Stage 1 Changes Enacted by Stage 2 Final Rule

Reid Haase, REACH HIT Consultant

During the lead up to CMS publishing its Stage 2 final rule for the EHR Incentive Program, the policy makers at ONC reflected on public input and their own internal consideration to streamline aspects of Stage 1 for eligible professionals (EPs), eligible hospitals (EHs) and critical access hospitals (CAHs). What resulted from this were sensible changes, some of which are mandatory for all Stage 1 participants and others that are optional. You’ll need to pay close attention to when each of the changes will be enacted as some started as early as October 1, 2012 for EHs and CAHs, whereas others will be optional in calendar/fiscal year 2013 and then become mandatory for calendar/fiscal year 2014.

Gone is the need to conduct a separate and unique test of HIE (replaced in Stage 2 through other objectives that accomplish exchange of patient information) and the ‘yes/no’ attestation question on submission of clinical quality measures was eliminated. You’ll also see that the clarifying wording of some objectives was changed to deal with claiming exclusions, such as in the menu set to ensure that participants were making the best attempt at accomplishing five of the 10 measures rather than claiming an easy exclusion such as for syndromic surveillance which many states are not prepared for.

Conversely, a new exclusion was provided for e-prescribing. Some providers are not able to send an electronic script as a pharmacy accepting the electronic prescription is not within a sensible distance (chosen as 10 miles in the new wording). Feedback was also incorporated for the charting of vital signs including blood pressure, height, weight and specified age ranges. Providers will be able to claim exclusions for those parts of the objective that do not make sense to their practice or patient population including age ranges.

The objective to provide electronic access or an electronic copy of a patient’s record has also been modified based on the Stage 2 requirements, specifically those surrounding the use of patient portals.

We’d recommend that you take a few minutes to review the changes in detail. They are outlined in a succinct, six page PDF document that you can download via the link below.

Stage 1 Changes Tipsheet > 

Stage 2 Overview Tipsheet >

Getting Ready for Stage 2 Meaningful Use – What Providers Can Do Now

Paul Kleeberg, MD, REACH Clinical Director for Minnesota and North Dakota

I am sure by now that many of you are aware that ONC and CMS have released new rules for the electronic health record (EHR) incentive program. These rules create new requirements in 2014 for those who will be attesting to Stage 1 as well as those who will be attesting to Stage 2 of meaningful use in 2014. For Stage 2, in addition to increasing some of the Stage 1 requirements, there is an increased emphasis on exchange of information and patient involvement.

Under Stage 2, patients will be allowed greater access to their EHR and will need to be more involved in their care. They will see their problems, medications, allergies, lab results and other items as they have been recorded in the EHR. For some providers, Stage 2 will mean that they will need to make sure their notes are complete; others may need to decide what information may need to be withheld. All providers will need to encourage patients to become more involved since there are measures of patient involvement. It would be wise to begin preparing your patients now. If you don’t have a portal, start getting one. If you do have a portal, make sure it is working and start encouraging patients to use it.

Stage 2 increases the focus on exchange of referral summaries and transfer of care summaries between providers. If you're in a clinic you will need to send a certain percentage of these documents electronically to another facility. Get ready now by thinking about who you're going to exchange with and begin to consider technology options. Note that the requirement is to exchange with facilities that run a different EHR from yours and are part of a different organization.

Finally, you may have heard that there is a new standard for EHR certification. Under the new rules, you will need to upgrade to 2014 certified software and use it meaningfully for at least one quarter during the 2014 payment year. We hear that vendors will be able to start the certification process for their products in January of 2013. If you have not done so already, contact your vendor to discuss upgrade plans and timeline so you know what to expect.

These changes may appear challenging but they will move us in the direction of making the EHR patient-centered so information will be available to each patient wherever and whenever they need it.