Free EMR Newsletter Want to receive the latest news on EMR, Meaningful Use, ARRA and Healthcare IT sent straight to your email? Join thousands of healthcare pros who subscribe to EMR and HIPAA for FREE!!

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

Posted on August 27, 2012 I Written By

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.

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.

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.

More information about Stage 2 will follow in future Meaningful Use Monday posts.

MU Core Measure: Conduct a Security Risk Analysis – Meaningful Use Monday

Posted on May 21, 2012 I Written By

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.

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.

Perhaps because in the past, CMS has issued little guidance as to exactly what constitutes a security risk analysis for meaningful use purposes, this measure has created a great deal of confusion, and in some cases angst, among providers. Some EPs worry that this measure is so comprehensive that it requires hiring a consultant, while at the other end of the spectrum, others assume that they automatically satisfy this requirement because their EHR is certified to meet the privacy and security standards specified by ONC. Neither is the case. 

Core Meaningful Use Measure: Protect Electronic Health Information

Conduct or review a security risk analysis in accordance with the requirements under 45 CFR 164.308(a)(1) and implement security updates as necessary and correct identified security deficiencies prior to or during the reporting period. 

According to CMS, this measure is not designed to introduce new security requirements above and beyond what is required for a practice to be HIPAA compliant—the HIPAA security rule already demands a security analysis and remediation. However, this does not mean that EPs should just attest “Yes” without being able to back up their attestation with documentation of the process that was undertaken and the steps take to address deficiencies. 

To help clarify this for providers, ONC recently published the “Guide to Privacy and Security of Health Information,” which contains two chapters that specifically address meaningful use. It’s definitely worth a read!

More on Stage 2: Clinical Quality Measure Reporting – Meaningful Use Monday

Posted on August 22, 2011 I Written By

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.

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.

In addition to the Meaningful Use Stage 2 recommendations discussed in last week’s Meaningful Use Monday, the HIT Policy Committee proposed a new framework for the reporting of clinical quality measures that was designed by its specifically-tasked Quality Measure Workgroup. The recommended concept is depicted in the graphic below—the intention is to broaden the scope of reporting to address a wider spectrum of factors affecting care and to accommodate all types of physicians.

Providers would report on some number of the core measures, (between 5 and all 8 or 9 is the recommendation), and at least one measure from each of the 6 menu “domains”. The core quality measure set would include all of the core and alternate core measures from Stage 1 and an additional 2 measures related to care coordination. Interestingly, there was no mention of establishing required thresholds to be met on any of the quality measures.

The intention is that all physicians (including specialists) will find measures relevant to their specialty in the core set as well as in each of the domains. This seems like a tall order from a practical perspective, given the primary-care focus of the Stage 1 quality measures, (particularly true of the core, but also the additional measures.) To accomplish this, the workgroup submitted quite a lengthy “library” of measures to CMS for its consideration—some measures are carried forward from Stage 1, others are recently retooled, and many are still “to be developed”.

We’ll be watching intently to see what CMS does with clinical quality measures, since this is such a fundamental part of meaningful use.

Meaningful Use Measures – Exclusions – Meaningful Use Monday

Posted on April 4, 2011 I Written By

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.

In response to strong lobbying activity and numerous comments from physicians, the Final Rule on Meaningful Use (Stage 1) included a provision for physicians to exclude certain measures that are outside the scope of their practice. This was primarily an accommodation made to enable specialists to participate in the EHR incentives program without substantially changing their practices—although some primary care physicians may find exclusions applicable to them as well.

For a physician to exclude a measure:

  • The measure must be explicitly identified as “excludable” in the Final Rule—not all measures contain such a provision. (6 core and 7 menu measures are potentially excludable, but for some there will be very few providers who would meet the criteria.)
  • The physician must meet the defined criteria for exclusion of that particular measure.
  • The physician must attest that he/she meets these criteria.

Excluding a measure is the equivalent of meeting that measure. Therefore, if a physician excludes one (or more) of the menu measures, he/she only has to satisfy 4 of the remaining 9 menu measures (or 3 of the 8, etc.) The excluded measure does not have to be replaced by another measure.

In the next Meaningful Use Monday posts, I will address each of the measures individually and will identify the eligibility criteria where exclusions exist. I’ll start with Reporting on Clinical Quality Measures (one of the 15 Core meaningful use measures) because while not technically excludable, there is an accommodation available for the many specialists who find none of the measures relevant.

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.

The Meaningful Use Measures – The Basics – Meaningful Use Monday

Posted on March 28, 2011 I Written By

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.

John requested that the next series of Meaningful Use Monday posts explore the ins and outs of the individual meaningful use measures. To begin this process, today’s post reviews the basic requirements and the type of information that providers will report. Next Monday’s post will address the options available to some providers to exclude certain measures. Following that, I will address the measures, one by one, week by week (…although I can’t promise that I won’t digress as subjects of timely interest arise!)

By now, most people interested in meaningful use know that there are 25 measures and that they are divided into two sets—Core and Menu. Providers must meet all 15 of the core measures and any 5 of the 10 menu set measures, as long as one public health measure is included. (Another way to look at the menu set is that providers can defer—presumably to Stage 2—5 of the 10 menu measures.)

How each of the 25 measures is reported varies in a number of ways, so it is important to carefully read the requirements:

  • For some measures, providers will be asked to simply attest that “Yes”, they met the measure—e.g., implemented a particular EHR functionality or performed a test of a specific capability.
  • Other measures have thresholds that must be met, and therefore require the reporting of numerators and denominators, using data generated by the EHR.
  • Denominators vary, e.g., some are based on all patients seen, while others refer to a particular subset of patients.

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.