CMS Unveils Proposed Stage 2 EHR Meaningful Use Requirements

The Centers for Medicare & Medicaid Services (CMS) released Feb. 24 a Fact Sheet on its proposed definition of Stage 2 meaningful use of electronic health records (EHRs).

CMS unveiled the Stage 1 Meaningful Use Final Rule in July 2010. That rule outlined initial requirements for the implementation of EHRs, with financial incentives available to eligible health care professionals (EPs), eligible hospitals, and critical access hospitals (CAHs) that adopt EHR technology consistent with those requirements.

A new proposed rule builds on and modifies stage 1 requirements. Under stage 1, meaningful use could be demonstrated by meeting a “core” group of requirements (15 for EPs, 14 for hospitals and CAHs) and five of 10 “menu” requirements. As proposed, Stage 2 would require that EPs meet (or qualify for an exclusion to) 17 core objectives and three of five menu objectives; hospitals and CAHs must meet (or qualify for an exclusion to) 16 core objectives and two of four menu objectives.

The majority of proposed Stage 2 objectives carry forward from the stage 1 requirements. As explained in the CMS Fact Sheet, “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objective in Stage 2, and the ‘provide patients with an electronic copy of their health information’ objective … has been replaced by an ‘electronic/online access’ core objective.”

Multiple Stage 1 objectives have been combined into 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.” As well, the proposed Stage 2 requirements change the age limitations for taking of vital signs, which is required under Stage 2 (this measure was optional under Stage 1).

The proposed Stage 2 meaningful use requirements would achieve greater applicability among specialists (for instance, by requiring that imaging results be accessible through certified EHR technology, and by requiring, in most cases, that cancer cases be reported to state cancer registries). Reporting of clinical quality measures (CQMs) remains a key requirement in Stage 2; EPs would be required to report on 12 such measures (up from six in Stage 1), while eligible hospitals and CAHs would be required to report on 24 CQMs (versus 15 under Stage 1). All such data must be submitted electronically.

CMS offers the carrot of incentives to those EPs, CAHs, and eligible hospitals that meet EHR meaningful use requirements, but also wields the stick of Medicare and Medicaid payment reductions to those providers who do not. Under the proposed rule, Stage 2 requirements will begin in 2014 for any provider who first attested to Stage 1 criteria in 2011.

Negative “payment adjustments” are slated to begin in 2015; however, “any Medicare provider that first demonstrates meaningful use in 2014 would avoid the penalty if they meet the attestation requirement by July 3, 2014 (eligible hospitals) or October 3, 2014 (EPs),” per the CMS Fact Sheet.

Watch EdgeBlast and AAPC’s Coding Edge magazine for more details on the Stage 2 EHR meaningful use requirements in the coming weeks and months.


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