On August 23, 2012, CMS issued the final rule on Meaningful Use Stage 2 criteria. This rule covers the Sage 2 criteria for Eligible Professionals (EPs), Eligible Hospitals (EHs) and Critical Access Hospitals (CAHs) for purposes of Medicare or Medicaid incentive payments for meaningful use of certified EHR technology. The rule will be effective in the next couple of weeks, depending on its actual publication in the Federal Register.
The Meaningful Use Stage 2 Rule covers a lot of territory
From new and revised Core and Menu Objectives and Measures for EPs, EHs and CAHs, to revised compliance timelines to revisions to penalties for healthcare organizations not adopting certified EHR technology over time, the new Meaningful Use Stage 2 Rule is expansive. As a matter of fact, if you’d like to peruse the yet to be published version of the full, 672 page document, here it is …
However, to help you along, we’d like to start our review with the changes to the Meaningful Use Core and Menu Objectives that EPs will have to address as they certify meaningful use in 2014.
The Final Rule gives providers more time to meet the Meaningful Use Stage 2 criteria.
- Providers who attested to Stage 1 Meaningful Use in 2011 or 2012 would not have to meet Stage 2 criteria until 2014.
- Providers who attest to Stage 1 Meaningful Use in 2013 or later, would not have to meet Stage 2 requirements until the second year after meeting Stage 1 criteria.
Most of the Meaningful Use Stage 1 Core and Menu Objectives remain unchanged from the original versions.
Two of those Objectives that were changed include:
- Core Measure 14: “Capability to exchange key clinical information (e.g., problem list)” among providers has been eliminated for CY 2013. Instead this measure is replaced with a measure covering “transitions of care”.
- Menu Objective 5: “Provide patients with timely electronic access to their health information” has been eliminated for CY 2014. Instead, this measure is replaced with a measure requiring allowing patients to view online, download and transmit electronic copies of health information.
Providers and vendors alike must grapple with Meaningful Use Stage 2
The issuance of this final rule has implications both for providers attempting to meet the MU criteria, and for vendors providing certified EHR technology. For instance, providers attesting to meaningful use under Stage 1 in 2013 must make sure their vendor has upgraded its capabilities to provide transition of care summaries while retaining the capability to provide patients with timely electronic access to their health information. We won’t know for some time yet if a vendor’s capabilities for online access meet the test of providing patients with timely electronic access.
The Meaningful Use Stage 2 criteria now include:
- For EPs, 17 Core Objectives and three of six Menu Objectives, for a total of 20; and
- For EH/CAHs, 16 Core Objectives and three of six Menu Objectives, for a total of 19.
As we expected, several Stage 1 Menu Objectives have moved to the Core list, and several new objectives have been added to the Menu list. And the performance thresholds have increased for a many objectives, which makes the capability to measure performance all the more important.
More Meaningful Use Stage 2 info to come …
In future posts, we will compare the EP Meaningful Use Stage 2 Objectives and Measures to the Stage 1 Objectives and Measures in some detail, so planning can begin. In the meantime, here is what’s becoming known as the Meaningful Use Matrix Stage 2, an organized and updated matrix listing the Meaningful Use Stage 2 Objectives and Measures. The goal posts have definitely moved, but the changes are very much related to the original goals: increasing the efficiency and effectiveness of our healthcare system.
And keep in mind that one objective has not changed: the requirement to conduct a HIPAA Security Rule Risk Assessment. This type of assessment is not something a software vendor can complete for you, nor can an ehr vendor supply you with the policies and procedures required under the Security Rule. But performing such an assessment is required before you attest to meaningful use of your EHR technology. The audits by CMS of meaningful use attestation are starting, so don’t forget about this requirement. Your entire incentive payment depends on it!