reminders for preventive/follow-up care
13. Use certified EHR technology to identify patient-specific education resources
14. Perform medication reconciliation
15. Provide summary of care record for each transition of care or referral
16. Submit electronic data to immunization registries
17. Use secure electronic messaging to communicate with patients on relevant health information
In addition to the 17 core objectives, there are 6 Menu Objectives (and remember, you’ll only have to do 3 of the 6).
1. Submit electronic syndromic surveillance data to public health agencies ($-for the additional interface)
2. Record electronic notes in patient records
3. Imaging results accessible through CEHRT
4. Record patient family health history
5. Report cancer cases to a public health central cancer registry
6. Report specific cases to a specialized registry
Important Note: While there are exclusions provided for some of these menu objectives, you cannot select a menu objective and claim the exclusion if there are other menu objectives that you could report on instead.

Changes to Clinical Quality Measures
Beginning in 2014, the reporting of clinical quality measures (CQMs) will change for all providers.
You have the option of submitting three months of CQM data online through the CMS Registration & Attestation System. This will be the same website you go to for attestation now.
You also have the option to submit a full year of data electronically using the QRDA format to receive credit for the EHR Incentive Program and the Physician Quality Reporting System.
Please note that your attestation for the Medicare EHR Incentive Program is not complete until you submit clinical quality measure data, so your EHR incentive payment will be held until your electronic submission is processed.
If you are a provider using Medicaid, you must submit your clinical quality measurement data to your State Medicaid Agency.
How to Select CQM’s in 2014
Beginning in 2014, eligible professionals must select and report on 9 of a possible list of 64 approved CQMs for the EHR Incentive Programs.
There is also a new requirement in 2014 that the quality measures selected must cover at least 3 of the 6 available National Quality Strategy (NQS) domains, which represent the Department of Health and Human Services’ NQS priorities for health care quality improvement. The 6 domains are:
• Patient and Family Engagement
• Patient Safety
• Care Coordination
• Population and Public Health
• Efficient Use of Health Care Resources
• Clinical Processes/Effectiveness
In short there are a lot of changes this year in addition to ICD-10 implementation.

Stay tuned….

Sunrise Services, LLC

 

Submit Quality Data for 2013 PQRS-Medicare EHR Incentive Pilot by February 28, 2014

Are you an eligible professional who is participating or wishes to participate in the 2013 PQRS-Medicare EHR Incentive Pilot? You can now submit your 2013 quality data.

 If you would like to participate in the pilot you must submit 12 months of CQM data by February 28, 2014 at 11:59 pm ET.

To successfully participate in the pilot, you must do the following by February 28, 2014:

  1. Register for an IACS account (for EHR submission only)
  2. Indicate intent to report CQMs using pilot in EHR Registration & Attestation System
  3. Generate required reporting files
  4. Test data submission
  5. Submit quality data

If you cannot submit your CQM data for 12 months electronically through PQRS, you must return to the EHR Attestation System and deselect the electronic reporting option.  Please note: if you do not submit your 2013 quality data or deselect the electronic reporting option in the EHR Attestation System, you will not receive an EHR incentive payment.

ICD-10 Walking Through the Workflow

With less than a year to go until the ICD-10 code set implementation deadline, physician practices should be pursuing a comprehensive plan designed to ensure a smooth coding transition with minimal cash flow disruption.

A key step in any ICD-10-CM transition strategy is to conduct a detailed assessment of existing workflows and processes to determine which elements will require modification, according to Bess Ann Bredemeyer, a consulting director with McKesson Business Performance Services (BPS).

By identifying each point in the claims lifecycle that ICD-10- CM will touch, appropriate adjustments can be made and simulations conducted to test the new processes against real-world conditions.

“The best way to proceed with an assessment is to begin at the patient encounter and then move through to the claim drop and denial management,” Bredemeyer said. “That way you won’t miss anything.”

Clinical Documentation  Whether the clinical documentation is sent directly to a coder or to data entry personnel, it is also important to ensure that any changes in National Coverage Determinations (NCDs) and payer’s Local Carrier Determinations (LCDs) are incorporated and reflected in the claim. A good approach includes:

  • Identifying the top 50 most utilized diagnoses codes
  • Evaluating where additional documentation will be required
  • Mapping out modifications to support appropriate reimbursement
  • Updating charge tickets, super-bills and other revenue cycle tools

This is a Test  With all the elements theoretically in place, it is critical to begin testing your new workflow to determine if it can handle ICD-10-CM. Code audits can assess both clinical documentation and coding to determine whether the claims should come through clean or not. A real-world testing process may also reveal previously unknown problems that would otherwise remain hidden until the ICD-10 go-live.

Don’t Be Denied  Because of the complexity of ICD-10-CM and the sheer magnitude of the change, it’s reasonable to assume that even the best-laid plans may encounter some unexpected problems. For that reason, it makes sense to be prepared for a rise in denials. For physician practices, that means ensuring that staffing is adequate to manage an increase in volume, and that problems will be quickly identified and remediated.

“There is no denying that the transition to the new code set will require planning and resources to mitigate the burden of change,” Bredemeyer said. “That’s why you should get started now on developing a workflow analysis impact assessment that will help you develop a detailed ICD-10 timeline and budget.”

Article Resource:

ReveNEWS, Industry Spotlight, “Walking Through the Workflow- An Important First Step,” November 2013 edition located on the McKesson ReveNEWS website

 medisoft

Government offers model notices of privacy practices

The US Department of Health & Human Services (HHS) and the Office of the National Coordinator have released model notices of privacy practices in three customizable styles for healthcare providers and health plans. New rules for notices of privacy practices as required by the HIPAA Omnibus Rule go into effect on Monday, September 23.

Access the model notices and more information on the notice requirements at the HHS website.