Meaningful Use Update 07/14/2010

 July 14, 2010 
It is official. The U.S. Department of Health and Human Services Secretary Kathleen Sebelius hosted a live video conference on July 13th to announce the final rules targeted to improve the delivery of health care, increase safety and quality, and reduce costs.
The rule is the result of The Center for Medicare and Medicaid Services (CMS) receiving over 2,000 comments from the public. These were used as a catalyst to shape the resulting final rule. The proposed ruling was composed of a broad set of 23 “hospital required” and 25 Eligible Professionals (EP) objectives. The all-or-nothing approach was felt to be too rigorous and unachievable for the providers.
The final regulation has been structured to be more flexible for the providers while still providing significant improvement in the delivery of care in the United States.  
Listed below are some of the key changes to the regulation:
  • In order to provide flexibility to achieve the Stage One criteria, the requirements will be segmented into “Core” and “Menu Set” requirements. All Eligible Hospitals and EPs will need to meet “Core” requirements, 14 and 15 respectively. The requirements vary slightly between the two settings of care. Additionally, ten (10) “Menu Set” requirements have been identified. These also vary slightly between the two settings of care. Both Eligible Hospitals and EPs will choose 5 items to meet for “Stage One.”
     
  • Computerized Order Physician Entry (CPOE) requirement has been modified to “more than 30% of patients with at least one medication in their medication list that has been ordered through CPOE.”
     
  • Several of the previously stated required measurements have been reduced or changed so that the criteria are achievable.
     
  • The number of required Clinical Quality Measures to report to CMS has been reduced.
     
  • Added “Menu Set” objectives (1) to provide conditional, specific educational materials to the patient and (2) to record advanced directives for patients older than 65 years of age.
     
  • Removed the objective for electronic claims submission and insurance validation.
     
  • “Hospital Based” defined as an EP who performs substantially all of their services in an inpatient setting or emergency room only.
An outline of the regulation highlights and the changes have been included as an attachment.  
Key Dates:
Timing Activity
July 1, 2010
 
ONC started accepting applications for ONC-Authorized Testing and Certification Entities
 
Fall 2010
 
ONC projects certified EHR software will be available
 
January 2011 
 
Eligible hospitals and EP may register for incentive program on CMS website
 
April 2011
 
Medicare program attestation may begin 
(mid) May 2011    
 
Medicare EHR pay will begin
 
May 2011
 
States could begin initiating incentive payment programs on a rolling basis, subject to CMS approval of the State Medicare HIT plan 
 
This regulation is a major piece of the HITECH legislation. It is felt that this final rule strikes a balance between what is achievable for the hospital and the EPs while still rigorous enough to lay the ground work for a 21st century healthcare system in the United States.  
As your partner, CareTech will continue to educate you through this process. We welcome your inquires and work on your behalf to help you achieve all of your IT strategic goals including Meaningful Use.
“Get ready to set your GPS. The road to a 21st century healthcare system, through the Meaningful Use of an electronic healthcare record, is ready.”
Paula Gwyn, Strategic Planning, CareTech Solutions
Contact us for more information

MU: “Skipping Years” Means Losing Incentive Money 07/30/2010

 July 30, 2010 
“Skipping years” means losing incentive money.  
While we all keep a laser focus on achieving Stage 1 of Meaningful Use, it is important that we plan for the requirements of the subsequent stage as well. There is a new concept of “skipping years” that has been introduced in the final Meaningful Use Ruling. This concept is one that needs to be considered as we look to our long-term IT strategic plans related to Meaningful Use for the next few years.  
How does this work?
The first consideration is to determine when the eligible hospital wants to register with The Center for Medicare and Medicaid Services (CMS) for their first Meaningful Use adoption year. This is the first year that the hospital will begin reporting and attesting to the Meaningful Use core and chosen menu standard. This process starts with a 90-day continuous-reporting period.
Outlined below is the revised CMS payment table in the final rule. Changes include the removal of Stage 3, FY2015 requirements at this time, and a relaxing in the 2014 requirement for first adopters in 2013 to jump to Stage 2 in a single calendar year. Stage 3 requirements will be forth coming. The changes have been highlighted in yellow in table 1.
                      CMS Payment Table – (Table 1)



The next consideration topic for the timing for achieving Stage 1 Meaningful Use criteria is the implication and timing of achieving Stage 2 requirements. This is how the “skipping years” concept needs to be part of the planning process.  
This “skipping years” concept is related to two requirements in the final ruling;
  1. The incentive program is available to an eligible hospital for four contiguous years.
  2. A hospital cannot remain at Stage 1 for more than two years.
So why is this important to the eligible hospital?  
If a hospital starts the reporting process in FY2011, they must be ready to move to Stage 2 in FY2013 (October 1, 2012). If the hospital cannot meet Stage 2 at that time they will be forced into “skipping a year” of incentive (in this case a 50% incentive calculation) and will forfeit incentive payments at that time. If that same hospital achieves Stage 2 in the next fiscal year (FY2014), they will be eligible for incentive money but it will be at the next logical year’s tiered calculation or 25%.
Since the incentive is only available for four consecutive years, this will be the final year that the hospital will be eligible for incentive money under this program. In this case the hospital will only receive three of the potential four years of potential incentive dollars at the tiered incentive rate of 100%, 75%, and 25%. If they never achieve the Stage 2 criteria prior to FY2015, then they would only receive the incentive dollars for the first two payment years.  
Skipping years does not apply to Medicaid in the same way. There is no reporting requirement for meeting Meaningful Use criteria for Year One. Year Two requires 90 days of reporting and Year Three requires a full year of meeting all requirements.
Takeaway
Meaningful Use has implications over a number of years. It is essential to consider the Stage 1 and Stage 2 requirements in our gap analysis and IT strategic planning. Future capital requirements, operational and clinical ramifications will need to be considered, as well as the governance to shepherd the process. Planning, timing, and milestones to consider;  
  • Incentive dollars are available for (at most) four years.
  • Make sure you are ready for Stage 1 and have a plan to get to Stage 2 in the given timeline.
  • You can wait until FY2012 to register for Stage 1 and still receive all four years of incentives.
  • If Meaningful Use is not met in a given reporting year, then the incentive is “skipped.”
  • The reporting year for FY2011 begins October 1, 2011.
  • CMS registration website will be open in January, 2011.
  • It is anticipated that the earliest possible payment will be May, 2011.
  • Te latest a hospital can start to demonstrate Meaningful Use and still be covered in the FY2011 is July, 2011.
“Strong governance and planning are key factors in the success of meeting Meaningful Use goals in the short and long-terms.”
Paula Gwyn, Strategic
Planning, CareTech Solutions
Contact us for more information

MU: Mark your Calendars: The Time Has Come to Register 04/04/2011

 APRIL 2011 
Mark your calendars: The time has come to register.  
Attestation for the Medicare Electronic Medical Record incentive program begins April 18th. This means that those who are ready to receive Medicare incentives for Meaningful Use Stage One can complete their applications.  
Each participating hospital or professional will need to complete their registration for the program. The dedicated portal can be located at: EHR Incentives Login
The Center for Medicare and Medicaid has also published a preview of the application and attestation process so that you can understand the process steps. The preview may differ slightly from the final release. Attestation Sneak Peek
A user guide has also been released. The user guide contains step-by-step instructions for completing the attestation process. There will also be educational webinars about the attestation process. The user guide can be located at: User Guide
Please be reminded that providers are encouraged to begin their 90-day reporting period in time to attest for the Medicare 2011 payment year. The last day to begin the 90-day reporting period for the 2011 incentive payment is July 3, 2011, for eligible hospitals and critical-access hospitals. The final date for eligible professionals to attest is October 1, 2011.  
The Medicaid EHR incentive program participation varies by state, so please reach out to your CareTech Client Executive or email Jim Deren or myself for clarification. You can also review state-specific information at: Medicaid State Info
Please visit the Meaningful Use toolkit on CareTech Central to read about the latest Meaningful Use developments and how these laws might affect our existing and prospective hospital clients. CareTech Central
“The time has come to start confirming your timing to register and attest for incentive payments. Even if your plans are to wait for a year or two, it is still recommended that you start reviewing this information so that you are prepared when the time comes.”
Paula Gwyn
Strategic Planning
CareTech Solutions
For an archive of our newsletters, please visit the Resources page on CareTech.com.

 

MU: Get Local! 05/11/2011

 May 2011 
Get Local!  
Need to learn more about what’s happening with health information technology in your state?  

The NIST Cybersecurity Framework focuses on developing a risk management process and guides healthcare and other organizations through a five-step process, as well as providing a needed set of security functions (i.e., activities and outcomes). These functions are further broken down into categories, subcategories and informative references. In the end, the Framework outlines a comprehensive set of cybersecurity controls and an approach to organizational cybersecurity risk management.

Healthcare Information and Management Systems Society (HIMSS) has launched a new State Healthcare Information Technology (HIT) Dashboard. The tool is cited as the premier resource of today’s healthcare Information Technology initiatives around the United States. The dashboard provides an easy-to-read visual interface, tracking key initiatives including Regional Extension Centers, Health Information Exchanges, and state-specific legislation information. The tool also displays local HIMSS chapters and HIMSS Davies Award recipients.
The screen print below shows the state-specific information for Florida.  

Figure 2 –
Drill down by geographic area
The mapping process allows you to drill down into geographic-specific regions to identify resources such as local HIEs or RECs.

The drill-down will also link to state-specific legislation information as well as where to access additional information. 
Click the link to go to the dashboard
http://www.himss.org/statedashboard/
Specific items that can be located on the dashboard are:

  • State Resources: A single repository of state-specific health information, state organizations and state-related resources.
  • Regional Extension Centers: Name and amount-awarded information about the Regional Extension Centers.
  • Health Information Exchanges: Name, location and details of self-reporting health information exchange organizations including state-designated entities.
  • State Legislation Tracking: Description and reference information on pending state legislation.
  • HIMSS Chapter Information: Links and locations of HIMSS chapters.
  • Davies Award Recipients: Name, organizational description and affiliated news releases of Davies Award recipients.
In a time of information overload and sometimes a drought of different HIT topics, this resource appears to be an easy-to-use dashboard to let you access state-level information in a single repository.
“In a time of information overload, this resource appears to be an easy-to-use dashboard to let you access state-level information in a single repository.”
Paula Gwyn
Strategic Planning
CareTech Solutions
For an archive of our newsletters, please visit the Resources page on CareTech.com.

 

MU: Security Risk Assessment 09/14/2011

 September 2011 
Meaningful Use: Security and Risk Assessments  
One of the 14 Meaningful Use Core Set objectives is to:  

Protect electronic health information created or maintained by the certified EHR technology through the implementation of appropriate technical capabilities

The Stage 1 measure is:
  1. Conduct or review a security risk analysis per [HIPAA] and
  2. Implement security updates as necessary and correct identified security deficiencies as part of its risk management process
The requirement for a security risk analysis may sound vague and unclear, but those who specialize in information security regard risk assessment as an essential step to improving an organization’s security program. This article will explain what must be done to meet this Meaningful Use requirement.  
In order to attest to this Stage 1 requirement, both the assessment and the correction of identified security deficiencies must be completed by the end of your first EHR reporting period. The work can be completed prior to the beginning of the EHR reporting period. The scope of the assessment must be (at least) your certified EHR technology.  
The HIPAA requirement referenced in the Stage 1 measure says:  
Conduct an accurate and thorough assessment of the potential risks and vulnerabilities to the confidentiality, integrity, and availability of electronic protected health information held by the covered entity.
A risk analysis or risk assessment is a systematic process to analyze, identify and evaluate security vulnerabilities and the level of risk associated with each vulnerability. A risk management plan is developed to reduce (mitigate) unacceptable risks to an acceptable level. The risk analysis and risk management plan should be presented to leadership for decisions concerning appropriate response and for incorporation of needed activities into organizational plans. Some risks may be addressed through system configuration changes, patches or software upgrades. Others may require new policies to be developed and workforce training. Some will require the purchase and implementation of new technology and will have a budgetary impact. Yet others may require process changes and some may impact staffing levels. These are just a few examples of steps that may be necessary.  
HIPAA emphasizes that a risk analysis is to be thorough. It should look at risks to confidentiality, integrity and availability of information. It is not just an assessment of what happens in the IT department but analyzes security risks in every department that uses or discloses electronic patient information.  
For additional information on risk assessment you may contact Jeff Bell or Jim Hunter.  jeff.bell@caretech.com or jim.hunter@caretech.com
Two useful guides on risk assessment are:  
“A risk analysis or risk assessment is foundational to developing a security program that provides the necessary protection for patient privacy. That is why HIPAA and the EHR incentive program require it.”
Jeff Bell, CISSP, CPHIMS, ACHE
Director of Client Services
CareTech Solutions
 

MU: EHR Incentive Program 10/26/2011

 October 2011 
EHR Incentive Program
Medicaid Adopt, Implement, Upgrade (AIU) Option  
Even if you are not ready to attest to meeting all of the requirements for stage one of Meaningful Use, you may be eligible for a portion of the Medicaid payment immediately. Hospitals and eligible providers who meet the thresholds for Medicaid may be eligible for the first-year payment through the “Adopt, Implement, Upgrade” provision.  
Through this provision, a hospital or eligible provider merely needs to purchase certified EMR technology within the first payment year. For hospitals, that year is the Federal fiscal year which ends September 30. For eligible providers, it’s the first year is the calendar year that ends December 31.  
For AIU, a provider does not have to have installed certified EHR technology. The definition of AIU in 42 CFR 495.302 allows the provider to demonstrate AIU through any of the following: (a) acquiring, purchasing or securing access to certified EHR technology; (b) installing or commencing utilization of certified EHR technology capable of meeting meaningful use requirements; or (c) expanding the available functionality of certified EHR technology capable of meeting Meaningful Use requirements at the practice site, including staffing, maintenance, and training, or upgrading from existing EHR technology to certified EHR technology per the EHR certification criteria published by the Office of the National Coordinator of Health Information Technology (ONC). Thus, a signed contract indicating that the provider has adopted or upgraded would be sufficient.  
Medicaid payments will occur no later than 5 months after attestation.  
The chart below shows criteria for an eligible provider or hospital. Note that hospitals must have a 10% volume of Medicaid discharges.  
The equation is used to determine the Medicaid volume. For hospitals, discharges are used in place of encounters.
In order to receive your Medicaid payment you will need to follow these steps.  
  1. Ensure your state is a participant in the Medicaid EHR incentive program.
  2. Obtain a CMS EHR Certification ID
  3. Obtain an Incentive and Attestation login and password
  4. Register for the EHR Incentive Program
    • Select the “Registration” Tab
    • Select “Hospital” for hospitals. You will be prompted to select Medicare, Medicaid, or both. Also you will be prompted to select AIU (Adopt, Implement, Upgrade)
  5. Attest for the EHR Incentive Program
    • Select the “Attestation” Tab
“Haven’t implemented all stage one Meaningful Use requirements yet? If at least 10% of your hospital discharges are Medicaid patients, you still may be eligible for early incentives through the Medicaid Adopt, Implement, Upgrade (AUI) provision.”
Jeff Bell
Strategic IT Planning
CareTech Solutions
 

MU: Stage 2 12/22/2011

 December 2011 
Meaningful Use Stage 2
While most hospital and care providers have made significant progress toward achieving Stage 1 of the Meaningful Use requirements for an electronic medical record, it is critical that planning for the subsequent stages begin now.
Stage 1 focuses on the capture and sharing of clinical information among the care team. Stage 2 and 3 focus on advanced care processes, decision support and improved outcomes.  
Completion and continued compliance with all Stage 1 requirements are prerequisites to meeting the Stage 2 and 3 goals. Hospitals and eligible providers need to implement and attest to all Stage 1 menu requirements that were not achieved during Stage 1. End users will also need to ensure that their software is upgraded to certification in order to meet subsequent Stage 2 and 3 functionality.
Requirements  
Stage 2 and 3 requirements include an expanded set that falls into these categories. 

        1. Thresholds are increased from Stage 1
        2. Functionality must be expanded from just having certain capabilities in 
            place to actually transmitting and measuring information
        3. New functionality is required
Key thresholds that are increased include:
  • Expanding order types and percentages of numerators for orders
  • Prescriptions
  • Demographics
  • Vital signs
  • Smoking status
  • Continuity of care record
  • Discharge instructions,
  • Providing summary of health information
  • Office visit summaries
  • Access to health information
  • Medication reconciliation
Menu set requirements that must be achieved include:
  • Advanced directives
  • Structured lab data
  • Medication reconciliation
  • Summary of care records
  • Patient reminders

Functionality that must be expanded to send actual data includes:

  • Drug interaction checks
  • Clinical decision support
  • Drug formulary checks
  • HIE
  • Submission of immunization data
  • Reportable lab results
  • Syndromic surveillance data
New functionality that is required includes:
  • Electronic notes for inpatient and outpatients
  • Electronic prescription checking
  • Web access to patient data
  • Secure Internet messaging with patients
  • Self-management tools
  • Electronic health records
  • Capturing and listing care team members
  • Longitudinal care plan
  • Public health alerts
“Completion and continued compliance with all Stage 1 requirements are prerequisites to meeting the Stage 2 and 3 goals.”
Jim Deren
Strategic IT Planning CareTech Solutions
Organizations must continue to capture a patient’s problems, active medications, and med allergy list, as well as continue to meet all security measures.
Timing
The Federal Government has extended the timeframe for requiring attainment of Stage 2 by an additional year. Measurement and attestation will require continuous compliance for the entire year, which is the federal fiscal year (October 1 – September 30) for hospitals and calendar year for ambulatory providers.  
Your target dates will vary depending upon when you attest to Stage 1. For hospitals first attesting in 2012, you must go live and begin measuring by October 1, 2014, in order to provide one year of data on September 30, 2015. If a hospital first achieves Stage 1 in 2013, they must go live and begin measuring Stage 2 by October 1, 2015, in order to attest to one year of measurement on September 30, 2016.
Reduced Medicare payments begin on October 1, 2014, if a hospital has not achieved Stage 1 or fails to continue to meet the minimum thresholds for the appropriate stage. For the ambulatory environment, reduced Medicare payments will begin January 1, 2015, for hospitals that have not achieved or sustained the appropriate stage for meaningful use. There are no penalties for Medicaid providers.
Based upon public feedback, the HIT Task Force is considering a number of changes to the law that may involve adding Behavioral Health, Rehabilitation Services, Ambulatory Surgery Centers, and Long-Term Care to the scope of services. The final rule for Stage 2 is expected to be completed in February of 2012.  

Timing

 

MU: Stage 2 Summary 03/13/2012

 March 2012 
Meaningful Use Stage 2 Summary
60-Day Feedback Period
On Feb. 23, 2012, the CMS released the Notice for Proposed Rulemaking (NPRM) for the Stage 2 requirements for Meaningful Use of Electronic Medical Records. This date begins a 60-day feedback period where comments and recommendations will be received in order to finalize the Stage 2 requirements. CareTech is in the process of developing our feedback to the proposed ruling. A copy of our comments will be available for client review. The target date for finalizing the rule is late summer of 2012.
Expanding Functional Requirements
The rule continues to expand upon the functional requirements that are included in Stage 1 by increasing thresholds of certain requirements and emphasizing bona fide data exchange, longitudinal care plans, evidence-based clinical decision support, and increased standardization of data and data exchanges. While the objective of Stage 1 was to build a foundation in order to capture information electronically, the goal of Stage 2 is to “encourage the use of health IT for continuous quality improvement at the point of care and the exchange of information in the most structured format possible.”
Changes to Stage 1 Functionality
Providers and hospitals will be required to continue to adhere to Stage 1 functionality as well as meet the requirements for the new Stage 2 rules. A number of changes have been introduced that modify Stage 1 functionality and will take effect in 2013. These include:
“The goal of Stage 2 is to encourage the use of health IT for continuous quality improvement at the point of care and the exchange of information in the most structured format possible.”
Jim Deren
Strategic IT Planning CareTech Solutions
  • Consolidation of certain requirements (making it one requirement to maintain patient problem list, allergy list, and active medication list)
  • Removal of certain requirements (ex. 3 EH QCMs, capability to exchange key clinical information)
  • Modifications in the calculation for denominators for certain requirements (most significantly, how CPOE denominators are calculated for med orders)
  • Threshold changes of existing functionality
  • More specific data exchange elements through interfaces that actually work
As expected, Stage 1 menu items, such as incorporating lab results as structured data, generating patient lists by condition and sending patient reminders, have moved to core competencies. For Stage 2, eligible providers are met with 17 core objectives and the selection of three of five menu items for 20 total, 18 objectives for hospitals made up of 16 core, and two of four menu items.  
Other Stage 1 Core Objectives  
Thresholds in other Stage 1 core objectives are increasing as Stage 2 quality measures, such as CPOE from 30 percent to 60 percent, with the addition of lab and radiology orders along with medications. Electronic prescribing of non-controlled substances rises from 40 percent to 65 percent, and so on. Provisions for 90-day first-year reporting also remain.  
CMS also proposed modifications to existing Stage 1 criteria, including changes to the age limitations for vital signs, and requiring the electronic exchange of summary-of-care documents. Another proposed change to Stage 1 objectives includes the use of computerized physician order entry (CPOE) systems for medications. Stage 1 currently requires providers to track the number of patients receiving at least one medication order by CPOE. Proposed changes to Stage 1 will only affect any hospital or eligible provider that is first attesting in 2013 or later.
Quality Measures
According to CMS, another important change in Stage 2 is quality measures: they are now a distinct category of Meaningful Use. In 2014, all those attesting to any stage of Meaningful Use will need to electronically report on quality measures (some may be required, others selected from a long list of potential measures). Hospitals will select 24 measures from the 50 being proposed. Eligible providers will be required to submit 12 quality measures.
Menu set requirements include:  
  • Radiological images and information accessible through certified EMR technology
  • Cancer cases identified and reported to a state cancer registry
  • Record patient family health history as structured data
  • Generate and transmit permissible discharge medications electronically
  • Ability to identify and report specific case information to a specialized registry
The requirement to conduct a security risk assessment remains as a core requirement. Stage 2 calls for special attention to addressing the encryption of stored data.  
Stage 2 Target Timeframe  
The target timeframe for achieving Stage 2 is 2014. Hospitals will receive full stimulus payments if they can successfully attest to Stage 1 before Sept. 30, 2013. Penalties in the form of reduced Medicare payments have been extended to July 1, 2014, for acute care hospitals; Sept. 30, 2015, for CAHs; and Oct. 1, 2014, for eligible providers for successfully attesting. The filing deadline for each of these is two months after completion of the attestation period.

CareTech will be providing an additional detailed summary of the Stage 2 implications in the near future. We encourage feedback from our clients that we can aggregate and send to CMS prior to the end of the comment period.

The final rule can be found at http://www.ofr.gov/OFRUpload/OFRData/2012-04443_PI.pdf.  Please send comments to Jim Deren at jim.deren@caretech.com  or Paula Gwyn at paula.gwyn@caretech.com
 

MU: Don’t Forget about Radiology 07/25/2012

 July 2012 
Meaningful Use – Don’t Forget about Radiology
When developing an IT strategy to achieve Stage 1 of Meaningful Use, hospitals are urged to consider the implications for Radiologists. According to industry reports, most organizations are unaware of, and have not prepared to address the HIT requirements that will affect them related to providing outpatient radiology services.
Even if your organization does not employ eligible providers in ambulatory settings, Radiologists who provide more than 10% of their services (which includes invasive procedures and diagnostic services) are subject to the Stage 1 Meaningful Use requirements for eligible providers. The basis for determining outpatient volume is the sending of claims for a service using place of service code 22. This would apply to almost every hospital that has a Radiology Department.
Compliance: Incentives and Penalties
Radiologists who comply can receive $63,000 if they qualify and select the Medicaid option and $44,000 per provider for Medicare. In order to receive the maximum stimulus money, they must attest as Eligible Providers – no later than December 31, 2012.
Radiologists will also be subject to Medicare penalties if they do not comply with the MU requirements by Jan 1, 2015. This means they will need an EMR that is certified as an AMBULATORY product. They need to have it in place and start measuring by October 1 of this year in order to receive full stimulus incentives. Medicaid-eligible providers can extend the time to meet these requirements by one year if they select the Acquire, Implement, Upgrade option.
Utilizing EMR to Achieve Requirements  
“Hospitals need to evaluate and consider how the radiology services they provide will affect their Meaningful Use compliance.”
Jim Deren
Strategic IT Planning CareTech Solutions
It may be possible to utilize part of your inpatient EMR to achieve five of the requirements per the CMS hybrid provision – meaning the product addresses both inpatient and outpatient requirements. These requirements include Medication CPOE, one clinical decision support rule, recording demographics, providing an electronic copy of health information to a patient, and exchange of clinical information with other providers. EPs that choose to leverage the new hybrid flexibility still need technology certified for all non-hybrid Ambulatory criteria.
Please note that a number of requirements can be claimed as exclusions for Radiologists as they they may not apply to providing diagnostic radiology services such as;  
  • Providing clinical summaries if there is no office visit
  • Entering medication orders – if the radiologist writes less than 100 Rx orders
  • Capturing immunization data
  • E-prescribing
  • Capturing structured lab data if no lab orders are placed by the Radiologist
  • Performing med reconciliation if the Radiologist was not a recipient of a care transition
  • Providing a summary care record for transitions of care if none occurred
  • Providing patients with an electronic copy of their health information
  • Submitting electronic syndromic surveillance data
Impact on Workflow  
The impact on workflow may be significant because you may need both an inpatient product for the hospital and outpatient product or RIS attached to your EMR for the Radiologists.
Although organizations that do not employ Radiologists are not responsible to address these requirements, it is likely that your Radiology group will desire assistance in order for them to gain compliance. If you have not accommodated this requirement into your IT planning, we encourage you to check with Radiology and EMR vendor to see what capabilities currently exist.  

Additional information may be found at www.radiologyMU.org

 

MU: Overview of the Stage 2 Final Rule 10/09/2012

 October 2012 
Overview of the Stage 2 Final Rule
On Aug. 23, 2012, the Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator (ONC) released the next round of rulemaking in the journey to Meaningful Use (MU). The official posting of these final rules appeared in the Federal Register on Sept. 4, 2012. The next phase of core and menu set measures are, on the whole, more aggressive than those of Stage 1.
Stage 2: Continuous Quality Improvement
With Stage 1 focused on the adoption and implementation of Certified EHR Technology and the capture of critical, structured data elements, CMS intends for Stage 2 to advance clinical processes for continuous quality improvement, and to pave the way for Stage 3 to advance quality outcomes.
Increase in Total Objectives, Changes in Stage 1 Measures  
The overall number of total objectives increased to 19 for Hospitals and 20 for Eligible Providers (EPs). Both hospitals and providers will need to select three of six menu items within these requirements. CMS has eliminated some Stage 1 measures, modified others, and added entirely new measures to achieve its goals. Core Quality Measures are no longer a Meaningful Use core requirement – but must be achieved to attest to Meaningful Use. All menu set requirements have been moved to core for Stage 2.
Key Changes within Stage 2  
Key changes within the Stage 2, the final rule, include:  
“The good news is that achievement and continuation of the Stage 1 requirements will automatically address several of the Stage 2 requirements for hospitals and providers. Any hospital or provider that has achieved Stage 1 will be about 60% done with Stage 2 requirements.”

Jim Deren
Strategic IT Planning
Specialist
CareTech Solutions

  • Stage 2 timing and program staging
  • – Early adopters (2012 and prior) will only need to measure 90 days for year one of Stage 2 in 2014
  • Certified EHR Technology updates – Attesters will need to purchase the base certified technology but only additional functionality that is relevant to their environment. A list of certified technology can be found at “http://onc-chpl.force.com/ehrcert
  • Core and menu set requirements – include new thresholds, increased functionality, new requirements, and the merging of some requirements
  • Clinical quality measures – have changed and the number of measures increased. Electronic transmission is required starting in 2014
  • Medicare payment adjustments – penalties will begin for those that have not attested by 2015 or those who do not continue to attest once achieved
  • Changes to the Medicaid EHR Incentive Program – expand the method for counting Medicaid patients
  • Appeals and audit process has been expanded to include new situations
  • The earliest that Stage 2 criteria will be effective is in federal fiscal year 2014 (Oct. 1, 2013) for eligible hospitals and calendar year 2014 (Jan. 2, 2014) for eligible providers
Certified Software Changes
In parallel to the CMS final rule defining Meaningful Use for 2014 and beyond, ONC has issued a final rule on standards, implementation specifications, and certification criteria for EHR technology to support the next round of Meaningful Use. The rule, referred to as the “2014 Edition,” represents an entirely new definition for Certified EHR Technology. CMS has eliminated the requirement regarding the need to “possess” EHR modules that are not going to be used to achieve Meaningful Use until a future stage.  
CareTech Solutions has compiled a more detailed summary of the Stage 2 specifications which can be provided upon request.  
Additional helpful public information links are:
The next newsletter will include a detailed look at Stage 2 requirements and specifications.


For an archive of our newsletters, please visit the
Resources page on CareTech.com.