On February 23, CMS released proposed rules for Stage 2 of Meaningful Use (MU) that will determine if Eligible Providers qualify or continue to qualify the Medicare/Medicaid EHR Incentive payments after December 31, 2013. Note that eligible providers who qualify for the EHR incentives in 2012 can receive up to $44,000 and up to $39,000 if they qualify in 2013 under the Stage 1 Measures. However, the potential EHR incentive drops to $24,000 for practices qualifying in 2014 using the Stage 2 Measures. Either way, practices have to meet the Stage 2 requirements in 2014 to continue to receive EHR incentive payments.
If you have not yet qualified, but plan to meet the MU standards, you need to consider the proposed Stage 2 items in your EHR selection and/or MU strategy. If you have already qualified, Stage 2 includes enough changes and additions that require monitoring your EHR vendor and a plan to meet the proposed requirements in time.
The proposed Stage 2 rules include adjustments and clarifications to the Stage 1 measures. In addition to higher thresholds and tighter timeframes, the proposed Stage 2 standards include significant changes to the Stage 1 requirements that will affect your MU strategy and how you use your EHR.
Importance of Patient Portals
Under the original Stage 1 Meaningful Use measures, patient portals were an option to deliver the clinical summary, but not a necessity to meet the Stage 1 Requirements.
Stage 2 requires the ability for a patient to view health information online within 4 days of information being available to the physician and secure messaging with a patient. Both MU measures require the use of a patient portal. Under the Stage 1 efforts, Practices should seriously consider using a patient portal to deliver Stage 1 clinical summaries and establish a patient portal presence to allow patients to access information and communicate with your practice.
To Do: Pay more attention to the capabilities of your EHR vendor and their patient portal strategy and verify their ability to offer patient portal tools for MU.
To Do: Carefully plan your patient portal roll out strategy in order to attract patients that will be needed to meet the Stage 2 Measures. In some cases, patients have to be educated and encouraged to use the portal.
Electronic Summary of Care
One Stage 1 Menu Measure requires sending a paper or electronic summary of care record to another provider for patients transitioning to another provider or setting. Stage 2 promotes this measure to a Core (Required) measure.
To Do: Practices should include the Summary of Care Menu Measure in your Stage 1 plan. Thereby, you will have fewer challenges to deal with maintaining the Meaningful Use requirements when Stage 2 takes effect in 2014.
To Do: Specialty practices should carefully consider the implications of the electronic summary of care on incoming referrals. For example, an electronic relationship with the practice’s referral sources may be a business necessity since practices need to use electronic summary of care record for 10% of referrals and transitions of care. Once referring practices are using electronic referrals, they will discover electronic referrals are cheaper and easier that paper referrals or phone calls.
To Do: All practices should monitor the outgoing referral provider destinations to select appropriate specialists and practices to meet the summary of care transmission measure. The new core measure requires summary of care for 65% of referrals/transitions and 10% of patient referrals should be electronic.
Expansion of Computerized Provider Order Entry (CPOE)
CPOE under Stage 1 MU was only about prescriptions. Under Stage 2, CPOE now includes lab and radiology orders as well as prescriptions. Additionally, Stage 2 requires use of CPOE for 60% of these orders rather than the 30% of prescriptions under Stage 1.
To Do: Closely check on the order entry and management tools of the EHR. Prescriptions are typically managed under a specific set of EHR features. Most EHRs have a completely different feature to deal with other orders. The ease of use of the order feature and the ability to track the order process is less than effective in many EHRs.
Lab Tests Promoted to Stage 2 Core Measure
Under Stage 1 of MU, lab test results were a menu item. Stage 2 of MU promotes lab results to a Core Measure.
To Do: Include the lab results MU Menu Measure as part of your Stage 1 Measures. Thereby, you will only have to increase use to 55% of clinical lab tests to meet the Stage 2 Measure.
New Stage 2 Menu Measure
Stage 2 includes a new menu measure that scans or test images ordered for a patient are accessible through the EHR. Note that this requirement will require a new look at how the EHR manages the order as well as the image viewing and annotation tools of your EHR. For example, some EHR systems assume that incoming images are reviewed by the physician before the image is scanned into t he EHR.
To Do: Review the “out of the box” image tools of your EHR system.
To Do: When replacing test and imaging equipment, acquire test and imaging equipment that will be able to deliver images to your EHR effectively and efficiently.
To Do: Discuss image acquisition opportunities with providers and hospitals that may be performing tests on your patients.
The Stage 2 MU Core and Menu Measures are proposed and subject to a 60 day comment period. However, due to the effort needed to deploy changes and attain the appropriate MU measures, it is not unreasonable to expect that the Stage 2 requirements will further challenge EHR vendors and their practice customers. Raising awareness now and considering the Stage 2 Measures in your EHR strategy is prudent and will save you time and money in your effort to qualify for and continue to meet the EHR Incentive requirements.
Ron Sterling (800-967-3028, www.sterling-solutions.com) publishes the popular EHR Blog Avoid-EHR-Disasters.blogspot.com, and authored the HIMSS Book of the Year Award winning guide “Keys to EMR/EHR Success.” He is an independent EHR consultant. Hear Ron speak in an archived webinar sponsored by Kareo: What You Need to Know About Selecting the Right EHR. Ron most recently wrote for Getting Paid on 5 Patient Service Benefits from an EHR.