Which Allscripts products will be needed to meet MU Stage 2, including Population Health functionality, and when will those products be ready?
Allscripts EHRs – specifically Sunrise, Enterprise, and Professional– are each already certified for Stage 1 requirements. Each will also be certified according to the new requirements to qualify as “2014 editions,” and those versions will be made available to our clients who are participating in Stages 1 and Stage 2 well in advance of the program deadlines for 2014. In fact, most will be generally available by the end of the first quarter of 2013. Thus, Allscripts EHRs will be ready with Population Health functionality to meet or exceed the requirements of Stage 2 MU.
Will Allscripts be able to support these upgrades for all its clients?
Yes, Allscripts remains committed to ensuring that every client will have the ability to successfully demonstrate Meaningful Use.
How can Allscripts clients participate in PQRS? What products and versions are needed?
Allscripts clients, using any Allscripts EHR, can participate in PQRS through a registry.
What if I already attested for MU stage 1? What do I do now to prepare for Stage 2?
If you successfully attested for Stage 1 in 2011, you must attest to a full 12-month reporting period for both 2012 and 2013, and then 90 days in 2014 when you start Stage 2.
If you successfully attested for Stage 1 in 2012 for the first time, you will need to continue performing and satisfying the Stage 1 requirements in 2013 but this time for a full year (a 12-month reporting period). You will then move to Stage 2 in 2014 and attest to a 90-day reporting period. 2014 is the only year that there will be the 90-day allowance for Stage 2.
To prepare for Stage 2, we recommend familiarizing yourself with the rules and evaluating the need for additional provider and staff training to ensure an appropriate level of readiness.
If we've already attested for Stage 1, how does Stage 2 being delayed until 2014 affect our plans for 2012 and 2013? Does it change anything for 2012/ 2013 respectively?
The only change is that in 2013 you will again demonstrate Stage 1, instead of beginning Stage 2 at that point, as the Stage 1 rule originally stated back when it was published in 2010. You must now demonstrate MU for a full year in 2013 exactly as you are now doing in 2012.
What if I have yet to attest for MU stage 1? What should I do now?
You can begin Meaningful Use at any time, provided you demonstrate MU for 90 consecutive days in a single year for your first year. To accommodate this 90-day requirement, you would have needed to begin your MU reporting period by October 3, 2012 to be able to participate this year. Additionally, your attestation would need to be submitted to CMS through its web site no later than two months after the end of the program year, though you can file it as soon as you complete the 90 days to receive your payment faster. That said, you can start Stage 1 as late as 2014 without being subject to penalties.
When do the changes to Stage 1 take effect?
All the changes to Stage 1 found in the final rule become effective in 2014. Some of them become optionally effective in 2013.
Learn more about the
changes to Stage 1 in this CMS tipsheet.
What are the differences in reporting requirements between Stage 1 and Stage 2?
Stage 2 continues the drive to value-based healthcare, raising the bar on most measures and adding new functional and clinical measures with special emphasis on information exchange and patient engagement. Stage 2 also includes more flexibility and options, including changes for 2013 with emphasis on penalties, reviews and appeals.
Eligible Hospitals can compare Stage 1 and Stage 2 Measures here.
Eligible Providers can compare Stage 1 and Stage 2 Measures here.
How do we balance and/or choose between Medicare and Medicaid reporting requirements?
Eligible Professionals are only able to choose one program to participate in and can only switch between programs once. Requirements between the programs are largely identical. A handful of states have slightly adjusted requirements around public health reporting, but for the most part, requirements are the same no matter if you choose to participate in Medicaid or Medicare.
Additionally, when the Medicaid payments end, Medicare payment adjustments will still remain in effect. At this point, no state has implemented Medicaid payment adjustments for non-participation in the program, though they do have the right to do that under the HITECH Act in the future.
What are the CQM requirements for Stage 2?
All CQM requirements begin in 2014 for participants in both Stage 1 and Stage 2. You must report on nine CQMs from a menu of 64 (which contains most of the current 44 plus new ones currently being finalized by measure developers). Some examples of the new measures include: pediatric, obstetric, behavioral/mental health, HIV medical visits, antiretroviral therapy, oral health. You must include at least one CQM from three of the six domains. CMS has also recommended “Core groups” for general practice and pediatrics, and many are geared towards Medicaid providers.
What are the financial implications of participating in MU versus not participating in MU, and what timelines are associated with those implications?
If a provider does not participate in any particular year of MU, that provider forfeits the incentive payment for that year, and if participating in the Medicare program, when/if that provider decides to return to the program, he or she will not be able to make up for that lost year(s). For example, if you skip the second and third years of the program before returning the following year, you would only be eligible for the payment associated with the fourth year.
Furthermore, if any year of non-participation is from 2013 onward, you will also incur a penalty in the form of a “payment adjustment,” which will be assessed beginning in 2015 and continue indefinitely at a maximum of 5% of your fee schedule.
For those who do participate, stimulus incentives continue for five years (under Medicare) or six years (under Medicaid), including all of Stage 1 and Stage 2, and the first year of Stage 3 for most (unless you started in 2011, in which case you have five years at Stages 1 and 2).
How does eRX figure into MU?
eRX is very important to MU as several of the measures associated with MU are tied to ePrescribing behaviors. Participating in MU thus satisfies requirements related to the MIPPA incentive program, which is now largely based on penalties.
Payment adjustments are also cumulative across the various programs – if someone doesn't participate in MIPPA and doesn't participate in MU, they will see double the penalty.
How does CPOE figure into MU?
CPOE requirements for medications continue from Stage 1 to Stage 2. Additionally, in Stage 2, labs and radiology are added as additional CPOE measures. CPOE is, in all cases, about the order entry process and not about the transmission of the order.
Explore this useful matrix of the measures and exclusions.
What are the key components of the patient engagement measure for MU Stage 2?
The Stage 2 final rules have eased, but not eliminated, patient engagement measures as compared to the NPRM. There are requirements related to the speed with which a provider must share information with a patient electronically, measurement of patients' access to information via a portal and patient education.
Explore this useful matrix of the measures and exclusions.
Is CMS expanding the measures to cover more specialties?
Generally, the MU program is not specialty-specific, and the functional measures related to general program participation are generally applicable across the board. The Stage 2 final rule does allow exemptions from the payment adjustment perspective for certainly specialties (pathologists, radiologists and anesthesiologists).
As far as the clinical quality measures, which are much more tied to specialty, those are being expanded by approximately 50% in Stage 2 so that providers have more choices. The final CQMs will be released by the government throughout the Fall of 2012.
What should providers know about HIPAA and MU?
The rules of HIPAA still apply to all care processes falling under the Meaningful Use program. Additionally, there are expansions of HIPAA that were called for under the HITECH legislation, and we expect those Final Rules from HHS shortly.
Which providers are considered “eligible” for MU?
- doctor of medicine or osteopathy
- a doctor of oral surgery or dental medicine
- a doctor of podiatric medicine
- a doctor of optometry
- a chiropractor
Find additional information about eligible providers