Final stage 2 MU rule offers healthcare providers some compromises and EHR tweaks, and also requires greater patient engagement.
By Nicole Lewis, InformationWeek
September 04, 2012
URL: http://www.informationweek.com/healthcare/policy/meaningful-use-stage-2-are-you-ready/240006670
Under the Meaningful Use stage 2 final rule, eligible professionals (EPs) working in a hospital can apply for incentive payments if they can demonstrate that they've acquired a certified electronic health record (EHR), and are using it in lieu of the hospital's EHR. To qualify, EPs must show that they implemented the EHR and maintain the system, including supporting hardware and interfaces needed to achieve meaningful use, without receiving reimbursements from the hospital.
"We know that there are EPs who work within certain areas or unit of hospitals–for example, neonatal care–but use entirely separate systems, and this application process will allow those EPs to ask for a redetermination of their hospital-based status based on those factors," a spokesman for the Centers for Medicare & Medicaid Services (CMS) told InformationWeek Healthcare. 
Expanding the criteria for EPs to apply for incentive payments is one of the many changes incorporated into the Meaningful Use stage 2 final rule, a 672-page document recently published by CMS.
Many of the changes address real-world concerns that healthcare providers face as they prepare their systems to meet Meaningful Use criteria, said Dr. Farzad Mostashari, National Coordinator for Health IT at the Office of the National Coordinator for Health Information Technology.
[ For more on Meaningful Use stage 2, see Meaningful Use Stage 2 Rules Finalized. ]
"What you will see [in the stage 2 final rule] is some compromises frankly between the aspirational goals and the realities of where the market is and the pressures on providers and vendors in terms of timeline," Mostashari said during a webcast August 24 hosted by the National eHealth Collaborative.
Extending the timeline to meet Meaningful Use stage 1 deadlines is one area of compromise. In the stage 1 Meaningful Use regulations, CMS established a timeline that required providers to progress to stage 2 criteria after completing two years in the incentive program. This original timeline would have required Medicare providers who first demonstrated Meaningful Use in 2011 to meet the stage 2 criteria in 2013.
However, CMS pushed back the timeline by one year. The earliest that the stage 2 criteria will be effective is fiscal year 2014 for eligible hospitals and critical access hospitals (CAH), or calendar year 2014 for EPs.
Hospitals and physicians must also keep in mind that many of the stage 1 requirements that have been carried forward to stage 2 have a concomitant rise in threshold levels, according to Rob Anthony, a health specialist in the Office of eHealth Standards and Services at CMS.
Explaining the new requirements during the webcast, Anthony said health providers must show that more than 50% of prescriptions are completed through electronic prescribing, up from the stage 1 threshold of 40%. Reporting of demographic information, vital signs, and smoking status has moved from 50% in stage 1 to more than 80% in stage 2. CMS also raised the requirement for reporting instances of clinical decision support and intervention from one to five. These interventions include reporting on drug-to-drug interactions and drug allergy interaction alerts.
Turning to clinical quality measure (CQM) reporting in stage 2, beginning in 2014 EPs must report on nine out of 64 total CQMs, and eligible hospitals and CAHs must report on 16 out of 29 total CQMs.
In addition, all providers must select CQMs from at least three of the six key healthcare policy domains recommended by the Department of Health and Human Services' National Quality Strategy. These are: 1. Patient and Family Engagement; 2. Patient Safety; 3. Care Coordination; 4. Population and Public Health; 5. Efficient Use of Healthcare Resources; and 6. Clinical Processes/Effectiveness.
Stage 2 will also focus more intensely on facilitating patients' access to their records, and replaces stage 1 objectives that call for clinicians to provide electronic copies of health information or discharge instructions, with the stage 2 objectives that allow patients to access their health information online.
For EPs, stage 2 requires that patients have the ability to view online, download, and transmit their health information within four business days of the information being available to the EP. Eligible hospitals and CAHs are required to provide patients the ability to view online, download, and transmit their health information within 36 hours after discharge from the hospital.
Patients must also do their part in stage 2, which calls for more than 5% of patients to send secure messages to their EP, and more than 5% of patients to access their health information online. CMS is introducing exclusions based on broadband availability in the provider's county.
Stage 2 also facilitates batch reporting. Starting in 2014, groups can submit attestation information for all of their individual EPs in one file for upload to the attestation system, rather than having each EP individually enter data.
In the stage 2 criteria, the feds emphasized the need to exchange health information between providers to improve care coordination for patients. One of the core objectives requires EPs, eligible hospitals, and CAHs who transition or refer a patient to another care setting or provider to furnish a summary of care record for more than 50% of those transitions of care and referrals.
Additionally, there are new requirements for the electronic exchange of summary of care documents: EPs, eligible hospitals, and CAHs that transition or refer their patient to another care setting or provider must electronically provide a summary of care record for more than 10% of transitions and referrals.
The EP, eligible hospital, or CAH that transitions or refers a patient to another care setting or provider must either: a) conduct one or more successful electronic exchanges of a summary of care record with a recipient using technology that was designed by a different EHR developer than the sender's, or b) conduct one or more successful tests with the CMS-designated test EHR during the EHR reporting period.
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