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Stage 2 MU Remains Challenging, Yet Attainable

August 27, 2012
by Jennifer Prestigiacomo and Mark Hagland
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Industry leaders say even though there’s relief in the timeline and requirements, Stage 2 will still be tough to meet

Industry reaction has been largely positive toward the final rule for Stage 2 meaningful use, but many acknowledge that even though there is relief in the timeline, many requirements will still be challenging to meet. The federal Centers for Medicare & Medicaid Services (CMS) issued the final rule for Stage 2 meaningful use under the American Recovery and Reinvestment Act/Health Information Technology for Economic and Clinical Health (ARRA-HITECH) Act last Thursday, Aug. 23.

Ferdinand Velasco, M.D., chief health information officer of the 25-hospital Texas Health Resources in Arlington, Texas, thinks that the public comments of his organization, as well as others, were heard, especially in regard to having fewer requirements in the final rule.

“I do think that the MU Stage 2 final rule and standards and certification rule continue to be ambitious, but, I think, reasonable and attainable,” says Velasco. “I don’t think it would have been realistic to the original timeframe that we could have started the reporting period on October 1, 2012; and in fact, now we have a little more time. Now there’s a three-month reporting period, and that gives the vendors and providers more space. I think it’s an acknowledgement of the concerns being expressed by the community around the original timeline.”

Much of everything in the proposed rule is still there, apart from a few tweaks here and there, says Jane Metzger, research principal of the Global Institute for Emerging Healthcare Practices in Waltham, Mass., a division of the Falls Church, Va.-based CSC. “I think comments in every cycle have always said, it’s too much—too long a list of things. And on that front, I don’t think Stage 2 gave too much relief,” she adds. “Another area of comment [is there] has been too little time. And until we got some of these clarifications in the final Stage 2 rule, the timeline had become ridiculous, because of all the delays in getting Stage 2 out and Stage 2 verification wasn’t up and running, and all of that. And I thought overall that there was relief there.”

Easing up on Patient Engagement, Interoperability
CMS did let up a bit on the requirement for patients to view, download and transmit their health information, lowering the threshold from 10 percent to 5 percent, which Velasco thinks is not an unreasonable requirement since the meaningful use incentive program is “quasi-voluntary.”

“I can well appreciate the perspective of those critical of that requirement, but that’s where healthcare is going in general,” he adds. “And providers increasingly are having to take some responsibility for their patients doing the right thing. So I think [CMS] is making a very clear statement that patient engagement, and interoperability, another one of those controversial areas, are key focus areas, despite the pushback from the healthcare providers.”

One requirement that was retained in the final Stage 2 rule was that eligible providers and hospitals conduct health information exchange with providers not on the same technology platform. However, CMS eased up and replaced the organizational and vendor limitations of exchanging information with another vendor to having providers conduct one or more successful data exchange tests with a “CMS designated test EHR” during the EHR reporting period.

“They’ve pared down the requirement to basically a yes/no question,” says Velasco. “And if you can’t do that, there’s also the CMS test you can use to test interoperability. So it is a challenging requirement, but not an onerous one. I’ve always maintained that HITECH was not a bailout in the way that the rest of the stimulus might have been. It’s meant to move the ball forward.”

This allowance for data exchange tests certainly helps in areas where there are dense market shares of one particular EHR vendor, which occurs many times in smaller communities, says Robin Raiford, research director in the Advisory Board’s IT Strategy Council. However, the capability to share information outside of a particular organization’s EHR system is particularly necessary in the case of snowbirds, those who spend part of the year in a warmer part of the country.

Clinical Quality Measures Still a Challenge
The specific requirements for clinical quality measures were not a part of the final rule for Stage 2; they have been disconnected from the meaningful use stages and will be published in October. “Clinical quality measures are no longer a core requirement, and that makes it a whole lot harder to sort out,” says Metzger. “And there are different rules and timelines for future Stage 1 attesters. So people who’ve already figured out Stage 1 and are still working toward it have to do a reality check. I think this makes it really hard for vendors.”

Velasco agrees that the requirements for the electronic recording of quality measures are not to be underestimated, and “hospitals and vendors need to look seriously at the pilot underway on electronic reporting.”

“The one thing that they didn’t do in Stage 1 that I hope they’ll address is capturing data on deferred items, such as laboratory data,” Velasco adds. “We could only report on minimum numbers; so CMS didn’t get any data on how far providers had actually gotten. Really, they should collect the data on all menu items; and they didn’t. It’s simple, really.”

Metzger contends there’s a whole lot of new complexity around denominators for some of the measures. “They’re options; there’s no longer just one way to comply with many of the measures,” she says. “And again, that’s confusing for the providers, but it’s very, very tough for the vendors, because regardless, they have to support those options.”

Raiford says that even though capturing all the clinical quality measures is still challenging, it was encouraging to see CMS ease up on the number of quality measures to report from 24 to 16. “The thing that has been really buried and not really talked about is there is a great relief in terms of quality measures,” says Raiford.

She says this requirement will signal vendors what they need to build and hospitals what they need to chart, which will make quality measures overall less burdensome. “In the hospital side particularly, there’s something called negation rationale of why didn’t you give a medicine or why didn’t you do an order, and they’re actually going to make a subset of which elements have to be made in the EHR, and which elements have to be charted against, which would be way less burden than there is right now.”

Further Recommendations for HIT Leadership     
Velasco says CIOs need to continue to move the ball forward in terms of achieving Stage 2, even though CMS added an extra year to achieve Stage 1. “They need to be very familiar with the legislation, and not just rely on the excellent analyses there because there are a lot of nuances involved; this is what we experienced in Stage 1,” he adds.

“A pro-active thing that you can do now without your 2014 edition certified software is start looking at those five measures that you deferred to Stage 2 and put those in your plan to do them in your next year,” says Raiford. “You’ll be ahead of game, so when you do have to do summary of care at 50 percent, you’re not struggling to get to that number.”

Raiford also recommends not pushing back software upgrades to anywhere close to July 1, 2014. She advocates getting upgrades earlier if available to get a buffer in case organizations need to redo their reporting periods in July.

“Though there was some relief in timing, there’s still an awful lot to do over a very short period of time,” concludes Metzger. “And with all these retroactive changes to Stage 1, it’s much more complex, not only for the providers, but especially for the vendors.”


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