On August 23, 2012, CMS announced the release of the Final Rule for Stage 2 requirements for Meaningful Use, which eligible professionals, eligible hospitals, and critical access hospitals (CAHs) must meet to continue to participate in the Medicare and Medicaid Electronic Health Record Incentive Programs. The Final Rule is generally effective on November 5, 2012; some provisions became effective on September 4, 2012, the date the Final Rule was published in the Federal Register.
In November of last year, HHS announced that it would delay the start date for Stage 2 requirements, due to significant implementation and compliance obstacles experienced by the vendor and provider communities for Stage 1 requirements. As a result, the earliest that the now final Stage 2 criteria will be effective is in fiscal year 2014 for eligible hospitals and CAHs or calendar year 2014 for eligible professionals.
To be eligible for reimbursement, providers must demonstrate meaningful use for a consecutive 90-day EHR reporting period in the first year they participate and then for a full year EHR reporting period for subsequent years. Under the Stage 2 Final Rule, CMS requires that for 2014, providers, regardless of their meaningful use stage, demonstrate meaningful use for only a three-month EHR reporting period. This will permit providers upgrading to 2014 Certified EHR Technology to have adequate time to implement the system.
Stage 1 established a core and menu structure for objectives that providers had to achieve to demonstrate meaningful use. Stage 2 requirements maintain this structure for meaningful use objectives.
While some Stage 1 objectives were either combined or eliminated, most of the Stage 1 objectives are now core objectives under the Stage 2 requirements and the thresholds have been raised. To demonstrate meaningful use for Stage 2, eligible professionals must meet all 17 core objectives and 3 (out of 6) menu objectives; and eligible hospitals and CAHs must meet all 16 core objectives and 3 (out of 6) menu objectives.
Stage 2 includes two new core objectives: (1) eligible professionals must use secure electronic messaging to communicate with patients on relevant health information; and (2) eligible hospitals and CAHs must automatically track medications from order to administration using assistive technologies in conjunction with an electronic medication administration record. Stage 2 also replaces the prior Stage 1 objectives requiring that patients be provided electronic copies of health information or discharge instructions and timely access to health information, and instead requires that patients be allowed to access their health information online (within 4 business days of the information being available to the eligible professionals, and within 36 hours after discharge from the hospital for eligible hospitals and CAHs).
The Stage 2 requirements also place an emphasis on health information exchange between providers in an effort to improve care coordination. One of the core objectives for eligible professionals, eligible hospitals and CAHs requires providers who transition or refer a patient to another provider to provide a summary of care record for more than 50% of those transitions of care and referrals.
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