(Last Updated On: February 22, 2017)

The Center for Medicare and Medicaid Services (CMS) announced on August 23, 2012 a final rule concerning Stage 2 of the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. The rule contains the specific criteria that eligible hospitals, critical access hospitals (CAH) and eligible professionals are mandated to attain in order maintain participation in the Electronic Health Record Incentive Programs.

The EHR program goal is to find meaningful ways within the infrastructure of health information technology (HIT) to use HIT as part of the way to reform the overall healthcare system by improving healthcare quality, efficiency and patient safety.

Stage II Highlights Timeline

The original proposed timeline for implementation of State II was set to occur in 2013, under the published rule that timeline has been extended for all providers who attested to meaningful use in 2011 to 2014. This gives all an additional year to meet the Stage II criteria.

Change in Objectives

The Stage 2 menu structure is fundamentally the same as the structure of Stage 1. Regarding hospitals and CAHs; they must meet the standard for 16 core objectives and 3 of 6 menu (choice) objectives. Eligible professionals must qualify by meeting the standards of 17 core objectives and also meet 3 of 6 choice objectives. Although the structure of the objectives is similar to the original proposal, the final rule defines some changes in both core and menu objectives that have changed.

Reduction in Patient Engagement Percentages

The original rule contained a provision that to meet Meaningful Use criteria ten percent of patient populations had to have online access to their health information and be able to participate in secure messaging with providers. Bowing to industry pressure, the final rule has reduced the participating percentages to 5 percent.

Summary of Care Documents

The initial proposal contained a provision that more than 65 percent of transfer of care and referrals have summary of care documents available to the new providers. CMS has lowered that requirement to 50 percent. A related proposal called for a minimum of 10% of patient records be exchanged electronically. The 10 percent threshold is still required but changes to this requirement have also been adopted in the final rule.

Measurements Related to Quality of Care

According to the final rule CMS is mandating the eligible hospitals and CAHs must report on 16 of 29 Clinical Quality Measures (CQM), EPS are required to report on only 9 of 64 CQMs. Nevertheless, CMS also mandates that all providers select 3 of the six key healthcare policy domains from the Health and Human Services (HHS) National Quality Strategy. These six area are:

  • Care coordination
  • Efficient use of healthcare resources
  • Patient safety
  • Clinical processes/effectiveness
  • Patient and family engagement
  • Population and public health
  • Medicare Payment Adjustments

By law, adjustments to Medicare payments will take effect in 2015. However, the CMS kept in the final rule its proposal that any Medicare provider who demonstrates meaningful use in 2013 will not be subject to payment adjustments in 2015. In addition, providers who first demonstrate meaningful use in 2014 can also avoid payment adjustments provided they meet the attestation requirement by July 3, 2014 for eligible hospitals and CAHs and October 3, 2014 for eligible providers.

CMS also expanded the original proposed exceptions to the payment adjustments to include a fourth which is by specialty/provider type concentrated among three specialties: anesthesiology, radiology and pathology. Infrastructure, unforeseen circumstances, and new CAHs/eligible hospitals are also exception categories for eligible hospitals and CAHs.

Getting educated on the final Stage 2 rules are vital to your continuing to be incentivized for compliance. The National E Health Collaborative (NeHC) offers comprehensive workshops on understanding and implementing the final rules. In fact the topics in this post and many more are thoroughly reviewed in the NeHC online workshops. Though implementation has been delayed by a year, providers can wisely use that time by understanding and implementing needed changes.

Alan E is a freelance writer/editor with a background writing about healthcare issues.