Answering Meaningful Use Stage 2 FAQs
Learn more about the penalties, responsibilities and terms that most often baffle practices.
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 ophthalmology practices struggle to understand new Stage 2 measures as well as older measures that were modified for Stage 2, particularly due to their scope of practice and the technology used.
Here, we answered some frequently asked questions to help you understand Stage 2’s more confusing measures.
Q: What happens if I attested for 2014 and/or previous years and choose not to attest in 2015 or future years?
A: You will be receive the following penalties beginning in 2017 (based on not attesting in 2015) and every year thereafter:
• 2017 penalty. 3% of your Medicare payments (excluding injectables)
• 2018 penalty. 4% of your Medicare payments
• 2019 penalty and every year thereafter. 5% of your Medicare payments. (The penalty could cap 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), assuming no future legislation increases the annual penalty above 5%. Counteracting this penalty would require approximately one additional patient visit per day (180 additional payment visits per year x $150 revenue collected per patient visit = $27,000 per year x 10 years).
Q: With regard to the CPOE Measure, what does CMS mean by a “laboratory order”?
A: In the CMS definition, a laboratory is defined as an outside facility. Therefore, lab tests done within your office do not count for this measure.
Q: What does CMS mean by a “radiology order,” and which ophthalmology imaging technologies are included?
A: A radiology order is an order for any imaging service that uses “electronic product radiation.” Electronic product radiation is defined as 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 product.
The practice 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.
Keep in mind that the definition only includes technologies that generate an image and use “ionizing and non-ionizing radiation,” which includes 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 in 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.
Q: With regards to CPOE, “orders” can only be entered by “licensed healthcare professionals or credentialed medical assistants,” but what options do I have for non-credentialed scribes?
A: Consider Certified Medical & Surgical Scribe (CMSS) certification offered by the American College of Medical & Surgical Scribes (www.theACMSS.org). Also, the Joint Commission on Allied Health Personnel in Ophthalmology (JCAHPO) recently announced a new Ophthalmic Scribe Certification (OSC), a 125-item examination that meets the CMS rule.
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.”
Q: How does the Menu Set measure for “imaging results” differ from the CPOE Core Measure for radiology orders?
A: The CPOE Core Measure refers to the ordered test, and this Menu Set measure refers to the “result” of the ordered test that was ordered. This measure requires that the imaging results be saved in the EHR or “accessible” from the EHR, if stored in a third-party image management system. (“Accessible” is defined as a link.)
Q: For secure messages to count for MU, does the provider need to respond personally?
A: 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 e-mail, 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, the reply is not required to be electronic — an EP or staff member could reply to a patient’s electronic message with a telephone call or office visit.
Q: How does CMS define a “transition of care”?
A: 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, this applies any time a patient moves from your practice to another provider or any time a patient is referred or returns to your practice will be a transition of care.”
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. This involves identifying the patient’s most accurate list of all medications, including name, dosage, frequency, and route, by comparing the medical record to an external list of medications obtained from a patient, hospital, or other provider.
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.
CMS announced changes
Stage 2 MU requirements and reporting will have additional changes this year related to 2015 reporting. Watch for these changes, and monitor your internal reporting on the measures to ensure your practice avoids possible penalties. OP
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.