AAMC Contacts : Ivy Baer: Ibaer@aamc.org Lori Mihalich-Levin: Lmlevin@aamc.org

1. Meaningful Use Stage 2 Proposed Rule Proposed rule: http://www.gpo.gov/fdsys/pkg/FR-2012-03-07/pdf/2012-4443.pdf AAMC comment letter: https://www.aamc.org/download/281814/data/aamccommentletteronmeaningfulusestage2proposedrule.pdf AAMC Contacts: Ivy Baer: Ibaer@aamc.org Lori Mihalich-Levin: Lmlevin@aamc.org Jennifer Faerberg: Jfaerberg@aamc.org Mary Wheatley: Mwheatley@aamc.org Scott Wetzel: Swetzel@aamc.org

2. Stage 2Decision Tree: Medicare INCENTIVE! (CMS)! YES Have you attested to EP quality measures (CMS)? YES NO Have you attested to core & menu measures of meaningful use (CMS)? YES NO Are you using certified EHR technology (ONC)? NO YES 2015: Unless are hospital-based or meet an exception, penalty begins Are you a non-hospital based EP? (CMS) NO YES NO: $0; no penalty Are you an eligible professional (EP)?

3. Stages of Meaningful Use By Payment Year Source: Federal Register, Table 2 (March 7, 2012 p. 13703)

4. Stage 1 Stage 2 EPs 17 core 3 of 5 menu 20 total objectives EPs 15 core 5 or 10 menu 20 total objectives Hospitals/CAHs 14 core 15 of 10 menu 19 total objectives Hospitals/CAHs 16 core 2 of 4 menu 18 total objectives

5. Stage 1 Menu Moved to Proposed Stage 2 Core • Implement drug-formulary checks • Record existence of advance directives (core for EH only) • Incorporate lab results as structured data (only where results are available) • Generate pt lists for specific conditions • Send pt reminders • Summary of care record • Submit reportable lab data (core for EH only) • Submit syndromic surveillance data

6. New Measures – Proposed

7. Major Clinical Quality Measure (CQM) Changes (EPs and Hospitals) • Through 2013 – • Report 3 core/alternate core + 3 measures (EPs) • Attest to results or EHR-PQRS pilot submission (EPs) • Continue to report 15 CQMs finalized in Stage 1 (Hospitals) Changes in 2014 – • Criteria for CQM same for all stages (EPs) • 3 options for reporting, including group reporting (EPs) • Electronic submission (EPs) • Report 24 out of 49 (proposed) CQMs (Hospitals) • Must have at least one measure in each of the six quality domains (Hospitals) • Ability to pick the measures most relevant to their patient population or services offered (Hospitals)

8. 2014 CQM - 3 Options for EPs OR * Option only available for Medicare EHR Incentive CMS will finalize either option 1a or 1b.

9. Group Reporting - CQM • Three possible methods • 2 or more NPIs within single TIN • ACO • GPRO • Group options available for: • CQM reporting only AND • All EPs in the group are beyond the first year of Stage 1 • Data must be reported from Certified EHR Technology

10. Penalties- EPs • In general, a penalty will be based on data from 2 years prior to the penalty. (Exception: EPs can apply up to Oct of the previous year if it is their first year of MU) • Determining 2015 penalty: • 1% percent reduction based on 2013 reporting period (for most EPs) • Can report until Oct 2014 if first year reporting • Additional 1% reduction if not an e-prescriber in 2014

11. To avoid penalties, do what by when? (Hospitals) To Avoid Penalties in FY: • Existing Meaningful User: • MU for All of FY 2013 • Attest by November 30, 2013 • New Meaningful User: • MU for April 3, - June 2, 2014 • Attest by July 1, 2014 • Existing Meaningful User: • MU for All of FY 2014 • Attest by November 30, 2014 • Existing Meaningful User: • MU for April 3, - June 2, 2015 • Attest by July 1, 2015 2015 2016

12. AAMC Concerns/Comments with the Proposed Rule • The requirements and timelines for achieving Meaningful Use Stage 2 are too aggressive. • New attesters should have more time to meet the requirements for Meaningful Use Stage 1. • The core measures in the proposed rule are new and untested and therefore greater flexibility should be provided to hospitals and EPs to report this information. • The proposed CQMs are not market ready and would not lead to better outcomes in patient care. These quality measures should not be incorporated into the pay-for-performance programs without a supplemental process to ensure the validity of the EHR data capture. • A group reporting option for CQMs and meaningful use measures should be implemented.