EHR Incentive | EMR and HIPAA

EHR Penalties after Meaningful Use Failure

While at HIMSS I had a discussion with the consulting firm Stoltenberg Consulting. I was really intrigued by their approach to EHR consulting and will likely write more about it later. Plus, the started what in many ways became a theme of my HIMSS experience around rural healthcare EHR. You can be sure I’ll be writing about rural EHR here on this site and on Hospital EMR and EHR much more in the future.

In our casual introductory conversation we had a good discussion about how many of the smaller hospitals look at meaningful use and the EHR incentive money. Needless to say, many of these smaller institutions are faced with a huge challenge when it comes to adopting an EHR and showing meaningful use. Many of these rural hospitals barely have an IT staff and the CFO usually takes care of the IT environment. I heard one story at HIMSS where the IT person at a rural hospital started out as the janitor and his home IT skill made him the most qualified person to help.

Needless to say, rural and smaller hospitals have some real challenges facing them when it comes to EHR adoption and showing meaningful use of that EHR. Although, an even worse thought struck me in my discussions about these smaller hospitals.

Imagine many of these smaller hospitals making a good faith effort to adopt EHR and show meaningful use. It’s not that hard to see many of these hospitals falling short of the meaningful use standard. What will this mean to that organization? They’ve spent millions on an EHR. They won’t get the EHR incentive money they likely used as a justification for the EHR spending. To add insult to injury, now they’re going to get penalized for not being meaningful users of an EHR.

This scenario honestly makes me sick to even consider. Something similar could easily happen in small ambulatory practices as well. The scale of the damage will just be different. I expect in meaningful use stage 1 this won’t likely be a problem since it’s self attestation. However, this could become a much bigger issue in meaningful use stage 2.

Although, consider an organization who fails a meaningful use stage 1 audit. In most cases you can’t go back and fix whatever you failed in the audit. You’d be in a very similar situation where you have to return the EHR incentive money and would be open to the meaningful use penalties. At least that’s my understanding of how the EHR penalties will be implemented. If you know otherwise, I’d love to hear it.

While I think the above scenarios are brutal, hopefully this will also serve as a warning for those hospitals pursuing EHR and the EHR incentive money. Be sure you are able to show meaningful use or you’ll not only lose out on the incentive money, but you’ll also be open to the EHR penalties. Not to mention, are you ready for a meaningful use audit?

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March 15, 2013 I Written By John Lynn

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit.

Tags:EHR Incentive EHR Penalties EHR Spending HIMSS HIMSS 2013 Rural EHR Rural Hospitals Small Hospital EHR Stoltenberg Consulting

EHR Benefit – Accessibility of Charts

Written by: John Lynn

It’s time for the second installment in my series of posts looking at the long list of EHR benefits. In case you missed the first post, go and check out the EHR benefit of legible notes.

Accessibility of Charts
The second EHR benefit is similar to the Legibility of Notes benefit in that it is easily forgotten as a benefit to EHR and it can be hard to quantify the value of the benefit in dollar amounts. Plus, it is really easy to see how nice accessible charts are to an organization.

There are a number of ways to look at the EHR benefit of accessible charts. The most obvious one is when you think about the number of times a chart has gone missing in a clinic. In most cases, the chart isn’t really missing. It’s in the clinic somewhere, but no one can find it. Remember all those special places that a chart could hide: exam room, physician’s desk, front desk, nurse’s desk, lab sign off box, physician’s car, hospital, physician’s home, etc etc etc. Oh yes, I didn’t even mention HIM not being able to find the chart because someone (probably someone other than HIM) misfiled the paper chart.

I’m sure most HIM people who read this will have a visceral reaction. I’m sure many are likely thinking, “But we do an amazing job keeping track of all those paper charts.” I agree with them 100%. A good HIM person has done an amazing job keeping track of paper charts. It would be 100 times worse if they weren’t there. The problem is that if a dozen people are using the paper chart, the reality is that charts are going to go missing.

Now think about the concept when it comes to EHR. None of those lost chart locations exist. The nurse can’t accidentally take the chart and forget to file it. The doctor can’t forget the chart at home or in his car. No one can misfile the chart.

Think about it. An EHR solves 100% of the problem of missing paper charts.

Besides misplaced paper charts, the idea of chart accessibility is an important one when you consider the idea of accessing an EHR remotely. Even if you use a less than ideal remote desktop solution, a physician can access an EHR anywhere they have an internet connection. For web based EHR, you get exactly the same experience accessing the EHR remotely as you would in the office.

I’ve heard horror stories (at least their pretty horrible to me) of doctors getting late night patient calls which require them to get dressed, go into the office, open the medical records room to access a patient chart. With an EHR, that same workflow has the doctor booting his computer and logging into the EHR. This doesn’t apply to all doctors, but for those that do it’s a dramatic difference.

The biggest fear I’ve heard from doctors in this regard is they often equate chart accessibility with their accessibility. The argument goes that if they can access the chart 24/7, that it also means they have to work 24/7. I think this is a myth that doesn’t match most realities. Just because you had a key to your office and could go and work on paper charts 24/7 doesn’t mean you had to do it. The same is true with remote access to EHR. You choose when is appropriate and important to access and work on the EHR and when not to do so.

The key difference between EHR and paper charts is that when you do want to access a patient’s record remotely you have that option available to you. That doesn’t mean you always have to do so, but it is nice to have that option available.

When talking about EHR accessibility, I think also about the landscape of connected mobile devices (smart phones, tablets, etc). All of these devices are connected to the internet at all times and could provide a doctor access to their EHR almost anywhere in the world. Try doing that with paper.

The problem here is that most EHR don’t do well on mobile devices. Remote desktop from a smart phone or tablet works, but is a pretty terrible user experience. A native mobile app provides a much better experience for users, but we’re still in the early days of EHR mobile app development. As this matures, the accessibility of charts will become an even bigger EHR benefit.

The False Economies of EMR

Written by: John Lynn

In my recent look around the EMR twittersphere on EMR & EHR, I briefly commented on the challenges of choosing the wrong EMR and EMR Switching. Dan Haley from athenaHealth asked for some deeper clarification of my comment, “I’d say the biggest driver of EMR switching is thanks to the EHR incentive money and meaningful use.”

Here was my response:

I think there are a whole list of things in the HITECH act which encourage and promote the use of outdated technologies. I’m sure this is something you agree with and know all about as well.

My core argument has been, sure we’re seeing an increase in EHR adoption. However, what if the EHR incentive money is incentivizing doctors to adopt the wrong EHR. By wrong EHR I mean one that they don’t like, that can’t adapt to changing technology, that can’t support the future Smart EMR requirements that are bound to come, that kill a physician’s workflow, that cause a doctor to not want to be a doctor, etc.

I think we may be headed this direction and the number of doctors switching EHR software is a decent example of why this is the case. I’m sure that some would argue that meaningful use is driving people to switch EHR software and that the switch we’re seeing happening is from EHR software that isn’t highly functional to EHR software that is highly functional.

While this argument is true in some cases, there are just as many cases which illustrate that the EHR switching was because their first MU EHR was such a terrible experience that they had to switch EHR. Plus, we’re just at the start of this. Many are painfully grinding through the day to day with an EHR they hate. Wait until that explodes.

Even worse is those clinics that are switching EHR for the sake of EHR incentive money and go from an EHR they enjoy to one they hate. Add in the many doctors who are stuck using an EHR that was selected by some large company who didn’t worry too much about the physician needs and we’re in for a crazy next couple years.

Hopefully this gives you a better idea where my comment was coming from. Needless to say, I’m not sure that HITECH has been a benefit to doctors. The short term numbers might look good, but it might have just created some painful underlying difficulties going forward.

With all of this said, there are some beautiful EHRs out there that make doctors lives better. I’m pro-EHR when it’s done right. I just don’t see meaningful use and EHR incentive promoting the right EHR adoption methods.

This provided some interesting background for a conversation I had recently with a doctor. He told me, “It seems like there are a number of false economies driving EMR adoption.”

I think meaningful use and EHR incentive money driving EHR adoption is a false economy. This doctor described to me how many of his colleagues weren’t using the EHR that they wanted, but instead were using an EHR that they “had” to use. What are some of the forced requirements for EHR that create these false economies besides meaningful use and EHR incentive money?

Another False EMR economy is around HIE connections. Many doctors can’t select the EHR they want to use and fits their workflows best because their local HIE may or may not choose to support a connection with that EHR. So, the doctor opts for an EHR that does connect with the local HIE even though it wasn’t their EHR choice.

Hospital Connections is another false economy. Similar to an HIE, many doctors will opt for what they consider to be a less than desirable EHR because it’s the one that works with their local hospitals.

I’m not trying to pretend that doctors should be the end all be all in EHR selection. A physician can think one EHR is the best and not realize until after using it that another EHR would have been better. Sometimes you think you have a great EHR until you actually use another one and realize what you’re missing. However, the easiest recipe for disaster with EHR is for a doctor to hate using an EHR. As I mention above, it will not end well and will drive the future EMR switching that I’ve predicted.

EHR Benefit – Legibility of Notes

Written by: John Lynn

I’ve hinted for a little while that I was going to start a series of posts talking about the various benefits of using an EHR. I think this is an important subject worth discussing in greater detail. I hope that this series of posts will also help us move past meaningful use of an EHR for the government EHR money and explore all the other reasons why healthcare should fully adopt an EHR.

Back when I first started blogging about EMR software (It was 2005, before the term EHR came to be), I made this list of EMR and EHR benefits over paper charts. I’ll be using that list as the starting point for this series of EHR Benefit posts. I love the first paragraph on that page (which I likely haven’t touched since 2005):

This list is just a starting point to list off all the possible benefits of having an EMR or EHR. Probably a poor one, but a start nonetheless. My plan is for this list to grow over time as I think of new benefits or as people suggest things I’ve most certainly missed. Also, I think that most people often focus too much on the financial benefits of an EMR and so hopefully this list will include financial and other benefits beyond the financial implications.

The list definitely did grow, but I guess I never got around to updating the intro paragraph. Although, I am pleased to see that even back in 2005 I was as interested in the non-financial benefits of EHR. Certainly the financial benefits of EHR are incredibly important, but far too many people don’t take into account the other non-financial benefits in their analysis of EHR benefits. It’s just too hard for many to try and compare or put a value on the non-financial benefits of EHR. We’ll try to point these benefits out just the same.

Now for the first EHR benefit on the list:

Legibility of Notes
I’m really glad to start with an EHR benefit that everyone can understand with little explanation. Poor medical handwriting has been a running challenge in healthcare for as long as we’ve been documenting patient visits. I did a quick search on Google for “write like a doctor” and it had about 321 million results. That’s quite pervasive.

I can’t think of anyone that would argue that healthcare doesn’t have a challenge reading physician’s handwriting. No doubt there are plenty of exceptions to this, but even those with beautiful handwriting still have to read other doctors’ handwriting from their own office or from other doctors’ notes that get sent to their office. It’s great to have the notes, but if you can’t read them then what’s the point.

While certainly illegible handwriting is a major problem in the office, it also extends outside the office as well. Think of all the times pharmacists have had to call a doctor to clarify the prescription a patient brought in. Even worse than that is the number of times the pharmacist misread a script because a doctor’s handwriting is illegible. This becomes a non-issue in an electronic world where the prescription is either printed or ePrescribed.

Of course, none of this is new territory. Every doctor understands these benefits better than I’ve explained here. However, far too often when we think about implementing an EHR, we forget about these simple and easy to understand benefits. How much time is saved in your clinic by being able to read the handwriting in the chart? How much time is saved in healthcare when referrals come in an easy to read, legible format? How much time and how many lives are saved by pharmacists getting the proper prescription to the patient? All of these are hard measures to quantify, but they are real, tangible benefits of an EHR.

I won’t mislead you into thinking the shift from paper charts to EHR solves all the legibility problems. Many template driven EHR software that creates a mass of mostly irrelevant data can be just as hard to decipher as the hieroglyphic handwriting of some doctors. However, I’ve seen a tidal wave of push back against these documentation approaches and I think we’re getting better. I think the shift to quality of care reimbursement versus procedure based reimbursement will help this to go away as well.

There are other things a clinic leaves behind with paper charts. I’ve heard many tell me how many times they looked at the handwriting to recognize who had documented something in a paper chart. Certainly that same info is available in an EHR, but you do lose the instant recognition of who charted what in the chart.

Despite not being able to put a nice dollar value on the Legibility of Notes, it’s certainly an EHR benefit that can’t be forgotten. It’s very easy to adopt an EHR and take this for granted.

Meaningful Use the Commodity – Meaningful Use Monday

Written by: John Lynn

I decided to take a step back this week for Meaningful Use Monday to look at where we are in the new world of health IT which includes the commonplace terms of EHR incentive money and meaningful use. Plus, I’m probably waxing a bit nostalgic today as I think about the David Brailer keynote at the Digital Health Conference today (follow my tweets on @ehrandhit for more coverage) where he spoke a bit about the origins of healthcare IT.

At this point it seems that meaningful use has become basically a commodity. There are very few EHR vendors out there now that aren’t certified EHR that can help a physician get to meaningful use (Although there are some non-certified EHR still). Basically, if you are doing EHR, then more than likely you are doing meaningful use. Or at least you’ll have that opportunity if you want. Some would argue that means that this result is a function of the meaningful use bar being set too low.

In fact, that is largely what the congressmen’s argument was in their letter to HHS about halting meaningful use. The real question is whether this is a problem. I personally don’t mind all the EHR competition. I think it would have been worse if the government incentive, meaningful use, and the RECs essentially narrowed the field of EHR vendors down to only a few.

The argument on the other side is around the “paradox of choice.” There’s little doubt that many practices are in a situation where there are so many EHR choices that they make the decision not to choose. However, I see this more as an excuse not to do EHR from people who didn’t really want to do EHR in the first place. I’m not sure these people would have been doing EHR even if there were only a few choices.

This does leave us with a challenging problem going forward. The EHR churn rate is going to go through the roof. David Brailer pointed this out today in his keynote and he’s right that it’s already happening today. Although, the majority of the EHR churn that’s happening now is from those organizations that are going after meaningful use. The major EHR churn rate of the future is going to come from EHR consolidation.

What does this all mean? Now more than ever, an organization needs to do good due diligence on the stability of the EHR software. Notice that I didn’t say EHR vendor. Just because you’re a large EHR vendor that’s financially stable doesn’t mean that the EHR software is safe (see Exhibit A and Exhibit B).

One thing is clear though, meaningful use and EHR are here to stay. There’s no escaping EHR. We’re finally back to the point where doctors are no longer asking if they should do EHR. Instead, they’re asking how, when and which EHR they should do. This is a very good industry trend.

What Would Happen If EMR Incentive Program Was Halted?

Written by: Katherine Rourke

Particularly over the next few months, with the presidential election looming and the aftermath underway, I doubt we’ll see any changes to the Meaningful Use program. But it’s worth asking nonetheless, given the recent request by some Congressmen that HHS halt the MU program, what would happen if MU incentive payments suddenly came to a halt.

Here’s a few observations based on what we know or can easily guess right now:

1. The effects would be very widespread.

As HIMSS notes in its press release opposing the cut:

“Recently-released CMS data show that over 2,700 Eligible Hospitals and 73,000 Eligible Professionals have attested to Meaningful Use Stage 1 requirements since the incentive program began in 2011.”

I don’t know what percentage of EPs that represents, but that’s approaching roughly half of all U.S. hospitals, depending on which ones you count. Pulling back incentives would slam the other half.

2. Efforts to bring rural/critical access hospitals on board would stall.

ONC is just kicking off a program to have all 1,000 critical access/small rural hospitals meaningfully using health IT by 2014. (More to follow on this on our sister site HospitalEMRandEHR.com.) While big hospitals might move ahead on their efforts for other reasons, these smaller hospitals probably wouldn’t have the means to do so.

According to HIMSS data, such hospitals are already way behind when it comes to health IT adoption. A halt in incentive payments could only make this worse.

3. Future incentives would be viewed with suspicion.

I don’t know about you, but if I was promised incentives for taking on a very, very expensive and rigorous process, had them pulled back, then had them restored, I’d lose trust in the Meaningful Use program. ‘Nuff said.

4. EMR adoption would lose momentum.

Hospitals and eligible providers have taken on big expenses and risks to bring on EMRs and supporting health IT, but if they don’t see the promised incentives as being completely predictable, they might slow or stop their efforts. How much so would depend on how committed they already were, of course, but the EMR adoption process would lose momentum.

Incentives are giving many hospitals and EPs an excuse to move forward, and without that many might sit on their hands for a while.

What other effects do you think it would have if the incentive payments stopped flowing for a while?

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October 11, 2012 I Written By Katherine Rourke

Katherine Rourke is a healthcare journalist who has written about the industry for 30 years. Her work has appeared in all of the leading healthcare industry publications, and she's served as editor in chief of several healthcare B2B sites.

Filed Under: EHR EHR Stimulus Electronic Health Record Electronic Medical Record EMR EMR Technology Hospitals Meaningful Use

Tags:EHR Incentive EHR Stimulus EMR Incentive EMR Stimulus HIMSS Meaningful Use ONC

EHR Certification Value (or lack therof)

Written by: John Lynn

It seems like this question comes up every couple months about the value of EHR certification. A reader of EMR and HIPAA, QA, recently offered the following comment about EHR certification.

The issue is less that the certification bodies are unscrupulous and more that the certification criteria themselves are a joke.

If one thinks that certification denotes that a system is safe, usable, reliable and will support the care delivery needs of any particular healthcare organization, then one will be quite disappointed.

If one thinks that certification denotes that a company offering a system has certain financial stability, legal liability coverage or quality management systems in place, one will be similarly disappointed.

ONC has no interest in rigorous certification. Only higher attestation numbers.

I think this comment hits the nail on the head. I won’t say that EHR certification provides no value, but let’s not do what far too many people are doing and misconstrue the value EHR certification offers. I echo QA’s comments that EHR certification does not certify:

EHR Safety
EHR Usability
EHR Reliability
EHR Financial Stability
EHR Liability Coverage
EHR Quality Management

Let’s not make EHR certification into more than what it delivers. I think most people have gotten this message, but a few are still lingering in the shadows.

Will Meaningful Use and EHR Incentive Put Medicare in a Bad Position?

Written by: John Lynn

In response to Jennifer’s post on Raising EMR in the Meaningful Use era, the always colorful Al Borges, MD provided the following comment:

Ahhh- but John, you’ve never compared EHR/MU to Death! The current Federal Government involvement in HIT is to providers more like the 5 steps of death and dying:

1) Denial and isolation: “This is not happening to me.”
2) Anger: “How dare Obama do this to me! What a jerk!”
3) Bargaining: “Please Obama- just let me continue to survive under Medicare.”
4) Depression: “I can’t bear to face going through this, I’m meaningfully depressed.”
5) Acceptance: “I’m ready to empty my pockets, go into debt, and possibly buy an expensive EHR or just retire… I don’t know. All I know is that I don’t want to struggle anymore.”

I, for example, am perpetually stuck in step 2. I continue to buck the system whenever I can. I’ve actually quit doing hematology/oncology and streamlined my [now] internal medicine practice to survive in these tumulous waters. Result: as more than 60% of the offices next to Virginia Hospital Center [my admitting hospital] have closed and been bought out by the hospital, I’m part of the less-than-40% that have survived. My income for 2011 will most likely show a doubling of my personal gross income.

As I’ve become a “nonpar” Medicare provider, I initially lost many Medicare patients, but I’ve gained what I want now- cash paying and younger PPO/HMO patients to fill in the empty slots. Many Medicare patients now have come back too, because I give them attention and the best care that I can offer. They pay me up-front using the “nonpar” Medicare contractual scale. THEY end up paying the current (s.a. eRx) and future penalties that Medicare will shell out, which is what always happens when big government taxes businesses- the clients end up paying the bill.

Some go through to step 5, buy an EHR, then either deinstall their systems, become hospitalists (or go to another endeavor), or retire. I plan on NOT going through these routes, at least for the next 10 years.

What needs to occur is that the Federal Government has out of HIT. Until that happens, we will never achieve a true “meaningful use” of EHR systems. Yes, doctors will get into inexpensive EMRs (like I have), but they will never buy into something that they cannot afford in both time and money. If EHR/MU continues, you’ll see Medicare suffer as doctors opt out or become “nonpar” making it difficult for the elderly to get the care that they need.

I know that Dr. Borges isn’t the only doctor that has done what he’s done. He’s much more outspoken about it than most, but every doctor I’ve ever met has had essentially the same feeling about Medicare: They hate it. Those that only modestly hate it do so because they realize that currently their livelihood depends on it. Although, even those wish they had a way to get out from Medicare.

While Dr. Borges story is interesting, his last question is the one that I think should be most concerning. Will the EHR incentive money and meaningful use drive many doctors to abandon Medicare and put Medicare in a bad position? One thing I believe goes against this trend is the number of hospital owned practices. I haven’t dug into the economics of hospital owned practices, but I’m pretty sure they won’t have the same flexibility to leave Medicare. I’d love to hear if you think otherwise.

Is Dr. Borges in the minority or could EMR and MU become a real issue for Medicare?

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September 12, 2012 I Written By John Lynn

Filed Under: ARRA EHR EHR Stimulus Electronic Health Record Electronic Medical Record EMR HealthCare IT HITECH Meaningful Use

Tags:Al Borges EHR Incentive Meaningful Use Medicare

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

Written by: Lynn

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.

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September 10, 2012 I Written By Lynn

Filed Under: ARRA EHR EHR Stimulus Electronic Health Record Electronic Medical Record EMR ePrescribing HITECH Meaningful Use

Tags:ARRA CMS EHR Incentive EHR Stimulus EMR Incentive EMR Stimulus HHS HIE HITECH Lynn Scheps Meaningful Use Meaningful Use Monday Meaningful Use Stage 1 Meaningful Use Stage 2 Vital Signs Measure

Meaningful Use Stage 2 Final Rule: What You Need to Know—At Least For Now – Meaningful Use Monday

Written by: Lynn

Without delving into all the specifics detailed in the 672-page Final Rule for Stage 2, what is important to comprehend—for now—is how Stage 2 raises the bar set by Stage 1 and how it intensifies the focus on health information exchange and patient engagement.

The following are some highlights of Stage 2:

The Final Rule not only confirms 2014 as the earliest effective date for Stage 2 (as expected), but it provides additional leeway for providers and for vendors by limiting the Stage 2 reporting period to 90 days in 2014, instead of a full year.
EPs must meet or exclude all 17 core measures and must meet—not “meet or exclude”—3 of the 6 menu measures. (Unlike Stage 1, exclusions of menu measures do not count unless the EP cannot find 3 relevant menu measures.)
All Stage 1 menu measures except syndromic surveillance become core measures.
5 new menu measures have been added: access to imaging results, family history, progress notes, reporting to cancer registries, and reporting to specialized registries.
Stage 2 increases most Stage 1 thresholds.
CPOE is expanded to include lab and radiology orders, in addition to prescriptions.
Patient portals play an important role as a means of providing patients with access to their medical records. Physicians will have to ensure that at least 5% of the patients they see actually view, download or transmit their health information and that over 5% of the patients seen send them a secure e-mail message containing clinical information, (i.e., not just a request for an appointment.)
Clinical summaries of office visits must be available to patients within 1 day, instead of the 3-day timeframe in Stage 1.
The Stage 1 measure requiring a test of the ability to exchange clinical data with another provider has been dropped effective 2013, in favor of a more robust 2014 Stage 2 requirement for ongoing exchange of a significantly more extensive data set.
EPs will report on 9 of 64 clinical quality measures, and after the provider’s first incentive year, the CQM data must be submitted electronically, rather than by attestation.
In an effort to streamline the reporting process, Stage 2 offers opportunities for batch reporting by group practices and for consolidated CQM reporting for PQRS and meaningful use.
Penalties and hardship exemptions are defined, establishing October 1, 2014 as the latest date by which an EP can attest for the first time and avoid a 1% payment adjustment in 2015.