Objectives

Do I have to have an interface for Quality Measures in Stage 2 of Meaningful Use?

No – Initially, CMS indicated plans to require electronic submissions for Clinical Quality Measure (CQM) data but no specifications were provided and the electronic submission requirement was later retracted. The current process for submitting Quality Measures remains acceptable. More information is available on the CMS website.

My facility does not perform many immunizations. Do we still have to report this data?

According to the final rule, an Eligible Hospital or Critical Access Hospital may be exempt if they do not administer any of the immunizations to any of the populations for which data is collected by their jurisdiction’s immunizations registry or immunization information system during the EHR reporting period. Evident recommends each facility contact the state public health agency for confirmation of exclusion - and to request a letter of exclusion (for auditing purposes).

Does my facility have to perform a security risk analysis for Meaningful Use Stage 2?

As with Meaningful Use Stage 1, each facility will have to review or conduct a security risk analysis of the certified EHR prior to the end of the reporting period. A new review must occur for each subsequent reporting period. Parameters of the risk analysis are defined in 45 CFR 164.308(a)(1) created by the HIPAA Security Rule.

I see there are multiple objectives that are not listed for Meaningful Use Stage 2, that were required with Meaningful Use Stage 1. Does my facility have to continue the Stage 1 objectives?

Yes, there are some Meaningful Use Stage 1 objectives that have been incorporated into Meaningful Use Stage 2 objectives. In order to meet the new Stage 2 objectives, the previous Stage 1 objectives must be met.

Where will the Meaningful Use Stage 1 and Stage 2 Statistics Report be located?

The Meaningful Use Stage 1-2011, Stage 1-2014 and the Meaningful Use Stage 2 Statistics Reports are now found under the following path: Hospital Base Menu > Other Applications And Functions > Word Processing > AdHoc Report
These new reports will now be listed under the middle column.

For Stage 2, can Drug-Drug and Drug-Allergy interaction checks count toward the five required clinical decision support interventions?

No. The final rule states that in order to meet the Clinical Decision Support objective, Drug-Drug and Drug-Allergy interactions have to be turned on for the entire reporting period in addition to four clinical support interventions related to four or more clinical quality measures.

The Imaging menu object reads as follows: “Imaging results consisting of the image itself and any explanation or other accompanying information are accessible through Certified EHR Technology.” What does “accessible through Certified EHR Technology” mean?

According to CMS, “accessible through Certified EHR Technology” is defined as either incorporation of the image and accompanying information into Certified EHR Technology, or as an indication in Certified EHR Technology that the image and accompanying information are available for a given patient in another technology with a link to that image and accompanying information.

For the objective Record Demographics, is the final cause of death needed to meet this objective?

No, EHs and CAHs must record in the patient's EHR the preliminary assessment/impression of the cause of death. No further documentation is required. This measure does not require cause of death to be updated if the case is referred to the Department of Health or the coroner’s office.

When will the Meaningful Use payment adjustments start?

Payment adjustments will be applied beginning Oct. 1, 2014, for Medicare-eligible hospitals. CAHs will be applied beginning with the fiscal year 2015 cost reporting period.

If my hospital can only participate in the Medicaid EHR incentive program, are we excluded from the payment adjustments starting in FFY 2015?

Yes. If your hospital is only eligible to participate in the Medicaid Incentive program and you do not bill Medicare, you are excluded from the Federal Fiscal Year (FFY) 2015 payment adjustments.

Transition of Care: When a patient moves from say ER to Inpatient to Skilled all in-house with all areas having full access to the EHR, do we need to create a Patient Summary with each?

No. Patients who transition within the same facility that shares the same certified EHR should not be included in the numerator or denominator of this objective. Additional software set-up is required. Please contact Software Support.

For the menu objective “Lab Results to Ambulatory Providers,” are all ambulatory lab orders included in the denominator or just those that were sent electronically?

Only the electronically received ambulatory lab orders are to be included in the denominator.

What is a “unique” patient?

CMS defines a unique patient as “a patient admitted to the hospital inpatient or emergency department more than once during the EHR reporting period.” Per CMS, “for the purpose of measurement, that patient is only counted once in the denominator for the measure.”

What elements should our facility be documenting on the summary of care for Meaningful Use?

Recently, we have been provided with the following correspondence from CMS. While problems, medication list  and medication allergy list are the key components to populate the numerator of the summary of care measure, CMS now states they will be looking for the CCD to have all of the below elements populated below, if known.  If your facility has attested, Evident recommends that your facility reviews all of the patients in your attestation period contained in the numerator, and make sure the data elements below are documented If known, since this information has recently been made available to us.

We apologize for any inconvenience this FAQ has caused but want to make sure you are aware of recent CMS information. Please also note that any FAQs that are released after the final rule are regarded as “sub-regulatory guidance” by CMS and must be followed within a reasonable amount of time. CMS also communicates the updated FAQs to auditors who utilize the information for  Meaningful Use audits.

FAQ response from CMS: 

Thank you for your recent inquiry. Below is the information you requested regarding the meaningful measures for transitions of care. Our response focuses on the measure for eligible hospitals (EHs), but the eligible professional (EP) measure is essentially the same.

As adopted by CMS, the Stage 1 and Stage 2 objectives require hospitals that transition their patient to another setting of care or provider of care or refer their patients to another provider of care (including long-term care) to provide a summary care record for more than 50 Percent or transitions of care and referrals.

For the Stage 1 measure, CMS did not specify the contents of the summary of care record. While the hospital can send an electronic or paper copy of the summary care record directly to the next provider or can provide it to the patient to deliver to the next provider, if the patient can reasonably expected to do so. However, beyond the CMS requirements, in order to meet this objective and its measures, the hospital must use the capabilities and standards of certified EHR technology (CEHRT) established by the Office of National Coordinator for Health IT (ONC), specifically, the standards found at 45 CFR 170. 205(a)(1) and (2). The ONC has defined the content of a summary of care record to include at a minimum, diagnostic results, problem list, medication list, medication allergy list, and procedures.

For the Stage 2 measure, CMS specifies that the summary of care record must include the following elements:
* Patient name.
* Referring or transitioning provider's name and office contact information (EP only).
* Procedures.
* Encounter diagnosis
* Immunizations.
* Laboratory test results.
* Vital signs (height, weight, blood pressure, BMI).
* Smoking status.
* Functional status, including activities of daily living, cognitive and disability status
* Demographic information (preferred language, sex, race, ethnicity, date of birth).
* Care plan field, including goals and instructions.
* Care team including the primary care provider of record and any additional known care team members beyond the referring or transitioning provider and the receiving provider.
* Discharge instructions
* Current problem list (Hospitals may also include historical problems at their discretion).
* Current medication list, and
* Current medication allergy list.

If the provider does not have the information available to populate one or more of the fields listed, either because they can be excluded from recording such information (for example, vital signs) or because there is no information to record (for example, laboratory tests), the provider may leave the field(s) blank. The only exception to this is the problem list, medication list, and medication allergy list. In the event that there are no current or active diagnoses for a patient, the patient is not currently taking any medications, or the patient has no known medication allergies, confirmation of no problems, no medications, or no medication allergies would satisfy the measure of this objective. In circumstances where there is no information available to populate one or more of the fields listed previously, either because the eligible hospital or CAH can be excluded from recording such information (for example, vital signs) or because there is no information to record (for example, laboratory tests), the eligible hospital or CAH may leave the field(s) blank and still meet the objective and its associated measure.

Beyond the CMS requirements, in order to meet the Stage 2 objective and its three measures, the hospital must use the capabilities and standards of certified EHR technology (CEHRT) established by the Office of National Coordinator for Health IT (ONC), specifically, the standards found at 45 CFR 170.314(b)(2), (g)(1), (g)(2). The ONC has defined the content of a summary of care record to include “at a minimum, the Common MU Data Set and the following data expressed, where applicable, according to the specified standard(s):
(A) Encounter diagnoses. The standard specified in § 170.207(i) or, at a minimum, the version of the standard specified § 170.207(a)(3);
(B) Immunizations. The standard specified in § 170.207(e)(2);
(C) Cognitive status;
(D) Functional status; and
(E) Ambulatory setting only. The reason for referral; and referring or transitioning provider’s name and office contact information.
(F) Inpatient setting only. Discharge instructions.”

For further information regarding the certification and standards criteria, you should contact the ONC at: 
• (202) 690-7385;
• E-mail: onc.request@hhs.gov; or
• Visit its Web site at http://healthit.hhs.gov.

The purpose of providing the summary of care records is to assure that the provider to whom the patient is transferred or referred obtains the  most recent information on the patient that may be crucial to his/her care.  A summary of care record that does not include the required contents as defined by the ONC could not be counted in the numerator of the measure.

The tracking number for this inquiry is 330002. If you have further questions, please visit the CMS Medicare & Medicaid EHR Incentive Programs Website located at http://cms.gov/EHRIncentivePrograms/. You will find accurate and up-to-date information about the programs, including eligibility, payment amounts, requirements, upcoming events and more. Bookmark the above link and check back often to learn more about these programs, or contact the EHR Information Center at (888) 734-6433.

The Medicare and Medicaid EHR Incentive Programs listserv provides timely, authoritative information about the programs, including registration and attestation updates and details about the payment process. The listserv messages are another CMS resource to provide you with the latest news about the Incentive Programs. On average, two messages are sent per week. Information on how to join the listserv can be found at http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentiveProg....

Thank you,

The EHR Information Center

Should swing bed patients be counted in the denominators of Meaningful Use measures for the hospital?

Unique swing bed patients who receive inpatient care should be included in the denominator of Meaningful Use measures. However if the EH or CAH cannot readily identify and include unique swing bed patients who have received inpatient care, those patients may be excluded from the calculations for the denominators of Meaningful Use measures.

Who can enter in medication orders to meet the measure for CPOE?

Any licensed healthcare professional can enter orders into the medical record for purposes of including the order in the numerator for the measure of the CPOE objective if they can enter the order per state, local and professional guidelines. The order must be entered by someone who could exercise clinical judgment in the case that the entry generates any alerts about possible interactions or other clinical decision support aides. This necessitates that CPOE occurs when the order first becomes part of the patient's medical record and before any action can be taken on the order. Each provider will have to evaluate on a case-by-case basis whether a given situation is entered according to state, local and professional guidelines, allows for clinical judgment before the medication is given, and is the first time the order becomes part of the patient's medical record.

If I choose the menu item Electronic Notes, does that mean we have to have to use an electronic progress note through Physician Documentation to meet the objective?

Yes, CMS has recorded this measure as the following: "Enter at least one electronic progress note created, edited and signed by an authorized provider of eligible hospital’s or CAH IP/ED (POS 21 or 23) for more than 30% of unique patients admitted to the hospital/CAH’s IP/ED during the EHR reporting period. The text of the electronic note must be text searchable and may contain drawings and other content." CMS further defines an “electronic note” as an electronic progress note. Therefore, Evident interprets this as a progress note and our statistics will be looking for this specific document to be populated through the Physician Documentation application in order to meet this objective.

What patient types are to be included for Meaningful Use?

There are two methods for calculating ED admissions for the denominators for measures associated with Stage 1 and Stage 2 of Meaningful Use objectives. EHs and CAHs must select one of the methods below for calculating ED admissions to be applied consistently to all denominators for the measures. That is, EHs and CAHs must choose either the “Observation Services method” or the “All ED Visits method” to be used with all measures.

Observation Services method: The patient is admitted to the inpatient setting (place of service (POS) 21) through the ED. The patient initially presented to the ED and is treated in the ED’s observation unit or otherwise receives observation services. Details on observation services can be found in the Medicare Benefit Policy Manual, Chapter 6, Section 20.6. Patients who receive observation services under both POS 22 and POS 23 should be included in the denominator.

All ED Visits method: An alternate method for computing admissions to the ED is to include all ED visits (POS 23 only) in the denominator for all measures requiring inclusion of ED admissions. All actions taken in the inpatient or emergency departments (POS 21 and 23) of the hospital would count for purposes of determining meaningful use.

How will my hospital meet the measure that requires 5% of the patients to View, Download & Transmit when that is out of our control?

The View, Download & Transmit objective has two measures that must be met for Meaningful Use Stage 2. They are as follows: • Provide patients the ability to view online, download and transmit their health information within 36 hours after discharge from the hospital.
• More than 5% of patients admitted to IP/ED (POS 21 or 23) of the eligible hospital must view, download or transmit to a 3rd party their health information.

Patient education is going to be a vital part to successfully achieving this portion of the objective. There are a number of ways we have heard hospitals are going to help educate their patients on this objective. Here are some examples:
• Via Patient Education Documents entailing the process of View, Download, & Transmit.
• Host hospital luncheons, bingo games, and education sessions at the hospital and have patients log in to the Patient Portal.
• Have a hospital kiosk where patients can log in to the Patient Portal to retrieve their information.