No Surprises With Release Of The Proposed Rule For Stage 2 Meaningful UseMarch 9, 2012
After much anticipation among providers and health IT vendors throughout the U.S. healthcare landscape, The Centers for Medicare and Medicaid Services (CMS) finally released its proposed rule for Stage 2 Meaningful Use of electronic health records (EHR) on February 23, 2012. The release of the proposed rule for Stage 2 provides details of how CMS is raising the expectation for healthcare providers to achieve meaningful use of EHR technology in order to qualify for future incentive payments.
As expected, Stage 2 Meaningful Use takes the criteria of Stage 1 to the next level by increasing the performance threshold of existing measures and motivating providers to utilize their record sharing capability to actually exchange information in a variety of transactions to drive incremental quality and care improvement.
With greater focus on health information exchange, the measure is now a key component in the “robust transitions of care” core objective, and the measure to provide patients with an electronic copy of their data in Stage 1 is replaced by “electronic/online access” as a requirement in Stage 2.
The proposed rule for Stage 2 also addresses a primary concern voiced by many providers pertaining to the challenges of reporting out quality measures. Starting in 2014, the reporting of quality measures will be easier for providers now that clinical quality measures for Stage 2 will align with existing quality programs, such as those used for the Physician Quality Reporting System and CMS’ Shared Savings Program. The same ease of reporting also applies to hospitals now that clinical quality measures will align with the Hospital Inpatient Quality Reporting and the Joint Commission’s Hospital Quality Measures.
CMS will keep the same core menu structure for required measures for Stage 2 Meaningful Use. Eligible providers will have to meet seventeen core objectives, three of the five menu options, and will report on twelve clinical quality measures. Hospitals will have to meet sixteen core measures, two of the four menu options, and will report on twenty-four clinical quality measures. CMS also outlines in the proposed rule how providers may electronically submit the quality measures and the agency is looking for public feedback on methods for submission. CMS is specifically interested in feedback regarding aggregate-level and group reporting options leveraging existing quality reporting systems.
Some of the core measures providers will have to meet during the reporting period for Stage 2 Meaningful Use include:
Providers will have to supply a summary of care record for more than sixty-five percent of the patients the provider transitions or refers a patient to another care setting or provider.
Providers will have to perform medication reconciliation for more than sixty-five percent of transitions of care in which patient moves into care of another provider or admitted to hospital or emergency room.
More than fifty percent of patients seen during the Stage 2 reporting period are provided online access to their information within four business days of their visit subject to provider’s discretion to withhold certain information.
Providers will have to use computerized physician order entry (CPOE) for more than sixty percent of medication, lab and radiology orders created.
Providers will have to implement five clinical decision support interventions for five or more clinical quality measures at relevant point in care and use functionality for drug-drug and drug-allergy interaction checks.
More than fifty-five percent of clinical lab test results whose results are positive/negative or of numerical format are incorporated into the EHR of patients as structured data.
Medical organizations will have to conduct or review security risk analysis, address encryption or security of data at rest and execute security updates as necessary and correct identified security deficiencies.
The proposed rule confirms that CMS will delay the start of Stage 2 until 2014 instead of the originally planned start of 2013. CMS decided to delay the start of the reporting period by one year because the original 2013 timeframe does not give vendors enough time to design, develop, and test new functionality so that providers can successfully deploy and attest to meeting Stage 2 requirements over the one year reporting period.
The one hundred thrity-two page proposed rule for Stage 2 Meaningful Use was officially posted in the Federal Register on March 7, 2012. This action officially launched the countdown for public comments for sixty days and CMS is encouraging the public to comment on the proposed rule online prior to the May 6, 2012 deadline.
CMS expects to release the final rule for Stage 2 Meaningful Use in the summer of 2012.