On Thursday, February 23, 2012, CMS announced the proposed Stage 2 requirements for the Medicare and Medicaid Electronic Health Record (“HER”) Incentive Programs. See Notice of Proposed Rulemaking, Federal Register. Under HITECH, eligible health care professionals (“EPs”), eligible hospitals and Critical Access Hospitals (collectively “hospitals”) can qualify for Medicare and Medicaid incentive payments when they adopt certified EHR technology and demonstrate “meaningful use” of that technology as defined by CMS. See EHR Incentive Programs
CMS states that the “proposed Stage 2 criteria for meaningful use focus on increasing the electronic capturing of health information in a structured format, as well as increasing the exchange of clinically relevant information between providers of care at care transitions.” See CMS Fact Sheets
Stage 2 incrementally moves health IT development forward. In Stage 1, EPs had to meet 15 “core” requirements and 5 of 10 “menu” items. Hospitals had to meet 14 “core” requirements and 5 out of 10 “menu” items. In Stage 2, CMS proposes that EPs now meet 17 core objectives and 3 of 5 menu items; hospitals must now meet 16 core objectives and 2 of 4 menu items. CMS further explains that:
Nearly all of the Stage 1 core and menu objectives have been retained for Stage 2. The “exchange of key clinical information” core objective from Stage 1 was eliminated in favor of a more robust “transitions of care” core objective in Stage 2, and the “provide patients with an electronic copy of their health information” objective was eliminated because it has been replaced by an “electronic/online access” core objective. There are also multiple Stage 1 objectives that have been combined into more unified Stage 2 objectives, with a subsequent rise in the measure threshold that providers must achieve for each objective that has been retained from Stage 1. This eliminates unnecessary accounting and reporting burden for providers by recognizing that, for providers who have been Stage 1 meaningful users for multiple years, recording these data in structured form has become a normal part of care delivery.
Additionally, in an effort to encourage providers to implement EHR at faster rates, CMS has proposed a one-year extension of the Meaningful Use timelines, giving providers more time to get into Stage 1 and a longer ramp-up into Stage 2.
The Stage 2 proposed rule will have a 60-day public comment period, with a final rule expected sometime in the summer of 2012.