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HealtHITech Law HIPAA, HITECH and Beyond

Meaningful Use Stage 2 Requirements Now Final

Posted in Meaningful Use, Rulemaking

The Centers for Medicare and Medicaid Services (“CMS”) has released its final rule for Stage 2 of the Medicare and Medicaid Electronic Health Record (“EHR”) Incentive Programs.  The rule specifies criteria that eligible professionals and hospitals must meet in order to continue to receive incentive payments.  CMS has indicated that the final rule will be published in the September 4 issue of the Federal Register, and will be effective on the 60th day following publication.


Whereas Stage 1 focused principally on data collection, Stage 2 emphasizes care improvement through a concerted effort to increase coordination of care.  According to CMS Secretary Kathleen Sebelius:

The changes we’re announcing today will lead to more coordination of patient care, reduced medical errors, elimination of duplicate screenings and tests and greater patient engagement in their own care.

For example, Stage 2 core objectives include using secure electronic messaging to communicate with patients on relevant health information.

A major change in the final rule concerns the timing of meeting Stage 2 requirements.  The original Stage 1 timeline required providers who received incentive payments for 2011 to be ready for Stage 2 in 2013.  Now, providers who first demonstrate meaningful use in 2011 will not have to meet the Stage 2 requirements until 2014.  We found the CMS image below particularly helpful:

To Learn More

Continue to monitor our blog as we plan to provide more in-depth analysis of the provisions of the final rule.  In a multi-part series, we will explore the Stage 2 objectives, clinical quality measures, as well as issues related to payment, such as hardship exceptions to the Medicare payment adjustments and the Medicaid eligibility expansion.  In the meantime, CMS has a number of helpful resources on its Stage 2 website which we recommend.