It has been over a week since the Stage 2 final rule was published and I know most of you have read the document cover to cover. For those of you who perhaps had better things to do (like taking care of patients), I am going to provide a broad overview of what to expect in 2014. In honor of the recent passing of an American icon, let’s consider, how does the final rule look from a distance?
New Reporting Period — A Not-so-Giant Leap
For starters there is an interesting new twist to the reporting period. Meaningful use participants in 2014, whether they are reporting Stage 1 or Stage 2, will use one of four three-month reporting periods. These four reporting periods are essentially the calendar quarters in 2014. The only exception applies to providers for whom 2014 represents their first year of meaningful use reporting. Those folks will use the continuous 90-day reporting period in play today for first timers.
There are some interesting caveats for this group of first timers as it relates to avoiding future payment adjustments, but let’s save that for a future post. Note this intriguing change to the reporting period only applies to 2014.
Houston, Tranquility Base here. The Eagle Has Landed.
In spite of the Health IT Policy Committee’s recommendation, ONC will continue to support a framework that includes a Core set of objectives and a Menu set of objectives. The successful Stage 2 provider will be expected to report 17 Core objectives (unless they qualify for an exclusion for one of the core objectives) and in addition they will report three objectives chosen from a Menu set that contains six objectives. Reporting a total of 20 objectives will sound familiar to many of you. Stage 1 providers are also expected to report 20 objectives (15 Core objectives and 5 Menu objectives). However, much of the similarity between Stage 1 and 2 ends here.
Core Objectives
Perhaps the best way to consider the Stage 2 objectives is to compare and contrast them with the Stage 1 objectives. CMS has published a nice overview, which I mentioned last week. Originally ONC reported plans to move all Stage 1 Menu objectives to the Stage 2 Core set. Without removing one’s boots it is easy to see something changed along the way (15 + 10 does not equal 17). A few interesting things happened along the way. First, one objective did not make the trip to the Core set and it remains on the Stage 2 Menu. That objective is our old friend Syndromic Surveillance. More about this later. Second, one of the existing Core objectives, reporting clinical quality measures to CMS, will become a fundamental requirement for successfully demonstrating meaningful use and it is no longer counted as a separate objective in Stage 2. Finally, several objectives were either retired or incorporated within a Stage 2 objective. I have identified this large group in the following table.
ONC has also created a new Core objective for Stage 2:
- More than 5% of unique patients send a secure electronic message to the provider from within the EHR
Menu Objectives
The Stage 2 Menu contains five new objectives in addition to Syndromic Surveillance. Providers must choose three to report. A new wrinkle for Stage 2 is that an exclusion will not count as one of your three reported Menu objectives. For example, if your local public health authority is unable or unwilling to receive syndromic surveillance data, you will qualify for an exclusion for this objective. However, you cannot report this exclusion as one of your three Menu objectives (as you can today for Stage 1). The intent here is to ensure providers are not “gaming” the system by avoiding objectives that apply to their scope of practice in favor of cherry picking easy ones (like exclusions). The five new menu objectives are:
- Create at least one electronic progress note for at least 30% of unique patient encounters
- At least 10% of all scans and tests whose result is an image that were ordered by the provider are incorporated into or accessible from the EHR
- At least 20% of unique patients encountered have a structured data entry for family history
- Successful ongoing submission of cancer case information to a cancer registry
- Successful ongoing submission of specific case information to a specialized registry
That’s One Small Step for Man, One Giant Leap for Mankind
This is one of my favorite quotes from Neil Armstrong, but I am not convinced it applies in this context. David Bowie’s “Ground control to Major Tom” comes to mind. The devil is always in the detail and as we return to earth in the coming weeks and months, we will take a much closer look inside the Stage 2 final rule. Only time will tell if the Stage 2 final rule looks more like a Space Oddity or a successful Apollo 11 splashdown. Rest in peace Mr. Armstrong.
RG says
Terry,
Thanks for the summary. I find it useful to get prepared little by little rather than save it to the very end. For number 5 in the menu above, are you going to use the Acumen CKD registry? For the FH (# 3 above), are you going to allow Acumen users to use the FH wizard and then keep track of it? For the electronic progress note, will a partially dictated note qualify? Also, the transition of care I think is going to cause a unique problem for the typical nephrologist. There are tons of these; From the CKD clinic to the hospital, from the HD unit to the Hospital, etc…Getting the medications that we give in the HD unit into acumen (e.g. epogen) is going to be a challenge. Perhaps an interface could be created. I like the point about the quarterly submission. That is a nice feature. Keep the blogs coming and we will try to implement the objectives in conjunction with your blog article, just like we did for part one.
Terry Ketchersid, Vice President and Medical Officer at HITSG says
We are in the midst of digesting the breadth and depth of the final rule Randy. Stay tuned as there will be much more to follow.