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.
