Measures Reporting for Eligible Providers

AHIMA Meaningful Use White Paper Series
Paper no. 5a

The fourth paper in this series reviewed the EHR certification requirements related to the final rule on meaningful use. This paper returns the focus to the meaningful use rule, offering an overview of the health IT functionality measures for eligible providers. A companion paper (5b) provides an overview of the requirements for hospitals.

Eligible providers (EPs) participating in the meaningful use program will be required to report on quality measures. The measures selected in the final regulation were developed to meet the stated objectives in support of the health outcome policy priorities.

The measures are grouped into two categories: health IT functionality measures and clinical quality measures. This paper focuses on the health IT functionality measures, which were developed to demonstrate the use of certified EHR technology in daily work processes.

Eligibility

Measures in stage 1 underline the importance of establishing functionalities in the EHR that will emphasize continuous quality improvement and ease of information exchange. Stage 1 is considered the foundation for EHR functionality that will expand in stages 2 and 3.

CMS originally put forward 27 required measures in the proposed rule. Based on reaction to the proposal, CMS made adjustments in the final rule allowing providers some flexibility in meeting the reporting requirements.

The measures are largely maintained from the proposed rule, but CMS divided them into two categories¾core and menu. EPs must successfully meet the measures of each of the core set’s 15 objectives.

The menu set includes 10 additional objectives, of which eligible professionals will choose five. The items not chosen will be deferred to stage 2 of the program. An EP may select any five objectives, with the caveat that at least one of the menu objectives includes a population and public health measure. CMS encourages EPs to implement all of the functionalities listed in stage 1, though this is not mandatory.

The core and menu sets are listed in a linked table, with the changes between the proposed and final rules noted.

In addition, AHIMA offers a comprehensive matrix mapping the certification criteria and meaningful use objectives against the content exchange standards, implementation specifications, and vocabulary standards. This is a member resource, and log in is required.

CMS anticipates all menu objectives in stage 1 to become a part of the core set in stage 2. In addition, it expects to raise the stage 1 thresholds and add new objectives. New goals will go beyond capturing data in electronic format to include the exchange of the data in structured formats. The intent of escalating measures “is to ensure that meaningful use encourages patient-centric, interoperable health information exchange across provider organizations regardless of provider’s business affiliation or EHR platform,” CMS writes.

The regulation acknowledges that not all EPs will be able to report on all objectives. In such cases EPs can still quality as meaningful users if they attest that they did not have a sufficient number of patients or actions on which to base a measurement. The attestation will remove the objective from consideration when determining the EP’s eligibility, assuming that other core set objective were met.

The same is true for the menus set. If an EP attests that it cannot measure one of the 10 objectives, the EP would then only have to satisfy 4 of the remaining 9 objectives.

CMS intends the measures to reflect the daily use of these EHR capabilities in meeting the program objectives. Further, CMS intends that EPs use the capabilities for all patients, not just for Medicare or Medicaid populations.

Hospital-based physicians do not qualify for the program. A physician is considered to be hospital-based if more than 90 percent of his or her services are provided under the place-of-service codes 21 (Inpatient Hospital) or 23 (Emergency Room, Hospital). If EPs practice at multiple locations, the measures are to be limited to actions taken at locations equipped with certified EHR technology.

CMS acknowledges that EPs who practice at multiple locations may not have access to certified EHR technology at each location. The rule’s intent is to include EPs who are able to meaningfully use certified EHR technology when it is available yet who also provide care to patients in other locations where it is not available.

To qualify as a meaningful user, 50 percent or more of an EP’s patient encounters during the EHR reporting period must occur at a location equipped with certified EHR technology. EPs who do not conduct 50 percent of their patient encounters in any one location would have to meet the 50 percent threshold through a combination of locations. CMS believes that this is a reasonable solution that advances the meaningful use priorities and provides some level of equity.

Methods of Demonstration

EPs will demonstrate that they satisfy the objectives and measures by providing an attestation through a secure mechanism, such as claims-based reporting or an online portal. This will not apply to the clinical quality measures, which CMS will require are reported electronically in 2012.

Through a one-time attestation following the completion of the EHR reporting period, EPs will identify the certified EHR technology used and the results of their performance on all the measures associated with the reported objectives for meaningful use.

As health IT matures, CMS expects to base demonstration of meaningful more on automated reporting, such as the direct electronic reporting of both clinical and nonclinical measures and documented participation in HIE. CMS advocates for uniformity and simplicity in this process and suggests that the Medicaid programs follow its lead.

Definitions

The final rule includes the following definitions, which are helpful in reviewing the objectives, measures, and reporting requirements.

EHR reporting period: The period in which the EP demonstrates meaningful use. In the first payment year (beginning January 1, 2011), this may be any continuous 90-day reporting period within the year. In subsequent years of the program, CMS requires a full year of EHR reporting period for demonstrating meaningful use.

Qualified EHR: CMS adopts this term as defined by the Office of the National Coordinator (ONC), which indicates that Congress intended to apply the definition found in section 3000 of the Public Health Service Act. “A qualified electronic health that is certified pursuant to section 3001(c)(5) of the PHS Act as meeting standards adopted under section 3004 of the PHS Act that are applicable to the type of record involved (as determined by the Secretary [of Health and Human Services]), such as an ambulatory electronic health record for office-based physicians or an inpatient hospital electronic health record for hospitals).

Certified EHR technology: The final rule also adopts the definition of certified EHR technology used by ONC in its rule on EHR standards and certification:

(1) A Complete EHR that meets the requirements included in the definition of a Qualified EHR and has been tested and certified in accordance with the certification program established by the National Coordinator as having met all applicable certification criteria adopted by the Secretary; or

(2) A combination of EHR Modules in which each constituent EHR Module of the combination has been tested and certified in accordance with the certification program established by the National Coordinator as having met all applicable certification criteria adopted by the Secretary, and the resultant combination also meets the requirements included in the definition of a Qualified EHR.

Unique patients: A patient may be counted only once during the EHR reporting period, even if seen by the EP multiple times. The meaningful use objective is not necessarily updated every time the patient is seen within the reporting period.

Transition of care: Within the final rule CMS modified its definition slightly to reflect an expansion of the descriptors as “the movement of a patient from one setting of care (hospital, ambulatory primary care practice, ambulatory specialty care practice, long-term care, hone health, rehabilitation facility) to another.” Additionally, CMS clarified that the receiving EP would conduct the medication reconciliation.

Relevant encounter: CMS finalized this definition as proposed, “an encounter during which the EP, eligible hospital, or CAH performs medication reconciliation due to new medication or long gaps in time between patient encounters or other reasons determined by the EP, or eligible hospital or CAH.”

Measures reporting for eligible hospitals is covered in paper 5b of this series.

Download a PDF version of this paper. For more ARRA resources, visit AHIMA’s Advocacy and Public Policy Center.

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The White Paper Series  
1. Overview of the Meaningful Use Final Rule 5b. Measures Reporting for Eligible Hospitals
2. Meaningful Use—Provider Requirements 6a. Clinical Quality Measures for Providers
3. Meaningful Use—Payments and Requirements 6b. Clinical Quality Measures for Hospitals
4. Meaningful Use and EHR Certification 7. Qualifying for Meaningful Use
5a. Measures Reporting for Eligible Providers 8. Preparing for Meaningful Use

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