Slideshow Surprises, Challenges in Proposed Stage 2 Meaningful Use Rules

Published
  • March 06 2012, 10:44am EST
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Surprises, Challenges in Proposed Stage 2 Meaningful Use Rules

HDM’s April edition will feature a granular look at surprises and challenges stakeholders have found in the proposed Stage 2 meaningful use rules. Following is a few nuggets from News Editor Joe Goedert’s upcoming story.

Bridging the Gap

A sigh of relief from HIT vendors and I.T. leaders: the proposal for EHR “gap certification” in Stage 2 means vendors only need to get new capabilities certified under Stage 2--they do not have to recertify continuing capabilities already certified under Stage 1.

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Good News on Group Reporting

Group reporting of quality measures--not individual but including all physicians in a practice, for instance--is permitted under the proposed rule, a welcome change from Stage 1, which required each eligible professional to attest individually.

Challenge: Patient Access

The rule calls for eligible professionals to provide more than 50 percent of patients the ability to view online, download and transmit their health information within four business days of the information being available to the EP; and within 36 hours of discharge for hospitals.


But that’s only half the battle, as more than 10 percent of patients actually have to view, download or transmit. How is that supposed to happen?

More About that 10%

Many Medicare patients are not engaged in the computer age and that could make meeting the 10 percent threshold even tougher than envisioned, predicts Jackie Lucas, vice president and CIO at seven-hospital Baptist Healthcare System in Louisville, Ky.


She also questions the value of the 10 percent threshold: Even if a provider knows if patients access the information, there’s no way of knowing if they used it meaningfully, she says.

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First-Time Order Generators

CMS in proposed Stage 2 is asking for comment on whether other licensed professionals can actually enter an order and be the first-time generator of the order after receiving a verbal, written or electronic communication from the physician.

While some states permit pharmacists to be the first generator in certain circumstances, other may not permit someone besides the physician to generate the first order, regardless of what a meaningful use criterion, says Shefali Mookencherry, principal consultant at Hayes Management Consulting.

Small Steps on Information Exchange?

Federal officials tout Stage 2 as a big leap forward in health information exchange, but the exchange envisioned in Stage 2 is primarily point-to-point using secure e-mail technology, as most state HIEs and many regional ones aren’t operational or ready for more advanced types of exchange, says Debra White, partner in the law firm Manatt, Phelps & Phillips.

Looking at Labs …

Stage 2 calls for incorporating at least 40 percent of lab results in the EHR as structured data using the LOINC vocabulary. In a way, that’s easy because national labs Quest Diagnosis and Lab Corp. use LOINC. But providers’ local labs as well will have to adopt LOINC, and providers in a market without a major lab could find making the threshold problematic.

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Tough Demographics

Capturing demographic information as structured data would rise from more than 50 percent in Stage 1 to more than 80 percent in Stage 2. While CMS has found that many Stage 1 attesters have easily passed 50 percent, it can be tough.


In the case of Preferred Health Partners, a multispecialty group practice in Brooklyn with 170 physicians, it’s been difficult to capture race and ethnicity information in a region with a huge immigrant population, says Joel Taylor, CIO. “People don’t want to give up that information.”

Worries About ICD-10, Consolidated CDA

A big question mark for vendors is the proposed use in Stage 2 of ICD-10 for clinical concepts (diagnoses, problem lists, etc.) and procedures, when there is no clear indication that the industry will have transitioned to ICD-10 by 2014. Stage 2 for hospitals starts Oct. 1, 2013, the same date that was set for ICD-10 compliance before the government announced a delay of unknown duration.


Another concern: The Continuity of Care Document or Continuity of Care Record could be used for patient summaries in Stage 1. Stage 2 requires the new Consolidated CDA, which few, if any, vendors currently support.

Very Tight Timetables

Federal officials said they expect Stage 2 to be a final rule this summer. Assume the final Stage 2 rule comes out in August.


Vendors will need two to four weeks of intensive evaluation before starting development of the upgrades their EHRs will need, says Robert Hitchcock, M.D., chief medical information officer at T-System Inc. Stage 2 starts for hospitals in October 2013, so they only have nine months to obtain and implement certified EHR upgrades--or a new system--and be proficient enough to be ready for meaningful use.

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Ready for Another Round?

In the rule, “Table 2: Stage of Meaningful Use Criteria by First Payment Year,” shows the progress through Stages 1 through 3 depending on when a provider starts, and lists “TBD” (to be determined) from 2018 through 2021. Then comes this sentence: “If there will be a Stage 4 of meaningful use, we expect to update this table in the rulemaking for Stage 3.”