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Summary of Proposed Stage 2 Rule of Meaningful Use

The Notice of Proposed Rule Making (NPRM) for Stage 2 requirements for meaningful use of electronic health records (EHRs) was recently released by the Centers for Medicare and Medicaid Services (CMS). The final rule is expected this summer.

In addition to the new requirement 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, eligible providers (EPs) need to either attest to meaningful use in 2013, or have achieved and attested to the first year of meaningful use by October 1, 2014.

The requirement as to when different Stages of meaningful use need to be met was officially relaxed.

Those that attest to meaningful use first in 2011 must meet Stage 2 criteria in 2014 and Stage 3 in 2016. All others will be required to demonstrate 2 years at Stage 1, 2 years at Stage 2, and then 2 years at Stage 3.

Quality measures are still not final.

However, in 2014 they will be submitted electronically. Quality measures are now a distinct category of meaningful use and the schedule is not tied to a particular Stage. In 2014, all those attesting to any Stage of meaningful use will need to electronically report the 2014 quality measures. The proposal is that EPs will submit 12 measures (some may be required, others selected from a long list of potential measures). 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.

There are many changes in requirements.

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. 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 (Computerized Physician Order Entry) for medications is 30% in Stage 1, the Policy Committee recommended it be raised to 50% and the proposed rule raised it to 60%. 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. 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% of office visits.

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 can also 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 since the entire installed base will need systems that meet these requirements. It is likely that vendors will only have the more recent versions of their products certified for Stage 2, increasing the number of customers that will need a major upgrade.

We will have a table that provides a summary of all the changes in requirements proposed to Stage 2. This table is available under our Forms tab, look under our Medicare Forms. It will be posted in a few days on our website at www.healthcarecompliancepros.com

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