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1 Meeting Stage 2 Meaningful Use Requirements No matter what form the final rule of Stage 2 MU takes, HCOs can t afford to bide their time Despite the growing number of MU attestations and the impressive size of payments, HCOs must prepare for MU changes Other requirements of Stage 2 may be more of a challenge Stoltenberg Consulting Inc Library Road Bethel Park, PA Phone: (888) or (412) Fax: (412) simplifying healthcare technology Preparing for Meaningful Healthcare Change: Meeting Stage 2 Meaningful Use Requirements Introduction Meaningful use (MU) is a major component of the federal government s program to encourage providers use of electronic health records (EHRs) to improve quality, safety and efficiency, reduce health disparities, engage patients and family members, improve care coordination, and maintain privacy and security of patient health information. As of February 2012, 2,000 hospitals and 41,000 physicians had received $3.1 billion in incentive payments for ensuring meaningful use of health IT, particularly certified EHRs, according to the U.S. Department of Health and Human Services (HHS). Since Stage 2 MU requirements have yet to be finalized, healthcare organizations (HCOs) must zero in and become educated on the differences and similarities of Stage 1 and 2 MU. For example, menu or optional items from Stage 1 MU are now core requirements, while thresholds are set higher and the number of optional menu items have declined in Stage 2. New to Stage 2 MU are requirements that relate to the electronic medication administration record (emar), patient access to information, electronic communications and public health reporting. No matter what form the final rule of Stage 2 MU takes, HCOs can t afford to bide their time. Meaningful use is not a destination or event but a journey that requires a long-term commitment of clinical, operational and financial resources. HCOs must look beyond MU requirements to the imperatives of patient engagement and care coordination. Only then can they qualify for payment incentives from the Centers for Medicare & Medicaid Services (CMS) while achieving the results needed in a healthcare environment dominated by accountable, value-based care and population health management. connect with us: FOUNDATION Platinum Member

2 Changing Requirements Recently, new and updated regulations for Stage 2 have helped drive hospitals awareness of impending requirements; specifically, CMS published the Notice of Proposed Rule Making (NPRM) for Stage 2 MU of EHRs in the Federal Register on March 7, A 60-day comment period concluded on May 11, 2012, with the final rule slated for release in the summer or fall of HCOs that already attested to MU in 2011 must meet Stage 2 criteria in 2014 and CMS will ask all other HCOs to demonstrate two years of MU at each of the three stages. While quality measures haven t yet been finalized, HCOs should also look forward to electronic submission of quality measures by The rule for Stage 2 requirements proposed that eligible professionals (EPs) submit 12 measures selected from a list of required and possible measures. While hospitals will select 24 measures out of a possible 50 measures, both hospitals and EPs must report one measure from each of six quality domains. These include: Patient engagement Population and public health Efficient use of resources Clinical effectiveness Patient safety Care coordination Under the proposed rule for Stage 2 MU, optional Stage 1 menu or optional items became core or mandatory items in Stage 2. Meanwhile, Stage 2 still retains the structure of core and menu items for newer requirements. For example, emar is a core requirement for hospitals in Stage 2; 10 percent of all medication orders for hospital patients will be tracked using emar. Additionally, image viewing is a new Stage 2 menu item, which states that 40 percent of all scans and images be available for viewing on the EHR. Stage 2 MU also features higher threshold levels sometimes beyond levels recommended by the HIT Policy Committee. For example, while Stage 1 required that 30 percent of patients have prescriptions filled through computerized provider order entry (CPOE), experts recommended an increase to 50 percent. Currently, the proposed rule requires that 60 percent of medication, laboratory and radiology orders be entered using CPOE. Under the proposed rule for Stage 2 MU, optional Stage 1 menu or optional items became core or mandatory items in Stage 2. Meanwhile, Stage 2 still retains the structure of core and menu items for newer requirements... Copyright 2012, Stoltenberg Consulting Inc. 2

3 HCOs Attest to MU But Still Look Forward HCOs have already attested to MU and earned incentive payments. According to CMS, as of May 2012, 2,400 hospitals and 110,000 eligible professionals had received $5.7 billion in incentive payments from the Program for ensuring meaningful use. These figures represent a jump from the 2,000 hospitals and 41,000 EPs who had received payments as of February Furthermore, the percentage of hospitals adopting EHRs more than doubled from 16 percent to 35 percent between 2009 and 2011, according to DHHS. And in January 2012 alone, the federal government paid out $519 million to EPs. EHR incentive payments could total as much as $44,000 under the Medicare Electronic Health Record Incentive Program and $63,750 under the Medicaid EHR Incentive Program. Despite the growing number of MU attestations and the impressive size of payments, HCOs must prepare for MU changes. In Stage 1 of MU, hospitals and EPS had core or mandatory requirements, as well as menu or optional requirements for which they had to meet the thresholds for a specific number while deferring the rest. In Stage 2 of MU, HCOs face a reduced number of menu or optional items with all but two menu items having morphed into core or mandatory requirements. In Stage 1, HCOs may have chosen to defer or not select certain items for attestation to MU. For example, they may have decided to defer attestation based on electronic transmission of summary records at transitions in care, submission of reportable lab results or immunization data for public health, medication reconciliation or providing patient with e-copies of their information or discharge instructions. However, with Stage 2, the scenario has shifted. Hospitals that chose to defer requirements related to patient requests for information in Stage 1 no longer have that option in Stage 2. In fact, 50 percent of hospital patients must have access to electronic copies of their health information and discharge instructions, while 10 percent of EP patients must access and download their information. Other HCOs that rejected attesting to MU based on care coordination and patient engagement need to realize that both competencies are essential to success in value-based accountable care and population health management. Other requirements of Stage 2 may be more of a challenge. While HCOS are likely to meet requirements related to emar, patient engagement and coordination of care will be more of a challenge. HCOs are still searching for ways to allow patients to view and download their information and transmit summary of care records at transition of care. 3

4 Stage 2: The Time is Now While HCOs could get by with just three months of operational use of capabilities in Stage 1, Stage 2 demands a full year. Neither hospitals nor EPs can afford to wait for the final rule to initiate action. No matter how the final rule changes, Stage 1 menu or optional items will transform into core or mandatory requirements. Therefore, HCOs must: Develop strategies to better engage patients, Build fresh approaches to care coordination and collaboration, and Capture quality data and electronically report on that data. HCOs must view patient engagement as more than a short-term action plan to qualify for incentives. Instead, patient engagement must evolve into a strategy through which patients share accountability for their care and work in partnership with providers to improve health outcomes. In the same way, HCOs must view information sharing not merely as a Stage 2 MU requirement but as an essential element of accountable, value-based care, population health management and system-wide healthcare transformation. As demands for quality reporting escalate, private and public payers will increasingly tie reimbursement to operational, clinical and financial performance. Offering patients and families the best possible care also demands that HCOs search for fresh ways to document, manage and report quality in real time. The goal is not only to report gaps in care, but also to prevent their occurrence. As HCOs turn their attention to patient engagement and care quality and coordination they should consider short- and long-term actions: Develop a patient portal to ensure that patients can access their health information and discharge instructions electronically. As an alternative, offer an EHR that provides patients with direct access to their information. Build programs and technologies that allow physicians to communicate with healthcare colleagues across the continuum of care as well as with patients and family members. Create mechanisms to exchange patient information at key transitions in care to identify and prevent gaps in care. Creating programs such as these will ensure that HCOs fulfill all three stages of MU requirements, qualify for MU incentives, and achieve clinical and business standards in an environment dominated by new Medicare payment structures, accountable, value-based care and population health management. While HCOs could get by with just three months of operational use of capabilities in Stage 1, Stage 2 demands a full year. 4

5 CMS Medicare and Medicaid Programs Milestone Timeline Certified EHR technology available and listed on ONC website JANUARY 2011 Registration for the EHR Incentive Programs begins APRIL 2011 Attestation for the Medicare Program begins FEBRUARY 29, 2012 Last day for EPs to register and attest to receive an Incentive Payment for CY 2011 Medicare payment adjustments begin for EPs and eligible hospitals that are not meaningful users of EHR technology Last year to receive Medicaid Payment Fall 2010 Winter 2011 Spring 2011 Fall 2011 Winter JANUARY 2011 For Medicaid providers, States may launch their programs if they so choose MAY 2011 Payments begin NOVEMBER 30, 2011 Last day for eligible hospitals and CAHs to register and attest to receive an Incentive Payment for FFY 2011 Last year to initiate participation in the Medicare EHR Incentive Program Last year to receive a Medicare EHR Incentive Payment Last year to initiate participation in Medicaid EHR Incentive Program Fall 2010 Winter 2011 Spring 2011 Fall 2011 Winter Certified EHR technology available and listed on ONC website January 2011 Registration for the Program begins January 2011 For Medicaid providers, States may launch their programs if they choose April 2011 Attestation for the Medicare Program begins May 2011 Payments begin November 30, Last day for eligible hospitals and CAHs to register and attest to receive an 2011 Incentive Payment for FFY 2011 February 29, Last day for EPs to register and attest to receive an Incentive Payment for 2012 CY 2011 Last year to initiate participation in the Medicare Program Medicare payment adjustments begin for EPs and eligible hospitals that are not meaningful users of EHR technology Last year to receive a Medicare Payment Last year to initiate participation in Medicaid Program Last year to receive a Medicaid Payment As provided by Centers for Medicare & Medicaid Services 5

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