E-prescription criteria for EHR attestation

Attestation requirements

DENOMINATOR/NUMERATOR/ THRESHOLD/EXCLUSION

* DENOMINATOR: Number of prescriptions written for drugs requiring a prescription in order to be dispensed other than controlled substances during the EHR reporting period; or Number of prescriptions written for d rugs requiring a prescription in order to be dispensed during the EHR reporting period,

NUMERATOR: The number of prescriptions in the denominator generated, queried for a drug formulary and transmitted electronically using CEHRT,

THRESHOLD: The resulting percentage must be more than 50 percent in order for an EP to meet this measure,

 EXCLUSIONS: Any EP who:

(1) Writes fewer than 100 permissible prescriptions during the EHR reporting period; or
(2) Does not have a pharmacy within their organization and there are no pharmacies that accept electronic prescriptions within 10 miles of the EP's practice Location at the start of his/her EHR reporting period.

Additional Information

. The provider is permitted, but not required, to Limit the measure of this objective to those patients whose records are maintained using certified EHR technology (CEHRT), Authorizations for items such as durable medical equipment, or other items and services that may require EP authorization before the patient could receive them, are not included in the definition of prescriptions. These are excluded from the numerator and the denominator of the measure ,

* Instances where patients specifically request a paper prescription may not be excluded from the denominator of this measure, The denominator includes all prescriptions written by the EP during the EHR reporting period.

 As electronic prescribing of controlled substances is now possible, providers can choose to include aII prescriptions or only permissible prescriptions as long as the decision applies to all
patients and for the entire EHR reporting period, The determination of whether a prescription is a ''permissible prescription'' for purposes of this measure should be made based on the guidelines for prescribing Schedule II-V controlled substances in effect on or before January 13,
2010 ,

* An EP needs to use CEHRT as the sole means of creating the prescription, and when transmitting to an external pharmacy that is independent of the EP's organization such transmission must use standards adopted for EHR technology certification,

* EPs should include in the numerator and denominator both types of electronic transmissions (those within and outside the organization) for the measure of this objective,

*  For purposes of counting prescriptions ''generated and transmitted electronically,'' we consider
the generation and transmission of prescriptions to occur concurrently if the prescriber and dispenser are the same person and/or are accessing the same record in an integrated EHR to creating an order in a system tiat is electronically transmitted to an internal pharmacy,

* Providers can use intermediary networks that convert information from the certified EHR into a computer-based fax in order to meet this measure as Long as the EP generates an electronic prescription and transmits it electronically using the standards of CEHRT to the intermediary network, and this results in the prescription being filled without the need for the provider to communicate the prescription in an alternative manner.

* Prescriptions transmitted electronically within an organization (the same legal entity) do not need to use the NCPDP standards, However, an EP's EHR must meet all applicable certification criteria and be certified as having tie capability of meeting the external transmission
requirements of 170,304(b), In addition, the EHR that is used to transmit prescriptions within tie organization would need to be CEHRT,

compare Medicare and Medicaid EHR program

Notable Differences between the Medicare and Medicaid EHR Incentive Programs

Medicare                                

• Federal Government will implement (will be an option nationally)
• Payment reduction begin in 2015 for providers that do not demonstrate Meaningful Use

• Must demonstrate MU in year 1
• Maximum incentive is $44,000 for EPs (10% bonus for EPs in HPSAs)
• Meaningful Use definition is common for Medicare
• Last year a provider may initiate program is 2014; Last year to register is 2016; Payment adjustments begin in 2015
• Only physicians, subsection (d) hospitals and CAHsVoluntary for States to implement (may not be an option in every state)

Medicaid

• Voluntary for States to implement (may not be an option in every state)

• No Medicaid payment reductions
• A/I/U option for 1st participation year
• Maximum incentive is $63,750 for EPs
• States can adopt certain additional requirements for Meaningful Use
• Last year a provider may initiate program is 2016; Last year to register is 2016
• 5 types of Eps, acute care hospitals (including CAHs) and children hospitals

Acronym Translation

A/I/U – Adopt, Implement or Upgrade

CAH – Critical Access Hospital

EHR – Electronic Health Record

EP – Eligible Professional

HPSA – Health Professional Shortage Area

Integration of PQRI and EHR reporting

Integration of PQRI and EHR reporting

Section 3002(d) of the ACA requires CMS to move toward integration of EHR measures with respect to the PQRI program. The AMA strongly supports efforts to streamline the clinical quality measures used in both the PQRI and EHR reporting programs. We encourage CMS to work with the PCPI to improve the development, and accelerate the testing, of clinically relevant measures for all Medicare physician specialties.

In order to align the two programs, clear program objectives must first be established. Currently, PQRI is a pay-for-reporting program and the CMS EHR Incentive Program is to demonstrate meaningful use of a certified EHR system. After the program objectives have been established and aligned, the measures and format for reporting the measures must then be aligned. The steps that the AMA recommends to achieve alignment of the PQRI and EHR Incentive program include:

•    Establish common program objectives;

•    Align the measures and establish a common format for reporting;

•    Once the "measures" and "reporting format" have been finalized and are aligned, the measures should be tested to see if they can be implemented in an EHR system; and

•    Upon completion of system testing, the measures should be piloted in an actual clinical environment. Pilots are very common in information technology. In fact, any technology implementation or rollout typically has a pilot test completed. Pilot testing provides real world results and feedback in a selected and controlled environment. Upon completion of pilot testing, an evaluation will need to be performed to determine that the results meet the original program objectives.

Electronic Health record

What is Electronic Health Records (EHR)

An Electronic Health Record (EHR) is an electronic version of a patients medical history, that is maintained by the provider over time, and may include all of the key administrative clinical data relevant to that persons care under a particular provider, including demographics, progress notes, problems, medications, vital signs, past medical history, immunizations, laboratory data and radiology reports   The EHR automates access to information and has the potential to streamline the clinician's workflow.  The EHR also has the ability to support other care-related activities directly or indirectly through various interfaces, including evidence-based decision support, quality management, and outcomes reporting.

EHRs are the inevitable next step in the continued progress of healthcare that can strengthen the relationship between patients and clinicians.  The data, and the timeliness and availability of it, will enable providers to make better decisions and provide better care.
For example, the EHR can improve patient care by:

• Reducing the incidence of medical error by improving the accuracy and clarity of medical records.
• Making the health information available, reducing duplication of tests, reducing delays in treatment, and patients well informed to take better decisions.
• Reducing medical error by improving the accuracy and clarity of medical records.