Changes ahead for meaningful use
On April 11, the Centers for Medicare & Medicaid Services (CMS) announced the proposed rule, Electronic Health Record Incentive Program—Modifications to Meaningful Use in 2015 Through 2017. This rule proposes significant changes to the meaningful use (MU) program, including changing the reporting period to 90 days in 2015 as well as removing several core and menu set measures from the program and reducing the reporting thresholds for other measures.
Based on the changes outlined below, the AAD recommends that members reconsider MU activities, especially those that may be labor-intensive or costly, while we await the final rule from CMS. Once the final rule is released in mid-July, the AAD will announce the finalized changes to the program on its website. Physicians will most likely report for a 90-day period after that time with attestation to occur in early 2016. For additional questions, please contact firstname.lastname@example.org.
The list below contains some of the more significant proposed changes to MU:
- Stage 1 would be eliminated from the program and all participants would be required to report either Stage 2 or a modified Stage 2 set of measures.
- There are 9 core objectives and 1 public health objective for Stage 2 or the modified Stage 2 set:
- Protect electronic health information
- Use clinical decision support
- Perform computer physician order entry (CPOE) on medication, lab and radiology orders
- Perform electronic prescribing
- Provide a summary of care record for transitions of care
- Identify and provide patient-specific education resources
- Perform medication reconciliation on patients
- Provide patients the ability to view their health information
- Use secure electronic messaging to communicate with patients
- Submit data to relevant public health and clinical data registries
- Stage 2 core measure for patient interaction is reduced from 5% of patients viewing, downloading or transmitting their medical record to only one patient being required to perform this action.
- Regardless of your stage, you would report for any continuous 90-day period in 2015.
- Stage 2 core measure requiring 5% of your patients to send a secure electronic measure is dropped to simply enabling the secure electronic messaging feature on your EHR.
- Attestation for 2015 won’t be available until after January 1, 2016.
As part of the American Recovery and Reinvestment Act of 2009, also known as the economic stimulus package, the Health Information Technology for Economic and Clinical Health (HITECH) Act created incentives for eligible dermatology practices for implementation and meaningful use of electronic health record (EHR) and e-prescribing (eRx) technologies.
In an effort to improve health care quality, safety, and efficiency through the promotion of health IT (HIT), the HITECH Act allows qualifying dermatology practices — that participate in Medicare and Medicaid — to be reimbursed up to $44,000 for adopting a certified EHR as long as they have at least $24,000 in Medicare allowed charges per year and use their certified EHR in a meaningful way based on three broad requirements:
- The EHR must be certified through the Office of the National Coordinator.
- The EHR must provide electronic exchange of health information.
- Eligible dermatologists must submit clinical quality measures and potentially other measures yet to be defined.
Beginning in 2011, objectives and measures defining meaningful use of EHR would be implemented over five years through three stages:
Stage 1: Data Capture and Sharing (implemented in 2011-2012).
Stage 2: Advance Clinical Processes (to be implemented in 2014).
Stage 3: Improved Outcomes (to be implemented in 2017).
The Centers for Medicare and Medicaid Services (CMS) issued a proposed rule in May 2014 which would allow providers to continue using electronic health records (EHR) certified for 2011 Edition certified EHR technology (CEHRT) or a combination of 2011 Edition and 2014 Edition CEHRT and report Stage 1 measures for Medicare meaningful use reporting in 2014.
Visit the AAD HIT-Kit for more information on specific measures and objectives for each stage of meaningful use.
AADA position on EHR and meaningful use
The American Academy of Dermatology Association (AADA) continues to advocate for, educate, and engage members to ensure that the health information technology (HIT) needs and priorities of dermatology are being addressed and met.
Specifically, the AADA is actively engaged in representing the concerns of dermatology practices and patients in the development and implementation of HIT systems and incentive programs. The Academy remains concerned that some provisions of HIT implementation, as well as other Medicare reporting requirements, pose an undue burden on physicians to achieve compliance with the regulations.
AADA advocacy activities
- HITECH Act and stage 1 meaningful use
In March, 2010, the AADA sent a comment letter to CMS, expressing its support of incentives that foster the voluntary adoption of affordable and reliable health information technology.
However, the AADA voiced its concerns that requiring overly burdensome benchmarks and complex requirements will only discourage office-based physician participation in the program, thereby risking growing reluctance to implement, manage, and maintain EHR systems. Specifically, the AADA asked CMS to consider a more flexible approach and scalable requirements for incentivizing and enabling dermatologists and their practices to comply with the first stage of meaningful use EHR adoption.
Read the AADA comment letter regarding the CMS meaningful use incentive program.
- Stage 2 meaningful use proposed rule
On March 7, 2012, the Centers for Medicare and Medicaid Services (CMS) released its proposed rule for stage 2 meaningful use. The AADA issued a comment letter to CMS expressing concern over unachievable compliance thresholds, as well as efforts that measure physician performance by initiatives that require patient action or compliance. The AADA stated that the proposed rule failed to advance meaningful physician-patient interaction.
Read the AADA comment letter regarding the stage 2 meaningful use proposed rule.
The AADA also joined more than 20 other specialty physician organizations in sending a letter to members of Congress highlighting the importance of improving the quality, safety and efficiency of patient care in the use of EHR technology.
Read the AADA letter to Congress regarding the stage 2 meaningful use proposed rule.
- Stage 2 meaningful use final rule
On Aug. 23, 2012, CMS announced its final rule to govern stage 2 of the Medicare and Medicaid EHR Incentive Programs. The final rule adopted many provisions presented in the proposed rule from March and the agency reduced some thresholds for successful compliance.
The CMS stage 2 meaningful use final rule was released without a comment period.
The AADA submitted a letter to the Agency for Healthcare Research and Quality (AHRQ) within the U.S. Department of Health and Human Services in response to the AHRQ’s request for information on developing and reporting on electronic quality measurements.
Read the AADA comment letter to AHRQ regarding suggestions for improving health IT-enabled quality measurement.
- Stage 3 meaningful use preliminary recommendations
On Jan. 14, 2013, the AADA submitted comments to the Office of the National Coordinator for Health Information Technology, Health Information Technology Policy Committee (HITPC), on preliminary stage 3 meaningful use recommendations for EHR.
The recommendations substantially boost requirements for data exchange among providers, and would include an increase in clinical-decision support by physicians and hospitals, through computerized physician order entry, medication reconciliation, and structured and machine-readable data.
The AADA expressed concern about the burdens physicians will face meeting these additional requirements — many of which are not yet fully supported by technology. The AADA suggested a measured approach to advancing meaningful use, and urged the HITPC to implement policies that would prospectively develop the infrastructure foundation necessary for advancing meaningful use.
Read the AADA comment letter regarding stage 3 meaningful use preliminary recommendations.
The HITPC is expected to review comments and make modifications to these preliminary recommendations. Accordingly, these recommendations may be considerably changed prior to any rulemaking. The AADA will have additional opportunity to comment when proposed and final rules are filed.
- EHR implementation improvements
The AADA signed on to a letter from the AMA calling on the U.S Department of Health and Human Services to extend the timelines providers have to implement 2014 Edition Certified EHR software and meet the Program requirements (Stages 1 and 2) through 2015. Read the joint letter.
On March 21, 2013, Rep. Diane Black introduced HR 1331 — a bill that would improve the implementation of electronic health records (EHR). Most notably, HR 1331 calls for the streamlining of program requirements so as to avoid unintended provider penalties. Additionally, the bill proposes the creation of a hardship exemption for solo practices and providers in or near retirement and establishes an appeals process before penalties are applied.
The AADA signed on to a letter supporting HR 1331 with the American College of Surgeons. Read the AADA letter of support.