Editor's note: This blog was written by Erica Drazen, managing director, Global Institute for Emerging Healthcare Practices at CSC.
The Centers for Medicare & Medicaid Services Stage 2 proposed rules for meaningful use released Thursday have many changes; some are subtle.
In addition to the new requirements to be a meaningful user of EHRs, there is one important clarification to the requirements for avoiding penalties.
To avoid penalties starting in 2015 for not being a meaningful user, you need to either attest to meaningful use in 2013, or have achieved and attested to your first year of meaningful use by July 1, 2014, for hospitals and Oct. 1, 2014, for eligible providers.
As reported earlier, the requirement as to when different stages of meaningful use need to be met was officially relaxed. Those who attest to meaningful use first in 2011 or 2012 must meet Stage 2 criteria in 2013 and Stage 3 in 2016. All others will be required to demonstrate two years at Stage 1, two years at Stage 2, and then two years at Stage 3. (Assuming the cutoff date for the program's payments has not passed.)
Quality Measures
Quality measures are still not final, but in Stage 2 they will be submitted electronically. The proposal is that eligible providers will submit 12 measures (some may be required, others selected from a long list of potential measures). Hospitals will select 24 measures (50 possible measures are proposed) in both settings; at least one measure will need to be reported from each quality domain: Patient Safety, Care Coordination, Population and Public Health, Efficient Use of Resources and Clinical Effectiveness.
The final list of quality measures will be published with the final rule. This delay affects both users and vendors; vendors are likely to require significant development effort to be able to capture and report on the expanded list of quality measures.
The proposed rule generally makes Stage 1 optional (menu) items required (core) in Stage 2. Stage 2 does retain the concept of core and menu requirements for new requirements. For example, use of e-MAR is now a core requirement for hospitals and the ability to view images is a new menu requirement.
Higher Thresholds
Many of the thresholds from Stage 1 have been raised, some to a higher level than those recommended by the HIT Policy Committee. For example, the requirement for CPOE for medications is 30 percent in Stage 1; the policy committee recommended it be raised to 50 percent, and the proposed rule raises it to 65 percent. Other new requirements include CPOE for laboratory and radiology orders; the ability of patients to view, download and transmit their health information; and public health reporting to cancer registries and other specialized registries.
The CPOE measurement was changed from being based on one order per patient to a percentage of all orders, which will raise the bar considerably. The only major recommendation from the policy committee that was not included in the NPRM was for an electronic physician note for 30 percent of office visits and 30 percent of hospital days. While no longer required for meaningful use, physician notes are a major source of data that will be required for electronic reporting of quality requirements.
To ensure that systems certified for Stage 2 also can meet Stage 1 requirements, a few Stage 1 requirements will be modified somewhat for 2014 onward. All the changes in requirements (even small ones) will have a major impact on vendors because the entire installed base will need to use a system that meets Stage 2 requirements in 2014, if they are still attesting to Stage 1. It is likely that vendors will only get the more recent versions of their products certified for Stage 2, which increases the number of customers who will need a major upgrade.
Following their publication in the Federal Register, the proposed rules will undergo a 60-day public comment period. What is your reaction to the changes?