Final Rule for Stage 2 Brings Some Changes to Stage 1 – Meaningful Use Monday

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 Stage 2 requirements don’t become effective until 2014, the Final Rule for Stage 2 contains some changes that apply—or can apply—to providers before then, and some that will apply to all physicians in 2014, even those still in Stage 1. These changes fall into 3 categories in terms of timing:  those that are effective in 2013, those that can be adopted in 2013 at the physician’s discretion, and those that are implemented in 2014.

Effective 2013:

  • Conducting a test of the EHR’s capability to exchange clinical information (Stage 1 Core Measure 14) will be dropped from the requirements. It will be replaced in Stage 2 by measures that require actual and ongoing exchange of information.
  • A new exclusion for the ePrescribing requirement is being added for physicians who have no pharmacy within 10 miles that accepts electronic prescriptions.

At Physician’s Discretion in 2013 (and required in 2014):

  • The Vital Signs measure will be restructured to separate the reporting of height and weight from the reporting of blood pressure. This is good news for those specialists who consider some, but not all 3 of the vital signs, relevant to their practice. Along with this change in the measure are revised minimum ages: blood pressure reporting will be required for patients age 3 and over instead of age 2, and height (or length) and weight will be required for all patients, even those under 2.
  • An alternate calculation for CPOE will help physicians—again, likely specialists—who do not prescribe frequently enough to meet the Stage 1 (30%) threshold. The denominator will be limited to “medication orders created by the EP during the EHR reporting period,” instead of “unique patients with at least one medication in their medication list.”

Effective 2014:

  • Currently, in Stage 1, if a provider attests to an exclusion for any menu measures, these measures can be counted towards the menu requirement. In Stage 2, this will no longer be true—excluded measures will not satisfy the menu requirement if there are other measures on which the provider could report instead. This will also apply to providers who are still reporting under Stage 1 in 2014—a change which those providers will likely perceive as inequitable since it did not apply to the earlier attesters. Those physicians who qualify for multiple exclusions—specialists, once again—will find that the menu set is really no longer a menu, as they will be left with few, if any, choices. 

So, while physicians do not have to focus on Stage 2 just yet, they should consider whether they might benefit from the 2013 changes described above.

About the author

Lynn Scheps

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.

5 Comments

  • I knew that good deal of exclusions counting as a completion wouldn’t last.

    I saw this as such a big deal that I created an easy to follow flow chart to MAXimize your exclusions.

    Still, for Stage 1, if you are not FIRST seeing from what you are excluded…you are doing it wrong.

  • Regarding the exchange of information, is there any specification as to who you exchange with? For instance, a doctor in an attached practice for Hospital X using Epic Ambulatory can PROBABLY ‘exchange’ data with the Epic system at the hospital, but probably not with any other practice or hospital. Would this be enough?

  • The exchange of data requirement has 3 parts:
    1) The EP must provide a summary of care record for 50% patients who are transitioned to ao another setting or provider of care. This can be paper or electronic “exchange.”
    2) For 10% of the transitioned patients, the summary must be delivered electronically. The EHR developer/vendor does not matter.
    3) At least one exchange must be with an EHR from a different vendor. By Stage 2, all 2014 Certified EHRs will be capable of accepting this information electronically, so you should be able to exchange the summary with a user of a non-EPIC EHR by then. However, CMS will provide a test-EHR to which you can send the summary as an alternative to meet the requirement.

  • Realize this for exchange of data: your EHR vendor is your “go to” for this.

    If you are using a MU certified EHR, then all of this should be able to happen just fine…BUT…you will probably need to get your vendor involved to ensure you know how to do this

  • Interesting and helpful. The reality is that until 2014 very little will happen, but that in 2014 there should actually be some progress in exchanging information. But I’m still confused; do you actually need an HIE for this? I seem to recall that PracticeFusion, for instance, has some ability to do this now between its client practices. And if you are testing with the CMS test-EHR, that would also seem to bypass HIE’s.

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