CMS proposes Stage 2 EHR meaningful use criteria

April 1, 2012

The U.S. Centers for Medicare & Medicaid Services (CMS) would target interconnectivity among health care practitioners using electronic health records (EHRs) under Stage 2 Medicare EHR Incentive Program goals and objectives proposed by the agency last month.

The proposed Stage 2 objectives would be essentially the same as the Stage 1 objectives implemented last year, with two notable changes, according to a CMS fact sheet.

“(The) CMS proposes to maintain the same core and menu structure for the (EHR Incentive) program for Stage 2. We propose for Stage 2 that EPs (eligible providers) must meet or qualify for an exclusion to 17 core objectives and 3 of 5 menu objectives,” the fact sheet states.

Nearly all of the CMS’ Stage 1 core and menu EHR utilization objectives have been retained in the proposed Stage 2 objectives, the agency notes.

The CMS will change the “exchange of key clinical information” core objective established for Stage 1 to a “transitions of care” core objective – which the CMS considers “more robust” – in Stage 2, according to the fact sheet.

The agency will eliminate the Stage 1 “provide patients with an electronic copy of their health information” objective and replace it with an “electronic/online access” core objective in Stage 2, according to the agency.

“There are also multiple Stage 1 objectives that have been combined into more unified Stage 2 objectives, with a subsequent rise in the measure threshold that providers must achieve for each objective that has been retained from Stage 1. This eliminates an unnecessary accounting and reporting burden for providers by recognizing that, for providers who have been Stage 1 meaningful users for multiple years, recording these data in structured form has become a normal part of care delivery,” the CMS fact sheet explained.

To qualify for incentive payments under the Medicare EHR Incentive Program, health care practitioners must implement EHR systems certified for use under the program and then meet utilization goals and objectives known as the “meaningful use” standards.

Practitioners can earn incentives for up five years over the six-year (2011-2015) life of the program. Practitioners can earn a first round of incentives by meeting the program’s Stage 1 initial objectives during their first year of participation in the program and can then receive additional payments by meeting more advanced Stage 2 and Stage 3 objectives during subsequent years.

The Stage 2 objectives proposed last month are consistent with plans previously announced by the CMS to emphasize installation of EHR systems under Stage 1 of the program, interconnectivity among health care practitioners under Stage 2, and the use of EHRs to enhance patient care under Stage 3.

“Because the Stage 2 objectives will essentially be based on the Stage 1 objectives, it is important for practitioners who have met Stage 1 standards to maintain ongoing compliance,” said Philip Gross, O.D., chair of the AOA Health Information Technology (HIT) Subcommittee. “That effectively gives practitioners a head start in maintaining the year-long compliance that is necessary to qualify for incentives under Stage 2 of the program.”

The Stage 2 meaningful use standards, officially proposed by the CMS in the Federal Register, are subject to a 60-day comment period. 

The agency could issue a finalized version of Stage 2 rules as quickly as 90 days thereafter, according to the AOA Advocacy Group.

The AOA Advocacy Group holds any use of EHRs that improves patient care could be considered “meaningful” and has been encouraging the CMS to ease specific utilization criteria as a means of reducing administrative burdens on practitioners and thereby encouraging EHR use.

“The AOA encourages members to implement EHRs, but not everyone can be an advanced user right away,” an AOA Advocacy Group staff person noted.

The finalized Stage 2 EHR standards will be the subject of a detailed analysis in a future edition of AOA News

The Stage 2 standards will also be covered in the AOA’s “Navigating Meaningful Use, Quality Reporting, and e-Prescribing with Electronic Health Records (EHR)” continuing education courses, according the AOA HIT Subcommittee.

AOA members can find a direct link to the proposed Stage 2 standards as well as other information on the Medicare EHR Incentive Program on the AOA website EHR page (www.aoa.org/EHR).

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