Automated measure calculation (MU3))

Automated Measure Calculation MU3

Regulation Text

§ 170.315 (g)(2) Automated measure calculation

For each Promoting Interoperability Programs percentage-based measure that is supported by a capability included in a technology, record the numerator and denominator and create a report including the numerator, denominator, and resulting percentage associated with each applicable measure.

External Link - ONC Certification Guide and Testing Requirements

Additional Requirements Information

Health IT Modules that are ambulatory systems only must use the ambulatory test data and test at least one of the two calculation methods: 1) Medicaid Promoting Interoperability Program; or 2) MIPS Promoting Interoperability performance category (TIN/NPI). ... Health IT Modules that test for the MIPS Promoting Interoperability performance category calculation methods must test for both the EC individual and EC Group calculation methods.

Resources

Each year the measures required by CMS change for interoperability requirements. The most update to date measures that can be found programatically currently can be found here: Github QPP Measures Data. Note that the Medicaid Interoperability incentives were discontinued in 2019 and currently only MIPS is eligible. Note that CMS is piloting a new type of MIPS that is based upon one's specialty (certain providers will need to check on [1] for the most up to date information on their requirements.

Time Analysis

Requirements are currently being analyzed.

This table was adapted from the File:ONC 2015 RequirementsMatrix MasterTable.pdf and aligned with the most recent OpenEMR MU3 analysis in 2022.

AMC Required Tests Matrix

ONC 2015 EHR Test and CMS programs	Certification Criteria that Directly Correlate with Utilization Expected by Medicare and Medicaid Promoting Interoperability Programs or MIPS Promoting Interoperability performance category Percentage Based Measures	Comments, Additional Certification Criteria	OpenEMR Comments	MIPS Objective
Required Test 1 – ePrescribing Medicare and Medicaid Promoting Interoperability Programs MIPS Promoting Interoperability Performance Category	§170.315(b)(3) Electronic Prescribing §170.315(a)(10) Drug- Formulary and Preferred Drug List Checks		(b)(3) not supported currently reviewing to determine if we will certify against this criteria during the 2nd half of the year by using an eligible e-prescribe module such as WENO (a)(10) not supported	Electronic Prescribing
Required Test 2a, b, or c – Patient Electronic Access Medicare and Medicaid Promoting Interoperability Programs MIPS Promoting Interoperability Performance Category	§170.315(e)(1) View, Download, and Transmit to 3rd Party §170.315(g)(8) Application Access – Data Category Request §170.315(g)(9) Application Access – All Data Request §170.315 (g)(10) Standardized API for patient and population services		(e)(1) not supported Currently being reviewed to see if we add e1 support (g)(8),(g)(9),(g)(10) supported. Documentation will be required to show we only support half of the MIPS requirement and explanation of how to collect the other part of this requirement (unless e1 support is added).	Provider to Patient Exchange
Required Test 3 – Patient Education Medicaid Promoting Interoperability Program	§170.315(a)(13) Patient-Specific Education Resources		(a)(13) not supported
Required Test 4a, b, or c – View, Download, Transmit Medicaid Promoting Interoperability Program	§170.315(e)(1) View, Download, and Transmit to 3rd Party §170.315(g)(8) Application Access – Data Category Request §170.315(g)(9) Application access – All Data Request §170.315 (g)(10) Standardized API for Patient and Population Services	(e)(1) not supported Currently being reviewed to see if we add e1 support (g)(8),(g)(9),(g)(10) supported. Documentation will be required to show we only support half of the MIPS requirement and explanation of how to collect the other part of this requirement (unless e1 support is added).		Provider to Patient Exchange
Required Test 5 – Secure Messaging Medicaid Promoting Interoperability Program	§170.315(e)(2) Secure Messaging		(e)(2) not supported, no longer eligible for certification in 2022
Required Test 6 – Patient Generated Health Data Medicaid Promoting Interoperability Program	§170.315(e)(3) Patient Health Information Capture		(e)(3) is certified through self-attestation
Required Test 7 – Support Electronic Referral Loops by Sending Health Information (formerly Transitions of Care) Medicare and Medicaid Promoting Interoperability Programs MIPS Promoting Interoperability Performance Category	§170.315(b)(1) Transitions of Care		(b)(1) supported	Health Information Exchange
Required Test 8 – Receive and Incorporate Medicaid Promoting Interoperability Program	§170.315(b)(2) Clinical Information Reconciliation and Incorporation	§170.315(b)(1) Transitions of Care – receive, display, and incorporate summary care records may support electronic receipt of transitions of care/referral summaries	(b)(2) not supported currently reviewing to determine if we will certify against this criteria during the 2nd half of the year (b)(1) supported
	OR §170.315(b)(2) Clinical Information Reconciliation and Incorporation		(b)(2) not supported currently reviewing to determine if we will certify against this criteria during the 2nd half of the year
Required Test 9 – Medication/Clinical Information Reconciliation Medicaid Promoting Interoperability Program	§170.315(b)(2) Clinical Information Reconciliation and Incorporation	§170.315(b)(1) Transitions of Care – receive, display, and incorporate summary care records may support electronic receipt of transitions of care/referral summaries	(b)(2) not supported
Required Test 10 – CPOE Medications Medicaid Promoting Interoperability Program	§170.315(a)(1) Computerized Provider Order Entry (CPOE) – Medications		(a)(1) supported, 2014 ONC gap eligible. Even though the Medicaid PI program ended this item is required to meet the Base EHR requirements.
Required Test 11 – CPOE Laboratory Medicaid Promoting Interoperability Program	§170.315(a)(2) CPOE – Laboratory		(a)(2) supported, 2014 ONC gap eligible. Even though the Medicaid PI program ended this item is required to meet the Base EHR requirements.
Required Test 12 – CPOE Radiology/Diagnostic Imaging Medicaid Promoting Interoperability Program	§170.315(a)(3) CPOE – Diagnostic Imaging.		(a)(3) not supported
Required Test 15 – Support Electronic Referral Loops by Receiving and Incorporating Health Information Medicare Promoting Interoperability Program MIPS Promoting Interoperability Performance Category	§170.315(b)(1) Transitions of Care §170.315(b)(2) Clinical Information Reconciliation and Incorporation		(b)(1) supported (b)(2) not supported currently reviewing to determine if we will certify against this criteria during the 2nd half of the year

Terminology

EP = Eligible Practitioner

Relevant OpenEMR Code Sections

This analysis was last updated on February 3rd 2022

Files and Commits

Files found relevant to this area are: amc.php

This commit introduced the AMC modules: d43cdab06aaaf09847e72c80f2a8bd39206c8fe9

This commit modified the AMC modules: e4f1be061d4ef1e8feefc09fdbebf304da0a29c2

AMC rule calculations can be found in the library/classes/rulesets/Amc/

AMC (g)(1) Automated Measure Recording patient reports seem to be created through this file amc_tracking.php

AMC report is done through the cqm.php file with the type set to amc

AMC Generation Process Flow

A user gets to the AMC generate report page by going to Reports -> Clinics -> Automated Measures (AMC) which opens up a tab for <site_id>/interface/reports/cqm.php?type=amc

From there the user selects their report properties they want and then submits the form which does the following process flow.

cqm.php -> Submit Form -> javascript::runReport() -> ../../library/ajax/collect_new_report_id.php (generate report id) -> cqm.php -> ../../library/ajax/status_report.php (poll status of generated report every 10 seconds) -> ../../library/ajax/execute_cdr_report.php (start report generation) -> cqm.php?report_id=<id> (load generated report).

execute_cdr_report.php flow

- Grabs a report id, date range, type, plan, organize_method, primary provider vs encounter based for the report - calls the function test_rules_clinic_batch_method in library/clinical_rules.php - grabs the patients the report pertains to -> buildPatientArray - breaks the patients up into groups of batches to be done at a time. - calls the function test_rules_clinic in library/clinical_rules.php -

AMC Wiki Page Documentation

Found some relevant wiki pages that will help in creating the GAP analysis and figuring all of this out

• CDR User Manual
• CDR Engine
• Clinical Decision Rules
• Description AMC

GAP Analysis

So the AMC clinical rules are in the clinical_rules table. There are columns for the 2011 criteria and columns to match AMC for the 2014 criteria. If the same architecture was followed we'd add two new columns for the 2015 criteria. We'd need a amc_code_2015 column and an amc_2015_flag. The code column would contain the referenced ONC criteria text and the flag would be to include that specific code class into the calculations.

It looks like the text descriptions are contained in the clinical_rules' list (stored in list_options). The option_id must match the specific rule id column in the clinical_rules table for that AMC measure.

• Required Test 2a,2b,2c - Providing Patient Access, View Download Transmit
  • In terms of GAP analysis it looks like the currently implemented AMC_314g_1_2_14_STG2 is very similar to PI_PEA_1. We would need to adjust the patient portal instructions article to explain how to access data via FHIR and we could have nearly identical logic.
  • Relevant Specification File:2022 MIPS PI Measures Provide Patients Electronic Access.pdf
  • Note we aren't linking to any Medicaid specification as those are no longer operable.

• Required Test 7 - Support Electronic Referral Loops by Sending Health Information (formerly Transitions of Care)
  • Gap Analysis. It looks like clinical rule id send_sum_1_stage2_amc or send_sum_stage2_amc is the AMC measures that need to be modified here. This corresponds with class files:
    • AMC_304i_STG1
    • AMC_304i_STG2
  • Relevant Specification File:2022 MIPS PI Measures Support Electronic Referral Loops by Sending Health Info.pdf
  • From what I can tell the AMC_304i_STG2 matches very closely the code specification in 2022 MIPS criteria

Skipped Tests Explanation

• E-Prescribe is not being certified though it may be certified in the 2nd half of the year. This skips the following Required Tests
  • Required Test 1 – ePrescribing
• Medicaid Promoting Interoperability program terminated CMS ended the medicaid PI program and the certification tests show they are for 2021 only. This skips over the following tests:
  • Required Test 5 – Secure Messaging (Note EHR secure messaging certification ended also which would skip this test for that reason as well).
  • Required Test 6 – Patient Generated Health Data
  • Required Test 10 – CPOE Medications
  • Required Test 11 – CPOE Laboratory
  • Required Test 12 – CPOE Radiology/Diagnostic Imaging
  • Note if we decide to certify against (b)(2) we will need to pass required test 8 and 9. Required test 9 appears to most closely match the AMC clinical rule from 2011 for 'med_reconc_amc'.