HHS Releases Final Rules for Meaningful Use Stage 2

By Christian Chai On August 23rd, the Department of Health and Human Services released the final rules for Stage 2 of its electronic health records meaningful use incentive program. Cowritten by the Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC), the new requirements will be published in the Federal Register on Sept. 4. iHT2 recently attended the NeHC webinar on Meaningful Use Stage 2. Here are some highlights and key changes found in the new provision (Berry, 2012): Deadline Extension. Beginning in 2014, participating providers who have met Stage 1 for two or three years must meet criteria for Stage 2. No providers will be required to attest to Stage 2 prior to 2014. This is an extension of the original 2013 deadline. For 2014 only, the reporting period for providers has been reduced to a 3-month quarter, providing an additional 9 months to upgrade to 2014 edition certified EHR technology. EHRs must meet 2014 ONC standards. Beginning in 2014, all participating providers must adopt certified EHR technology in accordance with the ONCs 2014 edition Standards & Certification Criteria Final Rule. Changes to core objectives. For EPs, the final rule contains 17 core objectives (1 new) and 3 of 6 menu options that must be met for a total of 20 measures. Hospitals must address 19 total measures, including 16 core (1 new) and 3 of 6 menu options. The total number of objectives remains the same as in Stage 1. However, there are two additional core objectives and two fewer menu options for both EPs and Hospitals. Patient Engagement. More than 5% of patients must send secure messages to their EP. Additionally, more than 5% of patients must access their health information online. Exclusions are available through CMS on the basis of broadband availability in the providers county. This 5% threshold was reduced from the 10% minimum initially proposed. Electronic Exchange. Stage 2 centers around actual usage of electronic information exchange. Providers must send a summary of care record for more than 50% of transitions of care and referrals. This was reduced from the initially proposed minimum of 65%. Electronic summary of care records must be used for more than 10% of transitions of care and referrals. At least one exchange must be with a recipient using a different EHR or a CMS test EHR. Batch reporting. Beginning in 2014, groups will be permitted to submit attestation information for all of their individual EPs in one file.

CQM Changes. In 2014 and beyond, EPs must report on 9 of 64 CQMs, while eligible hospitals and CAHs must complete 16 of 29 CQMs. Additionally, all providers must select CQMs from 3 of 6 health care policy domains from the HHS National Quality Strategy. CQM reporting. Reporting CQMs may no longer be one of the programs core objectives, but it is still required to demonstrate meaningful use. Starting in 2014, CQM reporting will be streamlined along with other CMS reporting programs to reduce multiple submissions and reduce provider burden. Furthermore, all Medicare-eligible providers beyond the first year of demonstrating meaningful use will be required to submit CQM data electronically to CMS. Medicaid providers will electronically submit CQM data to their respective state. Payment Adjustment. Medicare EPs and hospitals demonstrating meaningful use in 2013 will avoid a payment adjustment in 2015. Hospitals meeting requirements for the first time in 2014 must attest by July 1, 2014 to avoid the adjustment, while EPs have until October 1, 2014. Providers attesting in 2014 must thus begin their reporting periods at least 90 days in advance of this deadline. Providers must demonstrate meaningful use each year in order to receive payments. Eligibility Expansion. Changes were made to eligibility on several fronts. Certain providers can now be classified as non hospital-based EPs if they demonstrate that they are solely responsible for implementation and maintenance of CEHRT and do not receive reimbursement or any CEHRT from an eligible hospital or CAH. Determinations will be made through an application process. The definition of a Medicaid patient encounter was expanded to include anyone enrolled in a Medicaid program, including those with zero-pay claims. This eases the patient volume requirement of the incentive program, which is often cited as a barrier to participation. Approximately 12 childrens hospitals are now eligible for the Medicaid EHR incentive program. These hospitals were previously ineligible solely because they lack a CMS certification number since they do not bill Medicare.

The meaningful use initiative has exceeded initial government projections since the program began in January 2011. According to the Department of Health and Human Services, over 120,000 eligible professionals and more than 3,300 hospitals have qualified for participationapproximately 23,000 more than the government had hoped for by now. CMS has distributed over $6.6 billion in incentives (Manos & Mosquera, 2012).

First responses to the Stage 2 final rules were largely positive. The Medical Group Management Association, American Health Information Management Association, National Partnership for Women & Families, and Premier Healthcare Alliance all released statements endorsing the newly released requirements. Many of the associations cited improved quality reporting programs and the 2014 Stage 2 deadline extension as particularly strong measures (Goedert, 2012). The third and final stage of meaningful use is expected to begin in 2016 with an emphasis on improved outcomes.

Resources Berry, K. (2012). How to play by the (final) rules: an overview of meaningful use Stage 2 and the Standards and Certification criteria final rules [PowerPoint Slides]. Retrieved from http://www.nationalehealth.org/ckfinder/userfiles/files/Final%20Rules%20Power Point.pdf Goedert, J. (2012, August 23). Associations give first impressions of final meaningful use rules. Retrieved from http://www.healthdatamanagement.com/news/ehrelectronic-health-records-meaningful-use-448871.html?ET=healthdatamanagement:e2798:216331a:&st=email&utm_source=edito rial&utm_medium=email&utm_campaign=HDM_Daily_082412 Manos, D., & Mosquera, M. (2012, August 23). Final rules for Stage 2 meaningful use released. Retrieved from http://www.healthcareitnews.com/news/final-rulesstage-2-meaningful-use-released?topic=,08,29,19