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
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.
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.