5 Major Provisions for Stage 2 Meaningful Use
The Notice of Proposed Rulemaking (NPRM) issued for Stage 2 CMS EHR Incentive program outlines five major provisions to Stage 2 meaningful use for eligible professionals, eligible hospitals, and critical access hospitals. In the notice it proposes the objectives and measures for the program participants. One of those objectives is reporting Clinical Quality Measures (CQMs). By statute Medicare payment adjustments will take effect in 2015 for non adopters. The notice proposes processes and exceptions to the payment adjustments. In the Medicaid Program there are proposed modifications. And finally the delay and new proposed timeline for stage 2 and 3. The following is text taken from the NPRM.
Proposed Objectives and Measures for Stage 2 Meaningful Use
- EPs must meet or qualify for an exclusion to 17 core objectives and 3 of 5 menu objectives.
- Eligible hospitals and CAHs must meet or qualify for an exclusion to 16 core objectives and 2 of 4 menu objectives.
- Nearly all of the Stage 1 meaningful use core and menu objectives would be retained for Stage 2 meaningful use.
- The “exchange of key clinical information” core objective from Stage 1 would be re-evaluated in favor of a more robust “transitions of care” core objective in Stage 2.
- “Provide patients with an electronic copy of their health information” objective would be removed because it would be replaced by an electronic/online access” core objective.
- Multiple Stage 1 objectives that would be combined into more unified Stage 2 objectives, with a subsequent rise in the measure threshold that providers must achieve for each objective that has been retained from Stage 1.
Proposed Reporting on Clinical Quality Measures (CQMs) for Stage 2 Meaningful Use
- EPs, a set of clinical quality measures beginning in 2014 that align with existing quality programs such as measures used for the Physician Quality Reporting System (PQRS), CMS Shared Savings Program, and National Council for Quality Assurance (NCQA) for medical home accreditation, as well as those proposed under Children’s Health Insurance Program Reauthorization Act (CHIPRA) and under ACA Section 2701.
- For eligible hospitals and CAHs, the set of CQMs beginning in 2014 would align with the Hospital Inpatient Quality Reporting (HIQR) and the Joint Commission’s hospital quality measures.
- EPs, eligible hospitals, and CAHs would submit CQM data electronically. Solicitation of public feedback to determine mechanisms for electronic CQM reporting.
- EPs to report 12 CQMs and eligible hospitals and CAHs to report 24 CQMs in total.
Proposed Payment Adjustments and Exceptions
- Payment adjustment would be determined by a prior reporting period, successful meaningful user in 2013 would avoid payment adjustment in 2015.
- Any Medicare provider that first meets meaningful use in 2014 would avoid the penalty if they are able to demonstrate meaningful use at least 3 months prior to the end of the calendar or fiscal year (respectively) and meet the registration and attestation requirement by July 1, 2014 (eligible hospitals) or October 1, 2014 (EPs).
- Three categories of exceptions based on the lack of availability of internet access or barriers to obtaining IT infrastructure, a time-limited exception for newly practicing EPs or new hospitals who would not otherwise be able to avoid payment adjustments, and unforeseen circumstances such as natural disasters that would be handled on a case-by-case basis.
- Solicitation of comments on a fourth category due to a combination of clinical features limiting a provider’s interaction with patients and lack of control over the availability of Certified EHR technology at their practice locations.
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Category: EHR Incentive Program