Transitioning to Meaningful Use Stage 2

By Mike Jenkins, PMP, MBA

On February 17, 2009, the “Stimulus bill” earmarked $19 Billion for the “Health Information Technology for Economic and Clinical Health” (HITECH) Act.  HITECH encourages physicians to migrate to electronic health records (EHR) and to show “Meaningful Use”.  Eligible Providers (EPs) attested with 90-days data before 10/3/2012 could earn up to $44,000 over five years.  After 2012, the total earning decreased.  Those attesting with data captured after 10/2/2013 would be subject to Medicare penalties starting in 2015. 

 

Deadline for

attestation data

Maximum

ARRA Payout

10/2/2012

$44,000

10/2/2013

$39,000

7/1/2014

$24,000

less penalties

10/1/2014

penalties

 

The HITECH program extracts penalties if no MU by 2015.  Penalties are based on prior years reporting with a 2 year lag.  If the EP had MU attestation in 2013, there is no penalty in 2015.  Medicare MU registration and attestation must be done before 10/3/2014 to prevent adjustment in 2015.  This means the 90-day reporting period must start no later than 7/1/2014.  The EP must continue to meet MU requirements annually to avoid adjustments in subsequent years. 

The rules for an Eligible Professional (EP) are very simple. 

Buy a “Certified” EHR + Attest for Meaningful Use = Get incentive payments.

The Meaningful use program is building the foundation to drastically alter the way in which we provide care and referrals for patients.  Stage 1 requires providers to move from paper to electronic data capture.  Stage 2 requires providers share this data with patients and other providers.  Stage 3 is TBD.

Buying a “certified” system today requires providers to purchase a system that is certified by an ONC-ACB company in accordance with the 2011 rules.  Buying and using a system starting January 1, 2014 for Stage 2 attestation AND Stage 1 attestation must be done using a system certified under the 2014 rules.

Stage 1 certification required EPs to show meaningful use of 15 core objectives plus 5 of 10 menu objectives for a total of 20 objectives in order to attest and receive their checks.  Stage 2 makes this quite harder by requiring EPs to show meaningful use of 17 core objectives plus 3 of 6 menu objectives for a total of 20 to continue receiving checks and avoid penalties. 

Stage 2 requires more adoption including patient engagement.  EPs must prove more than 5% of their patients have sent secure message to the EP and more than 5% of their patients have accessed their health information online.  They must produce a Summary of Care for more than 50% of their patients.  They must electronically transmit more than 10% of information, and they must send at least one patient record to a recipient with a different EHR vendor or to CMS.

Stage 1 Clinical Quality Measures (CQMs) reporting required 6 out of 44 where 3 are core or alternate core and 3 are from the menu.  Stage 2 (After January 1, 2014) will require 9 out of 64 CQMs that are pulled from at least 3 of the 6 National Quality Strategy (NQS) domains. 

As of 6/25/2013 there is a stark contrast in the number of solutions certified on the ONC website (http://oncchpl.force.com/ehrcert).

 

Type

2011

2014

Ambulatory

3,217

47

Inpatient

1045

44

 

In conclusion, All EPs MUST use a 2014 certified EHR for 90 days to attest for 2014 starting January 1, 2014.  They must report on data collected no later than October 3, 2014 to avoid penalties.  This means they must have a fully operational 2014 certified system by July 1, 2014 in order to capture 90 days data in 2014.  A 2014 certified system is required for both Stage 1 and Stage 2 attestations.

While completing our own EMR certified for 2014 (Stage 2) we realize this is an order of magnitude harder than 2011 (Stage 1) certification.  Stage 1 has created a false sense of security among vendors and EPs.  The 2014 certification has raised the bar for EHR vendors and every EP who attests.  There will be some consolidation, but there will be vendors who choose to abandon their customers at the 11th hour.  EPs need to solicit their vendors now to get their commitment to finish their certification.  If they do not get a reliable answer, it is time to start considering plan B.

 

Mike Jenkins is the CEO of BuildYourEMR (www.buildyouremr.com), a PMP Instructor and a LEAN Six Sigma expert. He has a deep understanding of Information Technology in Healthcare that comes from serving Managerial and Director position at the most prestigious Healthcare IT companies in the country.

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