On January 12, the Health Information Technology Policy Committee’s meaningful use workgroup published a Request for Comments (RFC) on their initial Stage 2 meaningful use recommendations. The RFC will serve as the foundation for the formal recommendations due out later this year. The focus of the RFC is on Stage 2, and the purpose of Stage 2 is to build off of current Stage 1 criteria and establish a realistic bridge to Stage 3 goals.
Under the proposed recommendations, the scope of many required Stage 1 measures would be increased in Stage 2 – for example Computerized Physician Order Entry (CPOE) would be expanded to include lab/radiology orders in addition to medication orders, and the threshold would be increased from 30 percent to 60 percent of unique patients. The meaningful use workgroup is also considering recommending new measures in Stage 2 – for example, use of an electronic medication administration record (eMAR) and physician documentation, and measures that would all but require adoption of personal health records (PHR) and patient portals.
In a new report, “Preliminary Stage 2 Meaningful Use Requirements and Recommendations for Providers”, the Falls Church, Va.-based CSC summarizes the full list of preliminary Stage 2 and 3 recommendations. Even though the specifics and scope of many of the proposed measures will likely change, the underlying goals behind the measures will not. Since these are capabilities that will need to be used in Stages 2 and 3, CSC offers the following tips to take action now as part of Stage 1 to ensure they are prepared:
• Re-evaluate – and if necessary update – your plan for Stage 1: Most of the workarounds that technically could be used to meet the minimum requirements for some Stage 1 measures may not work in Stage 2.
• Do not ignore Stage 1 menu set items you have chosen to defer: CMS indicated in the final rule on the EHR incentive program that Stage 1 measures in the menu set would likely be required in Stage 2.
• Implement CPOE the right way from the start: Given that Stages 2 and 3 will likely expand the measure to include at least lab and radiology orders, it makes sense to implement CPOE for all orders right from the start.
• Ensure you have a plan for a robust patient portal: Even though some of the proposed measures may not be realistic (e.g. requiring that 20% of patients use a PHR when the national average is well below half of that number), the Policy Committee has clearly made engaging patients in their care a priority.
• Make sure your system is certified against Stage 2 in 2013, regardless of when you are planning to meet Stage 1: All hospitals and eligible professionals will need to have electronic health records that are certified against Stage 2 requirements in 2013, even if they have only qualified for incentives based on Stage 1 of meaningful use.
• Actively participate in a Health Information Exchange (HIE): Regardless of the specific threshold required for HIEs in Stage 2 or 3, participating in an HIE will go a long way towards meeting the eventual requirements.
• Keep an eye out for more details on Stage 2 requirements related to quality reporting and privacy and security: The preliminary recommendations do not address quality reporting and privacy and security.
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