The requirements to achieve incentives for Stage 2 of meaningful use were released by the Centers for Medicare & Medicaid Services (CMS) on February 23, 2012. Almost every measure contains some changes with some major changes.
The Stage 2 proposed rules for meaningful use have many changes – some are subtle.
In addition to the new requirements to be a meaningful user of EHRs, there is one important clarification to the requirements for avoiding penalties. To avoid penalties starting in 2015 for not being a meaningful user, hospitals and eligible providers (EPs) need to be either attest to meaningful use in 2013, or have achieved and attested to the first year of meaningful use by October 1, 2014 for EPs.
The requirement as to when different Stages of meaningful use need to be met was officially relaxed. Those that attest to meaningful use first in 2011 must meet Stage 2 criteria in 2014 and Stage 3 in 2016. All others will be required to demonstrate 2 years at Stage 1, 2 years at Stage 2 and then 2 years at Stage 3 (assuming the cut-off date for the program’s payments have not passed).
Quality measures are still not final, but in 2014 they will be submitted electronically. Quality measures are now a distinct category of meaningful use and the schedule is not tied to a particular Stage. In 2014, all those attesting to any Stage of meaningful use will need to electronically report the 2014 quality measures. The proposal is that EPs will submit 12 measures. At least one measure will need to be reported from each quality domain: patient safety, care coordination, population and public health, efficient use of resources and clinical effectiveness. The final list of quality measures will be published with the final rule due to be released mid-2012. This delay affects both users and vendors, vendors are likely to require significant development effort to be able to capture and report on the expanded list of quality measures.
There are many changes in requirements. The proposed rule generally makes Stage 1 optional (menu) items required (core) in Stage 2. Many of the thresholds from Stage 1 have been raised – some to a higher level than those recommended earlier by the policy committee.
The Computerized Physician Order Entry (CPOE) measurement was changed from being based on one order per patient to a percentage of all orders – which will raise the bar considerably. The only major recommendation from the policy committee that was not included in the Notice of Proposed Rule Making (NPRM) was for an electronic physician note for 30% of office visits and 30% of hospital days. However, physician notes are a major source of data that will be required for electronic reporting of quality requirements.
To ensure that systems certified for Stage 2 can also meet Stage 1 requirements, a few Stage 1 requirements will be modified somewhat for 2014 onward. All the changes in requirements will have a major impact on vendors, since the entire installed base will need systems that meet these requirements. It is likely that vendors will only have the more recent versions of their products certified for Stage 2 – increasing the number of customers that will need a major upgrade.
The attached tables provide a summary of all the changes in requirements proposed for Stage 2. Hospitals will have 16 core (required) measures and must select two of four menu (optional) objectives. EPs will have 17 core objectives and be required to select three of five menu objectives.
Table 1 – Summary of Requirements for Stage 1 and Proposed Changes for Stage 2
Table 2 – Continued – Summary of Requirements for Stage 1 and Proposed Changes for Stage 2
The final rule on Stage 2 is not anticipated from CMS until mid-2012.