Meaningful Use Stage 2 Proposed Rule
Proposed rule:
http://www.gpo.gov/fdsys/pkg/FR-2012-03-07/pdf/2012-4443.pdf
AAMC comment letter:
https://www.aamc.org/download/281814/data/aamccommentletteronmeaningfulusestage2proposedrule.pdf
AAMC Contacts:
Ivy Baer: Ibaer@aamc.org
Lori Mihalich-Levin: Lmlevin@aamc.org
Jennifer Faerberg: Jfaerberg@aamc.org
Mary Wheatley: Mwheatley@aamc.org
Scott Wetzel: Swetzel@aamc.org
Stage 2 Decision
Tree: Medicare
INCENTIVE!
(CMS)!
YES
YES
YES
YES
YES
Are you an eligible
professional (EP)?
2
Are you a non-hospital based
EP? (CMS)
NO: $0;
no
penalty
Have you attested to core &
menu measures of
meaningful use (CMS)?
Are you using certified EHR
technology (ONC)?
NO
Have you attested to EP
quality measures (CMS)?
NO
NO
NO
2015:
Unless are
hospitalbased or
meet an
exception,
penalty
begins
Stages of Meaningful Use By
Payment Year
First
Payment
Year
2011
2012
2013
Payment Year
2011
2012
2013
2014
2015
2016
2017
Stage 1 Stage 1
Stage 1
Stage 2
Stage 2
Stage 3
Stage 3
Stage 1
Stage 1
Stage 2
Stage 2
Stage 3
Stage 3
Stage 1
Stage 1
Stage 2
Stage 2
Stage 3
Stage 1
Stage 1
Stage 2
Stage 2
2014
Source: Federal Register, Table 2 (March 7, 2012 p. 13703)
3
Stage 1
4
Stage 2
EPs
EPs
15 core
17 core
5 or 10 menu
3 of 5 menu
20 total objectives
20 total objectives
Hospitals/CAHs
Hospitals/CAHs
14 core
16 core
15 of 10 menu
2 of 4 menu
19 total objectives
18 total objectives
Stage 1 Menu Moved to
Proposed Stage 2 Core
Implement drug-formulary checks
Record existence of advance directives (core for EH
only)
Incorporate lab results as structured data (only where
results are available)
Generate pt lists for specific conditions
Send pt reminders
Summary of care record
Submit reportable lab data (core for EH only)
Submit syndromic surveillance data
5
New Measures – Proposed
Measure
6
EP
EH
30% visits have at least 1 electronic EP note


30% of EH pt days have at least one e-note by MD, NP or PA


30% of EH med orders automatically tracked via electronic med
admin recording

80% of pts offered ability to view and download via web-based
portal w/in 36 hrs of discharge relevant info in the record

Online secure pt messaging in use

Pt preferences for communication medium recorded for 20% of pts


List of care team members (including PCP) available for 10% of
pts in EHR


Record of longitudinal care plan for 20% of pts with high priority
health conditions


Major Clinical Quality Measure (CQM)
Changes (EPs and Hospitals)
Through 2013 –
• Report 3 core/alternate core + 3 measures (EPs)
• Attest to results or EHR-PQRS pilot submission (EPs)
• Continue to report 15 CQMs finalized in Stage 1 (Hospitals)
Changes in 2014 –
• Criteria for CQM same for all stages (EPs)
• 3 options for reporting, including group reporting (EPs)
• Electronic submission (EPs)
• Report 24 out of 49 (proposed) CQMs (Hospitals)
• Must have at least one measure in each of the six quality domains
(Hospitals)
• Ability to pick the measures most relevant to their patient population or
services offered (Hospitals)
2014 CQM - 3 Options for EPs
1a) 12
measures/
6 domains
• At least one
measure in
each of the 6
domains
• 125
measures
OR
1b) 11 “core”
plus 1 measure
• 11 core
measures
listed
• One
additional
measure
2) PQRS-EHR
• Follows rules
for PQRSEHR
submission
• Could
change in
future rulemaking
Group
Reporting
• >=2 NPI per
Tax ID
Number
• ACOs*
• GPRO*
* Option only available for
Medicare EHR Incentive
CMS will finalize either option 1a or 1b.
8
Group Reporting - CQM
• Three possible methods
• 2 or more NPIs within single TIN
• ACO
• GPRO
• Group options available for:
• CQM reporting only AND
• All EPs in the group are beyond the first year
of Stage 1
• Data must be reported from Certified EHR
Technology
9
Penalties- EPs
In general, a penalty will be based on data from 2
years prior to the penalty. (Exception: EPs can
apply up to Oct of the previous year if it is their
first year of MU)
Determining 2015 penalty:
• 1% percent reduction based on 2013 reporting
period (for most EPs)
• Can report until Oct 2014 if first year
reporting
• Additional 1% reduction if not an e-prescriber in
2014
10
To avoid penalties, do what by when?
(Hospitals)
To Avoid Penalties in FY:
Existing Meaningful User:
• MU for All of FY 2013
• Attest by November 30, 2013
2015
2016
New Meaningful User:
• MU for April 3, - June 2, 2014
• Attest by July 1, 2014
Existing Meaningful User:
• MU for All of FY 2014
• Attest by November 30, 2014
Existing Meaningful User:
• MU for April 3, - June 2, 2015
• Attest by July 1, 2015
AAMC Concerns/Comments with
the Proposed Rule
• The requirements and timelines for achieving Meaningful Use
Stage 2 are too aggressive.
• New attesters should have more time to meet the requirements for
Meaningful Use Stage 1.
• The core measures in the proposed rule are new and untested and
therefore greater flexibility should be provided to hospitals and EPs
to report this information.
• The proposed CQMs are not market ready and would not lead to
better outcomes in patient care. These quality measures should not
be incorporated into the pay-for-performance programs without a
supplemental process to ensure the validity of the EHR data
capture.
• A group reporting option for CQMs and meaningful use measures
should be implemented.
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