Summary of Meaningful Use 2015 Proposed Rule Changes
Last week CMS released the proposed modifications to the MU program for the 2015 reporting year. In reviewing them I created the following outline for myself to help understand and digest the 210 pages. I thought I would share my work with the following disclaimers.
IMPORTANT DISCLAIMERS
- This is based on the proposed modification for the 2015 reporting period. They are open for public comment for two months and will be revised before they are final.
- This is a brief, high level summary. There are many caveats, clarifications, and details that I did not capture as I just wanted a summary of the measures.
- This summary is purely my interpretation and does not represent endorsement by any other individuals or corporations. I have no particular expertise and make no representations as to such.
- Since my work is focused on EHs and CAHs in the Stage 2 reporting period this summary catches only that which impacts facilities within this demographic.
The summary below has two sections. First is a section with the key changes broken down into four components; the proposed change in the reporting period, a listing of the eliminated objectives, the modified thresholds, and some notes about the proposed new structure of the objectives.
The second section is an outline summary of all the measures as they would look if accepted as they are currently proposed.
KEY CHANGES
Reporting Period
The proposed changes “will allow eligible hospitals and CAHs (regardless of their prior participation in the program) to attest to an EHR reporting period of anycontinuous 90-day period within the period between October 1, 2014 and the close of the 2015 calendar year.”
Eliminated Objectives
Removing requirements for “objectives and measures which are redundant or duplicative or which have topped out."
- Record Demographics
- Record Vital Signs
- Record Smoking Status
- Structured Lab Results
- Patient List
- Summary of Care
- Measure 1 – Any Method
- Measure 3 – Test
- eMAR
- Advanced Directives
- Electronic Notes
- Imaging Results
- Family Health History
Modified Thresholds
- Changing the threshold from the Stage 2 Objective for Patient Electronic Access measure number 2 from "5 percent" to "equal to or greater than 1".
- Changing the threshold from the Stage 2 Objective Secure Electronic Messaging from being a percentage-based measure, to yes-no measurestating the "functionality fully enabled".
- Consolidating all public health reporting objectives into one objectivewith measure options following the structure of the Stage 3 Public Health Reporting Objective
- Changing the eligible hospital electronic prescribing objective from a "menu" objective to a mandatory objective with an exclusion available for certain eligible hospitals and CAHs.
Objective Structure
- Eliminate the distinction between core and menu objectives and all retained objectives and measures would be required for the program.
- For the public health reporting objectives and measures proposal is to consolidate the different Stage 2 core and menu objectives into a single objective with multiple measure options.
- The structure of meaningful use for 2015 through 2017 would be 8 required objectives plus 1 public health objective with 3 measure options
SUMMARY OF OBJECTIVES
Computerized Provider Order Entry (CPOE)
Use computerized provider order entry (CPOE) for medication, laboratory and radiology orders directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local and professional guidelines.
Measure 1: More than 60 percent of medication orders created by authorized providers of the eligible hospital's or CAH's inpatient or emergency department (POS 21 or 23) during the EHR reporting period are recorded using computerized provider order entry.
Measure 2: More than 30 percent of laboratory orders created by authorized providers of the eligible hospital's or CAH's inpatient or emergency department (POS 21 or 23) during the EHR reporting period are recorded using computerized provider order entry.
Measure 3: More than 30 percent of radiology orders created by authorized providers of the eligible hospital's or CAH's inpatient or emergency department (POS 21 or 23) during the EHR reporting period are recorded using computerized provider order entry.
Clinical Decision Support (CDS)
Use clinical decision support to improve performance on high-priority health conditions.
Measure 1: Implement five clinical decision support interventions related to four or more clinical quality measures at a relevant point in patient care for the entire EHR reporting period. Absent four clinical quality measures related to an eligible hospital or CAH's scope of practice or patient population, the clinical decision support interventions must be related to high-priority health conditions. It is suggested that one of the five clinical decision support interventions be related to improving healthcare efficiency.
Measure 2: The eligible hospital or CAH has enabled and implemented the functionality for drug-drug and drug allergy interaction checks for the entire EHR reporting period.
Patient Electronic Access (VDT)
Provide patients the ability to view online, download, and transmit information about a hospital admission.
Measure 1: More than 50 percent of all patients who are discharged from the inpatient or emergency department (POS 21 or 23) of an eligible hospital or CAH have their information available online within 36 hours of discharge.
Measure 2: At least 1 patient who is discharged from the inpatient or emergency department (POS 21 or 23) of an eligible hospital or CAH (or his or her authorized representative) views, downloads, or transmits to a third party his or her information during the EHR reporting period.
Protect Electronic Health Information
Protect electronic protected health information created or maintained by the CEHRT through the implementation of appropriate technical capabilities.
Conduct or review a security risk analysis in accordance with the requirements in 45 CFR 164.308(a)(1), including addressing the security (to include encryption) of ePHI data stored in Certified EHR Technology in accordance with requirements in 45 CFR 164.312(a)(2)(iv) and 45 CFR 164.306(d)(3), and implement security updates as necessary and correct identified security deficiencies as part of the EP, eligible hospital, or CAHs risk management process.
Patient Specific Education
Use CEHRT to identify patient-specific education resources and provide those resources to the patient.
More than 10 percent of all unique patients admitted to the eligible hospital's or CAH's inpatient or emergency department (POS 21 or 23) are provided patient specific education resources identified by Certified EHR Technology.
Medication Reconciliation
The eligible hospital or CAH who receives a patient from another setting of care or provider of care or believes an encounter is relevant should perform medication reconciliation.
The eligible hospital or CAH performs medication reconciliation for more than 50 percent of transitions of care in which the patient is admitted to the eligible hospital's or CAH's inpatient or emergency department (POS 21 or 23).
Summary of Care
The eligible hospital or CAH who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care provides a summary care record for each transition of care or referral.
The eligible hospital or CAH that transitions or refers their patient to another setting of care or provider of care (1) uses CEHRT to create a summary of care record; and (2) electronically transmits such summary to a receiving provider for more than 10 percent of transitions of care and referrals.
Electronic Prescribing
Generate and transmit permissible discharge prescriptions electronically (eRx).
More than 10 percent of hospital discharge medication orders for permissible prescriptions (for new, changed and refilled prescriptions) are queried for a drug formulary and transmitted electronically using Certified EHR Technology.
Measure Exclusion: Provider may claim an exclusion for the eRx objective and measure if for an EHR reporting period in 2015 they were either scheduled to demonstrate Stage 1 which does not have an equivalent measure, or if they are scheduled to demonstrate Stage 2 but did not intend to select the Stage 2 eRx menu objective for an EHR reporting period in 2015.
Public Health Reporting
Active engagement with a public health agency to report public health data.
Report to 4 of the following registries:
Option 1 – Immunization Registry Reporting: The eligible hospital or CAH is in active engagement with a public health agency to submit immunization data and receive immunization forecasts and histories from the public health immunization registry/immunization information system (IIS).
Option 2 – Syndromic Surveillance Reporting: The eligible hospital or CAH is in active engagement with a public health agency to submit syndromic surveillance data from an emergency or urgent care department for eligible hospitals and CAHs (POS 23).
Option 3 - Case Reporting: The eligible hospital or CAH is in active engagement with a public health agency to submit case reporting of reportable conditions.
Option 4 - Public Health Registry Reporting: The eligible hospital or CAH is in active engagement with a public health agency to submit data to public health registries.
Option 5 – Clinical Data Registry Reporting: The eligible hospital or CAH is in active engagement to submit data to a clinical data registry.
Option 6 – Electronic Reportable Laboratory Result Reporting: The eligible hospital or CAH is in active engagement with a public health agency to submit electronic reportable laboratory results
Eligible hospitals and CAHs may choose to report to more than one public health registry and more than one clinical data registry to meet the number of measures required to meet the objective.
