By now, you've likely seen the Stage 2 regulations for CMS' EHR Incentive Programs — but do you fully understand them? Are you a little overwhelmed with the increased percentages in the core measures to meet and the tasks to perform?
We asked Rosemarie Nelson, a healthcare consultant with the Medical Group Management Association, to get to the bottom of the 17 core measures you'll have to meet. Her "What It Means" analysis for each measure gets through the government-speak and tells you what to do — and how to do it.
Record using CPOE more than 60 percent of medication, 30 percent laboratory, and 30 percent radiology orders created by the eligible professional (EP).
What It Means
Although some physicians may see this as a burden, it is actually a strong benefit to the practice operations. By creating orders, the staff can track for open/outstanding orders to be sure the patient has complied and/or to be sure the result has been received. No more walking into the exam room with a patient expecting to hear about their CT or MRI and realizing that the report is missing!
Generate and transmit permissible prescriptions electronically (e-Rx)
More than 50 percent of all permissible prescriptions, or all prescriptions written by the EP, are queried for a drug formulary and transmitted electronically using certified EHR technology.
What It Means
This combines a core and a menu (optional) requirement from Stage 1. It makes a lot of sense to combine electronic prescribing with the application of a drug formulary so that the practice eliminates some of the back-and-forth with the pharmacy when the patient’s prescription is off formulary. A win-win operationally with better service to the patient.
More than 80 percent of all unique patients seen by the EP during the EHR reporting period have demographics recorded as structured data.
What It Means
This is a simple, one-time event that requires modification only if the patient has a change, and of course as structured data, you can use the fields for reaching out to patients via automated phone, mail, or e-mail. It is likely that you’ve been recording this information as structured data for as long as you’ve had a practice management/billing system.
More than 80 percent of all unique patients seen by the EP during the EHR reporting period have blood pressure (for patients age 3 and over) and height/length and weight (for all ages) recorded as structured data.
What It Means
You’ve been weighing patients, capturing height and taking blood pressures and recording it in a paper form — that’s structured data that is even more easily captured online in a table/matrix for easy graphing. Parents love to see the progress of their children, and graphing my weight and blood pressure might just create that teachable moment to get me to change my behavior (or at least take my medication)!
The EP records, for more than 80 percent of all unique patients age 13 or older, smoking status as structured data.
What It Means
This is another simple capture at intake. Most likely your EHR has a designated field because the vendors understand the components of meaningful use as well.
The EP implements five clinical decision support interventions related to five or more clinical quality measures; and the EP enables and implements the functionality for drug-drug and drug-allergy interaction checks for the entire EHR reporting period.
What It Means
This is an increase from three to five clinical measures with the assumption that your EHR automatically provides alerts/warnings for drug-drug and drug-allergy interactions. The key here is that you/your team are alerted during the patient encounter if that patient is missing or in need of the quality measure. For example, if I am a diabetic and have not had a foot exam, the EHR should alert the intake nurse so that the nurse has me prepped (shoes and socks off) for the provider.
More than 55 percent of all clinical lab test results ordered by the EP are incorporated in certified EHR technology as structured data.
What It Means
Lab interfaces! Operationally your practice is much more efficient if the bulk of incoming lab test results are automatically updated in the EHR as structured data. It is far more efficient for you to review/trend my PSAs or HB A1Cs over time if the values have been entered into a chart/matrix rather than simply opening up PDF after PDF to compare and contrast the current result to the previous value. You may need to have your EHR interfaced to two labs to meet the 55 percent benchmark, but that will vary by geographic location and payer requirements for labs in-network. Look at your current volumes to prioritize the interface work if you don’t currently have test results interfaced.
Generate at least one report listing patients of the EP with a specific condition.
What It Means
This can be very helpful to be sure that you are following patients as you’d expect. For example, if you typically follow patients with a particular disease quarterly, or annually, or any other routine, a report that lists all those patients with their last visit date and their next scheduled appointment will help you identify those patients out of compliance. In addition to meeting your own quality standards for monitoring those patients, the report will help you generate revenue by getting those appointments scheduled. And, it all happens when your EHR administrator generates that one report.
More than 10 percent of all unique patients who have had an office visit with the EP within 24 months prior to the beginning of the EHR reporting period are sent a reminder, per patient preference.
What It Means
This is a huge marketing boost for your practice. First, you send the patients a message that says you’re looking out for them as well as their auto mechanic looks after the oil change in their car! In addition, it gets the established patient back into your practice. It costs 12 times as much to recruit a new patient as it does to maintain an established patient in a medical practice.
More than 50 percent of all unique patients seen by the EP during the EHR reporting period are provided online access to their health information within four business days after the information is available to the EP, subject to the EP’s discretion to withhold certain information. And, more than 5 percent of all unique patients seen by the EP (or their authorized representatives) view, download, or transmit to a third party their health information within four business days.
What It Means
Think about how invasive technology has become. Can you get your patients to stay off their smartphones during your patient visit? Achieving a 5 percent benchmark of patients, or their representatives (think about me helping my elderly mother manage her care, or my very connected niece with a toddler and newborn), is very achievable in today’s online world. Here’s a tip for making that connection with your patients: Introduce the patient to the convenience of self-service, 24-hour available health info through your patient portal in the exam room and tell them that at check-out the staff will tell them more. Then train your check-out staff to provide patients with a pamphlet or handout that instructs them on how to log on the first time and when they can expect to see their lab work, or access their children’s immunizations.
The EP provides clinical summaries to patients within one business day for more than 50 percent of office visits.
What It Means
Make this item a regular part of the check-out process. Train your staff to provide the clinical summary to the patient with their next scheduled appointment and/or their payment receipt. Make it a routine for all and you’ll have no problem reaching the 50 percent benchmark. Be sure that your EHR documents that you’ve done this, so that you can easily report how frequently it was performed.
The EP provides, for more than 10 percent of all office visits, patient-specific education resources identified by EHR.
What It Means
I have been visiting medical practices for several years where I’ve seen providers and/or nurses hand out educational material and even write prescriptions for websites that the patient can review. Incorporating this into the EHR will make it even easier to streamline the work flow and include the educational resources with the clinical summary distributed at check-out.
The EP performs medication reconciliation for more than 50 percent of transitions of care in which the patient is transitioned into the care of the EP.
What It Means
Aren’t you doing this all the time? When you have a new patient, you typically collect from that patient all their medications and that’s just normal business! The trick here is to be sure that you are getting “credit” for it — how does your EHR log that you have completed that medication reconciliation? If you need to check a box once you’ve completed it, be sure to check the box!
The EP provides a summary of care record for more than 50 percent of transitions of care and referrals. And the EP provides a summary of care record for more than 10 percent of transitions and referrals either electronically transmitted using certified EHR technology to a recipient, or where the recipient receives the summary of care record via exchange facilitated by an organization that is a NwHIN Exchange participant, or in a manner that is consistent with the governance mechanism ONC establishes for the nationwide health information network. And, an EP must satisfy one of the two following criteria: 1. Conduct one or more successful electronic exchanges of a summary of care document with a recipient who has EHR technology that was developed or designed by a different EHR technology developer than the sender's EHR; 2. Conduct one or more successful tests with the CMS designated test EHR during the EHR reporting period.
What It Means
Now we’re starting to reach beyond our exam room’s walls and share this information about the patient with other care providers. The summary of care record is just that document that you’ve provided when you refer a patient out or that document that you receive when the patient has been seen elsewhere (think hospital emergency room discharge summary letter). You’ve been doing this and you’ll continue to do it, so hitting the 50 percent mark is a given. The concern is the electronic 10 percent. Remember, standards have been established that certified EHRs have embedded within their product, so you have the tools. You may need assistance from your EHR vendor to meet one of the two additional criteria: exchanging a summary of care document with a different EHR system, or if that isn’t feasible, conducting the exchange with a CMS-designated test EHR. Engage your vendor here and monitor your frequency. You will achieve the 10 percent if you start this process early.
The EP successfully submits electronic immunization data from the EHR to an immunization registry or immunization information system for the entire EHR reporting period.
What It Means
It is likely that you tested this once during Stage 1, so now it’s time to put it into regular practice. Some practices may be delayed by the receiving registry’s technology capabilities, but with the extended timeframes, the registries will likely be ready when you are.
The EP conducts or reviews a security risk analysis in accordance with the requirements under 45 CFR 164.308(a)(1), including addressing the encryption/security of data at rest in accordance with requirements under 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 provider's risk management process.
What It Means
This item is consistent with the Stage 1 requirement. The question is: Did you establish a process to review your risk analysis annually? Be sure you pull out the document or tool and update it annually including remediation plans or explanations for why you cannot remediate against a particular risk.
More than 5 percent of unique patients seen during the reporting period send a secure message using the electronic messaging function of the EHR.
What It Means
This ties in nicely to the requirement to provide patients with online access to their health information. Once you’ve made the connection with your patients and they have online access, provide the patient with online services like requesting prescription reissues and appointments. You’ll hit 5 percent just with those two items because patients are tired of trying to reach your practice on the telephone and getting put on hold. People use their computers and the Internet at all hours of the day and evening and by providing interactive services, you’ll free up your telephone staff because patients will have used your secure messaging during off hours. Be sure that your telephone triage staff manage the online messages as well as the telephone calls and messages.
Rosemarie Nelson is principal consultant for the Medical Group Management Association Health Care Consulting Group. She conducts educational seminars and provides keynote speeches on a variety of healthcare technology and operational topics. She has authored numerous articles on practice management issues, and her seminar presentations and publications have been well-received by physicians, administrators, office managers and staff throughout the country. Nelson can be reached at www.mgma.com/consulting/nelson.
Learn all about the Stage 2 rules for the EHR Incentive Programs:
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