The Proposed Regulation Heard ‘Round the World As the Senior Director of Advocacy aptly pointed out in a recent blog posting, the notice of proposed rulemaking for Stage 2 Meaningful Usewas released late last week – and if this is news to you, you’re probably living under a rock. At this point, most people know that Eligible Hospitals & CAHs are responsible for 14 core objectives and 5 of 10 menu objectives (19 objectives in total) for Stage 1 Meaningful Use. For Stage 2, regulators are proposing 16 core and 2 of 4 menu objectives. At this point you might be asking yourself, “I thought Stage 2 was going to be harder?” Well it is.
Many of the menu options in Stage 1 are proposed to be core for Stage 2. And a host of the Stage 1 core have been consolidated or dropped to make room for more complex objectives. The prime example is the “Transitions of Care” objective. To successfully meet this two-part objective one must: provide a summary of care record for more than 65 percent of transitions of care and referrals AND transmit that summary of care record electronically for more than 10 percent of transitions of care.
So that’s the objective – what are the details?
The transition of care objective must include:
· Patient name.
· Referring or transitioning provider's name and office contact information (EP only).
· Relevant past diagnoses.
· Laboratory test results.
· Vital signs (height, weight, blood pressure, BMI, growth charts).
· Smoking status.
· Demographic information (preferred language, gender, race, ethnicity, date of birth).
· Care plan field, including goals and instructions, and
· Any additional known care team members beyond the referring or transitioning provider and the receiving provider.
· Discharge instructions (for eligible hospitals and CAHs only)
· An up-to-date problem list of current and active diagnoses.
· An active medication list, and
· An active medication allergy list.
The Transitions of Care objective combines elements of previous Stage 1 objectives that are no longer being measured individually:
· Maintain an up-to-date problem list
· Maintain an active medication list
· Maintain an active medication allergy list
And the final kicker is this: In order to meet the second part of the objective (electronically transmit summary of care record for more than 10 percent of transitions of care) EPs, EHs or CAHs must send the summary of care record “to a recipient with no organizational affiliation and using a different Certified EHR Technology vendor than the sender…”
In short, under proposed rules, the electronic transmission of the summary of care record does not count towards the 10 percent threshold unless the exchange is 1) between unaffiliated providers 2) using different products 3) from different vendors.
This is merely a taste of the nearly 700-page Meaningful Use and Standards & Certification Criteriaproposed rules that CHIME will be examining. For more information on changes between Stage 1 and Stage 2, please view this side-by-side crosswalk. Additionally, Health Policy Alternatives has constructed a 54-page summaryof the Meaningful Use proposed rule, which can be found here.
Join the conversation on StateNet’s Meaningful Use Stage 2 group, where you’ll find the latest information and have access to summaries and regulation text.
More ICD-10 Comings and Goings Last week during HIMSS12 CHIME decided to weigh in on the recent announcement that “HHS will initiate a process to postpone the date by which certain health care entities have to comply with ICD-10.” In a letter sentto HHS Secretary Sebelius, CHIME strongly urged Secretary Sebelius to move quickly and decisively in setting a new compliance date for converting to ICD-10. CHIME said that a prolonged delay to ICD-10 implementation, or more specifically, prolonged uncertainty about the timing and details of a delay, would create more problems than it would solve. “We encourage HHS to remain committed to ICD-10 as many organizations have already begun substantial investments that turn wasteful if abandoned for another path,” the letter said. CHIME also warned that if the postponement process required physicians to meet one compliance date and hospitals a different date, unnecessary costs would be incurred. Instead, CHIME said that payers should have a date set in advance of doctors and hospitals. “This would allow providers an additional and needed opportunity to test ICD-10 transactions with payers. A consistent start date across the provider community and an earlier date for payers would make the delay much more meaningful.”