Kudos to CMS for responding positively and reasonably to many of the comments submitted by physicians and/or their professional organizations regarding the Proposed Rule for Stage 2 meaningful use. Of course, there were also a number of issues that could have been addressed more favorably from the providers’ perspective—and I will address those in my next EMR Straight Talk post—but I was pleasantly surprised to see the changes and the compromises that CMS did make that will benefit physicians.
The most significant concession was related to timing: in 2014, physicians will only report for a 90-day calendar quarter—rather than a full year, as originally intended. This should result in higher-quality, more-usable EHRs as vendors will have more time to develop, test, and certify their new versions. It also eliminates the fiasco that surely would have ensued for providers were they all to require upgrading by their vendors within a very small window of time. This new schedule also ensures that physicians will have the time they need to implement, and sufficiently train on, the new versions of their software, enhancing the likelihood that they will be able to successfully demonstrate meaningful use. The 90-day reporting period also provides some flexibility for those unfortunate physicians who hastily purchased an EHR in a rush to meet meaningful use and now find themselves dissatisfied with their decision—they will have down time that will make the replacement process easier.
I was also pleased to see several changes that address the reporting burden for physicians. Stage 2 offers a batch-reporting option—however, providers must still individually meet all of the meaningful use requirements—and it attempts to harmonize clinical quality measure reporting across the various government programs. These were two proposed concepts that physicians strongly endorsed in their comments.
Specialists particularly appreciate the Final Rule’s successful resolution to the challenges posed by the vital-signs measure currently in force—the new requirement unlinks the reporting of height and weight from the reporting of blood pressure. Beginning in 2013 (i.e., a year before Stage 2 even takes effect), physicians who find height and weight relevant to their practices (but not blood pressure) will be able to report the former while attesting to an exclusion for the latter. This will remove an irrelevant step in the workflow for many specialists.
While CMS did hear the physicians on these important issues, there are other areas that the Final Rule did not sufficiently address. I will discuss these in my next post.