Thursday, August 23, 2012

Rules for Stage 2 Meaningful Use

The U.S. Department of Health and Human Services has announced the release of the final rule for Stage 2 of meaningful use and ONC has updated the standards and certification criteria. When these rules were proposed they received over 6000 comments.

Through the Stage 2 requirements of the Medicare and Medicaid EHR Incentive Programs, the Centers for Medicare & Medicaid Services (CMS) hopes to expand the meaningful use of certified EHR technology. Certified EHR technology used in a meaningful way is one piece of a broader health IT infrastructure needed to reform the health care system and improve health care quality, efficiency, and patient safety. “The changes we’re announcing today will lead to more coordination of patient care, reduced medical errors, elimination of duplicate screenings and tests and greater patient engagement in their own care,” Secretary Sebelius said.

The Office of the National Coordinator for Health Information Technology (ONC) rule proposes the capabilities and related standards and implementation specifications that Certified EHR Technology will need to include to, at a minimum, support the achievement of "meaningful use" by eligible health care providers beginning with the EHR reporting periods in FY/CY 2014. The rule also provides revisions to the permanent certification program for health information technology, which include changing the name of the program to the "ONC HIT Certification Program."

In this rule, CMS will maintain the same core and menu structure for the program for Stage 2. For Stage 2 EPs must meet or qualify for an exclusion to 17 core objectives and 3 of 5 menu objectives. Eligible hospitals and CAHs must meet or qualify for an exclusion to 16 core objectives and 2 of 4 menu objectives.

There are at least three focus areas in the requirements for stage 2 meaningful use:
  • Standard data formats that allow health data to be captured and shared
  • Patients must have the ability to download, view and transmit their health information
  • Quality reporting is expanded
The Stage 2 Meaningful Use requirements will:
  • Make clear that stage two of the program will begin as early as 2014. No providers will be required to follow the Stage 2 requirements outlined today before 2014.
  • Outline the certification criteria for the certification of EHR technology, so eligible professionals and hospitals may be assured that the systems they use will work, help them meaningfully use health information technology, and qualify for incentive payments.
  • Modify the certification program to cut red tape and make the certification process more efficient.
  • Allow current “2011 Edition Certified EHR Technology” to be used until 2014.
The CMS final rule also provides a flexible reporting period for 2014 to give providers sufficient time to adopt or upgrade to the latest EHR technology certified for 2014. In the Stage 1 meaningful use regulations, CMS established an original timeline that would have required Medicare providers who first demonstrated meaningful use in 2011 to meet the Stage 2 criteria in 2013. The Stage 2 rule delays the onset of Stage 2 criteria. Any provider that attests to Stage 1 of meaningful use in 2011 or 2012 will attest to Stage 2 in 2014 instead of 2013. Therefore providers will not be required to demonstrate Stage 2 of meaningful use before 2014. A fact sheet on CMS’s final rule is available at http://www.cms.gov/apps/media/fact_sheets.asp.

Changes in the rule from Stage 1 Meaningful Use include:

  • Substituting “transitions of care” for “exchange of key clinical information” as a core objective, and providing patients electric and online access to their health records instead of providing electronic copies of the information.
  • Adding two new core objectives: using secure electronic messaging to communicate with patients, and automatically tracking medications from order to administration using assistive technologies in conjunction with an electronic medication administration record (eMAR.)
  • Allowing a batch reporting process for attesting to meaningful use, allowing information to be submitted in one file.
  • Reducing the patient engagement thresholds from 10 percent to 5 percent.
  • Reducing the threshold for sending summary-of-care records for care transitions and referrals from 65 percent to 50 percent, and requiring at least one exchange with a provider using EHR technology from a different vendor.

The ONC rule describes standards and certification criteria changes, including:

  • Adopting certification criteria for transitions of care ensuring EHR technology supports standards-based electronic health information exchange.
  • Requiring that test reports for EHR certification be publicly available, with developers following specific price transparency practices.
  • Allowing “gap certification” for certain criteria, which ONC says will make the process more efficient.

I will be publishing a deeper analysis after reviewing the new regulations.

UPDATE

After reading Steven Posnack's tweet below I uploaded the slides and embedded them: