Providers choosing not to adhere to clinical decision support information during treatment should document the reason why under Stage 2 meaningful use criteria, according to comments from the American Health Information Management Association on initial draft criteria. "When the treatment of care deviates from the direction guided by the CDS, this should be captured and included in the reporting for meaningful use," the association recommends.

AHIMA also urges policymakers to consider the current regulatory environment, which includes ICD-10 compliance and health reform initiatives among others, as 2013 draws near. "There are a number of other regulatory initiatives developing with a compliance timeframe of 2013 and we suggest aligning these programs to allow for a coordinated approach to implementation and production."

The association in its comment letter supports many of the draft criteria for Stage 2 but also points out areas of concern. For instance, Stage 1 requires use of CPOE for medication orders for more than 30 percent of unique patients with such orders, while draft Stage 2 calls for at least one medication, and one lab or radiology order for 60 percent of unique patients with such orders.

"AHIMA members are concerned there may be redundancy issues associated with changing from 'more than 30% unique patients' in Stage 1 to '60% of Rx, lab and radiology orders," according to the comments. "This is a significant change in the way the objective is calculated in Stage 2 and adds complexity and administrative burden in capturing orders not documented electronically. We request further guidance be developed on the numerator/denominator calculations and how certification rules associated with this objective will be defined and tested."

Click here for AHIMA's full comment letter.

--Joseph Goedert


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