As part of the Stage 2 rulemaking process, CMS has made a number of changes to Stage 1 criteria. For more detailed information on these changes, visit the CMS website. More information on the Stage 2 requirements can be found here.
Changes to core criteria
Most of the changes made to Stage 1 requirements were to the measure specifications for the core criteria. As such, they are not spelled out in detail here, but can be better understood by visiting the CMS website.
To assist you, here is a list of the criteria to which CMS has made changes:
- Computerized physician order entry for medication orders (2013+ - Optional)
- E-prescribing (2013+ - Required)
- Vital sign recording (2013 – Optional; 2014+ - Required)
- Clinical information exchange (2013+ - Optional)
- Provide patients with electronic copy of health information upon request (2014+ - Required)
- Provide timely electronic access to health information (2014+ - Required)
Note that going forward, clinical quality measure (CQM) reporting is no longer included in the list of core criteria. Instead, it is included as part of the base definition of a meaningful user, and thus, is still required.
Changes to menu set
Through analysis of the 2011 data, CMS determined that many individuals successfully qualified for the EHR incentive payments by reporting on criteria from which they met the exclusion criteria. Going forward, CMS will not allow you to qualify in this manner if there are other criteria for which you do not meet any of the exclusion criteria. Only if there are not enough criteria for which you do not meet the exclusions are you permitted to count those criteria towards meeting your three required objectives.
For more information on these changes, visit the CMS website.
Changes to clinical quality reporting
As part of the requirements for the EHR Incentive Program, physicians must collect data on a set of quality metrics. Many, including the ACC, urged CMS to synchronize this requirement with other quality reporting programs, such as the Physician Quality Reporting System (PQRS). While CMS did not do this as much as the College requested for the Stage 1 rule, this is one of the areas where CMS made changes in the Stage 2 rule that may also apply for Stage 1. Keep in mind that physicians can participate in both the PQRS and the EHR incentive program and receive separate payments for successful participation in both programs. However, you will also need to be aware that the reporting periods and deadlines for these programs are not necessarily identical. These deadlines will also vary based on whether you are attempting to earn the incentive or avoid the payment adjustment.
For Stage 1, the PQRS measures and the EHR incentive program measures may or may not overlap. The measure reporting will be conducted through different mechanisms. Most PQRS measures for cardiology are reported via registry; for the EHR incentive program, quality measure reporting will be done through attestation during Stage 1, as discussed above.
Through 2013, to fulfill the quality reporting requirement of the EHR incentive program, physicians were required to report on a set of three core measures and three additional measures. If any or all of the three core measures were not applicable to your practice, there were three alternate core measures. If enough of the core and alternate core measures did not apply to your patients, you were able to report a zero value to reach the requirement to report on six measures. ONC changed some of the requirements for certification of EHRs for 2014 pertaining to CQM reporting. As a result, those using systems only certified for the 2014 Edition for Stage 1 reporting in 2013 were allowed only to report on CQMs included in both the Stage 1 and Stage 2 final rules. Given that a Stage 1 core CQM, National Quality Forum 0013 is not in the Stage 2 set of CQMs, you needed to select one of the alternate core CQMs to replace it.
Beginning in 2014, all physicians participating in the EHR Incentive Program, regardless of stage, must meet the same requirements for CQM reporting. Rather than requiring reporting on three core and three additional CQMs, physicians will be required to report CQMs using one of two mechanisms:
- Option 1: Report nine CQMs from at least three different domains
- Option 2: Submit and satisfactorily report CQMs under PQRS’ EHR Reporting Option
CQMs are divided into six domains based on the National Quality Strategy:
- Efficient Use of Healthcare Resources
- Clinical Process/Effectiveness
- Patient Safety
- Population/Public Health
- Patient and Family Engagement
- Care Coordination
Option 1 requires that measures be reported from at least three out of these six domains. Option 2 carries no such requirement. Neither option will include a required core set of CQMs be included in the total CQMs reported, although CMS does include two recommended core sets, one for adults and one for children, that the Agency encourages physicians report, to the extent that they are applicable. In the event that there are not nine CQMs covering at least three domains that are applicable, then you will need to report on those for which you have patient data and then report the remaining required CQMs as “zero denominators.”
For Option 2, those who participate in both the PQRS and Medicare EHR Incentive Program will satisfy the CQM reporting requirement for the EHR Incentive Program if they satisfactorily report the required number of PQRS CQMs under the PQRS EHR reporting option using a certified EHR. Those who select this option will be subject to the PQRS reporting periods for CQMs only; you must meet the EHR Incentive Program reporting periods for all other requirements. Physicians who participated in the Medicare EHR Incentive Program for the first time in 2014 choosing this option were not able to avoid the 2015 penalty because all requirements, including submission of CQM data, had to be met and attested to by Oct. 1, and the reporting period for PQRS ends on Dec. 31.
Those physicians who have participated in the PQRS know that one of the difficulties with that program is that measure specifications are often not finalized until Dec. 31 of the preceding calendar year. For the EHR incentive program, CMS has opted to finalize those quality measure specifications immediately, so they are already available for you to begin integrating into your practice workflow. Keep in mind that even where the measures overlap, the specifications for the EHR Incentive Program clinical quality measures may not be the same as those for PQRS unless you select Option 2.
The list of the current CQM measures associated with the EHR Incentive Program is available on CMS’ website.This list is updated by CMS as needed.