Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money. Check out Lynn’s previous Meaningful Use Monday posts.
Although I cannot claim to have read through the entire 455-page Proposed Rule on Stage 2 Meaningful Use, the fact that it is shorter than the 864-page rule that defined Stage 1 does not mean that it is simpler—it just requires less explanation since the basic structure of the program has not changed.
Rather than trying to summarize the Rule at this point, I am just going to point out some highlights gleaned from the presentations at HIMSS last week and from my quick skim through the document:
- The meaningful use bar has been raised significantly for Stage 2.
- The earliest that any providers will be subject to Stage 2 requirements is 2014; all EPs operate under Stage 1 requirements for their first 2 years of participation, regardless of when they first enter the program.
- Most measures have higher thresholds, some have increased complexity, and new measures have been added.
- Providers have fewer choices—there are 17 Core Measures that all providers must meet (subject to the same types of exclusions as Stage 1), all Stage 1 Menu Measures except syndromic surveillance become Core Measures, and providers will have to meet 3 of the 5 Stage 2 Menu Measures.
- True interoperability is required—Stage 2 no longer asks providers to test their ability to exchange clinical data, but rather requires them to successfully exchange information on an ongoing basis across organizational and EHR vendor boundaries.
- Providers will be accountable, to some degree, for actions by patients. For example, it will no longer be sufficient to make clinical information available to patients online—in Stage 2, a percentage of patients will have to actually access this information.
- Providers will have the flexibility to purchase just the capabilities that they need to meet meaningful use—e.g., a chiropractor who does not prescribe will not have to have an EHR with ePrescribing capabilities, and a provider who is still at Stage 1 will not have to possess the meaningful use capabilities relevant to Stage 2 (until he gets to Stage 2).
- Providers will report on 12 clinical quality measures, and there will be a broader array of measures from which to choose. One option under consideration would consolidate reporting for meaningful use and PQRS.
- 2015 penalties can be avoided by demonstrating meaningful use in 2013, or for those who enter the program in 2014, by successfully attesting no later than October 3, 2014.
For more information, see the CMS Stage 2 Meaningful Use Fact Sheet.