If you followed the rules for Stage 1 meaningful use of electronic health records (EHRs) this year, last year – or plan to begin next year – to earn incentive dollars, get started now learning about Stage 2. The 672 pages released Aug. 23 will heighten worries about cost and about privacy/confidentiality, but you’ll like the increased flexibility Stage 2 rules offer with timelines.
The Centers for Medicare & Medicaid Services (CMS) has delayed the onset of Stage 2 criteria until 2014 for eligible professionals, including physicians. The other good news is the Medicare reporting period for 2014 will be 90 days. CMS took this step to better align with quality measurement programs like the Physician Quality Reporting System (PQRS) and to allow you time to upgrade your EHR system, if necessary.
But it’s not time to turn attention from Stage 1 just yet. Purdue Healthcare Advisors’ Regional Extension Center (REC) Director Randy Hountz noted the new rules made some modifications to Stage 1. “While it is not necessarily the intent of subsequent stages of EHR meaningful use to impact previous stages, occasionally clarifications need to be addressed,” he said. “If you have already attested to 90 days of MU, note that some of these modifications may impact your 365-day reporting of Stage 1 MU in 2013.”
From Stage 1 into Stage 2
Stage 1 was somewhat basic, requiring tasks like data capture and distribution of copies of EHR data to patients. Stage 2 is intended to produce more health information exchange including secure patient access to personal health data. In addition, a provision requires that 5 percent of “unique” patients you see must actually download or transmit their personal health information, action physicians cannot ultimately control.
The Stage 2 requirements CMS announced late last month:
- Make clear that Stage 2 will begin as early as 2014, but no providers will be required to follow the Stage 2 requirements before 2014.
- Outline certification criteria for EHR technology, so you may be assured the systems you use will work, help you meaningfully use health information technology and qualify for incentives.
- Modify the certification process to cut red tape and make the road to certification more efficient.
- Allow current “2011 Edition Certified EHR Technology” to be used until 2014.
“The Stage 2 meaningful use rules ratchet up the thresholds we saw in Stage 1,” said David Groves, executive director of the Tri-State REC. “Stage 2 also builds on connectivity and electronic exchange requirements significantly.”
With Stage 2, core and menu objectives and clinical quality measures are back. This time you must meet 17 core objectives and three of six menu objectives. In Stage 1, you had 15 core and five of 10 menu objectives.
Clinical quality measures (CQMs) for Stage 2, designed to align with PQRS and other quality programs, will require you to submit nine measures from a minimum of three National Quality Strategy domains – out of a potential list of 64 CQMs across six domains.
“The Stage 2 rules are complex and physician practices are encouraged to use resources available to them from CMS or reach out to their Regional Extension Center representatives for more information,” said Groves. See the box on left for information from the RECs, CMS and others.