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You can send comments and impact final rules for Stage 2 meaningful use of EHRs
e-Reports, March 19, 2012
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Comment period on proposed rules remains open to all for 60-day window Untitled document

If you thought Stage 1 rules for achieving meaningful use of electronic health records (EHRs) were too tough or had too many objectives, you can help craft rules for Stage 2. For 60 days following publication of proposed Stage 2 rules in the March 7 Federal Register, your feedback is welcomed by the Centers for Medicare & Medicaid Services (CMS).

Here’s how to comment
In commenting, please refer to file code CMS-0044-P.

No comments by facsimile (FAX) transmission.

Submit comments:

1. Electronically.

Go to regulations.gov and follow “submit a comment” instructions.

2. By regular mail to:

Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-0044-P
P.O. Box 8013
Baltimore, MD 21244-8013

The medical community did help shape Stage 1 rules. CMS was inundated with comments for those, and officials now will be noting how much “pushback” they receive for Stage 2.

“Stage 1 rules changed significantly as a result of comments,” said Allison Bryan, field operations manager with the Purdue Regional Extension Center (REC). “The Office of the National Coordinator reads the comments and makes changes based on the feedback.”

Not interested in reading 455 pages of rules? Try digesting summary tables on pages 156 to 163 in the proposed document at this site. Also, see a Fact Sheet here.

Early reaction, points to note
The AMA immediately responded that it would carefully review the proposed rules for Stage 2 to prepare formal comments.

Purdue Regional Extension Center (REC) officials noted the more stringent objectives to evaluate include:

  • Enhanced interoperability – Requires transmission of lab and imaging results as structured data between different entities and successful exchange of data with a health information exchange (i.e., the Indiana Health Information Exchange, Michiana Health Information Network, HealthLINC, etc.) See related story on page 4.
  • Increased patient engagement – Requires that a percentage of patients access data through electronic means. You must provide data electronically and validate that a cohort of your patients has directly accessed that data.
  • Enhanced privacy and security criteria – Expanding upon already rigid standards, the proposed rule will require groups to protect (i.e., encrypt) the data while it is “at rest.”

“These potential objectives within the Stage 2 proposed rule may be quite challenging for independent practices,” said Purdue REC Director Randy Hountz. He encourages you to comment before the May 7 deadline.

Specific thoughts from Tristate REC
David Groves with the Tristate REC noted that first-time eligible providers (EPs) will always attest to Stage 1 first and then Stage 2, even if the first attestation is in 2014 or later.

“Eligible providers will need to meet 17 core Stage 2 objectives and three of five menu objectives,” Groves explained. “Exclusions will no longer count toward meeting those menu objectives.”

Percentages that EPs must meet for Stage 2 meaningful use are increased for many measures over requirements for Stage 1. “For example, the meaningful use threshold for CPOE (computerized physician order entry) as proposed will go from 30 percent of medication orders in Stage 1 to 60 percent of all orders in Stage 2,” noted Groves.

Starting in 2014, EPs must submit clinical quality measures (CQM) to CMS using EHRs and methods recognized in the rules. The CQM proposed are aligned more closely with quality reporting requirements for other programs, such as PQRS and NCQA. And CQM reporting will increase from six measures in Stage 1 to 12 in Stage 2. The list of potential CQMs from which you can select increases to 125 measures, to accommodate specialty practices.

Groves noted Stage 1 requirements for “Electronic Exchange of Summary of Care Document” will be significantly more demanding in Stage 2, focused on transitions of care. You must demonstrate that at least 65 percent of care transitions are accompanied by an electronic summary of care; at least 10 percent of those transitions can have no organizational affiliation with you. The other provider must be on a different EHR system.

“Achieving this goal will require connectivity solutions that enable cross-organizational communications with EHR technology,” said Groves.

If you’d like to submit a less formal or anonymous comment to proposed Stage 2 rules, post to Tristate REC’s website. REC staff will consolidate and forward to CMS.

A final rule is anticipated mid-summer with regulations taking effect Jan. 1, 2014.

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