Stage 2 Meaningful Use – Are You Ready?

Mae-ellen Gavin

The Stage 2 Meaningful Use proposed ruling states hospitals must attest to 18 objectives, 16 core and 2 of 4 menu objectives and Stage 2 now begins in FFY 2014 (10/1/2013).  By consolidating some objectives, introducing new ones and raising the threshold on some the bar is certainly raised.  With care providers already dealing with unprecedented change the proposed ruling confirms that the level of change will continue--impacting more providers, departments, and clinical workflows.   At Imprivata we are focused on helping our customers optimize the implementation of technology by providing a predictable, fast, secure way to access patient information—improving on utilization levels today and setting you up for continued success as you move towards attesting to Stage 2 Meaningful Use.   We’ve heard a lot from customers about CPOE initiatives in particular and how No Click Access®is helping to drive utilization levels to where they need to be for Stage 1 and even Stage 2.

As for our take on Stage 2?  Dare I say Meaningful Use has become more meaningful?   You can start to see how Stage 1 was just the foundation and we are now moving into areas that will really impact patient care and the delivery of healthcare.

  • Stage 2 consolidates several Stage 1 requirements into a single ‘Summary of Care Record for Transitions of Care’ objective making the tracking of problem list, medication list and medication allergy list more meaningful.   
  • The combined proposal of higher exchange requirements and the move to more structured data means we can move beyond just data entry and start to utilize that data to impact patient care. 
  • Besides consolidation of some of the Stage 1 objectives, there have been increases in thresholds and all menu objectives have become core, which means if you have not started on medication reconciliation then you need to start!
  • CPOE introduces not only an increased percentage but how that percentage is calculated—making it more challenging to reach. 
  •  I was surprised physician documentation was not included; the Stage 2 proposed ruling references a HIMSS Analytics 2008 survey stating that electronic documentation is already widely implemented and does not need to be a meaningful use requirement.  I agree this is probably true for nursing but that was not my understanding for physician documentation; of course with the focus on exchanging information in Stage 2 the documentation piece will probably be covered without requirements around electronic notes. 
  • There’s also one new core requirement -- e-MAR –which was added due to the timeline push out of Stage 2; should be interesting to see if this stays core in the final rule or moves to a menu objective.    
  • Plus, there’s some new menu objectives one of which will allow PACs vendors to become certified EHRs! 
  • The proposal to align Clinical Quality Measure (CQM) reporting required under Meaningful Use with the Hospital Inpatient Quality Reporting (HIQR) and the Joint Commission’s hospital quality measures as well as allowing the submission of CQM data electronically are all good things that hopefully save hospitals time and money.
  • Be sure to review the HIT:  Standards, Implementation Specifications, and Certification Criteria for EHR Technology, 2014 Edition for information on changes to the certification program and required standards such as LOINC, SNOMED-CT and ICD-10.  

And, if FFY 2014 is your first reporting period then you only need to report on 90 days of meaningful use; otherwise the reporting period is a full year.  If you don’t plan on attesting to Stage 1 until 2013, be sure to review the table starting on page 33 of the proposed rule.  You have the option to attest against the new definition of some of the objectives (e.g., new CPOE denominator)-this may or may not help you; starting in 2014, the new definitions are required. 

Below is a summary of the key changes and additions between Stage 1 and Stage 2 for hospitals.  
 

Objectives that Changed

CPOE (30% to 60%)

  • Denominator changed to total number of orders vs. unique patients with at least 1 order.
  • Lab and Radiology orders now included (beyond just meds)
  • CPOE order must now be the ‘first record of the order’ 

Record Demographics (50% to 80%)

Record Vital Signs (50% to 80%)

  • Height and weight must now be recorded for all patients (rather than 2 and over) and blood pressure for 3 and over.

Record Smoking Status (50% to 80%)

Clinical Decision Support (1 rule to 5 rules)

  • Rules must map to the clinical quality measures reported.
  • Drug-Drug/Drug Allergy Checks has been moved to this objective.

Lab Test Results as Structured Data (40% to 55%)

  • Moved from Menu to Core

Online Information to Patients (10% to 50%)

  • Replaces ‘Provide patients with an electronic copy of their discharge instructions and procedures at time of discharge, upon request.’
  • New additional measure that 10% of patients actually access the information.

Summary of Care Record for Transitions of Care (50% to 65%)

  • Replaces the Stage 1 ‘Exchange key clinical information’
  • Consolidates Stage 1 Requirements:  problem list, active medication list, active medication allergy list.
  • New Requirement to transmit to organizations with no affiliation or that are using a different certified EHR.

Protect Electronic Health Information

  • Specifically calls out encryption/ security of data at rest.
     

Objectives that moved from Menu to Core

Generate Patient Lists
Provide Educational Resources
Medication Reconciliation
Immunization Data Submission
Reportable Lab Results Submission
Syndromic Surveillance Submission
 

New Core Objective

e-MAR
 

New Menu Objectives

Imaging Results
Record Family History
eRx at discharge
 

No Change

Advanced Directives (Menu)