Meaningful Use Stage 2 – Yes, it is here, for better or worse

Meaningful Use Stage 2 (also known as 2014 Edition Standards & Certification Criteria (S&CC)Final Rule) is in the bag so to speak.  The next stage has been officially finalized and will be hitting your computer (and your EHR programs) over the next couple of years.  First off the new name (2014 edition) clues you into the first change- Stage 2 is going into effect one year later than previously decided per the original ARRA documentation.



According to the ONCHIT (Office of the National Coordinator for Health Information Technology) Stage 2 for Meaningful Use reflects their commitment to improving public heath reporting, security, clinical quality measurements and measures, interoperability between various electronic health exchange parties, patient engagement in their own health, patient safety, and of course reduce regulatory burden for you.  Oh yeah – and adding ease and efficiency to the certification process.  Whew, that’s a mouth full!  It’s also supposed to help and improve the testing methods, processes, and access to the testing results (for you) for the certified and certifying EHR products.

So, is there a quick way to explain things? Probably not, but then you probably don’t remember all that’s entailed in Stage 1 either.  I will try to hit some of the highlights that might be important to you over the next 2 years (which is when Stage 3 is due for delivery). 

Here is the quickie 3-page summary of Stage 2.

For EHR meaningful use reporting, prior to 2014, providers will be meet the CEHRT (Certified EHR Technology) definition by using an EHR certified to the 2011 (Stage1) criteria, or by using an EHR certified to the 2014 (Stage 2) criteria, or by using a mix and match (some of your EHR parts/programs might be certified to 2011 & some to the 2014 standards).  Any 2014 standard certified EHRs are supposed to be able to handle both the 2011 and the 2014 standards.  You will notice that these Stage 1 & 2 standard affect how you have to report in your office, as well as what software you need to be using.  The ONCHIT gives a breakdown of what “level” of software you need to be using, based on when you implement an EHR and begin using it for meaningful use. The Stage 2 (2014) requirements allow for Stage 1 (2011) certified EHR technology to be used through 2013.

Per CMS/ONCHIT, for 2014 only, the reporting period for (that year only) will be reduced to three months for everyone to allow providers the time to adopt 2014 certified EHR technology and prepare for Stage 2.  Again, all participants will have a three-month reporting period in 2014 whether 2014 is your first or your third year of reporting.

Other EHR software focus mandates in Stage 2 include:

• Enable providers to create a set of “patient summaries”, so if a provider switches EHR technology, they will be able to transfer the data, rather than manually re-enter their basic patient information into the new EHR system.
• Enable providers to access the test results used to certify the EHRs and provide a potential starting point for them to be able to assess any implementation issues associated with any potential certified Complete EHRs or Modules they might want to look at.  They will be made available on the ONC’s Certified HIT Products List (CHPL) along with all of the other information.

Some of the patient focused mandates in Stage 2 include:

• Increased requirements for health information stored on end-user devices.
• Requires EHR technology be able to support corrections and amendments to patient records.
• Enable secure messaging between a provider and a patient.
• Permit patients to securely view, download, and transmit their health information. (This replaces the Stage 1 requirement of being able to give a patient an electronic copy of their information.)

For providers, Stage 2 includes a beneficial change for those EPs that aren’t really eligible because a hospital gets the stimulus money instead of them – there is now a change that may affect some of you under that umbrella (per CMS):

 “Hospital-based EP Definition. CMS has modified the regulations on “hospital based” so that EPs who can demonstrate that they fund the acquisitions, implementation, and maintenance of CEHRT, including supporting hardware and interfaces needed for meaningful use without reimbursement from an eligible hospital or CAH —and use such CEHRT at a hospital, in lieu of using the hospital’s CEHRT—can be determined non-hospital based and receive an incentive payment. Determination will be made through an application process.”

Providers in a group will no longer have to attest individually, they will be able to attest as a group with multiple individuals attest all at the same time in the same file.

Most of Stage 1 persists (with some tweaks mentioned previously), but with minor tweaks on some items… You are required to do a higher percentage of most things (like send prescriptions electronically- from 30 to 60%) and some things require a lowered percentage (like secure messaging with patients – from 10 to 5%).

The focus has shifted slightly from what you are reporting to how it is being reported.  Interoperability between systems and parties is more of the premium focus with Stage 2, than patient information collection measures.

So, what are you waiting for?  You might as well start with Stage 1 now and reap some of the ARRA “stimulus” benefits while you can, before this all becomes a requirement.

Additional Information:

• Per the CMS website
• http://www.informationweek.com/healthcare/policy/meaningful-use-stage-2-rules-finalized/240006128
• http://healthaffairs.org/blog/2012/03/15/meaningful-use-of-health-it-stage-2-the-broader-meaning/

Looking for the first steps towards a new EHR? Download our quickie EHR Checklist (in case you missed it in this month's mail).