The Latest: The Centers for Medicare & Medicaid Services (CMS) released a final rule defining “meaningful use” of electronic health records (EHR) for Stage 2 of the Medicare and Medicaid EHR Incentive Programs, which will begin on October 1, 2013, for eligible hospitals and critical access hospitals (CAH). The Office of the National Coordinator (ONC) for Health Information Technology also released a companion final rule that sets certification criteria, standards, and implementation specifications for EHR technology.
In comments submitted earlier this year, HAP cautioned CMS that achieving Stage 1 meaningful use was very challenging for many providers, and that the proposed Stage 2 criteria and timing raised the bar too high and too fast on the EHR adoption requirements that hospitals and physicians must meet to qualify for additional Medicare and Medicaid incentive payments and avoid significant payment penalties for fiscal year (FY) 2015. CMS finalized a stringent set of meaningful use criteria for Stage 2 that includes a total of 22 hospital objectives, seven of which are new. All of the proposed objectives were finalized, and two new objectives that had not been proposed but were the subject of comment, also were included. In Stage 2, hospitals must meet each of 16 core objectives and three of six menu set objectives. The total number of required objectives was increased to 19 from the 18 proposed. CMS made some modifications to its proposed objectives and measures, such as small decreases in performance thresholds. Taken together, the rule’s definition sets a high bar for Stage 2.
The final rules will allow hospitals some flexibility in transitioning to Stage 2, by only requiring compliance for one quarter during the first year. While HAP appreciates the steps CMS has taken to address concerns over the transitions, concerns remain that this policy will not be sufficient to mitigate the significant market pressures imposed by the aggressive timelines in the meaningful use program. These demands are exacerbated by a policy finalized by ONC which will require all providers to upgrade to a new version of certified software during 2014, regardless of their stage of meaningful use. HAP will provide further details about both the CMS and ONC rules during the coming weeks.