As we reported last month, the Centers for Medicare and Medicaid Services (“CMS”) released its final rule for Stage 2 of its EHR Incentive Programs. This post is our second in a multi-part series addressing various aspects of the final rule.
“Meaningful use” is achieved in three stages. All providers must meet the meaningful use objectives under the Stage 1 criteria before moving on to Stage 2. Major changes from Stage 1 to Stage 2 are in the meaningul use objectives and clinical quality measures which providers must satisfy in order to receive incentive payments.
Stage 2 Core and Menu Objectives
To qualify for incentive payments under Stage 2, providers must satisfy a combination of core objectives and menu objectives. Providers must meet all core objectives, whereas providers may choose certain menu objectives from a list of available options.
To demonstrate Stage 2 meaningful use,
- Eligible professionals (“EPs”) must meet 17 core objectives and 3 menu objectives that they select from a total list of 6, or a total of 20 core objectives.
- Eligible hospitals (“EHs”) and critical access hospitals (“CAHs”) must meet 16 core objectives and 3 menu objectives that they select from a total list of 6, or a total of 19 core objectives.
A number of new core objectives were also introduced for Stage 2, which CMS believes will have a positive impact on patient care and safety:
- Use secure electronic messaging to communicate with patients on relevant health information (for EPs only).
- Automatically track medication from order to administration using assistive technologies in conjunction with an electronic medication administration record (for EHs and CAHs).
Stage 2 also replaces the Stage 1 objective to provide electronic copies of health information or discharge instructions with the following objectives which would allow patients to access their health information online:
- Provide patients the ability to view online, download and transmit their health information within 4 business days of the information being available to the EP.
- Provide patients the ability to view online, download and transmit their health information within 36 hours after discharge from the hospital.
The majority of the new Stage 2 objectives are menu objectives. These are as follows:
- Record electronic notes in patient records.
- Make accessible imaging results through CEHRT.
- Record patient family health history.
- Identify and report cancer cases to a State cancer registry (EPs only).
- Identify and report specific cases to a specialized registry (EPs only).
- Generate and transmit permissible discharge prescriptions electronically (EHs and CAHs only).
- Provide structured electronic lab results to ambulatory providers (EHs and CAHs only).
Stage 2 Quality Measures
All providers must report on clinical quality measures in order to qualify for incentive payments:
- EPs must report on 9 out of 64 CQMs.
- EHs and CAHs must report on 16 out of 29 CQMs.
In addition, all providers must select CQMs from at least 3 of the 6 following key health care policy domains recommended by HHS’s National Quality Strategy:
1. Patient and Family Engagement
2. Patient Safety
3. Care Coordination
4. Population and Public Health
5. Efficient Use of Healthcare Resources
6. Clinical Processes/Effectiveness
A complete list of 2014 CQMs and their associated National Quality Strategy domains will be posted on the CQM page of CMS’s EHR Incentive Programs website in the future.