This is the first of a series of many blogs dedicated to Meaningful Use Stage 2. In the coming weeks we will examine all of the proposed measures for Stage 2 attestation and the financial breakdown for providers.
On February 23, 2012, the Centers for Medicare & Medicaid Services (CMS) released its proposed rule regarding the requirements for providers attesting to Stage 2 Meaningful Use (MU) of certified Electronic Health Record (EHR) technology under the Medicare and Medicaid EHR Incentive Programs. The next day the Office of the National Coordinator (ONC) released the sister rule setting forth the new standards that need to be incorporated into certified EHR technology. Both rules do not take effect until January 1, 2014, this date takes into account the one year delay that was announced last year. For early adopters of EHR technology — those who attested in 2011 — it means they will, for the most part, work with Stage 1 technology for a full 3 years before they move to Stage 2.
Remember that the source of funding for Meaningful Use provider incentives is NOT the healthcare reform bill that was passed last year — The Patient Protection and Affordable Care Act (aka ObamaCare). The funding for Meaningful Use provider incentives is derived from American Recovery and Reinvestment Act of 2009 (ARRA, aka the stimulus package). We do not expect any funding related to the Meaningful Use program to be pulled, and we are confident that even if there is a Republican president come January 2013, the EHR incentive will continue to march forward. The program is a 3-stage program and Stage 2 will present EHR technology users and vendors with a new set of challenges. Last summer the government (CMS) published some loose guidelines outlining their intentions for Stage 2 and now they have published the preliminary rule. The government will accept comment for the next few months and then publish the final rule this summer and hopefully create test sites for vendors to assist in the preparation of updated EHR technology.
The real focus of Meaningful Use Stage 2 is on the following initiatives:
- Online access for patients to their health information
- Electronic health information exchange (HIE) between providers to enable care coordination
- Patient engagement
- Security and safety
The entities that certify EHR technology, “certification bodies” such as Drummond and CCHIT, are required to move from temporary certification bodies (ONC-ATCBs) to permanent certification bodies (ONC-ACBs). This process should occur later this year.
An industry expert recently commented that if your EHR is not cloud-based, achieving meaningful use in Stage 2 will be much harder. There is a rush for non-cloud-based systems to move into the cloud so that they can be better prepared to assist their clients with Meaningful Use Stage 2. MediTouch® is already cloud-based, and, in fact, we have coined the phrase “PureCloud™” technology. Many of the measures outlined for Stage 2 can already be met with the current MediTouch® version, but other measures will require hard work by our engineering team; some of those measures do not even have final standards yet! Our team is already meeting on a regular basis to ensure that our users will have the best Meaningful Use Stage 2 EHR system.
In my next blog on Meaningful Use Stage 2 we will begin to break down each measure. My advice, take a few deep breaths before you read our next few blog posts because the government has some “interesting” ideas about how you should administer your practice and relate to your patients. Stay tuned, but remember some of what they are proposing will probably not make it to the final rule.