On October 16, 2015 The Centers for Medicare and Medicaid Services (CMS) released changes to the Meaningful Use program which take effect in 2015 and continue through 2017. The goal of this Final Rule is to reduce the complexity of the EHR Incentive Program and rectify some of the problems that prevented providers from meeting the previous Stage 2 Meaningful Use requirements. You can decide for yourself whether they achieved that goal.
Every provider will complete and attest to 10 objectives. An overview can be found on the “Incentive Programs for Eligible Professionals: What You Need to Know for 2015 Tipsheet.”
The MU2 incentive program is different from the Physician Quality Reporting System (PQRS). I have written extensively about PQRS in previous blog posts and articles but not so much on MU2. Figuring out how much is at stake in these programs is difficult because it depends on when you started participating in the various programs (and whether you were successful), whether you claimed exemptions, and whether you were in special groups that might have been subject to higher or lower penalties (e.g. group practices or member of accountable care organizations had certain advantages or disadvantages).
While the programs are separate, there is important overlap and here is an example. PQRS penalties are different from the Value Modifier (VM). However, your performance on PQRS is used in the calculation of your VM (individuals who do well with PQRS fall in the “high quality” segment).
Meaningful Use has overlap with PQRS and the Value Modifier program in several areas, one of which is the area of Clinical Decision Support (CDS). To meet your MU2 requirements you need to have 5 CDS interventions related to 4 or more clinical quality measures (CQMs). This is actually an exciting opportunity and is where Intellicure clients have a big advantage over other wound care practitioners.
Follow my logic here:
- You must pass 9 Clinical Quality Measures (CQMs) to avoid penalties under PQRS. (The rules for this are complex and I am going to discuss them in detail below).
- To avoid penalties under MU2, you must (among other things) have 5 Clinical Decision Support interventions related to 4 or more CQMs.
So, at Intellicure, it seems logical to us, why not provide you with NINE Clinical Decision Support interventions related to at least 9 clinical quality measures – enabling to you to pass BOTH PQRS AND MU2?
I will be taking you step by step through the 9 quality measures we are suggesting that our clients focus on as part of PQRS, and the Clinical Decision Support within Intellicure that will ensure you pass those measures.
Overview of MU2
Here are 4 big picture things about these changes you need to know, and then we will drill down into the particulars.
- Every provider will now be completing a 90-day reporting period.
The Final Rule states that all providers will attest for a 90-day reporting period in 2015. By shortening the reporting period time-frame, CMS hopes to ease providers through the transition to the new modified Meaningful Use program.
- All providers are now in Stage 2 of Meaningful Use — with a “Modified Stage 2” for providers that were previously in Stage 1.
CMS has removed what was termed “Stage 1” from the program so that they could say that everyone is now in Stage 2. However, if a provider was going to be in Stage 1 in 2015, it’s going to be called “Modified Stage 2”, except the requirements will be the same as were in Stage 1. Got that?
- The core and menu measures have been simplified into 10 “Objectives.”
Every provider will complete and attest to 10 objectives, with one or several measures per objective. There is no longer a concept of “core” or “menu” measures.
- The Stage 2 measures that required patient engagement have been significantly reduced.
This is the measure that required your patients to access and view their data electronically. I won’t discuss what it was. The new requirement is that at least one patient seen by the eligible provider (EP) during the reporting period has to achieve the measure that is called, “Patient Electronic Access: View Download and Transmit health information.” Also, the secure messaging requirement is now that the EHR “fully enables” the capability for patients to send and receive a secure electronic message.
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Caroline Fife, MD
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