Top 10 Things to Remember for 2012 MU
Eligible Professionals (EPs) pursuing Stage 1 Meaningful Use (MU) in 2012 through the Medicaid EHR Incentive Program would be attesting to their first year of meaningful use, requiring a 90 day reporting period. These tips can also be applicable to second-year attestations to MU, requiring a full year reporting period, or efforts toward first-year meaningful use in years other than 2012: simply note the reporting period and that there are only 13 Core Measures in 2013 and beyond.
- An EP achieves meaningful use as an individual for actions performed for his/her patient population. Visit http://www.tn.gov/tenncare/mu_eligibleprof.shtml to read more about achieving meaningful use while working at multiple practice sites, regardless of whether such sites are associated with the same organization or use the same certified EHR technology.
- An EP reports meaningful use for his/her entire patient population. Meaningful use measures with a denominator of all unique patients (e.g., Core Measure 3, maintaining patient problem lists) must have their threshold achieved given that all unique patients, regardless of payor or whether such patients have their data in the EHR, are included in the denominator. As noted by CMS, "Please keep in mind that patients whose records are not maintained in certified EHR technology will need to be added to denominators whenever applicable in order to provide accurate numbers."
- An EP achieves meaningful use within the reporting period. For the first year of Stage 1 Meaningful Use, each of the core, selected menu measures, and core and selected clinical quality measures all must be achieved in that 90 day reporting period. The attestation reflects a time period during which various elements of meaningful use were achieved, and thus there is consistency within the attestation. Core Measures 1 (CPOE) and 4 (eRx), for example, have exclusions related to the number of prescriptions written during the EHR reporting period, so an exclusion for Core Measure 1 based on the number of prescriptions would also apply to Core Measure 4.
- An EP must achieve the 15 Core Measures unless he/she qualifies for a measure’s specific exclusion. Here, meaningful use becomes an all-or-nothing endeavor: the measure-specific exclusion must apply for an EP not to achieve a core measure, and many of the measures do not have exclusions available.
- An EP must attest to 5 of the 10 Menu Measures, including a public health measure. As no public health agency in Tennessee currently has the capacity to receive syndromic surveillance data from EPs in the standards mandated (Menu Measure 10), EPs should attest to Menu Measure 9, testing with the immunization registry.
- An EP must attest to the Clinical Quality Measures (CQMs). EPs attest to the CQMs through the same mechanism as attesting to the other measures, the TennCare attestation portal, for the same 90 day reporting period. The CQMs must be reported as generated by certified EHR technology, and in accordance with CMS guidelines, "a zero [is] reported in the denominator of a measure when an EP, eligible hospital or CAH did not care for any patients in the denominator population during the EHR Reporting Period."
- An EP must enable functionalities for the entire 90 day reporting period. For example, Core Measure 2, drug-drug and drug-allergy interaction checks, should be enabled for every unique patient seen by the EP during the 90 day reporting period. Other functionalities that should be enabled for the entire reporting period include Core Measure 11, the Clinical Decision Support Rule, and Menu Measure 1, implementing drug formulary checks.
- An EP must achieve the measures according to the measure timelines. As with implementing functions for the entire 90 day reporting period, other measures must be performed within certain timelines. For example, Core Measure 14 and Menu Measure 9, each concerning tests that must be performed, must be achieved during the 90 day reporting period or even before it within the same calendar year, but cannot be achieved after the 90 day reporting period ends.
- An EP must attest to his achievement of meaningful use. An attestation should reflect an EP’s work toward meaningful use. Any uploaded documents should match the information given in the attestation; for instance, the numbers and reporting periods should be consistent. Exclusions should only be claimed where applicable. Answers to questions should be appropriate; for example, the clinical decision support rule should be listed so that the EP demonstrates it was a rule or intervention that prompted an alert for a patient population for a target condition or risk factor.
- An EP should consider Stage 1 Meaningful Use in context. Efforts toward Stage 1 Meaningful Use for 90 days offer opportunities to improve EHR use and clinical workflow. Such improvements may benefit the practice as well as achieving Stage 1 MU for a full calendar year and later, Stage 2 MU. For example, testing with the immunization registry is one of the two public health objectives in Stage 1, but a core measure of Stage 2 is ongoing submission to the registry.