Deciphering MU Stage 2
Your frequently asked questions answered and explained.
By Jeff Grant and Darla Shewmaker
This year, more than 250,000 providers have to meet the requirements of Meaningful Use (MU) Stage 2, the EHR Incentive/Penalty program. Some EPs struggle to understand new Stage 2 measures as well as older measures that were modified for Stage 2.
Ophthalmologists, in particular, experience some problems due to their scope of practice and the technology used in today’s practice. To help you understand some of the more confusing Stage 2 measures, we’ve answered the following frequently asked questions.
WHAT DOES CMS MEAN BY A “RADIOLOGY ORDER,” AND WHICH OPHTHALMOLOGY IMAGING TECHNOLOGIES ARE INCLUDED?
First, let’s start with a couple of key definitions.
• Radiology Order. Order for any imaging service that uses “electronic product radiation.” The EP can include orders for other types of imaging services that do not rely on electronic product radiation in this definition as long the policy is consistent across all patients and for the entire EHR reporting period.
• Electronic Product Radiation. Any ionizing or nonionizing electromagnetic or particulate radiation, or any sonic, infrasonic or ultrasonic wave that is emitted from an electronic product as the result of the operation of an electronic circuit in such a product.
Keep in mind that the definition only includes technologies that generate an image and use “ionizing and non-ionizing radiation.” The technologies used in ophthalmology that meet the definition include: a-scans, b-scans, some pachymeters and most OCTs. Fundus photos, visual fields, fluoresceins and external photos do not meet the definition.
You are permitted to expand the definition to include any imaging technologies that you choose. This includes technologies that aren’t covered by the literal definition, such as fundus photos. However, expanding the definition might prevent you from being able to exclude radiology orders, especially if CMS doesn’t follow through on announced plans to reduce the reporting period in 2015.
» WHAT HAPPENS IF I ATTESTED FOR 2014 AND/OR PREVIOUS YEARS AND HAVE CHOSEN NOT TO ATTEST IN 2015 OR FUTURE YEARS?
You will be penalized beginning in 2017 (based on not attesting in 2015) and every year thereafter. The penalty in 2017 will be 3% of your Medicare payments (excluding injectables), increasing to 4% in 2018 and up to 5% in 2019 and every year thereafter. (The penalty could cap out at 3% if enough EPs continue to attest, but this is very unlikely.)
So, a provider with $500,000 in Medicare payments (excluding injectables) in 2017 and an annual growth rate of Medicare reimbursement of 3% (very conservative) will be penalized approximately $271,000 over the 10-year period (2017-2026). This penalty calculation assumes that no future legislation is enacted that would increase the annual penalty above 5%.
Counteracting this penalty would require about 180 additional payment visits per year, or close to one per day (180 x $150 revenue collected per patient visit = $27,000 per year x 10 years).
» WITH REGARD TO THE CPOE MEASURE, WHAT DOES CMS MEAN BY A “LABORATORY ORDER”?
A laboratory order must be an outside facility. Any lab test done within your office does not count for this measure.
HOW LONG IS THE MU REPORTING PERIOD FOR 2015?
Unless you are in your first year, the reporting period for 2015 is currently a complete calendar year. If this is your first year to attest, you can choose any 90-day period.
New legislation expected this spring will reduce the reporting period. In a formal statement on Jan. 29, CMS promised to modify aspects of the program to match long-term goals, reduce complexity and reduce providers’ reporting burdens as well as shorten the EHR reporting period in 2015 to 90 days.
» “ORDERS” CAN ONLY BE ENTERED BY “LICENSED HEALTH CARE PROFESSIONALS OR CREDENTIALED MEDICAL ASSISTANTS.” WHAT ABOUT NONCREDENTIALED SCRIBES?
Consider Certified Medical & Surgical Scribe (CMSS) certification offered by the American College of Medical & Surgical Scribes (www.theACMSS.org). CMS has ruled that this certification is acceptable “if a staff member of the eligible provider is appropriately credentialed and performs similar assistive services as a medical assistant but carries a more specific title due to either specialization of [their] duties or to the specialty of the medical professional [they] assist. He or she can use the CPOE function of CEHRT and have it count towards the measure.”
Note that a crosswalk between the duties, functions and educational areas of a medical assistant versus an ophthalmic scribe is available to members of ASCRS and ASOA.
» HOW DOES THE MENU SET MEASURE FOR “IMAGING RESULTS” DIFFER FROM THE CORE MEASURE CPOE FOR RADIOLOGY ORDERS?
The CPOE measure refers to the “order,” and this Menu Set measure refers to the “result” of the test that was ordered. This measure requires that the resulting image be saved in the EHR or, if stored in a third-party image management system, must be “accessible” from the EHR. “Accessible” is defined as a link.
» I JUST RAN MY MU REPORT FOR JANUARY 2015, AND MY PERCENTAGE ON THE “PATIENT REMINDERS” MEASURE IS VERY LOW. WHAT’S WRONG?
Reminders for previously scheduled services can’t be counted for this measure. So you must “remind” patients about things not already scheduled. This could be done through your software’s recall system, via a database query function that allows you to notify patients or some similar function.
If your percentage for this measure is low after the first or second month of the calendar year, relax. The percentage will grow as you continue throughout the year, because the denominator stays the same while the numerator grows.
So, your percentage will climb as you send more recalls, and it should exceed the 10% requirement over the course of a year, even if you only send a few recalls/reminders each month. However, if the reporting period is shortened (as CMS has announced), it might make it much more difficult for some practices.
» SHOULD I SIGN UP FOR THE IRIS REGISTRY? HOW WILL IT HELP ME MEET MU?
Eligible physicians who sign up and meet the reporting requirements can use the IRIS Registry to report clinical quality data to the Physician Quality Reporting System (PQRS) and the Medicare Electronic Health Record Incentive Program. The IRIS Registry, sponsored by the AAO, automatically extracts and submits the practice’s data for PQRS measures to the CMS. Each practice can map its patient data uniquely and continue to document according to its preference.
HOW DOES CMS DEFINE A “TRANSITION OF CARE”?
Transition of care is “the movement of a patient from one clinical setting (inpatient, outpatient, physician office, home health, rehab, long-term care facility, etc.) to another or from one EP to another.” Simply, transition of care applies any time a patient moves from your practice to another provider or any time a patient is referred or returns to your practice.
This process impacts two Stage 2 measures:
1. Core Measure 14/Medication Reconciliation. Medication reconciliation must be performed for at least 50% of the patients who are transitioned into your practice from another provider or care setting.
2. Core Measure 15/Summary of Care. A summary of care record must be provided for each transition or referral to another provider for a minimum of 50% of the referred patients. At least 10% of these summaries must be provided electronically.
PQRS data submission through the IRIS Registry also satisfies the requirement to report clinical quality measures (CQM). Participation in the IRIS Registry also satisfies a menu objective for Stage 2: Reporting to Specialized Registries. For more, visit http://www.aao.org/iris-registry.
» WE DID A SECURITY RISK ANALYSIS IN 2014. DO WE NEED ANOTHER ONE FOR 2015?
Yes, you need a security risk analysis for each reporting year. These steps may be completed outside of the EHR reporting period timeframe but must take place no earlier than the start of the EHR reporting year and no later than the provider’s attestation date.
» FOR SECURE MESSAGES TO COUNT FOR MU, DOES THE PROVIDER NEED TO RESPOND PERSONALLY?
Core Measure 17/Use of Secure Electronic Messaging states that “a secure message was sent using the electronic messaging function of CEHRT by more than 5% of unique patients (or their authorized representatives) seen by the EP during the EHR reporting period.” Secure messages include email, an EHR’s electronic messaging function, an online patient portal or any other electronic means. Check with your EHR vendor for detailed options for your patients.
The EP is not expected to personally respond to electronic messages to the patient and can assign responsibility to a staff member. Also, an EP or staff member could reply to a patient’s electronic message with a telephone call or office visit — the reply is not required to be electronic.
CMS announced that Stage 2 MU requirements and reporting will have additional changes this year that are related to 2015 reporting. Watch for these changes and monitor your internal reporting on the measures to ensure your practice stays on track to avoid possible penalties. OM
About the Authors
Jeff Grant is founder of HCMA, Inc., which specializes in management, operations and IT consulting for medical practices. Email him at email@example.com.
Darla Shewmaker has spent 17 years on the front lines of EHR design and implementation. She recently left her position as VP of product development at Compulink and is focusing on ophthalmic practice consultations, education and compliance. Email her at Darla@destinationsconsulting.com.