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How the Meaningful Use Stage 2 Timeline Affects Your Medical Practice

The following is a guest blog post by Dana Deardorff.
D. Deardorff pic
The year of 2014 will be a year of great transition for most medical practices. You may be in the beginning stages of using EHR/EMR software, or you may be installing Medical Practice (MP) software for the first time. Perhaps you have been using a software program, but you’ve realized you need to upgrade to software that is certified for Meaningful Use. Or, if you’ve purchased certified software, you may need help proving the “meaningful use” of that software, meeting the requirements of Stage 2.

What does Stage 2 Meaningful Use mean for your medical practice? In addition to more recording and reporting measures, Stage 2 of Meaningful Use emphasizes care coordination and HIPAA-compliant engagement with patients.

Meaningful Use Stage Requirements

Stage 1

Beginning in 2011, the focus was on data capturing and sharing. Eligible providers and hospitals were required to show meaningful use of software by meeting a set number of objectives. These objectives were broken down into core objectives and menu set objectives. To be eligible for incentive payments, eligible providers and hospitals needed to prove they met the requirements for a 90-day period in the first year of participation and the entire second year of participation.

In a nutshell, during Stage 1, you are expected to:

  • Capture health information in a standardized electronic format
  • Use EHR/EMR or MP software to track clinical conditions
  • Report clinical quality measures and public health information
  • Begin engaging electronically with patients via HIPAA-compliant software

Your EHR/EMR or MP software vendor should be able to explain the practical applications of these requirements to you, training your staff how to prove and report compliance.

Stage 2

Once you’ve met the requirements for Stage 1 of Meaningful Use, you will need to widen your focus to include clinical processes.

In shorthand, during Stage 2, you will be expected to:

  • Engage in more rigorous health information exchange
  • Engage in e-prescribing
  • Deliver lab results electronically
  • Offer increased patient-controlled data and engagement with patient through electronic means
  • Transmit patient care summaries securely and compliantly through approved electronic methods

On a practical level, this means your office will need to use software that provides the following features, amongst others:

  • Patient engagement portal, including mobile device access to messages and records
  • Electronic recording of and communication of immunization records
  • E-prescribing capabilities and communication

You can begin meeting Meaningful Use Stage 2 requirements now (2014), assuming you have already met Meaningful Use Stage 1 requirements for the minimum time frame. (Ninety consecutive days one year, and an entire year the following year. Be sure to learn more about the possible Meaningful Use Stage 2 delay.) You will need to do the same with Meaningful Use Stage 2 before you can proceed to Stage 3.

Stage 3

Beginning in 2016, eligible providers and hospitals can take on a third set of requirements, focused on improving quality of care, safety and efficiency. The end goal is to provide improved health outcomes.

Meaningful Use Timeline

Eligible hospitals are held to a fiscal-year timeline, but eligible providers are held to the calendar year. This means you will need to ask your EHR/EMR or MP software vendor to help you figure out what your practice’s deadline is and how to meet it for each stage. A good vendor should be able to help you overcome obstacles like:

  • Employee resistance to using new software or processes
  • Software implementation and integration challenges
  • Office procedure modifications and work flow changes

Participation in Stage 1 opened in 2011. Practices that were early participants are now moving into Stage 2 here in 2014. Those who participate soon will be eligible for Stage 3 participation as soon as 2016, taking advantage of years of incentive payments.

Medical Practice Participation

According to the Centers for Medicare and Medicaid Services, more than 355,000 health care providers have received incentive payments for their participation in the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs (as of February 2014).  Over $13.6 billion has been paid out through the Medicare EHR Incentive Program thus far, and over $7.5 billion has been paid out through the Medicaid EHR Incentive Program.

Incentive payments aren’t the only reason to upgrade your MP software. Medicaid and Medicare eligible providers and hospitals that do not meet Meaningful Use requirements will be subjected to penalties starting in 2015. These penalties will come in the form of payment reductions, starting at one percent, capped at five percent for each year eligible providers don’t demonstrate meaningful use.

If you haven’t tackled this challenge yet, you’ll want to take it on now, before you miss out on the incentive payments and lose out on a percentage of your Medicaid and Medicare payments.With the right guidance, you’ll find that the upgrade and training will result in an improved experience for everyone, staff and patients alike.

About Dana Deardorff of MediPro

MediPro, Inc. is a full-service medical billing software company offering practice management (PM) software, electronic health records (EHR) and electronic medical records (EMR) from IMS and McKesson. As of April 2014, IMS is certified for Meaningful Use Stage 2, and McKesson, which is certified for Stage 1, will soon also be certified for Stage 2. (McKesson is certified for Stage 2 now, they just haven’t made the formal announcement).

May 30, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit.

Meaningful Use Stage 2 Delayed Until 2015 (Unless You Don’t Want to Wait)

Big news coming out of HHS today, CMS issued a proposed rule that changes the EHR certification requirements, firms up the meaningful use stage 3 delay that was announced previously, and most importantly delays the meaningful use stage 2 requirement until 2015. I guess one could argue that it’s not a delay since you can still attest to MU stage 2 in 2014 if you’d like (some already have), but for practical purposes this is a delay in the enforcement of meaningful use stage 2 for many organizations.

It looks like CMS and ONC was listening to the backlash against meaningful use stage 2 and the potential fallout. This isn’t quite blowing up meaningful use, but it’s a step in that direction. Here’s the chart that ONC put out that shows the new timelines:
New Meaningful Use and EHR Certification Timelines - Meaningful Use Stage 2 Delay

It’s worth noting that this is just a proposed rule, but there were usually very few drastic changes between proposed rules and final rules in the past. Sure, there could be a few tweaks, but I bet this goes into place essentially as it stands.

This will be a relief to hundreds of EHR vendors that are behind on becoming 2014 Certified. I expect most will continue with their 2014 Certified plans, but many of their users will likely opt to stick with the simpler meaningful use stage 1 objectives and measures. What’s not clear to me is if the attestation process will stay the same (ie. self attestation in MU stage 1) or not. I’ve asked HHS and will update the post (see update at the bottom of the post) once I hear from them.

What do you think of these changes? What impact will this have on you and your organization?

Here’s another email that CMS sent out:

CMS and ONC Release NPRM Allowing CEHRT Flexibility and Extending Stage 2

Today, CMS and ONC released a notice of proposed rulemaking (NPRM) that would allow providers participating in the EHR Incentive Programs to use the 2011 Edition of certified electronic health record technology (CEHRT) for calendar and fiscal year 2014.

The NPRM will grant flexibility to providers who are experiencing difficulties fully implementing 2014 Edition CEHRT to attest this year. The proposed rule would allow providers to use EHRs that have been certified under the 2011 Edition, a combination of the 2011 and 2014 Editions, or the 2014 Edition.

Beginning in 2015, all eligible providers would be required to report using 2014 Edition CEHRT.

2014 Participation Options
Under this proposal, valid only for the 2014 reporting year, providers would be able to use 2011 Edition CEHRT for either Stage 1 or Stage 2, would have the option to attest to the 2013 definition of meaningful use core and menu objectives, and use the 2013 definition CQMs.

Providers currently working on Stage 1 in 2014 would be able to demonstrate:

  • Stage 1 (2013 Definition) using 2011 Edition CEHRT, or using a combination of 2011 and 2014 Edition CEHRT; or
  • Stage 1 (2014+ Definition) using 2014 Edition CEHRT.

Providers currently working on Stage 2 in 2014 would be able to demonstrate:

  • Stage 1 (2013 Definition) using 2011 Edition CEHRT, or using a combination of 2011 and 2014 Edition CEHRT;
  • Stage 1 (2014+ Definition) using 2014 Edition CEHRT; or
  • Stage 2 (2014+ Definition) using 2014 Edition CEHRT.

UPDATE: Here’s the response I got from CMS about the reporting periods:

Reporting periods are not changing.

For 2014 Only
Because all providers must upgrade or adopt newly certified EHRs in 2014, all providers regardless of their stage of meaningful use are only required to demonstrate meaningful use for a three-month (or 90-day) EHR reporting period in 2014:

Medicare eligible professionals beyond their first year of meaningful use must select a three-month reporting period fixed to the quarter of the calendar year for eligible professionals. Providers must attest to these reporting periods no later than February 28, 2015 at 12 am ET.

Medicare eligible professionals in their first year of meaningful use may select any 90 day reporting period.

Medicaid eligible professionals can select any 90-day reporting period that falls within the 2014 calendar year.

May 20, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit.

McKesson and Meditech Named as First “Test EHRs” by CMS and ONC

CMS and ONC just announced the first two “Test EHRs” are McKesson and Meditech. Here’s the details of their announcement:

As part of our and CMS’ ongoing effort to improve interoperability among certified Electronic Health Records Technology (CEHRT), we are pleased to announce McKesson and Meditech are the first two “Test EHRs,” selected from among certified EHRs. We strongly encourage others in the EHR technology developer community to participate in the program to become a CMS designated test EHR.

Under Stage 2 of Meaningful Use transition of care objective measure #3 [PDF - 218 KB]eligible professionals (EPs) and eligible hospitals/critical access hospitals (CAHs) must either:

– Conduct one or more successful electronic exchanges of a summary of care document, with a recipient who has EHR technology designed by a different EHR technology developer than the sender’s.

Or

– Conduct one or more successful tests with the CMS designated test EHR during the EHR reporting period

ONC and NIST conducted a pilot that ran from September through November of last year to finalize the test procedures. The pilot participants were AthenaHealthMcKesson andMeditech.

To find out more about becoming a CMS designated test EHR, read the “EHR Technology Developers” section of the FAQs on becoming a CMS designated test EHR and the “Developer Participant Information for Cross Vendor Exchange” document.

I find it interesting that AthenaHealth was a pilot participant, but isn’t one of the official “Test EHRs.” I wondered what happened there. Looks like a lot of EHR vendors will be able to at least connect to McKesson and Meditech.

January 16, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit.

CMS Releases MU Stage 2 Guide

CMS has released a new resource, An Eligible Professional’s Guide to Stage 2 of the EHR Incentive Programs, which provides a comprehensive overview of Stage 2 of the EHR Incentive Programs to eligible professionals. The guide outlines criteria for Stage 2 meaningful use, 2014 clinical quality measure reporting, and 2014 EHR certification.

The guide’s table of contents makes it easy for you to navigate through Stage 2 topics. Interactive tabs included at the bottom of each page allow you to transition between different chapters.

Chapters include:

  • What is Stage 2 of the EHR Incentive Programs?
  • What are the requirements under Stage 2 of Meaningful Use?
  • How will clinical quality measures (CQMs) change?
  • Resources

The guide can be found on the Educational Resources page of the EHR website.

September 17, 2013 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit.

Meaningful Use Attestation Deadline for 2012 and MU Stage 2 Testing Ready

Eligible professionals (EPs) who participated in the Medicare Electronic Health Record (EHR) Incentive Program in 2012 must complete attestation for the 2012 program year by February 28, 2013. In order to be eligible to attest you must have completed your 2012 reporting period by December 31, 2012.

CMS encourages Medicare EPs to register and attest as soon as possible to resolve any potential issues that may delay their payment.

Medicaid EPs should check with their State for their attestation deadline.

Resources from CMS
CMS has several resources located on the EHR Incentive Programs website to help EPs properly meet meaningful use and attest, including:

Also, for EHR vendors, ICSA just announced that they are now set to begin testing EHR software for meaningful use stage 2. That’s right. Meaningful Use stage 2 is just around the corner.

January 16, 2013 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit.

Meaningful Use Stage 2 Final Rule Published

UPDATE: For those not wanting to go through all 672 pages of the meaningful use stage 2 final rule, ONC has put out this summary PDF.

Today, CMS publishes the meaningful use Stage 2 Final rule in the Federal Register. The MU stage 2 final rule is 672 pages long.

The HHS press release announcing the EHR incentive money stage 2 final rule also offered these important points to note:

  • Make clear that stage two of the program will begin as early as 2014. No providers will be required to follow the Stage 2 requirements outlined today before 2014.
  • Outline the certification criteria for the certification of EHR technology, so eligible professionals and hospitals may be assured that the systems they use will work, help them meaningfully use health information technology, and qualify for incentive payments.
  • Modify the certification program to cut red tape and make the certification process more efficient.
  • Allow current “2011 Edition Certified EHR Technology” to be used until 2014.

The second point annoys me a little after hearing about some of the EHR certification fraud and issues it could cause providers that attest to meaningful use.

The press release also offered the following EHR incentive participation numbers:
-120,000 Eligible Health Professionals have participated
-3,300 Hospitals have participated
-More than half of all eligible hospitals and critical access hospitals and 1 out of every 5 eligible health care professionals

Watch for more detailed coverage of the meaningful use stage 2 final rule in our ongoing Meaningful Use Monday series.

August 23, 2012 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit.

Meaningful Use Stage 2 Comment Period Ends May 7th

ONC and CMS sent out the following email about the meaningful use stage 2 comment period. It closes very soon and so I encourage everyone to submit their comments on meaningful use stage 2. I’m a real proponent of the benefits of crowd sourcing and if enough people comment on meaningful use stage 2, I think we’ll receive the benefits of the crowd participating in the discussion and improving MU stage 2. I encourage doctors in particular to share their comments on the meaningful use stage 2 NPRM.

Please note that the comment period closes on Monday, May 7 for the notices of proposed rule-making (NPRMs) for Stage 2 of meaningful use and updated certification criteria.

The Office of the National Coordinator for Health IT (ONC) rule proposes the capabilities and related standards and implementation specifications that Certified EHR Technology will need to include to, at a minimum, support the achievement of “meaningful use” by eligible health care professionals beginning with the EHR reporting periods in FY/CY 2014. The rule also proposes revisions to the permanent certification program for health information technology, which include changing the name of the program to the “ONC HIT Certification Program.”

ONC’s rule complements the newly released Centers for Medicare & Medicaid Services (CMS) proposed rule for Stage 2 of the EHR Incentive Programs, clarifying the specifications necessary to meet the criteria for these programs.

Comments Can Be Submitted in 4 Ways

Both ONC and CMS rules identify that comments can be officially submitted in 4 ways:

  1. Electronically through www.regulations.gov – this is the preferred method
  2. Regular mail
  3. Express mail or overnight mail
  4. Hand-delivered/courier

Faxes are not accepted.

To enhance the public comment experience, ONC and CMS have made a copy of the rule available in Microsoft Word to make it easier those who comment to access and copy portions of their proposed rule for use in their individual comments.  Visit http://www.healthit.gov/providers-professionals/meaningful-use-stage-2 for more information.

May 4, 2012 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit.

Health Plan and Employer PHR

After the fall of Google Health, many had written off PHR (Personal Health Record) software as dead and gone. I can’t say that I had much hope for PHR software myself. Although, some of the recent moves by PHR vendor NoMoreClipboard have me pausing to reconsider what value a PHR could provide. My gut tells me they might want to distance themselves from the toxic term, PHR, but they’re definitely being creative with the platform they created.

Right before HIMSS I covered how the PHR could help to facilitate an ACO and Patient Centered Medical Home. Both ACO and PCMH are much more popular terms these days and quite frankly many are still trying to figure out how to make them a reality. I could see a PHR helping to make this happen.

Just yesterday, NoMoreClipboard announced a partnership with Healthx which makes PHR software available to Payers and Employers. I know that many in the investment world are arguing against trying to get money from payers and employers for wellness programs as a startup company. Although, NoMoreClipboard is not a startup company and I have little doubt that integrating their PHR with the Healthx portal was not easily accomplished. I’ll be interested to hear how many of the 12 million people who use Healthx end up using the PHR as well.

Add in the meaningful use stage 2 requirements that PHR can fulfill and maybe just maybe the PHR are back in style. Although, they’re not the PHR that most thought it would be. Instead, it’s taking on new forms that give it an interesting new life.

April 6, 2012 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit.

Meaningful Use Stage 2 Guidelines in Digestable Format

John Crankshaw and Jonathan Ploudre have put together a look at the meaningful use stage 2 guidelines in the most digestable format I’ve seen. You can find the PDF of their MU stage 2 guidelines here. I wish that it was a webpage instead of a PDF, but beggars can’t be choosers I guess.

I haven’t dug into the document completely to verify the accuracy of every single thing, but I did check a bunch of them and they were spot on. I think doctors will really love this summary of the meaningful use stage 2 guidelines. Hopefully many doctors will look it over and provide comments during the meaningful use stage 2 comment period. You have until May 7, 2012 to comment on MU stage 2.

March 8, 2012 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit.

Farzad Mostashari’s Post on Meaningful Use Stage 2 NPRM

I love that Farzad Mostashari and other people at HHS and ONC have been blogging about these exciting times in healthcare IT. Farzad recently did a post about the meaningful use stage 2 NPRM (see this Meaningful Use Monday post on Meaningful Use Stage 2). He starts off the post with some interesting numbers:

to date, more than 43,000 providers have received $3.1 billion to help make the transition to EHRs; the number of hospitals using EHRs has more than doubled in the last two years from 16 to 35 percent between 2009 and 2011; and 85 percent of hospitals now report that by 2015 they intend to take advantage of the incentive payments.

I’ve always found the ONC/CMS/HHS numbers to be a bit higher than reality. Although, I bet their hospital numbers aren’t too far off. There’s little doubt that hospitals are interested in EHR.

Farzad also offered the most succinct view of the 3 stages of meaningful use that I’ve seen. Here’s basically his vision for meaningful use:

  • Stage 1 (which began in 2011 and remains the starting point for all providers): “meaningful use” consists of transferring data to EHRs and being able to share information, including electronic copies and visit summaries for patients.
  • Stage 2 (to be implemented in 2014 under the proposed rule): “meaningful use” includes standards such as online access for patients to their health information and electronic health information exchange between providers.
  • Stage 3 (expected to be implemented in 2016): “meaningful use” includes demonstrating that the quality of health care has been improved.

I posted a comment on the blog post which is still waiting to be approved:

Some very interesting numbers and I appreciate the overall vision of what each stage will do. The first part of this post reminds me of what I heard at HIMSS, that ONC has become more of a marketing organization. I found that interesting since you could easily see why ONC is considered an EHR marketing organization.

These first year numbers are interest, but the second year numbers will matter even more. The first year numbers were likely those who already adopted EHR versus those that implemented EHR post-stimulus. Let’s hope the message that providers offer after they’ve implemented is that they love their EHR. If they start telling their colleagues that they hate the EHR that they were “forced” to implement because of the government carrots and sticks, then it will be quite disappointing.

February 27, 2012 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit.