Meaningful Use Stage 2: Speak Now or Forever Hold Your Peace

A preliminary set of recommendations for defining Stage 2 meaningful use was released by the Meaningful Use Workgroup of the HIT Policy Committee earlier this month in the form of a Request for Comment—the deadline for comments is February 25. The decision-makers in Washington clearly realize the value of securing buy-in from providers, having received over 2,000 comments to the proposed Stage 1 rule when it was issued last year. As a result of those lobbying efforts, which included the Voice of the Physician Petition that we circulated on EMR Straight Talk, CMS made changes that accommodated the specialists and made participation realistic for them.

This is the opportunity for physicians to have a voice in Stage 2 before the final recommendations are submitted to CMS this summer. This request comes very early in the process of developing and finalizing the requirements—the workgroup will consider the comments and then present its recommendations to the HIT Policy Committee, which will review and revise and then forward them to CMS, which will issue the final rule. So for this stage, providers have the chance to provide input well before recommendations become set in stone.

Since most providers haven’t even embarked on Stage 1, and many are not yet conversant in the rules and requirements for that stage (as evidenced by the results of the Meaningful Use IQ Test), the following are highlights of the proposed recommendations. Note that clinical quality measures are not discussed—they will be the subject of a separate set of recommendations.

  • The proposal does not address the excludability of non-relevant measures. I assume its retention is implied, but it is important to comment on the need to keep these options in place. This was a very valuable modification added to Stage 1, particularly for specialists.
  • Disappointingly, Stage 2 still does not define meaningful use in a way that adds value for many specialists, and a way that will keep them engaged once the significant portion of the incentives have been collected.
  • Menu measures will become core measures, so the measures physicians choose to defer in Stage 1 will be mandatory in Stage 2. Some of these measures pose challenges for specialists, e.g. sending reminders to 20% of patients may not be reasonable for certain specialists such as orthopaedists or ENT physicians, because they provide episodic care.
  • Most of the changes involve increased thresholds for satisfying the measures, e.g., CPOE increases from 30% to 60%, ePrescribing from 40% to 60%, etc. These changes should not present a challenge since the software and relevant workflows will already be in place from Stage 1.
  • There are several new measures, such as adding lab or radiology to CPOE and including online secure patient messaging.

To voice your thoughts on this initial set of recommendations, go to www.regulations.gov and click “Submit a Comment”. Don’t say they didn’t ask!

2 thoughts on “Meaningful Use Stage 2: Speak Now or Forever Hold Your Peace

  1. I am an Ophthalmologist. Having certain measures such as weight, blood pressure, etc. are irrelevant to what I do for my patients. It is crazy to require me to measure these parameters on all my patients, it is a big waste of time.

    Much of the reason that physicians and particularly specialists have been reluctant to purchase EMR software is because there are no requirements that the EMR vendors work together to produce a consistant database. This is necessary so that if a physician’s vendor goes out of business the patient data can be easily transferred to a new EMR vendor. I do not want to pay a large sum for EMR software only to see my vendor go out of business and lose all my money and have to retrain my staff all over again. There should be more federal requirements placed on the EMR vendors to keep things transferable for the physician.

  2. Reply- or Question:
    I have been told that a provider must complete and transmit their eRX before they can submit their charges to their respective EPM softwares for billing. Is this really intended or does this really mean they must submit their eRX before submitting their billing to the Medicare payor?

    Second Question: what happens in a group practice when some of the providers do not have the minimum numbers of Medicare patients to fulfill the minimum # of eRX submitted by June? Can we submit as a group rather than individual providers we do have a group NPI and Group Tax ID?

    Lastly – no one has really stated what is the point of this and what is going to be done with the data. I see plenty of Electronic Errors and I don’t see how any of this solves the problem at hand but sure does increase our costs and complexities of our practices. Can you help me understand the “meaning and outcome function of meaningful use?”

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