September 2014 3rd Party Newsletter

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September 2014
N OA 3 rd Pa r t y N ew s l e t t e r
Nebraska Optometric Association
Volume 14, Issue 9
Please forward to all of your doctors and staff
Click FILE and Click PRINT for a Printed Copy of This Newsletter
SPECIAL EHR ISSUE
delivery. P.4.
New CMS Rule Allows
Flexibility in Certified
EHR Technology for
2014
HHS published a
More about Patient
Electronic Access
Requirements
If you
EHR Incentive Program:
2014 CQM Electronic
Now Available: Provider
Reporting Guides CMS
User Guide for NIST EHR
are an eligible professional has posted two new
Randomizer Tool for
materials to help you
final rule that allows health participating in the EHR
Stage 2 Meaningful Use
Incentive Programs, you
report clinical quality
care providers more
will be required to meet
measures (CQMs) in 2014. Measure #3, “Transition
flexibility in how they use
of Care” CMS and ONC
Patient
Electronic
Access
P.5.
certified electronic health
record (EHR) technology
(CEHRT) to meet
meaningful use for an EHR
Incentive Program
reporting period for 2014.
Pp. 1-3.
measures. Patients’ access
to their EHRs can help
them make more informed
decisions about their
health care and improve
efficiencies in health care
encourage you to use a
new provider user guide
that outlines instructions
on how to use the NIST
EHR Randomizer. P.6.
AOA
AOA: Medicare
Advantage Fraud Waste
& Abuse Training Not
Needed by Most OD
Medicare Providers
Most optometrists who
contract with Medicare
Advantage (MA) plans
won't have to undergo
fraud, waste and abuse
training. P.7.
New CMS Rule Allows Flexibility in Certified EHR Technology for 2014
Rule will help more providers use electronic health record technology
On August 29, HHS published a final rule that allows health care providers more flexibility in how they use
certified electronic health record (EHR) technology (CEHRT) to meet meaningful use for an EHR Incentive
Program reporting period for 2014. By providing this flexibility, more providers will be able to participate and
meet important meaningful use objectives like drug interaction and drug allergy checks, providing clinical
summaries to patients, electronic prescribing, reporting on key public health data, and reporting on quality
measures.
Based on public comments and feedback from stakeholders, CMS identified ways to help eligible professionals,
eligible hospitals, and critical access hospitals (CAHs) implement and meaningfully use Certified EHR
Technology. Specifically, eligible providers can use the 2011 Edition CEHRT or a combination of 2011 and 2014
Edition CEHRT for an EHR reporting period in 2014 for the Medicare and Medicaid EHR Incentive Programs; All
eligible professionals, eligible hospitals, and CAHs are required to use the 2014 Edition CEHRT in 2015.
The rule also finalizes the extension of Stage 2 through 2016 for certain providers and announces the Stage 3
timeline, which will begin in 2017 for providers who first became meaningful EHR users in 2011 or 2012. An
updated meaningful use timeline and a chart with 2011 and 2014 CEHRT Edition options are available in the
press release.
For more information about the EHR Incentive Program, visit the EHR Incentive Programs website http://
www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/index.html?redirect=/EHRIncentivePrograms. For more information about CEHRT,
please visit the HealthIT.gov website http://www.healthit.gov/.
More on page 2….
To access the NOA 3rd Party web page: http://nebraska.aoa.org/prebuilt/NOA/index.htm
Page 2
N OA 3 rd Pa r t y N e w s l e t t e r
Review Final Rule to Determine
Your CEHRT Participation Options for Program Year 2014
The rule grants flexibility to providers who are unable to fully implement 2014 Edition CEHRT for an EHR
reporting period in 2014 due to delays in 2014 CEHRT availability. Providers may now use EHRs that have been
certified under the 2011 Edition, a combination of the 2011 and 2014 Editions, or the 2014 Edition for 2014
participation.
Beginning in 2015, all eligible providers will be required to report using 2014 Edition CEHRT.
2014 Participation Options
Under the rule, providers are able to use 2011 Edition CEHRT, and have the option to attest to the 2013 Stage
1 meaningful use objectives and the 2013 definition CQMs.
2011 CEHRT
Providers scheduled to meet Stage 1 or Stage 2:
 2013 Stage 1 objectives
http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/2013Definition_Stage1_MeaningfulUse.html
and 2013 CQMs
http://www.cms.gov/Regulations-and-Guidance/Legislation/
and 2013 CQMs
http://www.cms.gov/Regulations-and-Guidance/Legislation/
EHRIncentivePrograms/cqm_through_2013.html
Combination of 2011 & 2014 CEHRT
Providers scheduled to meet Stage 1:
 2013 Stage 1 objectives
; or
 2014 Stage 1 objectives
http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/2013Definition_Stage1_MeaningfulUse.html
EHRIncentivePrograms/cqm_through_2013.html
http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Meaningful_Use.html
and 2014 CQMs
http://www.cms.gov/Regulations-and-Guidance/Legislation/
EHRIncentivePrograms/2014_ClinicalQualityMeasures.html
Providers scheduled to meet Stage 2:
 2013 Stage 1 objectives
; or
http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/2013Definition_Stage1_MeaningfulUse.html
and 2013 CQMs
http://www.cms.gov/Regulations-and-Guidance/Legislation/
EHRIncentivePrograms/cqm_through_2013.html

2014 Stage 1 objectives
; or
 2014 Stage 2 objectives
http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Meaningful_Use.html
and 2014 CQMs
http://www.cms.gov/Regulations-and-Guidance/Legislation/
EHRIncentivePrograms/2014_ClinicalQualityMeasures.html
http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Stage_2.html
and 2014 CQMs
http://www.cms.gov/Regulations-and-Guidance/Legislation/
EHRIncentivePrograms/2014_ClinicalQualityMeasures.html
2014 CEHRT
Providers scheduled to meet Stage 1:
 2014 Stage 1 objectives
;
http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Meaningful_Use.html
and 2014 CQMs
http://www.cms.gov/Regulations-and-Guidance/Legislation/
and 2014 CQMs
http://www.cms.gov/Regulations-and-Guidance/Legislation/
EHRIncentivePrograms/2014_ClinicalQualityMeasures.html
Providers scheduled to meet Stage 2:
 2014 Stage 1 objectives
; ; or
http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Meaningful_Use.html
EHRIncentivePrograms/2014_ClinicalQualityMeasures.html

2014 Stage 2 objectives
http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Stage_2.html
and 2014 CQMs
http://www.cms.gov/Regulations-and-Guidance/Legislation/
EHRIncentivePrograms/2014_ClinicalQualityMeasures.html
(Continued on page 3)
The NOA Third Party Newsletter is published monthly by the Nebraska Optometric
Association with the assistance of Ed Schneider, O.D., Third Party Consultant. To reach
Ed (aka Dr. Quack):
1633 Normandy Court, Suite
 BEST to contact via Email at: [email protected]
To access the NOA 3rd Party
web page: http://nebraska.aoa.org/prebuilt/NOA/index.htm
Nebraska Optometric Association
A
Lincoln, NE 68512
http://nebraska.aoa.org/
Page 3
N OA 3 rd Pa r t y N e w s l e t t e r
(Continued from page 2)
CEHRT Flexibility Resources
To help the public understand the final rule’s changes to 2014 participation, CMS has developed the following
resources:
 CEHRT Interactive Decision Tool http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/CEHRT_Rule_DecisionTool.pdf –
providers answer a few questions about their current stage of meaningful use and Edition of EHR certification,
and the tool displays the corresponding 2014 options.
 2014 CEHRT Flexibility Chart (see below)– chart provides a visual overview of CEHRT participation options
for 2014.
 2014 CEHRT Rule Quick Guide
– guide provides
corresponding resources based on the option a provider chooses to participate in the EHR Incentive Programs
in 2014.
http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/CEHRT2014_FinalRule_QuickGuide.pdf
Extending Stage 2
The rule also finalizes CMS and ONC’s recommended timeline to extend Stage 2 through 2016. The earliest a
provider can participate in Stage 3 of meaningful use is now 2017.
http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/CEHRT2014_FlexibilityChart.pdf
To access the NOA 3rd Party web page: http://nebraska.aoa.org/prebuilt/NOA/index.htm
Page 4
Volume 14, Issue 9
Learn More about Patient Electronic Access Requirements
If you are an eligible professional participating in the EHR Incentive Programs, you will be required to meet
Patient Electronic Access measures. Patients’ access to their EHRs can help them make more informed
decisions about their health care and improve efficiencies in health care delivery.
In order to meet 2014 Stage 1 requirements, you must provide more than 50% of your unique patients
with timely access to their health information within four business days of the information being available
to you. If you are in Stage 2, you must also demonstrate that more than 5% of your unique patients view
online, download, or transmit to a third party their health information.
New CMS Guidance for Calculating Patient Electronic Access Across Multiple Providers
If you are an eligible professional, new CMS guidance may help you meet the Patient Electronic Access
objective.
Stage 2 Measure #2: Eligible Professionals in the Same Group Practice
Eligible professionals in group practices are able to share credit to meet the patient electronic access
threshold if they each saw the patient during the same EHR reporting period and they are using the same
certified EHR technology. The patient can only be counted in the numerator by all of these eligible
professionals if the patient views, downloads, or transmits their health information online. See https://
questions.cms.gov/faq.php?id=5005&faqId=9686
Stage 2 Measure #2: Providers with the Same Patient
If multiple eligible providers who see the same patient and contribute information to an online personal
health record (PHR) during the same EHR reporting period, all of the eligible providers can count the
patient to meet requirement if the patient accesses any of the information in the PHR. In other words, a
patient does not need to access the specific information an eligible provider contributed, in order for them
to count the patient to meet their threshold. See https://questions.cms.gov/faq.php?id=5005&faqId=7735
Stage 1 and Stage 2 Measure #1: Providers with Patients who Opt-Out
A patient can choose not to access their health information, or “opt-out.” Patients cannot be removed
from the denominator for opting out of receiving access. If a patient opts out, a provider may count them
in the numerator if they have been given all the information necessary to opt back in without requiring any
follow up action from the provider, including, but not limited to, a user ID and password, information on
the patient website, and how to create an account.
More Information
For more information on the Patient Electronic Access objective, review the 2014 Stage 1 and Stage
2 specification sheets and the Patient Electronic Access tipsheet.
To access the NOA 3rd Party web page: http://nebraska.aoa.org/prebuilt/NOA/index.htm
Page 5
Volume 14, Issue 9
EHR Incentive Program: 2014 CQM Electronic Reporting Guides
Are you an eligible professional or eligible hospital participating in the Medicare Electronic Health Record
(EHR) Incentive Program? If so, CMS has posted two new materials to help you report clinical quality
measures (CQMs) in 2014, including:
An Introduction to EHR Incentive Programs for Eligible Professionals: 2014 Clinical Quality Measure
Electronic Reporting Guide at http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/CQM2014_GuideEP.pdf
The guides are interactive. Users can click on the chapters of the Table of Contents for CQM information
relevant to their needs, including:
 CQM Overview Information
 Changes to CQMs in 2014
 List of 2014 CQMs
 Submitting CQM Data for the 2014 Reporting Year
Resources
Reporting CQMs for 2014
As explained in Chapter 2, beginning in 2014, the number of CQMs you report differs from previous years,
eligible professionals must select and report 9 CQMs from a list of 64 approved measures.
In 2014 only, you need to submit CQM data for a three-month or 90-day reporting period, regardless if you
are demonstrating Stage 1 or Stage 2 of meaningful use.
Reporting Once
Chapter 4 of each guide provides information on how to submit measures in order to satisfy requirements
both for meaningful use and other quality reporting programs, such as the Physician Quality Reporting
System (PQRS) program for eligible professionals at http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/pqrs/index.html
.
Want to learn more?
To learn more about CQMs, visit the Clinical Quality Measures web page and the eCQM Library web page.
Make sure to visit the Medicare and Medicaid EHR Incentive Programs website for the latest news and
updates on the EHR Incentive Programs.
To access the NOA 3rd Party web page: http://nebraska.aoa.org/prebuilt/NOA/index.htm
Page 6
Volume 14, Issue 9
Now Available: Provider User Guide for NIST EHR Randomizer Tool
for Stage 2 Meaningful Use Measure #3, “Transition of Care”
Are you a provider in Stage 2 of meaningful use who needs help meeting measure #3 of the
Transitions of Care core objective? If so, CMS and ONC encourage you to use a new
provider user guide (at http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/ProviderUserGuide_EHRRandomizer.pdf) that
outlines instructions on how to use the NIST EHR Randomizer (at https://ehr-randomizer.nist.gov/ehr-randomizer-app/
#/home), including:
 Required information
 Steps to register
 Guidance on how to perform the test
The guide walks providers through every step of the Randomizer—from registration to
completion of the test.
About the NIST EHR Randomizer
The Randomizer tool enables providers to exchange data with a Test EHR in order to meet
measure #3 (at http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/downloads/Stage2_EPCore_15_SummaryCare.pdf) of the Stage 2
Transitions of Care objective.
Once registered, the tool pairs a provider’s EHR technology with a different test EHR from the
list of authorized systems. The provider must then send a Consolidated Clinical Document
Architecture summary of care record to the Test EHR (See http://www.healthit.gov/policy-researchers-implementers/consolidated-cdaoverview).
Providers will receive an email with notification of success or failure that can be used as proof
of meeting the measure.
Transitions of Care Objective in Stage 2
The Stage 2 Transitions of Care objective for eligible professionals includes three measures.
Measure #3 is outlined below:
 Conduct one or more successful electronic exchanges of a summary of care document,
as part of which is counted in “measure 2” with a recipient who has EHR technology that was
developed by a different EHR technology developer than the sender’s, or
 Conduct one or more successful tests with the CMS designated test EHR during the EHR
reporting period.
More Information
For more information about the Stage 2 Transitions of Care objective and other Stage 2
requirements, visit the CMS Stage 2 of Meaningful Use webpage.
To access the NOA 3rd Party web page: http://nebraska.aoa.org/prebuilt/NOA/index.htm
Page 7
N OA 3 rd Pa r t y N e w s l e t t e r
AOA: Medicare Advantage Fraud Waste & Abuse Training Not Needed by
Most OD Medicare Providers
Timely information from the AOA:
Most optometrists who contract with Medicare Advantage (MA) plans won't have to undergo fraud, waste
and abuse training.
The AOA clarifies this point and others in a new "frequently asked questions" (FAQ) document that addresses a
final rule http://www.gpo.gov/fdsys/pkg/FR-2007-12-05/pdf/07-5946.pdf the Centers for Medicare and Medicaid Services issued in 2007.
Although it was issued seven years ago and updated in 2010, the AOA continues to receive questions about
this requirement.
The FAQ, available to AOA members at
http://www.aoa.org/login?redir=http%3A%2F%2Fwww.aoa.org%2Fdocuments%2Fsecure%2Fadvocacy%2FMedicare%20Advantage_FWA_Training.pdf%3Fsso%3Dy%26ct%
, seeks to assist ODs in better understanding how the
requirements in this rulemaking affect their practices.
3D8d696ae9ed5491a2232927b832cf44a7f9c36e2d8f89729e7d648c579103c0a88a5b86c8ac88b17b2920adf6201d3139f05be77b398c1c8a988dcb7f14741573
The final rule called on MA plans to put compliance plans into place to detect, correct and prevent fraud,
waste and abuse (FWA). Plans had to require FWA training of a number of different entities, including "first
tier, downstream, and related entities," such as a company contracted to provide claims processing or
marketing services.
"Since MA plans contract with physicians, a literal reading of the regulations suggested that Medicare
Advantage plans could only be in compliance if they had all of their contracted physicians complete the
training," the AOA's FAQ explains.
Most ODs won't have to complete training
ODs who contract with MA plans likely fall into the category of "first tier or downstream entity." But as the
FAQ explains, physicians enrolled in Medicare are exempt from the 2007 rule's training requirements.
In 2010, the agency clarified at http://www.gpo.gov/fdsys/pkg/FR-2010-04-15/pdf/2010-7966.pdf that any first tier, downstream or related
entities that had already met FWA certification requirements by enrolling in Medicare didn't need further
training and education. The agency had responded to concerns by AOA and other health care practitioner
organizations that doctors were already well aware of their obligations to avoid FWA, and that annual training
wasn't needed for those who had been screened through Medicare's enrollment process.
Had they not been exempt, they would have had to complete this training on an annual basis.
The exemption doesn't apply to everyone. ODs who contract with MA plans—but are not enrolled in
Medicare—might still be required by the MA plan to complete the annual training to ensure it remains in
compliance with CMS regulations.
In response to another frequently asked question, the FAQ says that AOA does not have a specific training
program available for FWA. CMS has developed a compliance program that is available at no charge.
Source (from the AOA): http://www.aoa.org/news/advocacy/aoa-answers-common-questions-about-medicare-advantage-fraud-waste-and-abuse-training?
sso=y&ct=1b5bd3b46dd3f1fb75eb6c2328122ef5fc9f54159c6c8c20a8935142d0c314d25eac972b799ce7d4ed350aaffa08962b4214831e40c4b6b0a2c5cc94e643a2b7
To access the NOA 3rd Party web page: http://nebraska.aoa.org/prebuilt/NOA/index.htm
Page 8
N OA 3 rd Pa r t y N e w s l e t t e r
Dr. Quentin Quack’s Quacked Humor
Dr. Quack thanks Janet Fett OD for the above contribution….
To access the NOA 3rd Party web page: http://nebraska.aoa.org/prebuilt/NOA/index.htm
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