A few days ago I got an email from a very respected colleague that went like this:
“You said that US Wound Registry is Vendor Neutral, however, I asked my hospital IT guru to find out if we could participate and she said no. We are using [she named a major hospital EHR] in the wound center. I think it is important to participate but if it can’t be done easily we just can’t do it. Any advice?”
I explained to her that on the US Wound Registry Website we have provided a list of the 20 wound care and hyperbaric specific quality measures available for reporting through the USWR, as well as the traditional PQRS measures which the USWR also reports. Clinicians need to pass 9 measures in total to avoid penalties. These 9 measures may be a combination of the USWR developed measures and traditional PQRS measures.
Intellicure will assist clients in finding the measures with which they are most likely to be successful, and will update clients soon with the details of that process.
Why is that necessary?
Remember that quality measures are essentially “exam questions.” They are actually very complicated math problems that use data from your electronic health record. Even the simplest quality measure has a numerator and a denominator, but nearly all of them are enormously complex. Take a look at the details of them on the USWR website! The measure specifies:
- what kind of visit can be considered
- the ICD9 or ICD-10 diagnosis code(s) of the patient that are included in the measure
- the procedures that are involved (if any)
- calculate any patients that are excluded, and then
- all the details that are needed to decide if you “pass the test” (e.g. did you use appropriate products for compression or off-loading?).
The measures have to calculate exactly the same way for each provider in the USA and that means they each have to “take the same test.” That means the measure has to be exactly the same. We can’t have one provider deciding what will constitute off-loading one way and another provider doing it a different way.
So, the measures are standardized electronically. Every certified EHR is able to report an eCQM. The question is, “Will your hospital EHR AGREE to put these eCQMs into your wound center EHR?” If they are not willing, then you as a wound care and hyperbaric medicine specialist are going to be left reporting smoking cessation, blood pressure control, immunizations, and BMI, etc., as the measure of your wound care quality of practice. You MIGHT be able to pass PQRS that way, or you might not. If you score badly, then your VM will be bad. That’s because in general, wound care patients use a lot of resources. If you have high-cost patients and your PQRS performance is low, then you will be in the negative 4% category – because your hospital EHR “IT department” doesn’t want to install quality measures that are already programmed. What’s wrong with that picture? Personally, I’d negotiate things differently with that hospital if it was going to cost me 4% of my revenue under VM + a 2% reduction under PQRS and maybe another 2% penalty for not meeting meaningful use requirements. What’s an 8% to 10% reduction in your revenue going to cost you next year?
Meaningful Use (MU) is Mandatory in 2016
There’s also a penalty if you don’t meet your requirements for “Meaningful Use” of an electronic health record. The data needed to report quality measures are obtained from multiple sources including electronic health records (EHRs). It is going to be impossible for clinicians to successfully participate in quality initiatives without a certified EHR. Legislation mandating EHR standardization and utilization was designed to facilitate the acquisition and transmission of quality data to the various governmental entities responsible for health care coverage and payment decisions, particularly the Centers for Medicare and Medicaid Services (CMS). In 2009, incentive programs were created to foster the adoption and Meaningful Use of EHRs. QHPs who haven’t already adopted and attested to meaningful use of a certified EHR faced a potential reduction of 1% of Medicare payments in 2015. That penalty will continue to increase by 1% annually to a maximum of 5% in 2019 and beyond.
In 2016 and 2017, individual practitioners – that means YOU—need to pass 10 Meaningful Use objectives and measures or face at least a 2% Medicare pay cut. It can be hard to calculate all your potential penalties because there’s a lot of fine print (e.g. whether you are solo or in a group practice, whether you can be exempted from some penalties for specific reasons, how you fall in the value modifier grid compared to other clinicians, etc.). However, when all possible penalties are added together, worst case, it is possible for a practitioner to face as much as a 15% Medicare payment reduction if they do not meet the deadlines for engagement in 2016.
Meaningful Use of an EHR
In 2009, Congress passed the Health Information Technology for Economic and Clinical Health Act (HITECH) as part of the “stimulus bill.” HITECH was a $20 billion dollar funded mandate to develop standards that would enable the nationwide electronic exchange of health information and to provide monetary incentives for doctors and hospitals to use health information technology (HIT). It included stimulus money (up to $44,000 per QHP) for clinicians who demonstrated the “meaningful use” (MU) of a certified EHR. The incentive money was made available in increments as clinicians meet progressively more demanding requirements referred to as MU “Stages”. We are now at “Stage 2” of meaningful use which requires QHPs to successfully pass the following 10 measures:
- Objective 1: Security Analysis
- Objective 2: Decision Support
- Objective 3: Computerized Physician Order Entry (CPOE)
- Objective 4: Electronic Prescribing
- Objective 5: Health Information Exchange (HIE)
- Objective 6: Patient Specific Education
- Objective 7: Medication Reconciliation
- Objective 8: Patient Electronic Access (VDT)
- Objective 9: Secure Messaging
- Objective 10: Public Health Reporting
What is important to understand is that even if you are NOT trying to obtain your EHR adoption money, as of 2016, you MUST meet all 10 of the above MU2 requirements or lose 2% of your Medicare revenue!
Tomorrow we will talk more about Objective #10